LOXO on Public Roads – Autonomous Driving in Action
You might soon spot one of our LOXO vehicles quietly rolling through your neighborhood. That’s because our autonomous delivery fleet is now operating on public roads in Switzerland and Germany.
Powered by our proprietary Digital Driver software, these vehicles represent cutting-edge autonomous technology:
- Some operate at Level 4 autonomy,
- Others are accompanied by a safety driver,
- And some are currently used for data collection.
Regardless of the use case, privacy and safety come first. That’s why all LOXO vehicles clearly display a notice about video recording, including a QR code and URL to our full privacy policy.
We want you to feel safe and informed. That’s why we’re transparent about how data is collected and used in accordance with the EU General Data Protection Regulation (GDPR). Our data processing serves solely to ensure road safety, advance autonomous driving features, and is subject to strict retention and anonymization policies.
Read our full privacy statement here:
Privacy Policy
LOXO is pleased to welcome you to our website. Protecting your data is of high importance to us. In the following, we would like to inform you about what personal data we collect as part of our project with partners and through the use of our autonomous delivery vehicles, and for what purposes we process this data.
Our privacy policy is always available to you – you can access, save, and print it. Please note that legal or technical changes may lead to updates to this policy. We therefore recommend reviewing it regularly.
I. Controller and Scope
The controller within the meaning of the EU General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection regulations is:
LOXO AG
Freiburgstrasse 251
3018 Bern
Switzerland
II. Principles of Data Processing
Personal data refers to any information relating to an identified or identifiable natural person. This includes, for example, your appearance, name, age, address, telephone number, date of birth, email address, IP address, or user behavior. Information that we cannot associate with your identity (or only with disproportionate effort), such as anonymized data, is not considered personal data.
Processing of personal data (e.g., collecting, querying, using, storing, or transmitting) always requires a legal basis or your consent. Once the purpose of the processing has been fulfilled and no legal retention obligations remain, processed personal data will be deleted.
If we process your personal data to provide certain services, we will inform you below about the specific operations, scope and purpose of the processing, the legal basis, and the respective storage duration.
III. Processing Activities
A. Video Recordings for the Safe Participation of Our Autonomous Test Vehicles in Road Traffic
As part of our project with REWE, we operate autonomous test vehicles in public road traffic. These vehicles are equipped with various sensors, including video cameras, radar, and positioning systems (e.g., GPS), which continuously capture data from the surroundings.
The video cameras record image data that may be stored and combined with other sensor data. The goal is to precisely analyze the vehicle’s environment and develop models for various traffic situations. For instance, other vehicles, pedestrians, cyclists, or traffic infrastructure are identified as dynamic or static objects — including their position and direction of movement relative to the test vehicle. In some cases, a person’s gaze direction may be considered to predict whether a pedestrian intends to cross the road.
It is not the system’s purpose to identify individuals, and such identification is not part of the system’s functionality. Data processing is solely for the purpose of traffic safety, technical development, and validation of autonomous driving functions. All objects are anonymized and classified algorithmically (e.g., as “pedestrian,” “car,” “truck”) with no reference to their identity. However, it is technically possible that personal data such as faces or license plates may be visible in the recordings.
To ensure transparency, our vehicles are visibly marked with a sticker showing a camera symbol, a reference to the controller (LOXO), a QR code, and a URL linking to the full privacy policy. This gives road users the opportunity to obtain information about the data processing.
Legal Basis for Processing
The processing of environmental data, including possible personal data, is based on our legitimate interest under Art. 6 (1)(f) GDPR. Our interest lies in vehicle safety, development, and secure operation of autonomous driving functions.
Storage Duration
We store your personal data only as long as necessary for the purpose, but no longer than two years.
Recipients and Transfers Outside the EEA
In limited cases, we may transmit the above video material to service providers outside the European Economic Area (EEA). Such transfers follow the principles of the EU Standard Contractual Clauses under Art. 46 GDPR to ensure an adequate level of data protection.
This processing does not involve automated individual decision-making, including profiling, within the meaning of Art. 22 GDPR.
B. Video Recordings for Evidence Purposes
If an accident, damage to a test vehicle, or another incident occurs, a video clip of up to 30 seconds may be saved for evidentiary purposes. This clip may include all personal data captured by the camera at that time—such as images of people, vehicle license plates, and other identifying features.
Legal Basis for Processing
Processing is based on our legitimate interest under Art. 6 (1)(f) GDPR, particularly the protection of property (test vehicles), defense against unjustified damage claims, and objective clarification of traffic accidents and similar events.
Storage Duration
The 30-second clip is saved only if such an incident occurs and will be retained according to legal provisions for asserting our rights. It will be deleted once no longer needed for evidentiary purposes.
This processing also does not involve automated decision-making, including profiling, as defined in Art. 22 GDPR.
IV. Your Rights as a Data Subject
Under the GDPR, you have the following rights regarding your personal data:
Right of Access (Art. 15 GDPR): You may request information about your personal data processed by us at any time by contacting: relations@loxo.ch. This includes purposes of processing, data categories, recipients, storage period, rights to correction, deletion, restriction, objection, the data’s origin (if not collected by us), data transfers to third countries or international organizations, and the existence of automated decision-making.
Right to Rectification (Art. 16 GDPR): You may request the immediate correction or completion of inaccurate personal data we hold.
Right to Erasure (Art. 17 GDPR): You may request deletion of your data unless processing is necessary for freedom of expression, legal compliance, public interest, or the defense of legal claims.
Right to Restriction (Art. 18 GDPR): You may request the restriction of processing if the data is contested, processing is unlawful and you oppose deletion, we no longer need the data, or you have objected under Art. 21 GDPR.
Right to Data Portability (Art. 20 GDPR): You may request your data in a structured, commonly used, machine-readable format or request transfer to another controller.
Right to Withdraw Consent (Art. 7(3) GDPR): You may withdraw your consent at any time, which will affect future data processing.
Right to Lodge a Complaint (Art. 77 GDPR): You have the right to file a complaint with a supervisory authority, usually in your place of residence, employment, or our company headquarters.
V. Right to Object
If your personal data is processed based on legitimate interests under Art. 6 (1)(f) GDPR, you have the right to object under Art. 21 GDPR, provided there are reasons arising from your particular situation.
VI. Data Security and Safeguards
We are committed to protecting your privacy and treating your personal data confidentially. To prevent manipulation, loss, or misuse of your stored data, we implement comprehensive technical and organizational security measures, which are regularly reviewed and adapted to technological progress.
