Public Privacy Notice – Video Footage and Location Data Collection via VX360

Last updated: 30.04.2025

Applies to: Individuals who may be recorded by the VX360 app in public spaces (e.g., pedestrians, drivers, license plate owners).

1. Who Are We?

NATIX Network Limited Asia Leading Chambers, Road Town, Tortola VG1110, British Virgin Islands Email: [email protected]

We are the data controller for any personal data collected through the VX360 system once footage is uploaded to our servers by our users.

2. What Data Might Be Captured?

The VX360 app is operated by vehicle owners or drivers who voluntarily participate in our program. When in use, the app may capture:

• Video footage of public roads and environments, including:

  • Pedestrians, cyclists, and other vehicles in proximity

  • Faces, license plates, or other identifiable features

  • Reflections or other indirect identifiers where visible

• Metadata such as GPS coordinates, timestamps, and device identifiers

This data may contain personal data as defined under the General Data Protection Regulation (GDPR).

3. Where Does the Data Come From?

The footage is recorded by private individuals using the VX360 dashcam device. When connected to the NATIX Companion App, the footage is uploaded to our servers for processing, analysis, and storage.

4. Why Do We Process This Data?

We process the uploaded footage and associated metadata for the following purposes, which serve our legitimate interest in operating and developing a secure and innovative mobility intelligence platform:

• Generating mobility, map, and traffic insights, products and services;

• Analyzing and aggregating video, location, and telemetry data to create commercial datasets, and other products and services;

• Validating contributions and preventing fraud;

• Rewarding users who provide high-quality data;

• Improving the performance and accuracy of our app, products, services, anti-fraud systems and reward mechanisms;

• Fulfilling applicable legal or regulatory obligations, including cooperation with law enforcement if required;

We do not use this data to profile individuals, or for marketing purposes.

5. What Is Our Legal Basis for Processing?

We process this data on the basis of our legitimate interest under Article 6(1)(f) GDPR. This includes our interest in:

• Operating a functional and fair data collection and reward platform

• Creating meaningful insights from road activity to support infrastructure, safety, and mobility solutions

• Ensuring the technical integrity and reliability of the services we provide

We have conducted a legitimate interest assessment to ensure that these interests are not overridden by your fundamental rights and freedoms, and we apply robust safeguards (see below) to minimize privacy risks.

6. Why Haven’t You Been Contacted Directly?

Since we do not know the identity of individuals captured in public footage, and have no practical means to contact them individually, we rely on the exception under GDPR Article 14(5)(b). This allows us to provide this information via public means (e.g., placards with links to this notice) when direct communication would involve a disproportionate effort.

7. How Do We Protect Your Privacy?

We take your privacy seriously and apply the following technical and organizational safeguards:

• Automatic blurring of faces and license plates, where technically feasible

• Access restrictions to footage, including encryption and role-based controls

• Time-limited retention of raw video content

• Pseudonymization and aggregation of data used for analysis or commercial output

• No sale, publication, or sharing of identifiable footage with third parties

Your data is never used to identify you, and we do not link the footage to other data sources in an attempt to determine your identity, unless it is necessary to meet the legal obligations or requested by law enforcement bodies.

8. Your Rights Under GDPR

Even if we cannot identify you, the GDPR grants you specific rights regarding any personal data that may relate to you. These include, where applicable:

• The right to access personal data we may hold about you

• The right to object to our processing on legitimate interest grounds (Art. 21 GDPR)

• The right to request erasure or restriction of processing

• The right to lodge a complaint with a data protection authority in your country

To exercise your rights or inquire further, please contact us at [email protected].

9. Further Information

You can find more details about how we process data, including for our app users, in our full Privacy Policy available at: https://docs.natix.network/policies/privacy-policy-campaign