Guidelines 1/2020 on processing personal data in the context of connected vehicles and mobility related applications
Paragraph 3.2.1 Legal basis
130. Regarding the application of the “ePrivacy” directive, two provisions have to be considered:
− art. 9 regarding location data other than traffic data which only applies to electronic communication services. ;
− art. 5 (3) for the gaining access to information stored in the generator installed inside the vehicle.