Customer Privacy
Policy
Scope and purpose
This policy applies to the processing of customer
personal data by the Volvo Car Group (referred to as “Volvo
Cars“ or “we”).
The purpose of this policy is to provide our
current, former and potential customers (jointly referred to as
“customers” or you) with a general understanding of:
- The circumstances under which we collect and
process your personal data.
- The types of personal data we collect.
- The reasons for collecting your personal
data.
- How we handle your personal data.
Commitment
The processing of your personal data forms an
important part of our provision of products and services to you. We appreciate
the trust you place in us when providing us with your personal data, and
consider your privacy an essential part of the services we offer.
In order to safeguard your personal data while
increasing the customer value and offering enhanced and safer driving
experiences, we adhere to the following five general
principles.
Freedom of choice
Your personal data belongs to you. We strive not to
make any assumptions regarding your privacy preferences and aim to design our
services so that you can choose whether to share your personal data with
us.
Balance of interests
Where the processing of your personal data is
necessary for the pursuit of a legitimate interest, and where this interest
outweighs the need to protect your privacy, we may process certain personal
data without obtaining your express consent. For more information, see the
“Consent” section below.
We will assess whether such a legitimate interest
exists based on the potential benefits to (including the safety of) our
customers and the general public.
Proportionality
Volvo Cars endeavours to only process customer
personal data that is adequate, relevant and not excessive in relation to the
purpose for which it has been collected.
We aim to anonymize your personal data when a
function or service can be achieved with anonymized data. If we combine
anonymized or non-personal data with your personal data, it will be treated as
personal data for as long as it remains combined.
Transparency
On request, Volvo Cars will provide customers with
further information regarding our processing of your personal data, which may
include excerpts from internal directives and guidelines.
Legal compliance
It is Volvo Cars policy to comply with the
applicable laws, rules and regulations governing privacy and data protection in
each and every country where we operate. Where necessary, we will adjust our
processing of your personal data as described in this policy to ensure legal
compliance.
Helpful definitions
The following terms, used throughout this policy,
have the meanings set out in EU Directive 95/46/EC on the protection of individuals
with regard to the processing of personal data and on the free movement of such
data. Accordingly:
“Data controller” means the
natural or legal person, public authority, agency or any other body which alone
or jointly with others determines the purposes and means of the processing of
personal data.
“Data processor” means a
natural or legal person, public authority, agency or any other body which
processes personal data on behalf of the controller.
“Personal data” means any
information relating to an identified or identifiable natural person ('data
subject'); an identifiable person is one who can be identified, directly or
indirectly, in particular by reference to an identification number or to one or
more factors specific to his physical, physiological, mental, economic,
cultural or social identity.
“Processing” means any
operation or set of operations which is performed upon personal data, whether
or not by automatic means, such as collection, recording, organization,
storage, adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available, alignment or
combination, blocking, erasure or destruction.
“Sensitive personal data” means
personal data revealing racial or ethnic origin, political opinions, religious
or philosophical beliefs, trade-union membership, and the processing of data
concerning health or sex life.
Data Collection
You may provide us with information about you or
your vehicle when utilizing Volvo Cars services in or outside a vehicle or in
other contacts with Volvo Cars, for example through our websites or customer
centres. We may also obtain such data from our authorized dealers and repairers
and other third parties. Such data (“Customer-provided personal
data”) may include:
- Your contact information (name, address,
telephone number, email address.
- Demographic information (age, marital status,
household composition.
- Vehicle information (vehicle identification
number (VIN), model, date of purchase, service history.
- Location data generated by your activities
(navigation assistance, search queries, location sharing. and
- Data pertaining to your purchase and use of our
products and services (customer preferences and settings, purchase history,
Volvo ID, MyVolvo).
Your vehicle will also automatically collect data
relating to the vehicle and its surroundings, primarily of a technical nature
and not directly related to you as a person. Such data
(“Vehicle-recorded data”) is typically connected to the
vehicle identification number (VIN) of the vehicle and may therefore be
traceable to you. Vehicle-recorded data may include:
- Safety information (whether airbags or belt
tensioners have been triggered, whether the doors and windows are locked or
open).
- System functionality status (of the engine,
throttle, steering, and brakes)
- Driving data (vehicle speed, brake and
accelerator pedal use, steering wheel movement.)
- Location data (the position of the vehicle in
case of an accident)
- Surroundings data (temperature outside the
vehicle, images).
Information about certain Vehicle-recorded data is
also included in the owners manual.
We are particularly careful and apply additional
measures if and when collecting and processing sensitive personal data, as
required by applicable law. To the extent personal identification numbers and
credit card numbers are stored by Volvo Cars, such information is also
considered sensitive. For avoidance of doubt, it is noted that applicable law
may require other kind of data to likewise be treated as sensitive personal
data. Applicable law may also limit the possibility to process location data in
certain countries.
Notice
Where reasonably practical or as required by
applicable law, we will, in collecting or registering your personal data, provide
you with:
- Specific information
as to the purposes of the processing of your personal data.
- The identity of the
data controller.
- The identities of any
third parties to whom the data may be disclosed.
- Other information
which may be necessary to ensure that you are able to safeguard your
rights.
The above information may, for example, be provided
when you purchase a vehicle, in the vehicles infotainment system, in mobile
applications developed by Volvo Cars, at www.volvocars.com or
otherwise in an agreement which you enter into with Volvo Cars.
Consent
Where reasonably practical or as required by
applicable law, we will obtain your consent prior to collecting or using your
personal data. The request for your consent will be clear and provide you with
a reasonable basis with which to make your decision. Your consent could always
be revoked, for example by terminating a particular service or contacting Volvo
Cars at the address indicated in the “Information and
Access” section below.
The collection and use of Vehicle-recorded data may
be necessary in order for:
- Technicians to diagnose
and rectify faults in vehicles during the service and maintenance of
vehicles.
- Volvo Cars product
development, for example enhancements of the vehicles quality and safety
features.
- Managing Volvo Cars
warranty undertakings.
- Fulfilment of legal
requirements.
When collecting or using Vehicle-recorded data for
these purposes, and for similar legitimate interests pursued by Volvo Cars, we
will generally not seek your consent unless this is deemed necessary in the
individual case or required by applicable law.
Volvo Cars authorized dealers and repairers
Volvo Cars stresses strict rules regarding data
protection compliance in its contracts with authorized dealers and repairers.
Please note, however, that Volvo Cars and its authorized dealers and repairers
are separate legal entities and that we are generally not responsible if such
entities do not follow applicable laws. If you have questions regarding your
dealers or repairers use of your personal data, please contact the dealer or
repairer directly.
Third party applications
You may be able to access applications and other
services connected to a vehicle but provided by a third party, which, for
example, may require transfer of location data and other Vehicle-recorded data
to the third party. Volvo Cars is not responsible for the collection or use of
personal data in third party applications or services, and recommends that you
carefully review the applicable terms and conditions of (and any privacy
statement related to) such applications or services prior to use. If you have
questions concerning a certain third partys use of your personal data, please
contact the third party directly.
Data Use
The personal data which Volvo Cars collects about
you and the vehicle will be used:
- To provide you with products and services,
including to verify your eligibility for certain purchases and services as well
as to offer you enhanced offers and experiences.
- To inform you of updates to, or changes in, our
products and services, including but not limited to changes to our terms and
conditions and policies.
- To inform you of new products, services and
events.
- To provide vehicle support and services (warranty
service, recall information).
- For product development purposes, for example to
improve vehicle performance, quality and safety.
- To evaluate and improve our offering to and
communication with customers.
- To comply with legal requirements.
For most processing acts, you are able to opt out
of our use of your personal data by updating your preferences, terminating a
particular service, revoking your consent to the processing by contacting Volvo
Cars at the address indicated in the “Information and
Access” section below or as otherwise instructed by us. However, and
unless otherwise follows from applicable law, you may generally not opt out of
the processing of your personal data:
- In relation to certain acts of collection and
further processing of your Vehicle-recorded data (see the
“Consent” section above).
- Which we perform in order to send you important
notices, such as changes to our terms and conditions and policies or in case of
product recalls.
- Which we perform in order to comply with our
legal obligations.
Retention
We will only retain your personal data for as long
as it is necessary to fulfil the purposes outlined in this policy or the
purposes of which you have otherwise been informed.
This means that once you have consented to our
processing of your personal data, we will retain your data in accordance with
the consent given and/or until you revoke your consent. If you have revoked
your consent, we may nevertheless retain certain personal data for the period
required in order for us to meet our legal obligations and defend ourselves in
legal disputes. If we have not obtained your consent to the processing, the data
will only be retained for as long as such a period of time as permitted by
law.
Data quality
Where we process your personal data, we strive to
ensure that it is accurate and up-to-date. We will seek to erase or rectify
personal data that is inaccurate or incomplete. For more information regarding
your right to ensure the accuracy of your personal data held by us, please see
the “Information and Access” section below.
Information and access
As stated in the “Notice”
section above, we may provide you with specific information concerning our
processing of your personal data when collecting or registering such
data.
Once per year you have the right to request, and
receive free of charge, information on:
- What personal data
relating to you we process.
- Where the personal
data is collected.
- The purpose of the
processing.
- With which recipients
or categories of recipients the personal data is shared.
Requests for such information must be made in
writing and be personally signed by you, and include information on name,
address and, preferably, your e-mail address. You also have the right to
request that we correct, block or delete any incorrect data relating to you.
Requests should be sent to: Volvo Car Corporation, Attention: The Data Protection
Officer, SE-405 31 Gothenburg, Sweden.
Your requests will be dealt with in a prompt and
proper manner. Requests to delete personal data will be subject to any
applicable legal requirements. Where the applicable law provides for an
administrative fee for complying with such a request, such a fee may be charged
by Volvo Cars.
In addition, you may be able to access an overview
of certain Customer-provided personal data held by Volvo Cars, and correct or
update your information, by logging in to your MyVolvo account.
Security
Volvo Cars strives to implement appropriate
technical and organizational measures in order to protect your personal data
against accidental or unlawful destruction, accidental loss or alteration,
unauthorised disclosure or access and any other unlawful forms of processing.
We aim to ensure that the level of security and the measures adopted to protect
your personal data are appropriate for the risks presented by the nature and
use of your personal data.
Disclosures to third parties
Volvo Cars may share your personal data:
- Between Volvo Cars entities.
- With Volvo Cars authorized dealers and repairers,
for the purpose of distributing product and service offers and other communications
to you.
- With suppliers providing services to Volvo Cars
in accordance with data processing agreements (as required by law).
- With other business partners for the purpose of
distributing product and service offers and other communications to you or for
research and development purposes.
- In connection with the sale or transfer of a
Volvo Cars entity or its assets.
- As required by law, for example in connection
with a government inquiry, dispute or other legal process or request.
- When we, in good faith, believe that disclosure
is necessary in order to protect our rights, for example in order to
investigate potential violations of our terms and conditions or to detect,
prevent or disclose fraud or other security issues.
A Volvo Cars entity being the data controller of
your personal data will, as a general rule, only disclose your personal data to
a third party if it has received your consent to do so. However, we may share
your personal data without your consent, unless we consider your consent
necessary in the individual case or your consent is required by law, in the
following situations:
- Vehicle-recorded data which is processed for
other purposes than ensuring or developing our products and services or in
order to manage our legal obligations.
- Transfers of your personal data between Volvo
Cars entities.
- Transfers of your personal data to suppliers
providing services to Volvo Cars internally.
- Situations in which disclosure is required by
law.
- Situations in which disclosure is necessary for
the purpose of a legitimate interest pursued by Volvo Cars (for example in
order to protect our legal rights, as described above).
When disclosing your personal data to third
parties, or between Volvo Cars entities, we will assess whether the disclosure
requires additional protective measures (for example, where a cross-border
transfer of personal data may occur).
Data processing on our behalf
We restrict access to your personal data to Volvo
Cars employees and suppliers who need to use the information in order to
process it on our behalf, and who are contractually required to keep your
personal data secure and confidential. We aim to choose the option for data
processing services that best safeguards the integrity of your personal data
towards any third party.
Marketing
We will not sell or trade your personal data with
third parties unless we have your consent to do so.
We will not share your personal data with third
parties for their marketing purposes, unless we have received your consent for
such disclosures. If you have provided such consent, but wish to stop receiving
marketing materials from a third party, please contact that third party
directly.
We may provide you with information regarding new
products, services, events or similar marketing activities. If you wish to
unsubscribe to a particular e-mail newsletter or similar communication, please
follow the instructions in the relevant communication. You may also use your
MyVolvo account to opt out of specific types of communication from Volvo Cars
and to change previously submitted preferences.
Changes
Volvo Cars reserves the right to amend this policy
from time to time. The date of the last modification is stated at the end of
this document. If we make any changes to this policy and to the way in which we
use your personal data, we will provide an updated version of this policy.
How do I contact
you?
If you have any questions concerning this Internet Privacy
Directive or otherwise on the handling of personal data at Volvo, contact us at
the following address: persdata@volvocars.com