Scope and purpose

This policy is applicable to the Processing of customers' Personal Data at all companies included in the Volvo Car Group ("Volvo Cars", “our”, “us” 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
• Distribution of responsibility for the Processing of Personal Data between various legal entities at Volvo Cars, and
• Contact details for us so you can receive information about and claim your rights in relation to our processing of your Personal Data.

This policy is updated continuously to reflect the measures taken by Volvo Cars in relation to your Personal Data.

Principles of data Processing

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.

Helpful definitions

Volvo Cars makes use of the below listed definitions in this policy:

• "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal       Data;
• "Processor" means a natural or legal person, public authority, agency or 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 natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
• "Processing" means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
"Sensitive Personal Data" means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the Processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Data collection

You may provide us with information about you or your vehicle when utilising Volvo Cars' services in or outside a vehicle or in other contacts with Volvo Cars, for example through our websites or customer centres (in this context, please note that phone calls may be recorded, with your consent, for quality assurance purposes). We may also obtain such data from our authorised dealers and repairers and other third parties. Such data may include:

• your contact information (name, address, telephone number, email address, etc.);
• demographic information (age, marital status, household composition, etc.);
• vehicle information (vehicle identification number (VIN), model, date of purchase, service history, etc.);
• location data generated by your activities (navigation assistance, search queries, location sharing, etc.); and
• data pertaining to your purchase and use of our products and services (customer preferences and settings, purchase history, Volvo ID, etc.).

Your vehicle will also automatically collect data relating to the vehicle and its surroundings, primarily of 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, etc.);
• system functionality status (of the engine, throttle, steering, and brakes, etc.);
• driving data (vehicle speed, brake and accelerator pedal use, steering wheel movement, etc.);
• location data (the position of the vehicle in case of an accident, etc.); and
• surroundings data (temperature outside the vehicle, images, etc.).

Information about certain Vehicle-recorded data is also included in the Owner's Manual.

We are particularly careful and apply additional measures if and when collecting and Processing Sensitive Personal Data, as required by applicable law. For avoidance of doubt, it is noted that applicable law may require other kind of data to also be treated as Sensitive Personal Data.

Notice

Where reasonably practical or as required by applicable law, we will, in connection to collecting or registering your Personal data, provide you with (i) specific information as to the purposes of the Processing of your Personal Data, (ii) the identity of the Controller, (iii) the identities of any third parties to whom the data may be disclosed and (iv) 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 vehicle's 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 specific and provide you with a reasonable basis with which to make your decision. We will never take your consent for granted. Instead, we will make sure that you can consent in a clear and transparent manner. Your consent is voluntary and may 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. If you do not give your consent, it may not be possible to use services or parts of services.

Collection and Processing of Personal Data without consent

Third party applications

You may access applications and other services linked with the vehicle but provided by a third party, which may, for example, require transmission of location data and other Vehicle-recorded data to this third party. Volvo Cars is not responsible for the collection or use of Personal Data in applications or services provided by a third party, and recommends that you carefully review applicable terms for (and any integrity policy related to) such applications or services before you use them. If you have questions concerning a certain third party's use of your Personal Data, please contact the third party directly.

International transfers

Volvo Cars may transfer your Personal Data to recipients in countries outside of the European Economic Area which may have differing data protection laws. This includes countries which the EU Commission does not consider to have an adequate level of protection for Personal Data. If this occurs Volvo Cars will ensure there is a legal ground for the transfer in accordance with applicable data protection legislation. You will also be informed about the legal ground, what safeguards were implemented, and where you can obtain a copy of information on these safeguards.

Data use

• in relation to certain acts of collection and further Processing of your Vehicle-recorded data relating to safety, quality and product improvement;
• 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; and
• which we perform in order to comply with our legal obligations.

Retention

Data quality

When we process your Personal Data, we strive to ensure that it is correct and up to date. We attempt to delete or correct Personal Data that is incorrect 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

Security

Volvo Cars has taken technical and organisational 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.

Disclosures to third parties

Volvo Cars may share your Personal Data:

• among Volvo Cars units;
• with Volvo Cars authorised dealers and repairers, for the purpose of distributing product and service offers and other communications to you; 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
• with other business partners or third parties where you have elected to receive a service from them and authorised them to request data from Volvo Cars, (for example, for Volvo In-car Delivery);
• with our product and service providers who work on our behalf in connection with the above uses, such as wireless service providers, companies that host or operate our website, send communications, perform data analytics, credit card processors, or system providers necessary to process, store, or manage credit card or financial information; and
with emergency services providers, such as law enforcement, roadside assistance providers, and ambulance providers, in order to deliver related services (for example, for Volvo On Call Emergency Support).

A Volvo Cars entity being the 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, if permitted by law 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:

• when disclosure is required by law; and
• when 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).

Data Processing on our behalf

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 Volvo Cars consumer portal account, or a similar service offered in your local market, to opt out of specific types of communication from Volvo Cars and to change previously submitted preferences.

Websites and cookies

In general, you can visit Volvo Cars websites without telling us who you are or revealing any information about yourself. However, to be able to provide you with certain services or offerings, we often need to record certain items of Personal Data such as your name and email address. We may also collect (by means of cookies) anonymous information on how you have used our websites prior to such recording. This information will be helpful to us in order to improve our websites or marketing. All Volvo Cars websites open to our customers include information concerning our use of cookies. For certain countries there is also an online procedure for accepting or declining cookies. For more information regarding our use of cookies, please consult the local information regarding cookies published for your country under www.volvocars.com.

Apps

When you download or register to use one of our apps, you may submit Personal Data to us such as your name, email address, phone number and other registration information. Further, when you use our apps, we may collect certain information automatically, including technical information related to your mobile device, and information about the way you use the app. Depending on the particular app you use and only after you have consented to such collection, we may also collect information stored on your device, including contact information, location information or other digital content. Further details about the kind of information we collect is set out in the information notice and/or the special notice for each individual app.

Third-party services and apps

Some third-part apps which you download, are preinstalled or you can sign up for may have separate terms and privacy policies that apply regardless of our privacy policy. Volvo Cars is not responsible for the use of Personal Data in apps or services from a third party. We recommend that you carefully review the user terms and privacy policy of each third party service or application prior to signing up, downloading, or using them. We also recommend looking for privacy choices and controls in third-party apps after downloading.

Children

Our services are not intended for use by children. We do not knowingly solicit or collect any Personal Data about children under the age of 13 nor market our products or services to them. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 13, please contact us. If we learn that we have inadvertently collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.

Monitoring

As a result of legal requirements, we have to monitor how our system works, including the vehicles we have produced. This means that we collect sample data from these vehicles.

Lodging of complaint to supervisory authority

Lodging of complaint to supervisory authority If you are of the opinion that we are processing your personal data in violation of data protection laws and regulations you have the right to lodge a complaint with your supervisory authority.

Contact details

To exercise your rights as a data subject, e.g. to obtain information or access to Personal Data that Volvo Cars process, kindly use this web form.

For other concerns regarding Data Privacy in Volvo Car Corporation, Attention: The Data Protection Officer, SE-405 31 Gothenburg, Sweden.

For requests regarding use of personal data as an employee or consultant, please follow this link.

For requests regarding use of personal data as a job candidate, a former employee or consultant, please follow this link.

Data protection representative

Volvo Cars has appointed a Data Protection Officer for the Group who can be reached via e-mail or via post as set out below:

E-mail address: globdpo[at]volvocars[.]com.

Postal address: Postal address: Volvo Car Corporation, Attention: The Data Protection Officer, avd 50092, VAK, 405 31 Göteborg, Sweden.