Privacy Notice – Volvo ID

Effective from: 2021-07-05

Published at: 2021-05-31

This document describes how Volvo Cars (as defined below) processes your personal data when you create and use your Volvo ID to get access to services within the Volvo Cars digital ecosystem (hereinafter “Volvo ID”).

You can find below:

1. Who we are

The entity responsible for the processing of personal data in relation to the creation and use of your Volvo ID is Volvo Car Corporation, having its registered office at Assar Gabrielssons Väg, SE-405 31, Gothenburg, Sweden, company registration number 556074-3089, hereinafter referred to as “Volvo Cars”, “we”, or “us”.

2. What personal data we collect and why

The creation and use of your Volvo ID, to get access to services withing the Volvo Cars digital ecosystem, involves the processing of the following categories of personal data:

We collect from you your identifiers (such as first and last name, phone number, preferred language, country, E-mail address and password) to create an account with us, provide you with access to the Volvo Cars Services that require a Volvo ID and to communicate with you regarding your Volvo ID. The legal basis of this data processing is performance of the contract you have enter into with Volvo Cars ((Art. 6.1.b) GDPR).

To provide an overview of your Volvo ID and its connected services on the Volvo ID Portal, we process your Volvo ID, vehicle information (VIN, car details) and services connected to your Volvo ID. The legal basis for this processing is the legitimate interest ((Art. 6.1.f) GDPR) to outline all cars and services that are associated with your Volvo ID.

We also process your personal data for troubleshooting purposes, in connection with the creation or use of your Volvo ID, to improve the reliability of our product. We then use part of your Volvo ID (user name and user ID). The legal basis for this is our legitimate interest ((Art. 6.1.f) GDPR) to secure a stable and relyable product to you.

3. How long we keep your data

We will keep your personal data as long as you have a registered Volvo ID. If you delete your Volvo ID (which you can do through the Volvo ID Portal) the Volvo ID together with associated data will be deleted thirty (30) days after your deletion request.

4. Who we share your personal data with

Our categories of processors supporting in delivering the Volvo ID are:

account creation and authentication service provider;
data hosting;
distribution of emails and sms; and
troubleshooting service provider.

They are limited by contract in their ability to use your personal data for any purpose other than to provide services for us in compliance with each data processing agreement in place. In some of these situations the use of the processors involves limited transfers of personal data outside of the European Union. We have taken precautions that such transfers are limited to the minimum necessary, and only involve data that cannot directly identify you and thus poses a very low risk in case of unauthorised disclosure.

5. Your rights in relation to the data processing we perform

5.1. Your rights under GDPR

As a data subject you have specific legal rights granted by the General Data Protection Regulation relating to the personal data we process about you. These are briefly explained below, and you can exercise them by filling out the dedicated form indicated below.

Right to withdraw consent: Where you have given consent for the processing of your personal data, you may withdraw your consent at any moment with effect for the future.
Right to access your personal data: You may ask from us information regarding personal data that we hold about you. We will provide you with a copy of your personal data upon request. If you request further copies of your personal data, then we can charge you with a reasonable fee that we base on the administrative costs. You have the right to the information about our safeguards for the transfer of your personal data to a country that is outside the EU and the EEA if you request that we confirm whether or not we process your personal data, and we transfer your personal data to a country that is outside the EU and the EEA.
Right to rectification: You may obtain from us rectification of incorrect or incomplete personal data concerning you. We make reasonable efforts to keep personal data in our possession or control which are used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to us.
Right to restriction: You may obtain from us restriction of processing of your personal data, if:
1. you contest the accuracy of your personal data, for the period we need to verify the accuracy,
2. the processing is unlawful and you request the restriction of processing rather than erasure of your personal data,
3. we do no longer need your personal data for the processing purpose but you require them for the establishment, exercise or defense of legal claims, or
4. you object to the processing while we verify whether our legitimate grounds override yours.
Right to portability: You have the right to receive your personal data that you have provided to us, and, where technically feasible, request that we transmit your personal data (that you have provided to us) to another organization, if:
1. we process your personal data by automated means;
2. we base the processing of your personal data on your consent, or our processing of your personal data are necessary for the execution or performance of a contract to which you are a party;
3. your personal data are provided to us by you; and
4. your right to portability does not adversely affect the rights and the freedoms of other persons.
You have the right to receive your personal data in a structured, commonly used and machine-readable format. Your right to receive your personal data must not adversely affect the rights and the freedoms of other persons. Your right to have your personal data transmitted from us to another organization is a right you have if such transmission is technically feasible.
Right to erasure: You have the right to request that we delete the personal data we process about you. We must comply with this request if we process your personal data, unless processing is necessary:
1. for exercising the right of freedom of expression and information;
2. for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject;
3. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or
4. for the establishment, exercise or defense of legal claims.
Right to object: You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing or for the establishment, exercise or defense of legal claims. If you object to the processing, please specify whether you also wish the erasure of your personal data, otherwise we will only restrict it. You also have the right to object at any time, regardless of any reason, to the processing of your personal data for direct marketing (which includes profiling to the extent that it is related to such direct marketing), if such processing was based on our legitimate interest. If the marketing was based on your consent, you can withdraw consent (see above).
Right to lodge a complaint: You can lodge a complaint to your local data protection supervisory authority or with any other data protection authority in the EU. However, we will appreciate if you first contact us to try and solve your problem – you can find our contact details below.

You can exercise your rights in relation to us by filling out this form, which will help us to deal with your request properly. The online form contains the information that we need to verify your identity and review your request. For requests submitted by telephone or email, you will need to provide us with sufficient information that allows us to reasonably verify that you are the person whose personal data we collected and describe your request in sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.

5.2. Your rights under Brazilian law

Our National Sales Company understands the importance of having access to your information, so it is committed to respecting your privacy.

We have created this “Privacy Notice” so that you clearly and transparently understand how we use and process this information, always in compliance with national data protection regulations, such as the Brazilian General Data Protection Law (“LGPD”).

Under the LGPD, individuals have certain rights related to their personal data, subject to limitations in this law, as follows:

Confirmation of the existence of data processing: You have the right to ask us whether we process data about you.
Information: You have the right to receive information about the processing of your personal data, including on the public and private entites with which we share your data.
Access to your personal data: With some exceptions intended to protect the rights of third parties, you are entitled to access the personal data we have about you or, in some cases, to receive a copy of such data in common electronic format.
Correction of incomplete, inaccuragte, or out-of-date data: You have the right to correct the personal data we hold about you, if they are factually incorrect, incomplete, or outdated. This right does not cover opinion issues, such as the opinions expressed in editorial contents.
Anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in non-compliance with the LGPD: You have the right to object to the processing and to request the anonymization, blockage, or elimination of unnecessary or excessive data or of data processed in noncompliance with the provisions of the LGPD.
Deletion of personal data: You have the right to have your personal data deleted whenever it is processed under your consent. In general, this right is not available when we still have a valid legal reason to keep your data (for example, because we are forced to do so according to the law).
Portability: In some circumstances, you have the right to request that we transfer the data that we have collected to another organization, or directly to you.
Consent withdrawl: If we are processing your personal data based on your consent, you are entitld to withdraw this consent at any time, in which case we will interrupt the processing, except if we have another legal basis to continue the processing. You also have the right to be informed about the possibility of not giving consent and its implications.
Complaints: You have the right to file a compliant about data privacy matters to the Brazilian Data Protection Authority (“ANDP”). Before doing so, please tell us your concerns so that we can try to solve them.

To exercise one or more of these rights or if you have any questions about these rights or the processing of your personal data, please use the following e-mail adress: sac.volvocars@volvocars.com.

6. Contact information

In order to exercise your rights, please see section 5 above. If you have any other questions regarding the subject matter of personal data protection, you can contact us at the following contact details:

Volvo Car Corporation

Post address: Assar Gabrielssons väg, SE-405 31, Gothenburg, Sweden

E-mail address: globdpo@volvocars.com

7. Data Security

Volvo Cars is committed to making every effort to ensure the privacy and protection of your personal data. Likewise, we contractually require that all of our business partners who, eventually, process your personal data also act accordingly.

In general, we have adopted the following security measures:

Tools and mechanisms available in the market for cryptography, anonymization and inviolability of information, whenever applicable;
Technology for individualization and identification of accesses, including to prevent unauthorized access to our systems, data bases and all digital environments;
Confidentiality terms with all of our employees and partners who have access to or handle consumer data on behalf of Volvo Cars, in order to guarantee the security and confidentiality of the data; and
Technology available on the market to protect our data bases and digital enviroments.

8. Children’s Privacy

Our products and services are not designed or intended for individuals under the age of 12. Therefore, if you are under the age of 12, we ask that you do not use our services, and do not provide us with any information. If you are aware that an individual under the age of 12 has provided us with information, please contact us at the email address globdpo@volvocars.com so that we can take the necessary steps to delete such data.

9. Changes to our Privacy Notice

We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this privacy notice at any time. Whenever we make substantial changes to this notice, and in particular when this notice underlies your consent, we will inform you of the changes. This privacy notice is current as of the date which appears at the top of the document.