Privacy Notice – Consumer surveys

Effective from: 2021-11-08

Published at: 2021-11-08

This document describes how Volvo Cars (as defined below) processes your personal information when you engage with one of our consumer surveys (hereinafter "Consumer Survey").

You can find the following information below:

For information about how Volvo Cars: (1) shares your information generally throughout our services, (2) protects your information, (3) collects and processes children's information, and (4) addresses Do Not Track, please see our Customer Privacy Policy.

1. Who we are

For the purposes of GDPR, Volvo Car Corporation ("VCC"), having its registered office at Assar Gabrielssons Väg, 40531 Gothenburg, Sweden, company registration number 556074-3089, and Volvo Car Canada Limited, having its registered office at 9130 Leslie St. Suite 101, Richmond Hill, Ontario Canada ("Volvo Cars Canada"), are joint controllers. For the purposes of Canadian law and as pertaining to information of Canadian residents, Volvo Cars Canada facilitates the Consumer Survey and collects the information on behalf of VCC as part of the global survey and uses the information for its own purposes for the improvement of its services. VCC and Volvo Canada are hereinafter referred to as "Volvo Cars," "we," or "us."

2. What personal data we collect and why

A. Information Collected from You

Volvo Cars collects certain personal information from you when you participate in a Consumer Survey. "Personal Information" is information about an identifiable individual. Specifically, Volvo Cars collects the following personal information for the corresponding purposes described below:

To Administer the Consumer Survey: We collect from you your identifiers (name, e-mail address, telephone number), and these data are stored within Volvo Cars.
Survey Responses: We collect the responses you provide to the questions we ask in the Consumer Survey. These may vary from survey to survey. Whether you respond to a particular survey is your choice.
To classify the answers: We collect additional identifiers (salutation, age, gender, ZIP code, and city); commercial information (contract type, subscription number, vehicle relationship (contract/sales type starting and end date)) and vehicle information (vehicle type, Vehicle Identification Number (VIN), and registration number (REG)). We use this information to conduct segmentation analysis of the substantive answers in the Consumer Survey based on age, gender, location, city of residence, vehicle type, relationship type, etc in order to inform and improve our customer service practices, inform and improve our products, determine and adapt supply to various markets, and analyze the performance of our warranty. To the extent GDPR applies, we process this information based on our legitimate interest to assess field action and warranty performance, to improve the business purpose and customer experience that your survey response concerns, and to understand overall survey performance and survey interaction (Art. 6(1)(f) GDPR). Volvo Canada facilitates the conducting of the survey on behalf of VCC and conveys the information to VCC to be used as part of a global survey for improvement of the product, customer services, supply, and warranty. Volvo Canada uses the information collected in Canada and uses the information for its own purposes in the improvement of customer services, supply, and warranty, in a manner which does not include building or modifying household or consumer profiles.

You can opt out of receiving survey messages at any time by clicking on the "unsubscribe" link in the survey correspondence to you. You may also choose not to respond to a particular survey without opting out of future ones. This will not affect our ability to use information you had already provided in survey responses before you unsubscribed. Please note that Volvo Cars will continue to send you e-mails necessary for the Services, your account, your purchase, or any assistance you request.

B. Information Collected Automatically

When you fill out the survey, we automatically collect identifiers (IP address) and internet or other electronic network activity information (device time, browser type, and operating system). We use this information for functional purposes to display the consumer survey in the correct format.

In addition to the personal information you provide, when you interact with the email invitation for the consumer survey we automatically collect information via web beacons or tracking pixels that tell us whether you have opened the consumer survey. We collect this data for statistical analysis and to understand the interests of our consumers. You can prevent this tracking by adjusting your e-mail settings to prevent the downloading of pictures.

3. How we protect your personal information

In order to help keep your responses secure, the invitation for feedback provides you with an individualized questionnaire that no other person can access. The survey website and our data storage facilities have security measures in place to help prevent the loss, misuse, or alteration of the information under our control. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure or impenetrable.

Only certain employees have access to the personal information you provide us. They have access only for case handling, data analysis, and quality control purposes.

4. How long we keep your personal data

Your survey feedback responses will be kept for up to five (5) years from the time you submit your response, after which time they will be anonymized.

5. How we share your personal information

For information about how we share your information generally throughout our services, please see our Customer Privacy Policy.

In connection with the consumer survey, we have shared your:

Personal identifiers, internet and other electronic activity information, commercial information, and vehicle information with our service providers to support delivery of the consumer survey and care operations, including our data hosting provider, communications provider, and IT support.
Personal identifiers and internet and other electronic network activity information with our IT support to identify and repair errors and to maintain and improve the consumer survey;
We share with VCC (on behalf of whom we collect it) the customer feedback results to be used for inform and improve our and their customer service practices. inform and improve our products. determine and adapt supply to various markets, and analyze the performance of our warranty.

If your responses to the survey lead us to believe that there are issues to follow up on and improve, you personal information will also be disclosed to your selected retailer to conduct such follow up with you.

6. Your rights in relation to the information we collect

6.1. 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 us for 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 a reasonable fee that we base on administrative costs. You have the right to 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 our 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 our restriction of the 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 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 their processing while we verify whether our legitimate interests override yours.
Right to portability: You have the right to receive your personal data that you have provided to us and, where technically feasible, to 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 is 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 hold the right to have your personal data transmitted from us to another organization 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 that requires processing by European Union or Member State law or other applicable law to which we are subject;
3. for archival purposes in the public interest, for scientific or historical research purposes, or for statistical purposes; or
4. for the establishment, exercise, or defense of legal claims.
Right to object: You may object to the processing of your personal data at any time 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 request the erasure of your personal data; otherwise we will only restrict it. You also have the right to object at any time, regardless of the 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 would appreciate it 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.

You can exercise these rights in relation to all of the joint controllers mentioned in this notice.

6.2 Your rights under Canadian Law

If our processing of your personal data is subject to Canadian law, the following section applies to you:

Accessing and correcting your personal data: For residents of Canada, you have a right to request access to your personal data and to request a correction to it if you believe it is inaccurate. If you would like to have access to the personal data we have about you, or if you would like to have it corrected, please fill out this form, which will help us to handle your request properly. In some cases, we may not be able to allow you to access certain personal data in certain circumstances: for example, if it contains personal data of other persons, or for legal reasons. To help protect against fraudulent requests for access to your personal data, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. 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 you must 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 correction requests using the information provided, we may ask you for additional pieces of information.
Right to withdraw consent: If you have given consent for the processing of your personal data, you may withdraw your consent with effect for the future. Please note that if you withdraw consent that in necessary for us to provide you with products or services, we may no longer be able to provide those products or services to you. You may withdraw any consent you have provided to our use of personal data to market to you without withdrawing consent needed to provide our goods and services. Your withdrawal of consent does not have retroactive effect, and there may be cases where we are permitted under the applicable law to process certain personal data without consent.
Security: In order to help prevent unauthorized access to or disclosure of personal data, we have put in place physical, electronic, and organizational procedures to help safeguard and secure the personal data we collect. Personal data may be accessed by persons within our organization or our third-party service providers who require such access to carry out the purposes described in this Privacy Notice or are otherwise permitted or required by applicable law. Personal data we collect are managed from our offices in Canada and European Union. Even though we have taken steps to help protect the personal data in our control, you should know that we cannot fully eliminate security risks associated with personal data. No security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.
International Data Transfers: Personal data that we collect may be stored and processed in Canada and the European Union. Personal data processed and stored in another country may be subject to disclosure or access requests by the governments, courts, or law enforcement or regulatory agencies in that country, according to its laws. By providing us with personal data, you consent to any such transfer of information outside of your country.

7. Contact information

In order to exercise your rights under the GDPR, please use the web form mentioned in the Customer Privacy Policy in Section 6.1. For your rights under Canadian law, please see Section 6.2. To contact us with any questions about this notice:

Volvo Car Canada Limited

9130 Leslie St. Suite 101, Richmond Hill, Ontario, Canada

You can also contact the Volvo Car Corporation Data Protection Officer as follows:

Company: Volvo Car Corporation

Mailing address: Volvo Car Corporation, Assar Gabrielssons Väg, SE-405 31 Gothenburg, Sweden

Email: globdpo@volvocars.com

8. Changes to our Privacy Notice

We reserve the right to modify our privacy practices and update and make changes to this privacy notice at any time and at our discretion. For this reason, we encourage you to refer to this privacy notice on an ongoing basis. This privacy notice is current as of the date which appears at the top of the document. We will treat your personal information in a manner consistent with the privacy notice under which it was collected, unless we have your consent to treat it differently.