Volvo Cars Privacy Notice – Vehicle Connectivity Services
Effective from:
Published at:
Thanks for using Volvo Cars vehicle connectivity services! Volvo Cars Asia Pacific Headquarters (with business address at 2088 Luyi Road, Jiading District, Shanghai, hereinafter referred to as “Volvo Cars”, “we” or “us”) takes the protection of users’ personal information and privacy seriously.
As we may collect and use your personal information when you are using Volvo Cars vehicle connectivity services (“Volvo Vehicle Connectivity Services”), we have formulated the privacy notice (this “Notice”) that covers how we collect, store, use, share and protect personal information of users. We will explain to you in this Notice the purpose, manner and scope of our collection and use of your personal information, your rights to your personal information, and the measures we take to protect the information security in order to provide full disclosure and obtain your consent or separate consent.
Unless explicitly stated otherwise, this Notice does not apply to products and/or services that are accessed through our products and/or services and provided to you independently by third parties (including but not limited to AMAP, IQT, iQIYI, BILIBILI, CNR New Media, Ding Talk, App Store etc.), such as third-party Apps accessed through our products and/or services. Third parties may collect your personal information and we may share your personal information with them in order to provide the relevant services to you successfully. Please see section 4.2 for details of the personal information we share with third parties. Please note that if you provide your personal information to a third party when using its products and/or services, your information will then be subject to the third party’s privacy statement or similar policy, and we are not liable for any improper use or disclosure of the information provided by you by any third party.
We understand that the related persons or entities other than you (including, without limitation, your contact, spouse, relatives, drivers, etc.) may also access and use our Volvo Cars App in using your vehicle, and their information is provided to us in the course of obtaining relevant products or services we provide to you (“you” and “related persons”, collectively referred to as “you”). You acknowledge that before such related persons provide any information to us, you have explained to them the purpose, method and scope of use of the information in accordance with this Notice and have obtained their consent to enable us to collect, retain, use, entrusted process, share, transfer and publicly disclose such information in accordance with this Notice. Meanwhile, you have notified such related persons of their rights to access, rectify and erase their personal information. If you need to resell or scrap your vehicle, or if your vehicle maintenance involves replacing the vehicle’s engine, please be sure to click Restore Factory Settings in the vehicle settings interface; otherwise, there is a possibility that the personal information generated by your use of the vehicle will be known by others.
Please use Volvo Connectivity Services after you have fully understood this Notice and clicked “Agree”. If you/your guardian do/does not agree to this Notice, you may object to our collection and use of your personal information by clicking “Disagree”, and then we may not be able to provide you with the relevant services.
This Notice will help you understand the following:
I. How we collect and use your personal information
II. How we use Cookies and similar technologies
III. How we store your personal information
IV. How we entrusted process, share, transfer and publicly disclose your personal information
V. How we protect your personal information
VI. Your rights to your personal information
VII. How we process personal information of minors
VIII. Third party service providers and their services
I. How we collect and use your personal information
We collect personal information in order to operate more efficiently and provide you with the best user experience. The ways we collect personal information include: (1) you provide to us directly in your used of Volvo Vehicle Connectivity Services; (2) we obtained in your use of Volvo Vehicle Connectivity Services; and/or (3) we obtained from third parties consented by you.
The information to be collected by us depends on the products or services you are using, the environment in which you interact with us, and the choices you make, including your privacy settings and the products and functions you use. Our products and functions include core business functions and value-added business functions. You may choose to consent us to collect and use your personal information. If you opt not to provide certain personal information necessary for core business functions, we may not be able to provide you with related services, respond to or solve your problems. If you opt not to provide certain personal information necessary for value-added business functions, you may not implement the relevant value-added business functions normally or achieve the desired functional results, but it will not affect your use of the corresponding core business functions.
1. How we collect and use your presonal information
1.1 Information you provide to us
1. To associate your IQT and AMAP accounts
When you choose to log in to third-party services (including third-party apps) through an associated account, we may need to provide the third party with your Volvo account ID, account log-in status for the purpose of identifying you, assisting you in completing your account bindings, logging in, and displaying your identification information.
1.2 Information collected in your use of products or services
1. Vehicle system activation and login
When you activate the vehicle system through the center screen in your vehicle, you need to scan the QR code on the vehicle system through the Volvo Cars App to authorize the login. At this time, we will collect your mobile phone number, user ID, user nickname, avatar, bound vehicle information and Vehicle Identification Number (VIN) from your Volvo Cars App account in order to achieve binding with the vehicle system, so as to further realize the interconnection between Volvo Cars App and the vehicle; at the same time, we will collect information about your vehicle settings, which will be used to synchronize your vehicle settings and preferences when you log in to your vehicle or other vehicles of the same car model using this account. You can also choose not to log in to your Volvo account and still use most of the features of Volvo cars.
You can independently choose to enable the face recognition login function. To realize this function, we will verify your identity by means of face information matching. We do not store and transmit the original face image data you provided outside the vehicle, we only keep the facial features generated from the original data and store them inside the vehicle for the implementation of the face recognition function.
The face recognition function is set to be disabled by default, unless you take the initiative to turn it on. After you have provided your face information, you can still turn off or turn on the function on your own initiative in the relevant function interface. If you refuse to provide this information, you can still choose to log in by scanning your Volvo Cars App account.
2. To provide you with multimedia service
Our online multimedia (online music, online video, CCTV cloud listening) services are provided and your relevant information is collected by our partners (iQIYI, BILIBILI, IQT, subject to the specific page display). Please be sure to read the privacy policy of the partners before using specific functions. We will also monitor the legal compliance of the partners by reviewing qualifications and signing contracts. In order to maximize the protection of your personal information security, we strongly recommend that you check the privacy terms of any third-party services before using them. In order to protect your legitimate rights and interests, if you find that such app or other similar apps are risky, we recommend that you immediately terminate the relevant operation and promptly contact us.
3. To provide you with maps and navigation service
The mapping and navigation services for the vehicle system are provided by Amap Software Co., Ltd. (AMAP). When you first choose to use the map and navigation services, you need to agree to and follow the navigation partner’s AMAP Terms of Service and/or AMAP Privacy Policy. In order to complete the navigation service, the navigation partner needs to collect and process vehicle location information, destination information, driving track, vehicle speed (instantaneous speed, average speed, maximum speed); and will record home address, company address, favorite address, historical search address according to your settings. You can view, modify and delete this information in the AMAP at any time. If you refuse to provide vehicle location information and driving track information, the third party will not be able to provide you with map and navigation services, but it will not affect your use of other functions and services that do not involve vehicle location information and driving track information.
When you use the Friends in Road function, you will get the location shared by your friends through WeChat and send it to the car screen. At this time, you can utilize the vehicle’s AMAP navigation to realize the navigation function. Please notice that in order to realize the location sharing to car function, we need to collect your Vehicle Identification Number (VIN), vehicle location information.
4. To provide you with weather service
When you use the weather function, we process your vehicle location information (city) in-vehicle in order to provide the appropriate weather conditions based on your location.
5. To provide you with voice service
The voice service of the in-vehicle system is developed by Volvo/Beijing Baidu Netcom Science Technology Co., Ltd (Baidu) and supported by voice recognition technology from our voice partner, Baidu. When you independently choose to turn on the voice function, you need to provide us with or allow us to collect the necessary information, including: voice audio, voice text, device information, network status information, otherwise we cannot provide you with voice search or human-computer interaction services. Baidu only processes audio data from audio to text in real-time and provides feedback on the recognized text content.
In particular, we would like to draw your attention to the fact that when you use the voice recognition function, although the audio content collected by the voice recognition function may contain personal information about you or others, we will not identify the individual based on the content of the personal information involved, and Baidu will delete the audio data as soon as we have completed the identification of the audio text content. If you use your voice to wake up other functions that collect personal information, we will also collect other personal information according to the specific function.
6. To provide you with the driving video data service
The video data from your dashcam is only stored in the vehicle's storage device and is under your control. We do not receive, store, or transmit the video data recorded by your dashcam. If you need to access the video data, please follow the instructions in your vehicle's owner's manual. According to applicable laws, the license plate in the video outside the vehicle and facial features of pedestrians are personal information and are protected by law. If you need to share the images outside the vehicle, please comply with the corresponding legal requirements to avoid infringing on the rights and interests of others.
7. To provide you with Event Data Recorder (EDR) service
To comply with the related legal requirements, we may collect and store safety-related information relating to crash or near-crash situations in an EDR – also known as the car’s “black box”. The safety-related information includes data:
- How various systems in your vehicle were operating;
- Whether or not the driver’s and passenger’s safety belts were buckled/fastened;
- How far (if at all) the driver was depressing the accelerator and/or brake pedal; and,
- How fast the vehicle was traveling.
The recording time is usually 5 seconds. Please noted that recording only takes place if a non-trivial collision situation occurs, and no data is recorded under normal driving conditions. Furthermore, the recording does not include who is driving the vehicle or the geographical location of the (near) crash. Please understand that the EDA service is a compulsory service according to laws and regulation. We need to collect your data above to provide you with EDA service.
8. To provide you with Driver Fatigue and Distraction Detection service
Driver fatigue and distraction detection function needs to collect your face information through the in-vehicle camera, analyze the characteristics of the driver's head position, eye position, and vision status whether the eyes are closed, and convert them into assessment values to determine your fatigue or distraction level and provide you with appropriate alerts.
The function processes all face information only in the vehicle. The face information will not be used for identification and will be deleted once the processing is completed. driver fatigue and distraction detection is turned off by default, and you can turn on or off via "Volvo Cars Vehicle Settings"-Driving-Driver Fatigue Reminder".
9. To provide you with Over the Air Update service (OTA) service
In order to enhance driving safety and continuously optimize vehicle functions, we will from time to time provide you with Over the Air Update service (OTA). When you use the OTA function to upgrade the system or software, we will collect your Vehicle Identification Number (VIN), vehicle configuration information, vehicle software information, vehicle function information, part series number ECU, vehicle status, battery power, upgrade time, upgrade progress information, such information is used to identify the current version of the in-vehicle system and the corresponding upgraded version of the situation and to allow the system to determine whether the current network state is able to support the in-vehicle system upgrade. In order to analyze the reasons for the failure of OTA upgrade, we will collect the log information of your vehicle during the OTA upgrade process. In addition, if you voluntarily choose to turn on the night upgrade service, we will also collect your night upgrade reservation time. Night upgrade service is disabled by default, you can turn on or off via "Vehicle Settings-OTA".
10. To provide you with Vehicle Connectivity and Vehicle Control service
When your car is connected with "Volvo Cars App" and can be managed and controlled through the app, including but not limited to Bluetooth key, remote control, environment adjustment, etc. (the details subject to the display of the car control functions in the App), we will push the alarm/alert information of each function to you and perform the relevant operation of your vehicle control in order to facilitate you to view and manage your vehicle in Volvo Cars App. We will collect relevant information about your vehicle according to the needs of specific functions, including Vehicle Identification Number (VIN), vehicle status information (including but not limited to lock status, door status, window status, trunk status, charging port cover status, air conditioning operation status, air conditioning temperature, ventilation status, seat heating status, seat ventilation status, steering wheel heating status, percentage of remaining battery power, available mileage, tire pressure temperature, tire pressure value, interior temperature, interior PM 2.5, total mileage, driving hours), and vehicle location information. You can control whether the location information is uploaded to the Volvo remote information service platform via the "Settings - General - Location information Upload" switch. If you choose to turn off the uploading switch, you will not be able to use the Volvo App to remotely view the vehicle's location function and electronic fence function, but it will not affect your use of other functions and services provided by us.
When you use the electronic fence function, in order to facilitate your vehicle location monitoring and alert you when the vehicle moves in a suspicious location, we will collect your vehicle location information, the start time and end time of the electronic fence that you set, the name of the fence, the center of the fence, and the radius of the fence.
Only you or your authorized vehicle user can use the remote vehicle control features. Remote vehicle control features include, but are not limited to: remote locking and unlocking, remote window/door control, remote air conditioning control, remote car finder, remote trunk control, remote passenger compartment ventilation, remote seat ventilation, and remote heated steering wheel.
11. To provide you with remote energy management and cabin environment control services
When you use the travel reservation service, we need to collect your travel cycle, travel time, battery temperature switch status, and cabin comfort switch status, in order to help you adjust the battery status to the optimal state and reduce driving energy consumption before you travel, as well as intelligently adjust the cabin environment (air-conditioning temperature/seat heating/steering wheel heating) to a comfortable state in advance. If you refuse to provide the above personal information, we will not be able to provide you with the corresponding services, but it will not affect your use of other functions and services provided by us.
12. To provide you with App Store service
When you download and use third-party apps through the App Store of your in-vehicle system, you need to agree and follow the third-party's Privacy Policy. Also, in order to provide you with App Store function, we may collect Vehicle Identification Number (VIN), vehicle model, IHUID, installed app information (app list, version number, package name).
13. To provide you with Vehicle User Manual liking function
When you use the Vehicle User Manual on your car system to log in to your account and then make a like, we will collect your user ID and like record so that we can better improve the content of the Vehicle User Manual. If you refuse to log in to your Volvo account, we will not be able to provide you with the service of liking this feature, but it will not affect your ability to use other functions and services that are not based on this information.
14. To provide you with Emergency Call (eCall) function
In order to ensure your safety, we have developed Emergency Call (eCall) function, which is made automatically to customer Service center in the event of a severe accident, detected by activation of one or more sensors within the vehicle, so that we can more quickly initiate rescue measures in the most appropriate manner after an accident.
When an emergency call is made, we need collect the following data:
- Vehicle Identification Number (VIN);
- Vehicle propulsion or engine specifications;
- Vehicle model specification;
- Time of the incident;
- Location of the incident; and
- Vehicle traveling direction.
15. To provide you with Bluetooth function
When your cell phone completes Bluetooth pairing with the vehicle, your cell phone device information (Mac address, Bluetooth name) will be read by the car to achieve pairing, after successful pairing, the car will request to get your local number for local number identification and cell phone network phone judgement, after completing the identification and judgement, it will be deleted. In order to display your address book and call records on the central control screen of the car, the car system will request your cell phone device to synchronize the address book and call records to the head unit, and before synchronization, it will apply for your consent through a pop-up window on the cell phone page. If you refuse to give consent, it will prevent you from checking the name of the caller and the call records on the car, but it will not affect your use of the Bluetooth phone function. When you remove the corresponding Bluetooth pairing, the related personal information stored in this function of the car will be deleted. Your above information will only be processed in the head unit and we will not process your related information.
16. To provide you with Intelligent Driving Assistance System function
- Driving Assistance Function
When you use the in-vehicle Intelligent Driving Assistance System (including forward collision warning/mitigation, rear collision warning, lane-keeping assistance, adaptive cruise control, traffic access recognition, door opening alert, lane change assist, subject to the specific page display), the external sensors on the vehicle need to collect information about surrounding obstacles, environmental conditions, the vehicle's operating status, and the internal signals to realize intelligent driving assistance.
- Parking Assistance related Functions
When you use the parking assistance system (including front parking assistance, rear parking assistance, visible parking assistance, subject to the specific page display), in-vehicle sensing devices and cameras will real-time collect images of vehicle surrounding obstacles, environmental conditions, vehicle operating status, parking status machine signals, and user activation signals to achieve intelligent driving assistance.
- Data Sharing Function
In order to improve and optimize Volvo’s Intelligent Driving Assistance System, the exterior sensors will record road information such as lane lines, road signs, traffic signal positions, as well as speed and vehicle location information, and this data will be transmitted to our partners who have the relevant qualifications. Through continuous learning, the Intelligent Driving Assistance System will enhance the road recognition capability. During this process, the data is protected by strict technical safeguards; it does not contain any video or images and is de-identified/anonymized to ensure that you cannot be identified by such data. At the same time, you can turn off the data sharing function at any time in the vehicle settings.
17. To provide you with Vehicle Problem Analysis, Remote Troubleshooting services
In order to provide you with Vehicle Problem Analysis, Vehicle Remote Troubleshooting services, we need to collect vehicle VIN number, vehicle log, model, model year, vehicle configuration information, vehicle software information, electronic control unit diagnostic data, diagnostic process vehicle data.
18. To provide you with Vehicle Operation Safety, After-sales service
In order to ensure the safe operation of your vehicle, to continuously monitor the vehicle operating status and provide early warning of abnormal conditions, as well as to provide after-sales service, screening and resolution of vehicle problems, we need to collect your Vehicle Identification Number (VIN), basic vehicle body data (e.g., main driver’s door status, main driver’s lock status, main driver’s seat ventilation status), three electric operation data (e.g., high-voltage battery charging status, battery temperature signal, high-voltage closure status), chassis driving data (e.g., steering wheel angle, vehicle speed, vehicle braking signal), intelligent air conditioning data (e.g., air conditioning status, compressor running time, compressor speed), power management data (e.g., small battery current, small battery charge, reason for not sleeping).
19. To provide you with User Experience Improvement services
In order to provide you with user experience improvement services, we need to collect your vehicle VIN code, user behavior (use of vehicle control, multimedia, voice, user center, application market, user manual, rear screen, air conditioning, artificial intelligence companion, menu bar, seat, boot guidance, camera (subject to the specific function display interface), the stay time on the relevant page, the contents of the operation (including likes, comments, multimedia usage, vehicle settings, etc.), network status information, and phone status information, you can turn off the switch to stop data collection at any time through "Vehicle Settings - User Experience Improvement Program". However, please note that if you turn off the collection of such data, you may not be able to get a better and personalized experience.
1.3 Information collected in accordance with laws and regulations
In order to comply with legal and regulatory requirements, we are required to monitor and upload the following vehicle data to national/local new energy monitoring platforms as well as to the data platforms of Volvo and its affiliates: vehicle static information, vehicle data, drive motor data, fuel cell data, engine data, vehicle location data, extreme value data, alarm data, and other information required to be monitored and uploaded in accordance with applicable laws, regulations or governmental requirements. We need to upload the repair electronic data to the Vehicle Repair Electronic Health Record System, including: repair basic information, license plate number, Vehicle Identification Number, date of delivery, mileage of delivery, settlement date, description of the fault, settlement list number, fuel type, list of repair parts, name of the parts, quantity of the parts, part number, list of repair items, repair item, and repair work hours.
1.4 Collect your information from third parties
When you choose to log in to third-party services (including third-party apps) through an associated account, we may need to collect your third-party account avatar, nickname, and OpenID from the third party for the purpose of identifying you, helping you complete account binding, logging in, and displaying your identity information.
We will use your personal information strictly for the purposes set forth in this Notice, and your personal information will only be used for the purposes that were determined, specified and authorized by you at the time of collection. We will ask for your consent in advance if we use the personal information collected for purposes not specified in this Notice, or when information collected for a particular purpose is used for other purposes. We will not provide your personal information and other vehicle data to third parties without your consent.
1.5 Other instructionsfor use
Personal information collected based on this Notice may be used for the following purposes in addition to the explicitly agreed upon purposes of use, but we are committed to using it in compliance with relevant laws and regulations, including obtaining your authorized consent when necessary:
1. Product and Service Improvement
We may use the personal information collected in accordance with this Notice to improve the quality of our services, enhance user experience, develop new products, and enhance product security through research, analysis, and forecasting.
2. Security and Anti-fraud
We may use the information collected in accordance with this Notice for purposes such as security prevention, fraud prevention and illegal monitoring to prevent infringement of our or other third parties' legitimate rights and interests, violation of regulations or rules of agreement, etc., so as to protect the legitimate rights and interests of you, us, other third parties and the public good.
3. User Profile
We may aggregate and analyze personal information collected in accordance with this Notice, such as making analysis or predictions based on personal preferences and operating behavior. However, please note that we currently do not form a model of your personal characteristics for your personal operating information and browsing habits on your vehicle, but only form a group-related portrait, and may use this characterization model for related eco-services. We will only use indirect profiles of you for services that refer to your personal information without your individual consent, e.g. we will only use indirect profiles of you when promoting commercial advertisements.
4. De-identification/anonymization of personal information
After collecting your personal information, we will promptly de-identify or/and anonymize the data by technical means. On the premise of not disclosing your personal information, we have the right to mine, analyze and utilize (including commercial use) the anonymized user database. When we want to use the information for other purposes not stated in this Notice, we will ask for your prior consent or use your information for other legitimate purposes. When we want to use the information collected for a specific purpose for other purposes, we will ask for your prior consent or use your information for other legitimate purposes.
2. Exceptions to authorized consent to collection and use of personal information
You are fully aware that, under applicable laws, we may not need your authorized consent to collect and use your personal information where one of the following circumstances is met:
- As necessary to conclude or perform on a contract to which an individual is a party;
- As necessary for the performance of legally-prescribed duties or obligations;
- As necessary to respond to public health incidents or to protect natural persons' security in their lives, health, and property in an emergency;
- Handling personal information within a reasonable range in order to carry out acts such as news reporting and public opinion oversight in the public interest;
- For a reasonable scope of handling of personal information that has been disclosed by the individual or otherwise already legally disclosed in accordance with Personal Information Protection Law of the People’s Republic of China;
- Other situations provided by laws or administrative regulations.
II. How we use cookies and similar technologies
1. Cookies and similar technologies
In the vehicle, we will use the analysis tool Sensors - a universal event tracking technology platform. The analysis tool will be based on your operation in the vehicle, record the relevant data, including user behavior (use of car control, multimedia, voice, user center, App Store, user manual, rear screen, air conditioning, artificial intelligence companion, menu bar, seat, boot guidance, camera (subject to the specific function display interface) related to the situation, time spent on the relevant pages, the content of the operation [including likes, comments, multimedia usage, vehicle settings, etc.), network status information, and telephone status information. This information helps us to understand how you use our products and/or services, to further develop and improve our products and/or services, to enhance your experience, to develop new products and to recommend content that may be of interest to you.
In order to provide you with user experience improvement services, we need to collect your application usage data and behavioral data and conduct related processing and analysis. You can reject the data collection at any time by turning off the switch through "Vehicle Settings - User Experience Improvement Program". However, please note that if you turn off such data collection, you may not be able to get a better and personalized experience.
III. How we store your personal information
1.
We will determine the duration of retention of your personal information only to the extent required by laws or regulations, and as necessary to achieve the purposes of this Notice. Upon the expiry of the above period, we will delete or anonymize your personal information.
2.
If we terminate our services or operations, we will notify you at least 30 days in advance, and delete or anonymize your personal information upon such termination.
IV. How we entrusted process, share, transfer and publicly disclose your personal information
1. How we entrusted process your personal information
Some specific modules or functions in our products or services are provided by external suppliers. For example, we will engage service providers to assist us in providing our roadside assistance services, maintenance and repair services, insurance services, charging post installation services and charging post operation and maintenance services. For companies, organizations and individuals that we entrust to process personal information, we will sign strict confidentiality agreements or other data protection related agreements with them, requiring them to comply with laws, regulations and our requirements, and take other measures that can ensure the confidentiality and security of personal information to process personal information.
2. How we share and transfer your personal information
We may, from time to time, share some of your personal information with our affiliates and strategic partners in cooperation with us in product and service offerings, or share or transfer your personal information in other circumstances to offer products or services you request. Volvo Cars may share your personal information to the following extent:
- Sharing among Volvo Entities: To the extent permitted by laws and regulations, your personal information may be shared with our affiliates to ensure compliance with laws, and protect the interests, property and security of us and our affiliates or business partners, you or other users or the public at large. We will share only such personal information as is necessary to achieve the purposes above. Without your consent, our affiliates will not use our shared personal information for any purpose other than those described above;
- Sharing with business partners: Some of our services will be provided by our authorized business partners only for the purposes stated in this Notice. We may share with our business partners some of your personal information to provide better customer service and user experience. Our business partners include the following:
- After-sale Service Provider. We may share your personal information based on the needs of after-sales service providers to provide services to you. For example, we may provide your Vehicle Identification Number (VIN), device information, network access certificate, log information related to networking functions to after-sales service providers for the purpose of identifying and diagnosing vehicle networking faults, assisting you in solving networking problems and/or upgrading product services; we may provide your vehicle diagnostic code, mileage to after-sales service providers for the purpose of providing you with vehicle repair, maintenance services.
- Supplier or Service Provider. In order to achieve continuous optimization and improvement of our products and provide you with better and more diverse services, we may share your personal information with suppliers or service providers to ensure the smooth completion of the services provided to you. Currently, the scenarios in which we share information with suppliers or service providers are detailed in Appendix I, "List of Third-Party Information Sharing".
- Third-Party SDK. Under certain specific business scenarios, in order to ensure the stable operation and functional realization of our products or services, and to enable you to use and enjoy more services and functions, we may embed third-party Software Development Kits or other similar applications (collectively referred to as SDKs) in our products or services to provide services to you. Currently, the third-party SDKs that our products or services access under this Notice that involve the collection of your personal information are detailed in Appendix II, "List of Third-Party SDKs".
- Transfer of Personal Information: We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:
- Transfer with explicit consent: We will transfer your personal information to other parties with your explicit consent;
- Transfer in the event of a merger, demerger, dissolution, acquisition, or bankruptcy: In the event of a merger, demerger, dissolution, acquisition, or bankruptcy involving the transfer of personal information, we will notify you of the name and contact information of the recipient of the personal information. We will inform the recipient that they should continue to fulfill the obligations described in this privacy statement and obtain your consent separately.
- We will share your information as required by laws or regulatory requirements in scenarios such as government investigations, disputes, and other legal procedures or requirements.
- We will disclose and share your information when we, in good faith, deem it necessary to protect our rights, for example, to investigate potential breaches of our terms and conditions or to detect, prevent or disclose fraud and other security concerns.
- We will only share your personal information for lawful, proper, necessary, specific and express purposes to the extent required for providing products and/or services. We will only allow Volvo Cars employees and affiliates who have a need to use your personal information to access your personal information when acting on behalf of Volvo Cars and we will only share the required personal information and the sharing behavior will be bound by the purposes stated in this Notice. Our affiliates will seek your consent separately if they intend to change the purpose for which your personal information is processed.
- Where personal information needs to be transferred due to merger, division, dissolution or declaration of bankruptcy, we will notify you of the name and contact information of the recipient. We will notify the recipient that it should continue to fulfill the obligations stated in this Notice and obtain your separate consent if the recipient makes any change to the purpose and method of information processing.
- We will enter into strict confidentiality agreements with companies, organizations and individuals with whom we share personal information, emphasizing our stringent data protection compliance requirements and requiring them to process personal information in accordance with our instructions and any other relevant confidentiality and security procedures. In the use of personal sensitive data, we require third parties to adopt data desensitization and encryption technology to better protect user data. However, please note that Volvo Cars and its authorized dealers and service providers are legal entities independent from each other, and we are generally not liable for unlawful acts of Volvo Cars’ authorized dealers or service providers. If you have any questions about the collection and use of your personal information by your dealers or service providers, please contact such dealers or service providers directly.
3. How we publicly disclose your personal information
We may publicly disclose your personal information only:
- when we obtain your separate consent; or
- when it is required by law: We may, as required to comply with laws, regulations, subpoena and other legal proceedings or action, or mandatory requirements of government authority, disclose your personal information if we, in good faith, believe that disclosure is necessary to protect our rights, to protect the safety of you and others, to investigate fraud or respond to government requests.
4. Exceptions to authorized consent to sharing, transfer or public disclosure of personal information
You are fully aware that, under applicable laws, we may share, transfer or publicly disclose your personal information without your prior consent where one of the following circumstances is met:
- As necessary to conclude or perform on a contract to which an individual is a party;
- As necessary for the performance of legally prescribed duties or obligations;
- As necessary to respond to public health incidents or to protect natural persons' security in their lives, health, and property in an emergency;
- Handling personal information within a reasonable range in order to carry out acts such as news reporting and public opinion oversight in the public interest;
- For a reasonable scope of handling of personal information that has been disclosed by the individual or otherwise already legally disclosed in accordance with laws and regulations;
- Other situations provided by laws or administrative regulations.
V. How we protect your personal information
We attach great importance to the protection of users’ personal information and take all reasonably practical measures to protect your personal information:
1. Technical measures for data security
We will adopt security precautions that meet industry standards, including developing reasonable systems, norms, and adopting security technologies to prevent unauthorized access, use, modification, damage or loss of your personal information.
Volvo Cars adopts encryption technology to encrypt and store users’ personal information, and isolate it through segregation technology. Volvo Cars adopts strict data access rights control and multiple identity authentication technology to protect personal information and avoid unauthorized use of data.
2. We only allow employees of Volvo Cars and its affiliates who have a need to know such information to access personal information, and we have strict access control and monitoring mechanisms in place for this purpose. We also require all personnel who may have access to your personal information to comply with their confidentiality obligations. If they fail to fulfill these obligations, we will pursue their legal liabilities or suspend our cooperation with them accordingly.
3. We recommend that you use complex passwords when communicating with other users by email, instant messaging, social networking software and other communication tools, and take care to protect your personal information.
4. You are reminded that the Internet environment is not 100% secure, and we will take security measures to ensure the security of any information you send us, in accordance with legal requirements and technological development. In the meantime, however, if any unauthorized access, public disclosure, tampering, or destruction of information is caused by any unpredictable and unpreventable damage to our physical, technical or management protection facilities, we will not be liable for any losses not caused by Volvo Cars.
5. Handling of security incidents
Please be sure to protect your personal information properly and only provide it to others when necessary. In order to deal with the potential risks such as leakage, damage and loss of personal information, Volvo Cars has established various rules and regulations, specifying the criteria for classifying and grading security incidents and security vulnerabilities as well as corresponding handling procedures. Volvo Cars has also set up a dedicated emergency response team for security incidents, which will, in accordance with good practice for security incidents, initiate security plans for different security incidents, to stop losses, analyze, locate, formulate remedial measures, and work with relevant departments to trace to the source and crack down on the incidents.
In case of any personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly notify you of the following matters: basic status and possible impacts of such security incident, response measures we have taken or will take, suggestions on how you may prevent or reduce risks on your own, and remedies available to you. We will also promptly notify you of relevant information of such incident through email, letter, phone call, push notification, or otherwise. If it is difficult to notify each personal information subject one by one, we will publish an announcement in a reasonable and effective manner. In addition, we will, as required by law, voluntarily report our disposal of the personal information security incident to the regulatory authority.
We have established a dedicated network operations and data security team to carry out work related to personal information protection. If you have any questions about our personal information protection, please contact us via any of the means stated at the bottom of this Notice. If you are aware of any leakage of your personal information (especially concerning your account and password), please contact us immediately via any of the means stated in this Notice and assist us in taking appropriate measures.
VI. Your rights to your personal information
We respect your rights to your personal information. Below is a list of your rights under the law, and we will explain how we protect these rights.
1. Right to be informed
We publish this Notice to inform you of how we may process your personal information. We are committed to ensuring transparency in the use of your information.
2. Right to access
You may inquire or access your personal information directly in our product or service interface, including logging in your account at any time through the product page to access your personal information in connection with your account.
You may access your personal information and vehicle usage data through your vehicle’s “System Settings” – “User Center”. If you are unable to inquire or access your personal information on your own or encounter any problems in exercising your right of access to data, you may contact us and request access to your personal information in any of the means disclosed in this Notice.
3. Right to rectification
You have the right to request us to correct or supplement any of your personal information that we have processed if you find it incorrect or incomplete. You can access, modify or supplement your nickname, avatar and related personal profile through the “Volvo Cars App” by going to “My” – “System Settings” – “Personal Profile”. You can also modify your personal profile by visiting the User Center on the head unit. You may apply for correction through Volvo Entities, authorized dealers, customer service hotline (10108666) and other channels.
4. Right to erasure
You have the option to delete certain personal information you have provided to us. For some of your personal information, you can contact us to delete it by calling our customer service hotline (10108666), and we will assist you in completing the deletion of the information within the time limit prescribed by laws and regulations.
5. Right to account cancellation
We provide you with the right to cancel your account. You can cancel your account through the “Volvo Cars App” “My”. You can cancel your account by visiting “My” – “System Settings” – “Cancel Account”. You may contact us directly via any of the means disclosed in this Notice to apply for cancellation of your account. After you submit your application, we may need to manually review your account cancellation to confirm that you meet the conditions for account cancellation. We will assist you with account cancellation within 15 business days after you submit the application. After you choose to cancel your account, we will erase or anonymize all relevant personal information under your account, unless otherwise provided by laws and regulations. After you cancel your account, we will no longer provide you with any products or services that require you to log in your account.
6. Right to portability
Where the conditions specified by the national cyberspace administration are met, you have the right to request the transfer of your personal information to a designated personal information processor. With formal authorization, you can exercise your right to portability by calling the hotline provided in this Notice.
7. Right to obtain a copy of your personal information
You have the right to obtain a copy of your personal information, which you may do yourself by: contacting us, providing it in text form. We may also, where technically feasible, such as the data interfaces have been matched, transfer a copy of your personal information directly to a third party nominated by you at your request.
8. Right to complaint
- You have the right to complain by contacting via any of the means disclosed in this Notice. We will respond to your complaint within 15 business days of receipt. If you are not satisfied with our response, especially when our personal information processing has infringed upon your legitimate rights and interests, you may also file a complaint with or report to the cyberspace, public security, industry and commerce and other regulatory authorities, or file a lawsuit to a court having jurisdiction.
- Please note that, for security reasons, we may verify your identity before processing your request. In principle, we will not charge a fee for your reasonable requests. For repeated requests that exceed reasonable limits, we will charge a fee as appropriate. We may reject those requests that are unduly repetitive, that require too many technical means (for example, developing new systems or making fundamental changes to existing practices), that pose a risk to the legitimate rights and interests of others, or that are very impractical, and state the specific reasons therefor in our response. Furthermore, we may not respond to your request if your request directly relates to national security, national defense, public health, criminal investigation, or other matters directly related to the public interest, or may seriously damage your, or other individuals’ or organizations’ legitimate rights and interests.
Subject to the relevant legal requirements, your close relatives may exercise the above rights to access, duplicate, correct, or erase your relevant personal information, unless otherwise arranged by you.
VII. How we process personal information of minors
- Our products and services are mainly intended for adults. If you are a minor under the age of 18, you must obtain prior consent from your guardian before using our products and/or services. In the case of collection of children’s personal information with the consent of their parents, we will only use or publicly disclose such information to the extent permitted by law, expressly consented by their guardian or necessary to protect the children. For the personal information of children under the age of 14, we will, in addition to comply with the provisions of this Notice on users’ personal information, adhere to the principles of legitimate necessity, informed consent, clear purpose, security assurance and lawful use, store, use, and disclose children’s personal information, and protect the legitimate rights of children and their guardians concerning the relevant children’s personal information in strict accordance with the Personal Information Protection Law, the Provisions on the Network Protection of Children’s Personal Information and other laws and regulations.
- We will erase the relevant personal information as soon as possible if we are aware that we have collected the personal information of a minor without the prior verifiable consent of his or her guardian.
- If you are the guardian of a minor, please contact us through the contact information below when you have questions about the processing of the information of the minor under your guardianship, or if you have evidence to prove that the minor has used Volvo Vehicle connectivity services without the consent of a guardian.
VIII. Third party service providers and their services
When using our products and/or services, you may access applications and other services linked to products such as Volvo vehicles and web pages but actually provided by third parties, for example, third-party applications that may require vehicle records including your location data to provide services to you. To this end, such applications and other services provided by third parties may involve your providing to third parties a particular type of personal information. Volvo Cars shall not be liable for any collection or use of personal information by third parties’ applications or services. We also recommend that you read the applicable terms and conditions (and any related privacy statements) carefully before using such applications or services and make a choice in your sole discretion after making sure you have fully understood its rules on collecting and using your personal information. If you have any question about a particular third party’s use of your personal information, please contact the third party directly.
IX. How your personal information is transferred globally
In principle, personal information collected and generated in the People's Republic of China will be stored in the People's Republic of China. As the Volvo Cars Group operates its day-to-day business through its affiliates and information systems around the world, your personal information may be transferred to, or accessed by Volvo Car Group overseas affiliates and third-party service providers ("Overseas Recipients"), subject to your individual consent:
| Serial number | Purpose | Field |
|---|---|---|
| 1 | In order to provide you with Volvo Vehicle Butler service, we provide you with emergency assistance in the first instance when you need emergency assistance in case of an accident, illness, external threat, and so on. And through the overall analysis of the call service, to ensure the normal operation and maintenance of the service system, so that you can enjoy the best quality with the car butler service. | Name, phone number, Vehicle Identification Number (VIN) |
Current physical storage locations for our data include Beijing, Shanghai, and Hangzhou.
The aforementioned Overseas Recipients are:
| Company name | Country/Region | Contact information |
|---|---|---|
| Volvo Car Corporation | Sweden |
|
X. Update of this Notice
1. This Notice will be updated to provide you with better services and to keep pace with our business development. We will not, however, reduce your rights under this Notice without your explicit consent. We will issue updates on our website and Volvo App, and remind you of such updates by website announcements or any other proper way before they take effect. Please visit Volvo Cars’ website to keep abreast of the latest Notice. In practice, in the case of product upgrades, we will also separately inform you of the personal information collected by the feature in the opening screen of the feature. By using or continuing to use our products and/or services after we have updated this Notice (in such event that we will promptly remind you of the updates), you agree to the content of this Notice (including the updated version) and consent to the collection, use, storage and sharing of your information in accordance with this Notice.
2. For material changes, we will also provide a more prominent notice (we will explain specific changes to this Notice by means including but not limited to emails, text messages or a special notice on the browser page, including separately obtaining your consent through the display screen for that feature).
Material changes referred in this Notice include, but are not limited to the following:
- Material changes in our service model. For example, the purpose of processing personal information, types of personal information processed, and the way of using personal information;
- Material changes in our ownership structure, organizational structure and so on, such as changes in ownership due to business adjustment, bankruptcy, merger and acquisition;
- Changes in the main recipients to which the personal information is shared, transferred or publicly disclosed;
- Material changes in your rights to participate in personal information processing and the way of exercising such rights;
- Changes in our department responsible for personal information security, relevant contact information and complaint channels; and
- High risks as indicated in the assessment report on the impact of personal information security.
3. We will also keep the old version of this Notice in archives for your reference.
XI. How to contact us
- If you have any questions, comments or suggestions about this Notice or matters related to your personal information, please send your comments to: Volvo Cars Asia Pacific Headquarters, Address: No. 2088, Luyi Road, Jiading District, Shanghai, or contact us by calling our customer service number (10108666) or via our contact for user rights matters (Xu Yaqin, 16621032398).
- We will usually reply within 15 working days, unless otherwise provided by laws and regulations. If you are not satisfied with our reply, especially if you believe our personal information processing has harmed your legitimate rights and interests, you may also file a complaint with or report to the cyberspace, telecommunications, public security, industry and commerce and other regulatory authorities, or take proceedings in the court of competent jurisdiction.
Appendix I
List of Third-Party Information Sharing
| List of Third-party Information Sharing | |||||
|---|---|---|---|---|---|
| Third party company name | Application scenarios/processing purposes | Types of personal information shared | Sharing Methods | Privacy Policy Link | Contact details |
| Tencent Technology (Beijing) Co., Ltd. | Authorize the Volvo account to establish a binding relationship with the IQT account in order to synchronize the login and logout of the IQT account with the Volvo account. | Volvo account ID, account login status information | Interface transmission | https://static.tai.qq.com/iqt/agreement/privacy_protection_day.html | http://kf.qq.com/Dataprivacy@tencent.com |
| LYNK&CO AUTOMOBILE Sales Co., Ltd. | Optimize user manual content | User ID, User Manual Likes Data | Interface transmission | https://www.lynkco.com.cn/contactus/privacypolicy | privacy@geely.com |
| AMAP Software Co., Ltd. | Authorize the Volvo account to establish a binding relationship with the Amap account in order to synchronize the login and logout of the Amap account with the Volvo account. | Volvo account ID, account login status information | Interface transmission | https://cache.amap.com/h5/h5/publish/238/index.html | 4008100080/gd.service@autonavi.com/Personal_Information_Officer@autonavi.com |
Appendix II
List of Third-Party SDKs
| List of Third-party SDKs | |||||
|---|---|---|---|---|---|
| SDK Name | Third party company name | Application scenarios/processing purposes | Types of Personal Information Collected | Collection method | SDK Privacy Policy |
| Sensors Analytics SDK | Sensors Network Science and Technology (Beijing) Co., Ltd. | Analyze user behavior for product functionality and user experience optimization. | User behavior (use of vehicle control, multimedia, voice, user center, application market, user manual, rear screen, air conditioning, AI companion, menu bar, seats, boot-up guidance, photo album camera, time spent on related pages, operation content [including likes, comments, multimedia usage, vehicle settings], etc.), network status information, phone status information. | SDK native collection, no data sharing involved | https://www.sensorsdata.cn/market/privacy_policy.html |
| Tencent Bugly SDK | Shenzhen Tencent Computer Systems Co., Ltd. | Provide developers with exception reporting and operation statistics, help developers find and solve exceptions, and provide users with follow-up feedback and other services. | Device information, system name, system version, country code, phone status information, network status information, system log information. | SDK native collection, no data sharing involved | https://static.bugly.qq.com/bugly-sdk-privacy-statement.pdf |
| Baidu Speech Recognition Android SDK | Beijing Baidu Netcom Science and Technology Co., Ltd. | Speech to text recognition, for voice interaction, speech content analysis, call center and other functional uses. | Device information, log information, audio information, network status information. | SDK native collection, no data sharing involved | https://ai.baidu.com/ai-doc/REFERENCE/Qkdykq1r3 |
| Baidu Speech Synthesis SDK | Beijing Baidu Netcom Science and Technology Co., Ltd. | Convert textual information into audio information. | Device information, log information, audio information, network status information. | SDK native collection, no data sharing involved | https://ai.baidu.com/ai-doc/REFERENCE/Jkdyl0v3v |
| Mobvoi Speech SDK | Mobvoi Information Technology Co., Ltd. | Provides hot word wakeup, speech recognition, semantic understanding, vertical search, and speech synthesis. | Device information, log information, audio information, network status information, location information. | SDK native collection, no data sharing involved | https://www.chumenwenwen.com/privacy-policy.html |