Customer Privacy Policy

Effective from: 2024-04-24

Published at: 2024-04-24

Volvo Cars (including but not limited to Volvo Car Sales (Shanghai) Co., Ltd. and others, hereinafter referred to as “Volvo” or “we”) attaches great importance to the protection of customers’ personal information and privacy right. When you provide us with your personal information, we appreciate the trust you place in us and regard protecting your privacy as an important part of the services we provide. Therefore, we have specially formulated the “Volvo Cars Website Privacy Policy” (hereinafter referred to as the “Privacy Policy”) to introduce to you how we collect, store, use, share, and protect your personal information.

Please read all the terms of this Privacy Policy (especially the content shown in bold) before using our products and/or services to confirm that you have fully understood our processing rules for your personal information, and make the appropriate choices you think. If you choose to use our products and/or services, you will be deemed to have fully understood and agreed to all the terms of this Privacy Policy. If you have any questions during the reading, please contact us by calling our customer service number: 10108666.

The Privacy Policy will help you understand the following:

1. How we collect and use your personal information

For the purpose of providing products and/or services to you as well as any other purpose under the Privacy Policy, Volvo may collect and use your personal information, including, without limitation, (personal sensitive information shown in bold):

Personal basic information: individual name, date of birth, gender, address, personal telephone number, mobile number, and email address;

Personal identity information: ID card, certificate of military officer, passport, and driving license;

Demographic information: age, marital status, and family composition;

Online identification information: Volvo ID, My Volvo, IP address, email address, Open ID on WeChat, and Open ID on Toutiao/Tik Tok App, and their respective passwords;

Personal property information: bank account information, VIN, vehicle model, purchase date, purchase history, maintenance & service history, license plate, vehicle recall, vehicle violation, history of insurance policies, and V value at Volvo World;

Personal location information: precise localization, navigational aid, search & inquiry, location sharing, and vehicle recovery; and

Other personal information: preferences and settings of customers, list of contacts, web browsing history, bound person authorized by vehicle owner, survey & evaluation, browser type, and mobile phone brand.

We will collect and use your personal information only for the purposes below:

i. The circumstance where you need to authorize us to collect and use your personal information

Circumstances where you need to authorize us to collect and use your personal information

In order to provide you with high-quality products and/or services in accordance with laws and regulations, the following information is necessary to fully perform the contract between you and us, or to enable us to comply with relevant legal obligations. We need to collect, store and use the following information about you in order to provide you with corresponding products and services. If you do not provide relevant information, you will not be able to enjoy our products and services. These functions include.

1. User registration

If you want to use “My Volvo”, you must provide the following information to register your account:

Your email address or mobile phone number (as Volvo ID); and

Your name and market (country or region).

In addition, you can voluntarily modify or supplement your information under your account after registration as needed.

Volvo uses a two-way confirmation procedure for registration. For example, this registration is only considered complete after you confirm your registration by clicking on the activation link contained in the email. The confirmation form can also be other methods such as entering the SMS verification code, actively checking and so on.

2. Car sales and after-sales support service

We are likely to collect your personal information for the purpose of supplying car sales and related services to you, including, without limitation, supplying the online car purchase service, verifying whether you are qualified to purchase some products and services, and providing you with vehicle support and services (such as test drive booking, warranty service, and recall information). Specifically speaking,

To supply the online car purchase service to you, we will collect and use your personal information as below:

We will collect and use your personal basic information like name, age, personal telephone number, and credit information (including credit blacklist) so as to verify whether you are qualified for purchasing a certain product or service.

To provide vehicle support and services for you, we will collect and use your personal information as follows:

For the booking of a test drive, we will collect and use your personal basic information such as name, personal telephone number, and email address;
For the car warranty service, we will collect and use your personal basic information including name, personal telephone number, and vehicle information (like license plate number, model, and VIN); and
For the recall of vehicles, we will collect and use your personal basic information like name, personal telephone number, address, email address, and vehicle information (such as license plate number, model, and VIN), and status of vehicle systems and functions (including engine, accelerator, steering system, and brake).

3. Order management service

When you order a specific commodity and/or service on the platform of Volvo, we will collect and use your personal basic information including the receiver’s name, address, and telephone number, and simultaneously the corresponding order will record and display the information about the commodity and/or service you purchase, the specific order number, the time when the order is placed, the amount to be paid by you, and the status of the order. The afore-mentioned information we collect and use is for the purpose of showing the information about the order to you, helping you successfully complete the relevant transaction, safeguarding your transaction, checking the order, and supplying the customer or after-sales service as well as assisting you in learning and managing your order information.

4. Information exhibiting and search service

While you access our website (www.volvocars.com) or use our APP or applet, we may collect the following information so as to enable you to quickly find what you need (like the information about any product and/or service), normally provide the information exhibiting and search service for you, and finally show the corresponding commodity information to you:

Your personal basic information including name, address and personal telephone number;
The information about the device via which you use our services, such as device name, device model, and device identifier, operating system, application version, device MAC address, language setting, resolution, and network ID of service provider (PLMN);
The type of the browser you use; and
The software list and the unique device identifier like IMEI / Android ID / IDFA / OPENUDID / GUID and SIM card/IMSI information Please be aware that the information stated above is the necessary basic information we should collect for the purpose of supplying the information exhibiting and search service and ensuring the normal operation of our products.

5. Vehicle support and user experience service

To support you to normally use our vehicle products and make you have safe, comfortable and personalized driving experience, we may need to collect:

Vehicle information including VIN and vehicle model;
Safety information including the information about whether the airbag restraint system or belt tensioner has been once triggered and whether vehicle doors and windows are locked or opened;
System function status information including system time, power system information, steering/braking/driver assistance function status, steering wheel status, odometer, and battery status;
Driving data including vehicle speed, running mode, usage of brake pedal and accelerator pedal, and steering wheel movement;
Location data including vehicle location information such as high-precision positioning data for self-driving system and accurate vehicle location in case of an accident; and
Environmental data including road and traffic information, ambient temperature, and image of the area where the vehicle drives as well as personal information including email address, mobile phone number, and information about biological recognition like speech and facial recognition.

We understand that the Privacy Policy has basically covered all the business scenarios where Volvo will collect and use your personal information. However, in respect of a part of specific and detailed information collection and use rules which may be involved, we will further inform you in the privacy policy applicable to the specific product or service and obtain your authorization or consent. In the meanwhile, we hereby promise you that we will not collect or use any of your personal information without your authorization or consent.

ii. The circumstance where you can choose whether to authorize us to collect and use your personal information

To ensure the quality of Volvo’s products and/or services as well as improve your experience at Volvo, we are likely to collect and use your personal information during the following services. In case that you do not furnish such personal information, you can still use the other functions in Volvo’s products and/or services, except these services; or you may be required to repeatedly enter some information while using some products and/or services. To be specific,

We are likely to collect the information which you enter in any questionnaire released on the website, APP and/or applet of Volvo.
As reasonably necessary for the provision of after-sales product guarantee and the improvement of service quality, we may supply after-sales tracking services and pay return visits to you via online and offline channels, during which we are likely to obtain other information of yours such as your name, personal telephone number, email address, and address, your personal data involved in vehicle information, and your feedback about the dealer’s service, and the relevant information furnished by you during your contact with the Customer Service.
For the purpose of providing you with the improved products and services and the updates of products, services, and activities, we may acquire your personal information like your name, personal telephone number, and email address.
To guarantee the quality of our products and/or services and further improve your experience during your contact with Volvo, we will irregularly seek for opinions and suggestions about the products and/or services concerned and then we will be likely to get the related information you provide during your contact with the Customer Service.
We will hold various activities and call up participants and then may obtain the personal information you furnish during your participation in such activities and the information concerned which you authorize us to get during the interaction between you and our affiliates.
In order to provide you with other services relating to you and your vehicle, we may also collect and use your personal information, as detailed below:
- To supply the repair/maintenance booking service to you, we may collect and use your personal basic information like name, personal telephone number, location information, driving log, vehicle failure information, license plate number, and vehicle model;
- To pick up your vehicle at your location or deliver your vehicle to your location, we may collect and use your personal basic information such as name, personal telephone number, pickup/delivery address, and license plate number;
- To provide you with the transparent workshop service, we may collect and use your personal basic information including license plate number and location information;
- To offer you the charging pile lookup service, we may collect and use your personal basic information including name, VIN, vehicle model, charging device number, location information, and other information necessary for the supply of the service;
- To help you download any product manual, we may collect and use your personal basic information such as name, personal telephone number, and mailing address if necessary;
- To furnish Volvo magazines to you, we may collect and use your personal basic information, like mobile phone number, name, detailed address, and post code.
- To provide you with the maintenance/repair reservation service, we will collect and use your personal basic information including name, personal telephone number, vehicle information (license plate number, vehicle model, and VIN), and business needs such as maintenance, overhaul, specific time and date, and dealer providing services;
- To offer the repair and maintenance logging service to you, we will collect and use your vehicle information including license plate number, vehicle model, VIN, and business needs such as maintenance, overhaul, specific time and date, and service dealer;
- To provide the free-of-charge vehicle pickup/delivery service for you, we will collect and use your personal basic information including name and personal telephone number, vehicle information (license plate number, vehicle model, and VIN), and business needs such as maintenance, overhaul, specific time and date, and service dealer;
- To inquire a traffic violation for you, we will collect and use your personal basic information such as name and personal telephone number as well as vehicle information like license plate number, vehicle model, VIN, and vehicle violations;
- To offer the one-key rescue service to you, we will collect and use your personal basic information like name and personal telephone number, vehicle information such as license plate number, vehicle model, and VIN, and status of vehicle functions including engine, accelerator, steering, and braking, and business needs such as specific date and time and dealer providing services;
- To notify you of an activity for vehicle owners, we will collect and use your personal basic information including name and personal telephone number, activity information (including information about previous activities attended, comments on activities, and registration for activity); and
- To inquire any pervious insurance policy for you, we will collect and use your vehicle information (license plate number, vehicle model, and VIN) as well as the pervious insurance policy information including insurance company, insurance type, and insurance purchase date;

iii. You are fully aware that we may not need your authorization to collect and use personal information in the following under the following circumstances:

Related to Volvo's performance of obligations under laws and regulations;
Directly related to national security and national defense security;
Directly related to public safety, public health, and major public interests;
Directly related to criminal investigation, prosecution, trial, and execution of judgments;
In order to protect your or other individuals’ life, property and other major legal rights and interests, but it is difficult to obtain your authorization and consent;
The personal information collected is disclosed to the public by yourself;
Collect your personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
What is necessary for signing and performing the contract according to your requirements;
What is necessary to maintain the quality of vehicles and the stable operation of safety functions, for example, technicians diagnose and repair vehicle faults during repairs and maintenance, Volvo Cars product development, and management of Volvo Cars’ warranty commitments; or
Other circumstances stipulated by laws and regulations.

iv. The circumstance where we obtain your personal information from any third party

It is possible for us to obtain your personal information, which any authorized dealer, service provider, or other third party can share with others, with your prior consent, including:

Personal basic information: name, address, personal telephone number, email, and information about person applying for repair;
Demographic statistics: age, marital status, and family composition;
Personal property information: bank account information, VIN, vehicle model, purchase history, and repair history;
Personal location information: navigation aid, search & inquiry, and location sharing; and
Online identification information: preferences and settings of customers, Volvo ID, My Volvo, Open ID on WeChat, and Open ID on Toutiao/Tik Tok App.

After confirming the legality of the source of your personal information, we will use your personal information in accordance with the provisions of the applicable laws and regulations as well as the covenants agreed upon with the third party involved.

v. Rules for the use of your personal information

We will use the collected personal information within the scope necessary to realize the functions of our products and/or services in accordance with the provisions of this Privacy Policy.
We will make statistics on the usage of our products and/or services, and may share these statistics with the public or third parties to show the overall usage trend of our products and/or services. However, these statistics do not contain any identification information about you.
When we want to use your personal information for other purposes not specified in this Privacy Policy, or if the information collected for a specific purpose is used for other purposes, we will require you to seek your consent in advance by checking the box.

2. How we use Cookies and similar technologies

The technology of cookies is a neutral technology via which a web server can store data in a client or read data from a client. We use cookies to assist you in swiftly and efficiently utilizing the products and/or services on our website as well as to help us make statistics of the quantity of unique visitors. By the application of cookies, we can supply considerate and personalized services to you and you can set specific service options.
To meet your individualized demand for online experience and provide you with easy access, we will send one or several small data files named Cookie to your computer or mobile device and the cookies assigned to you will be unique; and such a file can be read only by the Web server releasing cookies to your domain. The reason why we send cookies to you is to simplify the steps of your repeated login and store such data as your preferences or browsing history so as to provide you with the setting of preferences as well as help you optimize your selection of, and interaction with, the advertisement, and to determine your logging status and account or data security.
We respect your privacy right and you can choose to disable some types of cookies. You can learn more information and change our default settings by clicking titles of different categories. However, to disable some types of cookies may affect your website usage experience and our supply of some services. We will use cookies to remember the selection you have made in our Cookie Privacy Manager. There will be two effects as below:

If you delete all of your cookies, you should give us an update of your preferences again; if you use a different device or browser, you should tell us your preferences again.

3. How we share, transfer, and publicly disclose your personal information

i. Sharing

We will not share your personal information with any company, organization, or individual other than Volvo, except under the following circumstances:
1. Related to Volvo's performance of obligations under laws and regulations;
2. Obtain your explicit consent or authorization in advance;
3. Directly related to national security and national defense security;
4. Directly related to public safety, public health, and major public interests;
5. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
6. In order to protect your or other individuals' life, property and other major legal rights and interests, but it is difficult to obtain the authorization and consent of the person;
7. Personal information voluntarily disclosed to the public; or
8. Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.
In order to ensure that you can enjoy more quality warranty service timely and accurately, and get in touch with you, you fully understand and clearly agree that we will share your vehicle information, order information, equipment information, and location information with our authorized dealers, service providers and other affiliates for the provision and optimization of after-sales warranty services, the contact of test drive experience activities, and the push of relevant information you have subscribed to.
Volvo may share your personal information in the following areas:
1. Sharing among Volvo entities: To the extent permitted by laws and regulations, your personal information may be shared with our affiliates in order to ensure compliance with the law and protect the interests, property or safety of us and our affiliates or business partners, you or other users, or the public from damage. We will only share the personal information necessary to achieve the above-mentioned purposes. Without your consent, our affiliates will not use the shared personal information for any purpose other than those mentioned above; and
2. Sharing with business partners: Only to achieve the purpose stated in this Privacy Policy, some of our services will be assisted by authorized business partners. We may share some of your personal information with business partners to provide better customer service and user experience. Our business partners include the following types: Authorized dealers: In order to provide you with pre-sales services and after-sales warranty services, we will share your name, telephone number, email address, and location information with our authorized dealers to better provide you with the above services; Authorized service providers: In order to provide you with after-sales maintenance services, we will share your vehicle information, order information, and device information with our authorized service providers to better provide you with the above services.
3. Sharing in response to legal requirements, such as related to government investigations, disputes and other legal procedures or requirements;
4. When we believe that disclosure is necessary in order to protect our rights in accordance with the principle of good faith, for example, to investigate potential violations of our terms and conditions or to detect, prevent or disclose fraud and other security issues.
We will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and will only share personal information as is necessary to provide products and/or services. We will only allow access to your personal information to those employees and affiliates of Volvo who have the need to use it on behalf of Volvo. At the same time, we will only share necessary personal information and are bound by the purposes stated in this Privacy Policy. If our affiliates want to change the purpose of processing personal information, they will re-seek your authorization and consent.
We enter into strict confidentiality agreements with companies, organizations and individuals with whom we share personal information, highlighting strict requirements regarding data protection compliance and requiring them to handle personal information in accordance with our instructions and any other relevant confidentiality and security measures. In the use of personal sensitive data, we require third parties to adopt data desensitization and encryption technologies to better protect user data. However, please note that Volvo and its authorized dealers and service providers are separate legal entities. Generally, we are not responsible for the illegal acts of Volvo's authorized dealers and service providers. If you have any questions about the collection and use of your personal information by your distributors or service providers, please contact those distributors or service providers directly.

ii. Transfer and publicly disclose

In the case of mergers, acquisitions, asset transfers or similar transactions involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be subject to this Privacy Policy, otherwise we will require the company or organization to re-seek your authorization consent.

Except as clearly stated in this Privacy Policy, we will not transfer or publicly disclose your personal information to any company, organization or individual, except in the following cases:

Related to Volvo's performance of obligations under laws and regulations;
Directly related to national security and national defense security;
Directly related to public safety, public health, and major public interests;
Directly related to criminal investigation, prosecution, trial, and execution of judgments;
In order to protect your or other individuals' life, property and other major legal rights and interests, but it is difficult to obtain the authorization and consent of the person;
Personal information that you disclose to the public;
Your personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

4. How we protect and store your personal information

i. Our technologies and measures to protect your personal information

We take the security of personal information very seriously and take all reasonable and practicable measures to protect your personal information:

Technical measures for data security
- We will use security measures in accordance with industry standards, including the establishment of reasonable institutional norms, security technology to prevent unauthorized access to your personal information use, modification, to avoid damage or loss of data.
- Volvo adopts encryption technology to encrypt and store users' personal information, and isolate it through segregation technology. Volvo adopts strict data access rights control and multiple identity authentication technology to protect personal information and avoid unauthorized use of data.
We only allow employees of Volvo and Volvo 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. Failure to comply with these obligations may result in legal liability or termination of the cooperative relationship.
We recommend that you use complex passwords when using email, instant messaging, social networking software and other communication tools with other users, and pay attention to protecting the security of your personal information.
Please note that the Internet environment is not 100% secure and we will do our best to ensure the security of any information you send us by taking security measures in accordance with legal requirements and technological developments. At the same time, however, we will not be liable for any damages not caused by Volvo if our physical, technical, or managerial safeguards are unanticipated and unpreventably damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information.
Security incident handling
- Please protect your personal information properly and provide it to others only when necessary. To deal with possible risks such as leakage, destruction and loss of personal information, Volvo has established a number of systems to clarify the classification and grading standards for security incidents and security breaches and the corresponding handling processes. Volvo has also established a special emergency response team for security incidents, and in accordance with the requirements of the security incident disposal specification, it will initiate security plans for different security incidents, carry out stop-loss, analysis, positioning, develop remedial measures, and joint relevant departments to trace the source and combat.
- After the unfortunate occurrence of personal information security incidents, we will inform you in a timely manner in accordance with the requirements of laws and regulations: the basic situation of the security incident and the possible impact, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk, the remedial measures for you, etc. We will also promptly inform you of the incident by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to publish the announcement. At the same time, we will also take the initiative to report the disposal of personal information security incidents to the regulatory authorities in accordance with legal requirements.
We have set up a special network operation and data security team to carry out work related to the protection of personal information. If you have any questions about our personal information protection, you can contact us through the contact information listed at the bottom of this Privacy Policy. If you find that your personal information has been compromised, especially your account and password, please contact us immediately through the contact information in this Privacy Policy and assist us in taking appropriate measures.

ii. Storage of your personal information

We will only determine the duration of storage of your personal information for as long as required by law or regulation and as necessary to achieve the purposes of this Privacy Policy. After you cancel your Volvo ID, we will delete your personal information associated with that Volvo ID within 30 days, unless Volvo is required by applicable laws to store such data for a longer period of time. To implement the legal requirement to retain logs, we will retain web logs for at least six months in strict accordance with the “Cybersecurity Act” and related laws and regulations.
If we terminate our services or operations, we will notify you at least thirty days in advance and delete or anonymize your personal information upon termination of services or operations.

5. How you access and manage your personal information

Volvo takes your concerns about your personal information seriously and makes every effort to protect your rights to access, correct and delete your personal information so that you have the full ability to safeguard your privacy and security. Your rights include:

1. Access to your personal information

You have the right to access your personal information through Volvo entities, authorized dealers, the Volvo website, mobile APP, applets and customer center, except as otherwise stipulated by laws or regulations.

2. Correction of your personal information

If you discover that personal information about you has been processed incorrectly, you will have the right to ask us to make corrections. You can request a correction through Volvo entities, authorized dealers, or through the customer service phone number (10108666). You can make corrections by contacting us at 10108666.

3. Delete your personal information

You can request us to delete personal information in the following cases:

If we handle personal information in violation of laws and regulations;
If we collect and use your personal information without your consent;
If our handling of personal information violates our agreement with you;
If you have logged out of your Volvo account “My Volvo”; or
If we terminate our services and operations.

If we decide to respond to your request for deletion, we will also simultaneously notify the entities from which we obtained your personal information to request its prompt deletion, unless otherwise required by laws or regulations, or unless such entities have your independent authorization. When you delete information from our service, we may not immediately delete the corresponding information from our backup system, but will delete it when the backup is updated. You may contact us by calling Customer Service at 10108666 to delete it.

4. Withdrawal of consent

For most processing actions, you may withdraw your consent by updating your preferences, terminating certain services, or by contacting Volvo at the address posted at the bottom of this Privacy Policy. However, unless otherwise required by applicable laws, your consent cannot be withdrawn in the following circumstances:

Cases in which your authorized consent is not required;
Operations performed to send you important notices related to your vital interests, such as changes to our terms and conditions and policies or product recalls; or
Operations performed to fulfill legal obligations.

You can change the authorization consent yourself by contacting Volvo Customer Service at 10108666.

5. Reject commercial advertisement

If you wish to unsubscribe from specific email newsletters or similar communications, please follow the instructions in the relevant communication of the marketing campaign. You can also use you’re my Volvo account to unsubscribe from specific types of communications from Volvo. If you do not want to receive the commercial advertisement we send you, you can always reject it by replying T in the marketing SMS or by calling Volvo Customer Service at 10108666.

6. Response to your requests

If you are unable to access, correct or delete your personal information in the manner described above, or if you need to access, correct or delete other personal information generated by your use of our products and/or services, or if you believe that Volvo has violated any law or regulation or agreement with you regarding the collection or use of personal information, you may contact us at the other contact information listed at the bottom of this Privacy Policy.

For security purposes, we may require you to provide a written request or otherwise prove your identity, and we will respond to your request within 30 days after we receive your feedback and verify your identity. For your reasonable requests, we do not charge a fee in principle, but for repeated requests that exceed reasonable limits, we will charge a cost fee as appropriate.

We may deny requests that are unnecessarily repetitive, require excessive technical means (for example, requiring the development of new systems or a fundamental change in current practices), pose a risk to the legal rights of others, or are highly impractical (for example, involving the backup of information stored on tape). We may not be able to respond to your request under the following circumstances, as required by laws or regulations:

Directly related to national security or national defense security;
Directly related to public safety, public health, and significant public interests;
Directly related to criminal investigation, prosecution, trial and execution of judgments, etc.;
Where there is sufficient evidence that you have subjective malice or abuse of rights;
Response to your request will lead to serious damage to the legitimate rights and interests of you or other individuals or organizations; or
Involving trade secrets.

6. Protection of personal information of minors

Our products, website and services are primarily intended for adults. If you are a minor under the age of 18, you should obtain the prior consent of your guardian before using our products and/or services. In the case of personal information collected from children with parental consent, we will only use or publicly disclose this information as permitted by laws, with the express consent of the guardian, or as necessary to protect the child. For personal information of children under 14 years of age that may be involved, in addition to complying with the agreement on personal information of users in this Privacy Policy, we will uphold the principles of legitimate necessity, informed and consent, clear purpose, safety and security, and use in accordance with the law, and strictly comply with the requirements of the “Regulations on the Protection of Children's Personal Information Online” and other laws and regulations for the storage, use, and disclosure of children's personal information, and to protect the legal rights of children and their guardians.
If we find that we have collected personal information from minors without the prior consent of a verifiable guardian, we will attempt to delete the relevant data as soon as possible.
If you are the guardian of a minor, please contact us at the contact information disclosed in this Privacy Policy if you have questions about the handling of information about a minor in your custody or if you have evidence that the minor has registered to use our products and/or services without the consent of the guardian.

7. Disclaimer for third-party products and services

During the use of our products and/or services, you may access applications and other services linked to Volvo vehicles, web pages, etc., but provided by third parties, for example, third-party applications that may require data from your vehicle records, such as your location data, to provide services to you; for this reason, such third-party applications and other services may involve you providing third parties with certain types of personal information. Volvo is not responsible for the collection or use of personal information by third party applications or services, and we recommend that you read the applicable terms and conditions (and any relevant privacy statements) carefully before using such applications or services, and make your own choice after ensuring that you fully understand the rules governing the collection and use of your personal information. If you have any questions about the use of your personal information by a specific third party, please contact that third party directly.

8. How your personal information is transferred globally

In principle, the personal information we collect and generate within the territory of the People's Republic of China will be stored in the territory of the People's Republic of China.

Please note that since some Volvo vehicle after-sales warranty services may be provided by our overseas affiliates and cooperative third-party service providers ("foreign third parties"), you fully understand and expressly agree that we will transfer the above-mentioned personal information to the location of the aforementioned foreign third party (including but not limited to Sweden) to provide you with relevant services. We will require overseas third parties to adopt security measures such as encrypted transmission to ensure the safety of your personal information during cross-border transmission.

Such jurisdictions may have different data protection laws or even no relevant laws. In such cases, we will ensure that your personal information is sufficiently and equally protected within the territory of the People's Republic of China. For example, we will request your consent to cross-border transfer of personal information, or implement security measures such as data de-identification before cross-border data transfer.

9. Update of this Privacy Policy

This Privacy Policy may be updated to better serve you and as Volvo's business evolves. We will not, however, reduce your rights under this Privacy Policy without your express consent. We may issue updates on the Volvo website, the 沃尔沃汽车 app and alert you to updates through a website posting or other appropriate means before they become effective, and you should visit the Volvo website to keep up to date with the latest Privacy Policy. By using or continuing to use our products and/or services after we have updated this Privacy Policy (as we will prompt you the updates), you agree to the content of this Privacy Policy (including the updated version) and consent to the collection, use, storage and sharing of information about you in accordance with this Privacy Policy.
We will also provide more prominent notice of material changes (we will provide specific notice of changes to our Privacy Policy by means including, but not limited to, mail, SMS message, or a special notice on the browser page). Material changes to this Privacy Policy include, but are not limited to:
1. Significant changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used;
2. Significant changes in our ownership structure, organizational structure, etc. such as change of ownership caused by business restructuring, bankruptcy and merger, etc.;
3. Changes in the primary recipients of personal information sharing, transfer or public disclosure;
4. Significant changes in your rights to participate in the processing of personal information and the manner in which they are exercised;
5. When there is a change in the department responsible for handling personal information security, our contact information and complaint channels; and
6. When the personal information security impact assessment report indicates that there is a high risk.
We will also keep an older version of this Policy on file for your reference.

10. How to contact us

If you have any questions, comments or suggestions about this Privacy Policy or matters related to your personal information, please send your comments to: Volvo Cars Asia Pacific Headquarters, address: 2088 Luyi Road, Jiading District, Shanghai, or contact us by various means such as calling our Customer Service hotline (10108666).
Usually, we will reply within thirty days. If you are not satisfied with our reply, especially if you think that our personal information processing has harmed your legitimate rights and interests, you can also file a complaint or report to the supervisory departments such as Internet information, telecommunication, public security and industry and commerce, or file a lawsuit to the court with jurisdiction.
We will also keep an older version of this Policy on file for your reference.