Privacy Notice – Volvo ID

Effective from: 2023-01-12

Published at: 2023-02-13

Abstract of Volvo ID Privacy Notice

Volvo ID service is a membership service provided by Volvo Cars (including but not limited to Volvo Car Distribution (Shanghai) Co., Ltd, etc., hereinafter referred to as “Volvo” “we” or “us”) through 沃尔沃汽车 app, Volvo website, and Volvo vehicle-mounted connecting device. In this abstract of Privacy Notice, we will briefly describe the business functions provided by Volvo ID service and the personal information it requires, how we use, retain, share, store and protect your personal information, and how you can manage your personal information. Please read the full text of the Volvo ID Privacy Notice for more details.

1. Business functions and personal information processed

In order to provide you with the following services, we need to collect, use, share and store your personal information.

When you register a Volvo ID, we need to collect your personally identifiable information (e.g. first and last name, phone number, language, market (country or region), password and verification code).
In order to present an overview of your Volvo ID and its related services on the Volvo ID Portal, we collect your Volvo ID, vehicle information (VIN, car details), and service information related to your Volvo ID.
We process your personal data when creating or using your Volvo ID for troubleshooting purposes to improve the reliability of our products. We will use part of your Volvo ID (username and user ID).

You may refer to 1. How We Collect and Use Your Personal Information of the Privacy Notice for the specific collection of personal information and the use of permissions in relation to the functions you use or the matters you care about.

2. Sharing of personal information

Currently, we do not share personal information with any third party, nor do we use any third-party SDK.

3. Storage of personal information

We will store your personal information for the period required to provide services, but if the laws and regulations provide otherwise, you agree to let us store it for a longer period, for the purpose of dispute resolution or if it is technically difficult to delete personal information. In addition, after the expiration of the storage period, you agree that the storage period shall be reasonably extended in accordance with the law and the agreement.

4. Security protection of personal information

To protect your personal information, we have adopted various technical measures and organizational management measures. Nonetheless, the internet is not an absolutely safe environment. In the event of an unfortunate security incident, we will report to the regulatory authority or affected individuals in accordance with the provisions of laws and administrative regulations. You may refer to 3. How We Protect and Store Your Personal Information of the Privacy Notice for the specific measures we take.

5. Cross-border transfer of personal information

In principle, the personal information we collect and generate in China will be stored in China. As Volvo Car Group operates its daily business through affiliates and information systems around the world, after obtaining your separate consent, your personal information may be transferred to Volvo Car Group affiliates and cooperative third-party service providers outside China or accessed by overseas receivers. You may refer to 7. How your personal information is transferred globally of the Privacy Notice for more details.

6. Your rights

You can access, rectify, copy, transfer, and delete your personal information in accordance with relevant laws and administrative regulations. You can also withdraw consent, cancel account, be informed in advance of the suspension of operation of products and services, and obtain an explanation on the processing of personal information. You can exercise the aforementioned rights according to 4. How You Access and Manage Your Personal Information of the Privacy Notice, and we will respond within 15 business days in accordance with the provisions of laws and regulations, unless otherwise stipulated by laws and regulations. If you are not satisfied, you can also call our customer service number 10108666, contact our contact person for user rights affairs, Xu Yaqin (contact number: 16621032398), or file a complaint with other external agencies.

7. Protection of personal information of minors

We will only collect personal information from children with the consent of the child’s parents or other guardians. If you are a child under the age of 14, before using the Volvo ID, you should ask your parents or other guardians to read it carefully or read this abstract of Privacy Notice and Volvo ID Privacy Notice carefully together under the supervision and guidance of your parents or other guardians and use our products and services or provide us with information with the consent of your parents or other guardians.

This abstract of the Privacy Notice basically informs you of the processing of personal information in Volvo ID service. Nonetheless, in order to protect your rights and help you understand more about your personal information that needs to be collected and used for more functions, we strongly recommend that you read the full text of the Privacy Notice to fully understand how your personal information will be collected and used and how you exercise your rights. If you have any questions, please feel free to contact us.

Volvo ID Privacy Notice

Volvo Cars (including but not limited to Volvo Car Distribution (Shanghai) Co., Ltd, etc., hereinafter referred to as “Volvo” “we” or “us”) takes the protection of users’ personal information and privacy very seriously. When you provide us with your personal information, we appreciate your trust and view protecting your privacy as an important part of the services we provide. Thereafter, we have formulated Volvo ID Privacy Notice (hereinafter referred to as “Privacy Notice”) to introduce how we collect, store, use, share and protect your personal information when you use Volvo ID services (hereinafter referred to as “Volvo ID”) through our applications. Volvo ID services refers to membership services provided by 沃尔沃汽车 app, Volvo website and Volvo vehicle-mounted connecting device.

It is important to note that this Privacy Notice does not apply to services provided by any third party, and products or services that have their own legal notice and privacy notice. Unless explicitly stated by laws, we are not liable for any collection or use of your personal information by any third party. Unless granted by the third-party product or service, you don’t have the right to provide other institutions or individuals with all or part of the information of any third-party product or service, nor to use it for any illegal purpose.

Please carefully read all terms in this Privacy Notice (especially those in bold) before using our products and/or services to ensure that you have fully understood our processing rules for your personal information and make the choice you deem appropriate. If you do not agree to the terms of this Privacy Notice, you should immediately stop using Volvo ID. If you “check” on your own and click register/login to use our products and/or services, you will be deemed to have fully understood and agreed to all terms of this Privacy Notice. While reading, if you have any questions, please contact us by calling our customer service number 10108666 or by calling our contact person for user rights affairs, Xu Yaqin (contact information: 16621032398).

This Privacy Notice will provide the following information to you:

1. How We Collect and Use Your Personal Information

For the purposes of this Privacy Notice, personal information means all kinds of information recorded electronically or otherwise relating to an identified or identifiable natural person, excluding information that has been anonymized and processed. Sensitive personal information (bolded below) refers to personal information that, if leaked or used illegally, could easily lead to the infringement of a natural person's human dignity or endanger the safety of his or her person or property, including biometric, religious beliefs, specific identity, medical and health, financial accounts, whereabouts and trajectories; personal information of minors under 14 years of age; the vehicle's whereabouts, audio, video and images involved in the process of design, production, sale, use, operation and maintenance, etc. We will collect and use your personal information according to the following rules.

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

In order to provide you with quality products and/or services in compliance 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, save and use your following information in order to provide you with corresponding products and services. If you do not provide relevant information, you will not be able to enjoy the products and services we provide. These functions include:

We collect your personally identifiable information from you (e.g., first and last name, phone number, language, market (country or region), password and verification code) to create the account and enable you to access Volvo cars service that requires a Volvo ID and communicate with you about your Volvo ID.
In order to present an overview of your Volvo ID and its related services on the Volvo ID Portal, we collect your Volvo ID, vehicle information (VIN, car details) and service information related to your Volvo ID.
We also process your personal data when creating or using your Volvo ID for troubleshooting purposes to improve the reliability of our products. We will use part of your Volvo ID (username and user ID).

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

As necessary to conclude or perform on a contract to which the individual is a party, or as necessary for carrying out human resource management in accordance with lawfully formulated labor rules systems and lawfully concluded collective contracts;
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 the law;
Other situations provided by laws or administrative regulations.

C. Rules for the use of your personal information

We will use the collected personal information within the scope necessary to achieve the functions of our products and/or services in accordance with the stipulations of this Privacy Notice.
We will collect statistics on the usage of our products and/or services, and may share these statistics with the public or third parties to demonstrate the overall usage trends of our products and/or services. However, these statistics do not contain any identifying information about you.

When we intend to use your personal information for other purposes not specified in this Privacy Notice, or use the information collected for a specific purpose for other purposes, we will require your consent in advance by actively ticking

2. How We Share, Transfer and Publicly Disclose Your Personal Information

A. Sharing

In principle, we do not share your personal information with any companies, organizations and individuals outside of Volvo, except for the following:

Obtaining your express authorization or consent;
Required under applicable laws and regulations, legal process requirements or mandatory governmental requests or judicial decisions;
Sharing with third parties on the premise of taking effective security measures to protect your personal information (including but not limited to signing relevant confidentiality agreements, etc.).

B. Transfer

We will not transfer your personal information to any company, organization or individual, except for the following:

Transfer with explicit consent: we will transfer your personal information to other parties after obtaining your explicit consent.
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 Privacy Notice, and obtain your separate consent.

C. Publicly disclosing

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.

D. Exceptions

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 the individual is a party, or as necessary for carrying out human resource management in accordance with lawfully formulated labor rules systems and lawfully concluded collective contracts;
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 the law;
Other situations provided by laws or administrative regulations.

3. How We Protect and Store Your Personal Information

A. Techniques and measures for protecting your personal information

We attach great importance to personal information security and take all reasonably practical measures to protect your personal information.

Technical measures for data security
1. 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.
2. 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 technologies to protect personal information and avoid unauthorized use of data.
We only allow employees of Volvo 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.
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.
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.
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 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 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 a dedicated network operations and data security team responsible for 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 Privacy 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 Privacy Notice and assist us in taking appropriate actions.

B. Storage of your personal information

We will only store your personal information for as long as required by law or regulation and as necessary to achieve the purposes of this Privacy Notice. After the above-mentioned period of storage of personal information is exceeded, we will delete or anonymize the personal information. If otherwise required by law or regulation, we will comply with the mandatory requirements. After you cancel your Volvo ID, we will delete your personal information associated with that Volvo ID within 15 business days. To implement the legal requirements regarding log retention, we will retain weblogs for at least 6 months in strict accordance with the Cybersecurity Law and related laws and regulations.
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.

4. 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, rectification and deletion with respect to your personal information so that you have the full ability to safeguard your privacy and security. Your rights include:

A. Right to access

You have the right to access your personal information, unless otherwise provided by laws and regulations. If you would like to exercise your right to access your personal information, you may contact us in the ways disclosed in this Privacy Notice.

B. Right to rectification

You have the right to ask us to make corrections if you find that there is an error in the processing of your personal information. If you would like to exercise your right to rectification of your personal information, you may contact us in the ways disclosed in this Privacy Notice.

C. Right to deletion

You may make a request to us to delete personal information in the following cases:

If our processing of personal information violates laws and regulations or our agreement with you;
If you no longer use our products or services, or if you cancel your Volvo ID;
If our processing purpose has been achieved, cannot be achieved, or is no longer necessary to achieve the processing purpose;
If we no longer provide products or services to you, or if the retention period has expired;
If you withdraw your consent.

If you request the deletion of your personal information based on the above circumstances, you may contact us at any time through the contact information set forth in this Privacy Notice and we will respond within 15 business days, unless otherwise required by law or regulation. If we decide to respond to your request for deletion, we will also notify the entities from which we obtained your personal information to delete your personal information at the same time, unless otherwise required by law or regulation or unless those 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. Please know and understand that, according to laws and regulations, if the retention period stipulated by laws and administrative regulations has not expired, or if deletion of personal information is technically difficult to achieve, we will stop processing other than storing and taking the necessary safety protection measures.

D. Right to account cancelation

You can cancel your account at any time by going to "Me->System Settings->About->Cancel Account" in 沃尔沃汽车 app, or by contacting us through the contact details set out in this Privacy Notice or through 沃尔沃汽车 app customer service, and we will assist you with account cancellation after verifying your identity.

If you choose to cancel your account, we will promptly delete or anonymize all of your personal information in accordance with legal and regulatory requirements, except where otherwise provided by law. After you cancel your account, we will not be able to continue to provide you with account registration services and products or services that require account login.

E. Right to consent withdrawal

You have the right to withdraw your authorization, but each business function requires some basic personal information to be completed, and in the case of a service that relies on your authorization for its implementation or normal operation, if you withdraw your authorization, we will not be able to continue to provide you with the corresponding service or part of the function of the service will be affected. You may withdraw or change your authorization by:

You can withdraw authorization for us to access your personal information by turning off the appropriate device permissions (including location, photos, notifications, etc.) through the "Phone - System Settings" function of your device.
Contact us through the contact information disclosed in this Privacy Notice.

When you withdraw the relevant authorization, we will no longer process the corresponding personal information. However, your decision to withdraw your authorization will not affect the processing of personal information previously carried out on the basis of your authorization.

F. Right to access to a copy of your personal information and portability

You have the right to obtain a copy of your personal information in the form of basic data, identification information, and you may contact us through the contact information disclosed in this Privacy Notice.

Subject to the conditions set forth by the Cyberspace Administration and technically feasible, if the data interface has been matched, we may also transfer a copy of your basic information and identity information directly to a third party designated by you upon your request.

G. Right to explanation

You have the right to request an explanation of our rules regarding the processing of personal information. You may contact us through the contact information disclosed in this Privacy Notice.

H. Right to be responded

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 15 business days after we receive your feedback and verify your identity, except as otherwise provided by law or regulation. For your reasonable requests, we do not charge a fee in principle, but for requests that are repeated several times and exceed reasonable limits, we will charge a cost fee as appropriate. We may refuse requests that are unnecessarily repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical (for example, involving the backup of information stored on tapes). We may not be able to respond to your request if we are required by law or regulation to do so in the following circumstances:

Directly related to national security and national defense security;
Directly related to public safety, public health, and significant public interest;
Directly related to criminal investigation, prosecution, trial, and sentence enforcement;
Where there is sufficient evidence of subjective malice or abuse of your rights;
Responding to your request will result in serious damage to the legitimate rights and interests of you or other individuals or organizations;
Involving trade secrets.

5. Protection of Personal Information of Minors

Our products, websites 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 the 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 complying with the provisions of this Privacy Notice on users’ personal information and adhering to the principles of 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 Cyber Protection of Children’s Personal Information and other laws and regulations.

We will seek to 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 at 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 the Volvo Application without the consent of a guardian, we will take measures to respond within 15 business days, except as otherwise provided by law or regulation.

6. Disclaimer of Third-Party Products and 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 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.

7. How Your Personal Information Is Transferred Globally

In principle, the personal information collected and generated within the territory of China will be stored within the territory of China. As Volvo Car Group operates its daily business through affiliates and information systems around the world, after obtaining your separate consent, your personal information may be transferred to Volvo Car Group affiliates and cooperative third-party service providers outside China (Overseas Receiver), or accessed by Overseas Receiver. The purposes and types of our overseas transfer of your personal information are as follows:

Purposes	Types of personal information
To provide you with Volvo ID registration, login and account profile management services, and to continuously improve the reliability of the Volvo ID account management system through troubleshooting, so that you can enjoy accurate and secure services based on identification and verification.	Name, phone number, language (Chinese, English, etc.), market (country or region), password and verification code, email address, address, gender, date of birth

The aforementioned Overseas Receiver is:

Company Name

Country

Contact information

Volvo Car Corporation

Sweden

Data Protection Officer, DPO

Contact: globdpo@volvocars.com;

Contact Address: Group Privacy Office，Dept AA14100，VGHQ，SE-405 08，Göteborg, Sweden

We will fulfill our obligations of managing the security of data export as required by laws, regulations and relevant supervision, and take the necessary security measures to protect your personal information. You may exercise your legal rights directly against the Overseas Receivers at the contact information set forth in the above form, or you may request our assistance in contacting the Overseas Receivers at yaqin.xu@volvocars.com.

8. Update of this Privacy Notice

This Privacy 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 Privacy Notice without your explicit consent. We will issue updates on 沃尔沃汽车 app and remind you of such updates by 沃尔沃汽车 app announcements or any other proper way before they take effect. Please visit 沃尔沃汽车 app to keep abreast of the latest privacy policy. By using or continuing to use our products and/or services after we have updated this Privacy Notice (in such event that we will promptly remind you of the updates), you agree to the content of this Privacy Notice (including the updated version) and consent to the collection, use, storage and sharing of your information in accordance with this Privacy Notice.
For material changes, we will also provide a more prominent notice (we will explain specific changes to this Privacy Notice by means including, but not limited to, emails, text messages or a special notice on the browser page).

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, the 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.

9. How to Contact Us

If you have any questions, comments or suggestions about this Privacy Notice or matters related to your personal information, please send your comments to: Volvo Cars Asia Pacific Headquarters, Attention: 2088, Luyi Road, Jiading District, Shanghai, or contact us by calling our customer service number (10108666). Our contact person for user rights affairs is Xu Yaqin (16621032398).
We will usually reply within 15 business days. 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 or report to the cyberspace, telecommunications, public security, industry and commerce and other regulatory authorities, or bring a lawsuit before a court having jurisdiction.