This policy is applicable to the Processing of customers' Personal Data at all companies included in the Volvo Car Group ("Volvo Cars", “our”, “us” or "we"). The purpose of this policy is to provide our current, former and potential customers (jointly referred to as "customers" or "you") with a general understanding of:
This policy is updated continuously to reflect the measures taken by Volvo Cars in relation to your Personal Data.
Volvo Car Corporation (a Swedish legal entity with corporate registration number 556074-3089) is the Controller in relation to Processing of your Personal Data for research and development of new and current car models, and also for certain global services offered to customers. Furthermore, Volvo Car Corporation is Controller for any Processing of Personal Data in relation to the monitoring of the quality of the cars and any potential safety recalls as well as to meet regulatory requirements.
Each national sales company within Volvo Cars is generally responsible for marketing, sales and customer relations as well as market specific services in its market. The national sales company is Controller for the Processing of Personal Data for these purposes. In markets without a national sales company, an importer usually has the same responsibility as a national sales company. Therefore, the importer is the Controller in these instances. Volvo Cars contractually requires its dealers and repairers to comply with rules concerning data protection. Note that Volvo Cars and its authorised dealers and repairers are separate legal entities, and that we are generally not responsible if such dealers and repairers do not follow applicable laws. If you have questions regarding your dealer's or repairer's use of your Personal Data, please contact the dealer or repairer directly.
The Processing of your Personal data forms an important part of our provision of products and services to you. We appreciate the trust you place in us when providing us with your Personal data, and consider your privacy an essential part of the services we offer. In order to safeguard your Personal Data while increasing the customer value and offering enhanced and safer driving experiences, we adhere to the following five general principles.
Your Personal Data belongs to you. We strive not to make any assumptions regarding your privacy preferences and aim to design our services so that you can choose whether or not to share your Personal Data with us.
Where the Processing of your Personal Data is necessary for the pursuit of a legitimate interest, and where this interest outweighs the need to protect your privacy, we may process certain Personal Data without obtaining your consent if so permitted by law. In certain other situations, we may also process your Personal Data without your consent if so is required in accordance with applicable law. For more information, see the "Consent" section below.
Volvo Cars will only process our customers' Personal Data if it is adequate, relevant and necessary in relation to the purpose for which it has been gathered. We aim to anonymize your Personal Data when a function or service can be achieved with anonymized data. If we combine anonymized or non-Personal Data with your Personal Data, it will be treated as Personal Data for as long as it remains combined.
Volvo Cars believes in being transparent about which Personal Data we process and for which purposes. To us it is also vital to protect your Personal Data since one of Volvo Cars' core values is to protect what is important to you. On request, Volvo Cars will provide customers with further information regarding our Processing and protection of your Personal Data.
It is Volvo Cars' policy to comply with the applicable laws, rules and regulations governing privacy and data protection in each and every country where we operate. Where necessary, we will adjust our Processing of your Personal Data as described in this policy to ensure legal compliance.
The Personal Data which Volvo Cars collects about you and the vehicle will be used:
Volvo Cars makes use of the below listed definitions in this policy:
You may provide us with information about you or your vehicle when utilising Volvo Cars' services in or outside a vehicle or in other contacts with Volvo Cars, for example through our websites or customer centres (in this context, please note that phone calls may be recorded, with your consent, for quality assurance purposes). We may also obtain such data from our authorised dealers and repairers and other third parties. Such data may include:
Your vehicle will also automatically collect data relating to the vehicle and its surroundings, primarily of technical nature and not directly related to you as a person. Such data ("Vehicle-recorded data") is typically connected to the vehicle identification number (VIN) of the vehicle and may therefore be traceable to you. Vehicle-recorded data may include:
Information about certain Vehicle-recorded data is also included in the Owner's Manual.
We are particularly careful and apply additional measures if and when collecting and Processing Sensitive Personal Data, as required by applicable law. For avoidance of doubt, it is noted that applicable law may require other kind of data to also be treated as Sensitive Personal Data.
Where reasonably practical or as required by applicable law, we will, in connection to collecting or registering your Personal data, provide you with (i) specific information as to the purposes of the Processing of your Personal Data, (ii) the identity of the Controller, (iii) the identities of any third parties to whom the data may be disclosed and (iv) other information which may be necessary to ensure that you are able to safeguard your rights. The above information may, for example, be provided when you purchase a vehicle, in the vehicle's infotainment system, in mobile applications developed by Volvo Cars, at www.volvocars.com or otherwise in an agreement which you enter into with Volvo Cars.
Where reasonably practical or as required by applicable law, we will obtain your consent prior to collecting or using your Personal Data. The request for your consent will be clear and specific and provide you with a reasonable basis with which to make your decision. We will never take your consent for granted. Instead, we will make sure that you can consent in a clear and transparent manner. Your consent is voluntary and may always be revoked, for example by terminating a particular service or contacting Volvo Cars at the address indicated in the "Information and access" section below. If you do not give your consent, it may not be possible to use services or parts of services.
The collection and use of Vehicle-recorded data may be necessary in order for (i) technicians to diagnose and rectify faults in vehicles during the service and maintenance of vehicles, (ii) Volvo Cars product development, for example enhancements of the vehicles' quality and safety features, (iii) managing Volvo Cars' warranty undertakings and (iv) fulfilment of legal requirements. When collecting or using Vehicle-recorded data for these purposes, and for similar legitimate interests pursued by Volvo Cars, we will generally not seek your consent unless this is deemed necessary in the individual case or required by applicable law.
You may access applications and other services linked with the vehicle but provided by a third party, which may, for example, require transmission of location data and other Vehicle-recorded data to this third party. Volvo Cars is not responsible for the collection or use of Personal Data in applications or services provided by a third party, and recommends that you carefully review applicable terms for (and any integrity policy related to) such applications or services before you use them. If you have questions concerning a certain third party's use of your Personal Data, please contact the third party directly.
Volvo Cars may transfer your Personal Data to recipients in countries outside of the European Economic Area which may have differing data protection laws. This includes countries which the EU Commission does not consider to have an adequate level of protection for Personal Data. If this occurs Volvo Cars will ensure there is a legal ground for the transfer in accordance with applicable data protection legislation. You will also be informed about the legal ground, what safeguards were implemented, and where you can obtain a copy of information on these safeguards.
For most Processing acts, you are able to terminate our use of your Personal Data by updating your preferences, terminating a particular service, revoking your consent to the Processing by contacting Volvo Cars at the address indicated in the "Information and access" section below or as otherwise instructed by us. However, and unless otherwise follows from applicable law, you may generally not opt out of the Processing of your Personal Data:
We will only retain your Personal Data for as long as it is necessary to fulfil the purposes outlined in this policy or the purposes of which you have otherwise been informed. This means that when you have consented to our Processing of your Personal Data, we will retain the data for as long as the customer relationship lasts (and, where applicable, until the expiry of the warranty period) or until you withdraw your consent. If you have revoked your consent, we may nevertheless retain certain Personal Data for the period required in order for us to meet our legal obligations and defend ourselves in legal disputes. If we have not received your consent for Processing, the Personal Data will only be retained to the extent we are permitted to do so by law.
When we process your Personal Data, we strive to ensure that it is correct and up to date. We attempt to delete or correct Personal Data that is incorrect or incomplete. For more information regarding your right to ensure the accuracy of your Personal Data held by us, please see the "Information and access" section below.
As stated in the "Notice" section above, we may provide you with specific information concerning our Processing of your Personal Data when collecting or registering such data. You have the right to request (i) a copy of the Personal Data that we store about you, (ii) that we correct or remove Personal Data that you think is inaccurate, and (iii) to have your Personal Data deleted and to have our processing of your Personal Data restricted in certain circumstances. In addition you have the right to object to our processing of your Personal Data as well as to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format and to have these transmitted to another Controller.
Requests should be sent to the legal entity stipulated in the end of this document. Your requests will be dealt with in a prompt and proper manner. Where the applicable law provides for an administrative fee for complying with your request(s), such a fee may be charged by Volvo Cars. In addition, you may be able to access an overview of certain Personal Data that you have provided directly and that is held by Volvo Cars, and correct or update your information, by logging in to the Volvo Cars consumer portal account, or a similar service offered in your local market. For more information on your rights please contact our Data Protection Officer. Please see contact details for our Data Protection Officer in the end of this document.
Volvo Cars has taken technical and organisational measures in order to protect your Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of Processing.
Volvo Cars may share your Personal Data:
A Volvo Cars entity being the Controller of your Personal Data will, as a general rule, only disclose your Personal Data to a third party if it has received your consent to do so. However, if permitted by law we may share your Personal Data without your consent, unless we consider your consent necessary in the individual case or your consent is required by law, in the following situations:
We restrict access to your Personal Data to Volvo Cars' employees and suppliers who need to use the information in order to process it on our behalf, and who are contractually required to keep your Personal Data secure and confidential. We aim to choose the option for Processing services that best safeguards the integrity of your Personal Data towards any third party. Some of these processing activities might be performed outside of the EEA under a specific legal basis as required by national law.
We will not sell or trade your Personal Data with third parties unless we have your consent to do so. We will not share your Personal Data with third parties for their marketing purposes, unless we have received your consent for such disclosures. If you have provided such consent, but wish to stop receiving marketing materials from a third party, please contact that third party directly. We may provide you with information regarding new products, services, events or similar marketing activities. If you wish to unsubscribe to a particular e-mail newsletter or similar communication, please follow the instructions in the relevant communication. You may also use your Volvo Cars consumer portal account, or a similar service offered in your local market, to opt out of specific types of communication from Volvo Cars and to change previously submitted preferences.
In general, you can visit Volvo Cars websites without telling us who you are or revealing any information about yourself. However, to be able to provide you with certain services or offerings, we often need to record certain items of Personal Data such as your name and email address. We may also collect (by means of cookies) anonymous information on how you have used our websites prior to such recording. This information will be helpful to us in order to improve our websites or marketing. All Volvo Cars websites open to our customers include information concerning our use of cookies. For certain countries there is also an online procedure for accepting or declining cookies. For more information regarding our use of cookies, please consult the local information regarding cookies published for your country under www.volvocars.com.
When you download or register to use one of our apps, you may submit Personal Data to us such as your name, email address, phone number and other registration information. Further, when you use our apps, we may collect certain information automatically, including technical information related to your mobile device, and information about the way you use the app. Depending on the particular app you use and only after you have consented to such collection, we may also collect information stored on your device, including contact information, location information or other digital content. Further details about the kind of information we collect is set out in the information notice and/or the special notice for each individual app.
Some third-part apps which you download, are preinstalled or you can sign up for may have separate terms and privacy policies that apply regardless of our privacy policy. Volvo Cars is not responsible for the use of Personal Data in apps or services from a third party. We recommend that you carefully review the user terms and privacy policy of each third party service or application prior to signing up, downloading, or using them. We also recommend looking for privacy choices and controls in third-party apps after downloading.
Our services are not intended for use by children. We do not knowingly solicit or collect any Personal Data about children under the age of 13 nor market our products or services to them. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 13, please contact us. If we learn that we have inadvertently collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
As a result of legal requirements, we have to monitor how our system works, including the vehicles we have produced. This means that we collect sample data from these vehicles.
Lodging of complaint to supervisory authority If you are of the opinion that we are processing your personal data in violation of data protection laws and regulations you have the right to lodge a complaint with your supervisory authority.
To exercise your rights as a data subject, e.g. to obtain information or access to Personal Data that Volvo Cars process, kindly use this web form.
For other concerns regarding Data Privacy in Volvo Car Corporation, Attention: The Data Protection Officer, SE-405 31 Gothenburg, Sweden.
For requests regarding use of personal data as an employee or consultant, please follow this link.
For requests regarding use of personal data as a job candidate, a former employee or consultant, please follow this link.
Volvo Cars has appointed a Data Protection Officer for the Group who can be reached via e-mail or via post as set out below:
E-mail address: globdpo[at]volvocars[.]com.
Postal address: Postal address: Volvo Car Corporation, Attention: The Data Protection Officer, avd 50092, VAK, 405 31 Göteborg, Sweden.