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Privacy Notice – Consumer surveys

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Article version 2021.340.0

Privacy Notice – Consumer surveys

Effective from:

Published at:

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

You can find below:

  1. Who we are;
  2. What personal data we collect and why;
  3. How long we keep your data;
  4. Who we share your personal data with;
  5. Your rights in relation to the data processing we perform;
  6. Contact information;
  7. Changes to our Privacy Notice.

1. Who we are

The entities that are jointly responsible for the processing of personal data in relation to the Consumer Surveys are Volvo Car Corporation, having its registered office at Assar Gabrielssons Väg, 40531 Gothenburg, Sweden, company registration number 556074-3089, and Volvo Car Korea, having its registered office at 5th floor, Hakdong-ro 343, Gangnam-gu, Seoul, Republic of Korea, company registration number 106-81-70953, hereinafter referred to as “Volvo Cars”, “we”, or “us”.

2. What personal data we collect and why

When you interact with our Consumer Survey, we process the following categories of data about you:

  • Identifiers such as name, e-mail address, telephone number, salutation, age, gender, postal code, and city. We process this data in order to send the Consumer Survey and assess consumer performance by segmentation. The data is processed based on our legitimate interest to improve the business purpose and customer experience that your survey response concerns (Art.6(1)(f) GDPR).
  • Your Vehicle data such as vehicle type, Vehicle Identification Number (VIN), and registration number (REG). We process this data based on our legitimate interest to assess field action and warranty performance (Art.6(1)(f) GDPR).
  • Contract type, subscription number, vehicle relationship (contract/sales type starting and end date). We process this data in order to send the Consumer Survey and assess consumer performance by segmentation allowing us to improve the overall business operations and the consumer experience. The data is processed based on our legitimate interest to improve the business purpose and customer experience that your survey response concerns (Art.6(1)(f) GDPR).
  • Opening/clickthrough rates: We process this data for statistical analysis and range measurement, and to understand the interests of our consumers. For this analysis, the e-mail invites contain so-called web beacons or tracking pixels, which display single-pixel image files that are also embedded in our website, where we ask for your consent in order to deploy those. The data is processed based on our legitimate interest to understand overall survey performance and survey interaction (Art. 6(1)(f) GDPR).

3. How long we keep your data

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

In order to keep your responses secure, the invitation for feedback provides you with an individualised questionnaire that no other person can access. The survey web site and our data storage facilities have security measures in place to protect the loss, misuse, and alteration of the information under our control.

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

4. Who we share your personal data with

We will share your personal data with the following categories of third parties, on a need-to-know basis:

  • Our processors supporting our activity in general, such as providers of IT solutions;
  • Our processors supporting delivering the Consumer Surveys, which are limited by contract in their ability to use your personal data for any purpose other than to provide services for us in compliance with each data processing agreement in place:
    • Medallia, Inc. (EU, United States) – customer experience management.

Your personal data will be disclosed to and processed by your selected retailer (if applicable) and companies within the same group of companies as VCC. In relation to companies within the same group of companies as VCC located outside EEA, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

5. Your rights in relation to the data processing we perform

As a data subject you have specific legal rights granted by the General Data Protection Regulation relating to the personal data we process about you. These are briefly explained below, and you can exercise them by filling out the dedicated form indicated below.

  1. Right to withdraw consent: Where you have given consent for the processing of your personal data, you may withdraw your consent at any moment with effect for the future.
  2. Right to access your personal data: You may ask from us information regarding personal data that we hold about you. We will provide you with a copy of your personal data upon request. If you request further copies of your personal data, then we can charge you with a reasonable fee that we base on the administrative costs. You have the right to the information about our safeguards for the transfer of your personal data to a country that is outside the EU and the EEA if you request that we confirm whether or not we process your personal data, and we transfer your personal data to a country that is outside the EU and the EEA.
  3. Right to rectification: You may obtain from us rectification of incorrect or incomplete personal data concerning you. We make reasonable efforts to keep personal data in our possession or control which are used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to us.
  4. Right to restriction: You may obtain from us restriction of processing of your personal data, if:
    1. you contest the accuracy of your personal data, for the period we need to verify the accuracy,
    2. the processing is unlawful and you request the restriction of processing rather than erasure of your personal data,
    3. we do no longer need your personal data for the processing purpose but you require them for the establishment, exercise or defense of legal claims, or
    4. you object to the processing while we verify whether our legitimate grounds override yours.
  5. Right to portability: You have the right to receive your personal data that you have provided to us, and, where technically feasible, request that we transmit your personal data (that you have provided to us) to another organization, if:
    1. we process your personal data by automated means;
    2. we base the processing of your personal data on your consent, or our processing of your personal data are necessary for the execution or performance of a contract to which you are a party;
    3. your personal data are provided to us by you; and
    4. your right to portability does not adversely affect the rights and the freedoms of other persons.
    You have the right to receive your personal data in a structured, commonly used and machine-readable format. Your right to receive your personal data must not adversely affect the rights and the freedoms of other persons. Your right to have your personal data transmitted from us to another organization is a right you have if such transmission is technically feasible.
  6. Right to erasure: You have the right to request that we delete the personal data we process about you. We must comply with this request if we process your personal data, unless processing is necessary:
    1. for exercising the right of freedom of expression and information;
    2. for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject;
    3. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or
    4. for the establishment, exercise or defense of legal claims.
  7. Right to object: You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing or for the establishment, exercise or defense of legal claims. If you object to the processing, please specify whether you also wish the erasure of your personal data, otherwise we will only restrict it. You also have the right to object at any time, regardless of any reason, to the processing of your personal data for direct marketing (which includes profiling to the extent that it is related to such direct marketing), if such processing was based on our legitimate interest. If the marketing was based on your consent, you can withdraw consent (see above).
  8. Right to lodge a complaint: You can lodge a complaint to your local data protection supervisory authority or with any other data protection authority in the EU. However, we will appreciate if you first contact us to try and solve your problem – you can find our contact details below.

You can exercise your rights in relation to us by filling out this form, which will help us to deal with your request properly. The online form contains the information that we need to verify your identity and review your request. For requests submitted by telephone or email, you will need to provide us with sufficient information that allows us to reasonably verify that you are the person whose personal data we collected and describe your request in sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.

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

6. Contact information

In order to exercise your rights, please use the web form mentioned in the Customer Privacy Policy above. If you have any other questions regarding the subject matter of personal data protection, you can contact directly Volvo Car Korea that is indicated as a joint controller in this privacy notice, at the contact details mentioned here: https://www.volvocars.com/kr/support/contact-us.

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

Company: Volvo Car Corporation

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

Email: globdpo@volvocars.com

7. Changes to our Privacy Notice

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

ADDENDUM FOR USERS IN KOREA (CONSUMER SURVEYS)

This addendum shall apply to users in the Republic of Korea (“Korea”). In case this addendum deviates from the body of the Volvo Car Privacy Notice (“Privacy Notice”), the provisions of this addendum shall prevail.

1. Who we are

In Korea, Volvo Car Korea (referred to as “Company”, “we”, or “us” in this addendum) is responsible for the processing of personal information in relation to your engagement with one of our consumer surveys (“Consumer Survey”). The Company has its registered office at 343, Hakdong-ro, Gangnam-gu, Seoul, Korea.

2. What personal Information we collect and why

We collect your personal information as described in “What personal data we collect and why” of the Privacy Notice based on your consent, unless the applicable laws and regulations in Korea allow otherwise.

3. Disclosure of personal information to third parties

Other than the cases listed below in this Section, unless otherwise provided in the applicable laws and regulations, the Company will not use or provide users’ personal information to any other third party beyond the scope of purposes set forth in the Privacy Notice without the users’ consent, except in the following cases:

  1. If prior consent of the user is obtained; or
  2. If the case falls under any of the reasons prescribed in Articles 17 and 18 of the Personal Information Protection Act.

4. Processing of personal information by entrusted third parties

The Company entrusts third parties with the task of processing personal information of users in order to improve the quality of the Consumer Survey, and the Company ensures that such personal information is managed in a safe manner by clearly stating the following scope of entrustment in the relevant contracts pursuant to the relevant laws:

Entrusted Third PartyScope of Entrusted Tasks
Volvo Car CorporationCustomer satisfaction survey

5. Overseas transfer of personal information

The Company may transfer and manage personal information of users overseas for purpose of, among others, providing the Consumer Survey as follows:

Name and contact information of the company that the personal information is transferred to:

  • Volvo Car Corporation
  • Assar Gabrielssons väg, SE-405 31, Gothenburg, Sweden
  • globdpo@volvocars.com
  • Country: Sweden
  • Purpose of the overseas transfer: Customer satisfaction survey.
  • Date and method of transfer: At the time of service use through electronic transmission.
  • Personal information to be transferred: All collected items.
  • Period for retention and use by the transferee: Until fulfillment of the purpose of personal information provision.

6. Rights and duties of users and legal representatives and exercise thereof

Users, legal representatives, and any representative entrusted with such right can exercise their rights to request access to, modification, deletion, and suspension of processing of their personal information at any time. Also, the users and representatives can retract consent to the collection and use of their personal information or cancel registration at any time. To exercise rights through the data protection officer, please contact the data protection officer as set forth in Section 9 herein.

7. Retention period and method of destruction of personal information

We process and retain your personal information for a certain period as described in “How long we keep your data” of the Privacy Notice based on your consent, unless the applicable laws and regulations in Korea allow otherwise.

In principle, personal information of users will be destroyed without delay after fulfilling the purpose of collection and use.

Information provided by users will be placed in a separate database (or filing cabinet in case of personal information printed on paper) and stored for a certain period of time pursuant to the Company's internal policies and other applicable laws and regulations after fulfilling the purpose for which the personal information was collected and used.

The process and method for destruction of personal information is as follows:

  1. Destruction Procedure
    • The Company shall select the personal information to be destroyed and proceed with the destruction upon approval by the data protection officer.
  2. Destruction Method
    1. Personal information printed on paper will be destroyed by shredding or incineration.
    2. Personal information stored in electronic files will be destroyed via technical methods preventing restoration.

8. Security measures for personal information

The Company takes all necessary technical, managerial and physical measures as required by applicable laws and regulations to protect users’ personal information, including but not limited to the following:

  1. Managerial measures: Establishment and enforcement of internal management plans, periodic training of employees, etc.;
  2. Technical measures: Management of access authority to the personal information processing system, installment of access control systems, encryption of unique identification information, and installment of security programs, etc.; and
  3. Physical measures: Access control to data processing rooms, archive rooms, etc.

9. Data protection officer

Name: Lee, Manshik

Title: Head of Sales & Marketing

Contact Information: help.korea@volvocars.com

10. Modification of the privacy notice

The Privacy Notice and this addendum will be effective from 6th Dec. 2021.

Prior versions of the Privacy Notice and this addendum can be found here.