General Privacy Notice
Effective from:
Published at:
Welcome!
We take your privacy seriously and want to be transparent and provide you with information about how we use your personal data. We will only use your personal data for clearly described purposes and in accordance with your data protection rights.
To be able to provide you with the freedom to move in a personal, sustainable, and safe way, we continuously develop new products and services. As these become available, they will also be subject to this notice, unless we clearly inform you otherwise.
This notice explains how we at Volvo Cars process personal data. It applies to our interactions with individuals, such as existing and potential customers, website visitors and business partners. From now on we will collectively refer to the different individuals we interact with as ‘you’ or ‘your’.
Please note that some Volvo Cars products have their own privacy notice that will explain the specific processing occurring as part of that product or service. We have listed these for you below. You can easily access them by following the links directly.
In this notice you will find information about:
- Who we are
- What personal data we use and why
- 2.1 When you visit our websites
- 2.2 Communicate and connect
- 2.3 Marketing and offers
- 2.4 Providing our products and services
- 2.4.1 Test drive
- 2.4.2 Business customer with online Fleet Account
- 2.4.3 Connected services in our cars
- 2.4.4 Volvo ID
- 2.4.5 Pick-up & Delivery
- 2.5 Warranty, claim management and recalls
- 2.6 Research and development of our products and services
- 2.7 Employee of our business partner or consultant
- 2.8 For shareholders
- Sharing of your personal data
- How we obtain your personal data
- International transfers
- How long we keep your personal data
- Profiling
- Your rights and controls
- Contact information
- Updates to this notice
- Glossary
1. Who we are
Volvo Car Corporation is a Swedish legal entity with company registration number 556074-3089 and registered address at Assar Gabrielssons Väg, SE-405 31, Gothenburg, Sweden. Volvo Car Corporation and its group companies are responsible for the processing of your personal data (‘we’, ‘Volvo’, ‘our’, ‘us’). We are a global company and provide products and services worldwide. You can find more information about the group companies operating in the different markets here.
2. What personal data we use and why
Personal data is information that directly or indirectly relates to you as a natural living person. Accordingly, personal data is information about you, such as your name, date of birth, contact information, Financial information, IP-address and information you provide to us when you are in contact with our customer care service. Our use of your personal data is called processing. All processing of personal data needs to be justified. This is referred to as having a ‘legal basis’. The legal bases we rely on when processing different categories of personal data are described below. The legal basis differs depending on what purpose we use your personal data for. To read more about the different legal bases, please see below.
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Please note that where a data category appears in bold below, a glossary at the end of this notice explains in more detail what this data category includes.
2.1 When you visit our websites
We process certain personal data (especially Online identifiers according to the glossary) from you when you use our websites. The extent of Online identifiers and other personal data which will be processed is dependent on your concrete usage of our website services and functions, as described below. For further information about used technologies, such as cookies, please also see our cookie information notice.
The below table will list more in details the data elements referred to as “Online identifiers”.
| How will we use your personal data (‘purpose’) | The information we use (‘personal data’) | Legal basis |
|---|---|---|
| When you visit and interact with our website, we automatically collect the data which is sent from your browser to establish a connection to our website. |
| Our legitimate interest in providing you with a secure website. |
| To detect fraud and misuse when you interact with our web functions, e. g. misuse of forms, detection of bots. |
| Our legitimate interest in detecting fraud and misuse. |
| To remember the choices you have made on our websites (such as privacy settings, items in shopping cart, language). |
If you are logged-in information you provide to us (such as Contact details, orders, Vehicle details, configurations) | Our legitimate interest in managing our interactions with you, improving our business operations and customer experience. |
| To provide a chat function to you. |
| Our legitimate interest in managing our interactions with you, improving our business operations and customer experience. |
| To provide you with map services, we use embedded content by third party service providers that transfers personal data only when you are using this service. The map service providers are responsible for the subsequent data processing. |
| Our legitimate interest in providing you with a map service and to connect you with our business partners. |
| To measure how our websites are being used and to gain insight into how the services are used, to better understand user behaviour and improve the usability and reliability of the websites and ultimately your online experience. |
| Your consent to the performance and/or analytics cookies and subsequent data processing activities according to our consent management platform. |
| To show you personalized content and ads on other websites and social media platforms. And to measure the effectiveness of our campaigns. |
| Your consent to the marketing cookie categories and subsequent data processing activities according to our consent management platform. |
2.2 Communicate and connect
Communication is central for all relationships. We want to hear from you and be able to reply to you when you communicate with us. To do so, we need to process your personal data as explained below.
| How will we use your personal data (‘purpose’) | The information we use (‘personal data’) | Legal basis |
|---|---|---|
| To manage our interactions with you, communicate with one another and handle queries and complaints through any channel such as chat, email, social media platforms, webforms, our call centre or when you visit us in person. |
| Our legitimate interest in delivering satisfactory customer service to you and ensure a good customer experience of our brand. |
| To obtain a better understanding of your experiences, interests and concerns about our products, services and brand, by means of conducting insight related initiatives such as surveys and research studies. |
| Our legitimate interest in:
Your consent for marketing purposes in those countries where that is required to conduct surveys and research studies. |
| To plan, organise, and manage events you have agreed to and/or participated in. |
| Our legitimate interest in designing and managing events and publicising Volvo Cars’ activities. When you participate in a particular event, we refer to our Event Privacy Notice for more detailed information about how Volvo Cars uses your personal data in relation to that specific event. |
| If you are not yet a customer of Volvo Cars, we process your personal data for the purpose of lead management. |
| Our legitimate interest to satisfyingly handle prospective customers. |
2.3 Marketing and offers
We want to keep you updated and to be able to provide you with relevant news, marketing content and offers. To do so, we use the personal data that we collect directly from you and from third party providers. We also use this personal data to tailor communications to you and to personalise your experience with our content. Where we obtain information about you from third parties, we have implemented checks and reviews to confirm that the information was lawfully obtained by the relevant third party and that the third party has the right to provide us with this information. We will provide you with relevant news, marketing content and offers through multiple channels such as postal mail, phone, email, Volvo Cars app and social media.
If you do not wish to receive marketing and offers from us any longer, you can always let us know by selecting ‘unsubscribe’ at the bottom of each marketing email or similar in the other channels.
As part of our marketing communications, we work with digital advertising partners to create and show marketing content on social networks and online advertising networks. Going forward, we will refer to these partners as “Advertising Partners”. These providers use personal data provided by us and from other technologies such as cookies to display tailored and relevant advertisements. You can find more information on this below.
| How will we use your personal data (‘purpose’) | The information we use (‘personal data’) | Legal basis |
|---|---|---|
To record and manage your choices. To send marketing communications that you have requested or may be of interest to you, according to your preferences. |
| Your consent to receive direct marketing communications from us. Where you have bought a product or service from us, and where applicable, where we send marketing communications to you as representative for a business, our legitimate interest to send you marketing communications. Our legal obligation to document and demonstrate whether you have consented to receiving marketing communications from us and record and respect your contact preferences and when and what you have opted out from. |
To show and provide relevant marketing communications and offers to you that are personalized and tailored to your preferences and interests. To help us better understand your specific interests and preferences so that we can tailor communications to you. Tailoring of communications in this manner can be the result of analysing or predicting your personal preferences based on information we hold about you (referred to as profiling). |
| Our legitimate interest to provide more relevant advertising to you. Your consent to our processing of this personal data for the purpose of marketing and where applicable, your consent to relevant cookies and similar technologies. |
To show you relevant and tailored Volvo Cars advertisements, when you visit our Advertising Partners’ sites and within social media and direct communications (this is commonly referred to as retargeting). To make it possible for us to find and engage with the right audiences and to provide advertising to those individuals. |
| Your consent to relevant cookies or similar technologies on our website and where applicable your prior consent to marketing communications based on cookies and other Online identifiers which require your consent. Your consent to receiving marketing from us or in the case where you have bought a product or service from us, our legitimate interest to display and send you marketing. Our legitimate interest to advertise our products and services and provide more relevant advertising to you. We consider our Advertising Partners such as Meta and Google as jointly responsible with us (joint controllers) in these scenarios. |
| To obtain statistical insights into our marketing communications. |
| Our legitimate interest in measuring the efficiency of our marketing communications and activities subject to, whenever obtaining information from a device, the user having accepted advertising cookies. |
* This would be the case for app usage when you are logged in with your Volvo ID and in the case of web browsing, when you follow a link provided to you in an email and when you request a service linked to your phone number or email address, such as making a booking for a service or registering for a test drive.
2.4 Providing our products and services
A contractual relationship is created between us when you order, sign-up for or purchase a product or service. We will collect the information that is necessary for us to prepare for, enter into and fulfil the contract. The personal data we will collect will depend on the contract. Please click on the different contracts below to find out more.
2.4.1 Test drive
| How will we use your personal data (‘purpose’) | The information we use (‘personal data’) | Legal basis |
|---|---|---|
To administer and prepare your test drive. To be able to safeguard our rights and recover a test car (which we own) in the event of material breach of contract. |
| Performance of the contract. Our legitimate interest in monitoring your compliance with the contract (including, vehicle recovery where you have a signed up for a test drive). |
2.4.2 Business customer with online Fleet Account
| How will we use your personal data (‘purpose’) | The information we use (‘personal data’) | Legal basis |
|---|---|---|
To create a Fleet Account and to verify you as a Fleet Account user at login. To verify your identity and that you are an authorized person to sign on behalf of the company you work with. To communicate with you about the Fleet cars. For marketing, please see Marketing and offers. |
| Our legitimate interest in administering, concluding, and fulfilling the contract we enter with the legal entity you represent. Our legitimate interest in evaluating our online fleet service. |
2.4.3 Connected services in our cars
Many of our Volvo cars come with connected services. To provide these services we use the following personal data as explained below.
| How will we use your personal data (‘purpose’) | The information we use (‘personal data’) | Legal basis |
|---|---|---|
To assess the car’s state of health based on current and historical information in order to plan service and maintenance and carry it out where necessary. To contact you about your contract and the services included. To be able to safeguard our rights and recover a subscription car (which we or our financial partners own) in the event of material breach of contract. When necessary for our or third party’s legitimate interest to establish, exercise or defend ourselves against legal claims or upon request received from of a law enforcement authority and when they need information to perform their crime prevention and sanctioning activities, we may disclose information to the law enforcement authority subject to internal approval. |
| Performance of the contract (e.g., for maintenance services and predictive maintenance services that are included in a Care by Volvo subscription contract). Our legitimate interest in monitoring your compliance with the contract (including, vehicle recovery where you have a subscription contract). To comply with our or a third party's legal obligations or our legitimate interest in providing data to law enforcement authorities (e.g. police, courts) when a severe crime is suspected or when necessary to establish, exercise or defend ourselves against legal claims. |
| To be able to provide you with features of the car such as connected services and safety features of the car. |
| Our legitimate interest in providing you with features of the car and guaranteeing connected services. Performance of the contract (such as providing connected services to you). |
2.4.4 Volvo ID
A Volvo ID is a unique, personal, and non-transferable ID, that gives access to a wide range of Volvo services both online and in your car. For us to provide you with a Volvo ID, we will use your personal data as explained below.
| How will we use your personal data (‘purpose’) | The information we use (‘personal data’) | Legal basis |
|---|---|---|
| To create your Volvo ID and facilitate your access to services within the Volvo Cars digital ecosystem. |
| Performance of the contract. |
| To manage your booking(s), contact and communicate with you about services you have booked using your Volvo ID. |
| Our legitimate interest in managing and communicating with you about your booking(s). |
2.4.5 Pick-up & Delivery
Pick-up & Delivery is a service that gives you the opportunity to have your car picked-up for service or repair and then returned to you. To provide you with this service, we will use your personal data as explained below.
| How will we use your personal data (‘purpose’) | The information we use (‘personal data’) | Legal basis |
|---|---|---|
To create your Pick-up & Delivery account, provide the service, and communicate with you. To show you the nearest retailer or workshop that can deliver this service. |
| Performance of a contract. Your consent to the location tracking technologies on your device or our website. |
| To provide you with a loan vehicle (if applicable). |
| Performance of a contract. |
2.5 Warranty, claim management and recalls
For us to handle warranty matters, claims and any recalls of products and services, we will use your personal data as explained below.
| How will we use your personal data (‘purpose’) | The information we use (‘personal data’) | Legal basis |
|---|---|---|
To create and administer vehicle warranties (if applicable) and to assess and manage warranty claims you may make. To administer, enable and handle recalls and product related claims (such as product liability claims). |
| Performance of the contract. To comply with our legal obligations (e.g., to manage recalls and product safety/liability issues). Our legitimate interest in handling product liability claims. |
2.6 Research and development of our products and services
We continuously develop, assess, and conduct research on our products and services. To do this, we will use your personal data as explained below. In addition, we also conduct analysis on anonymized data and at an aggregated level. In these cases, the data cannot be connected to you as a person.
| How will we use your personal data (‘purpose’) | The information we use (‘personal data’) | Legal basis |
|---|---|---|
| To compile statistics and conduct analysis of our services and products, to understand the market interest in our products and offerings and how they are used. |
| Our legitimate interest in continuously improving our products, services, and offerings. |
| To analyse performance data from vehicles and other services and deliver updates when necessary. |
| Our legitimate interest in continuously enhancing the performance, quality and safety of Volvo vehicles, products, and services. Your consent, when required. |
| To plan our general management and operation of our business. |
| Our legitimate interest in understanding our business and customers. |
2.7 Employee of our business partner or consultant
As an employee of one of our business partners or a consultant, we use your personal data as explained below so that we can do business with the company that you represent or work with. However, the employees at our retailer partners or workshops engaged in selling and serving our cars are not included here.
| How will we use your personal data (‘purpose’) | The information we use (‘personal data’) | Legal basis |
|---|---|---|
| To maintain our business relationship with you, communicate with you and otherwise address matters concerning our business relationship. |
| Our legitimate interest in maintaining our business operations. |
| To manage safety and security at our facilities. |
| Our legitimate interest to maintain security and safety, prevent theft and fraud on our premises. |
2.8 For shareholders
We are a listed company on the Swedish stock market. This means that we must fulfil our obligations to you as a shareholder. To do this, we collect and store the following information about you in your role as a shareholder.
| How will we use your personal data (‘purpose’) | The information we use (‘personal data’) | Legal basis |
|---|---|---|
To identify shareholders, manage the shareholder register, prepare the general meeting, and conduct the general meeting and related meetings. To fulfil our obligations towards you as a shareholder under applicable legislation. To fulfil our obligations under applicable legislation, such as disclosing the share register upon request. To manage Volvo Cars’ holdings, including any share distributions where applicable. To communicate with you as a shareholder. |
| To comply with our legal obligation. Our legitimate interest in identifying you as a shareholder and to communicate with you. Our legitimate interest to manage and, where applicable, distribute our holdings and share relevant information (including but not limited to personal data relating to you as a shareholder) with third parties such as central securities depositories and banks issuing depository receipts, as relevant. |
3. Sharing of your personal data
We share data with various organisations to run our business, to maintain our relationship with you, and provide you with products and services. To justify our sharing of personal data we rely on different legal bases depending on the purpose. For example, this could be your consent or our or a third party's legitimate interest. In each case we have entered into necessary data protection agreements in order to ensure that your personal data is used lawfully and in accordance with the purposes set out in this privacy notice.
| Who (‘Recipient’) | Why (‘Purpose’) |
|---|---|
| Other group companies within Volvo Cars and its sub-processors | Personal data is transferred to other group companies for customer care and services related to planning vehicle service and maintenance, operation of the website and provision of IT systems for business support and data storage. |
| IT-suppliers and their sub-processors | Personal data is transferred to IT-suppliers who supply general business support systems to us, such as software and data storage providers. |
| Authorised Volvo Car retailer(s) (and its sub-processors) | Personal data is transferred to authorised Volvo car retailer(s) whenever this is necessary to fulfil your request, e.g. for the purpose of communication and administration of offer requests, test drives or the handover of cars and sharing relevant feedback you provide about your experience with them. |
| Authorised Volvo Car repairer(s) (and its sub-processors) | Personal data is transferred to authorised Volvo car repairer(s) for the purpose of providing the service under the Volvo service program. We also share relevant feedback that you have submitted to us. |
| Our legal advisors and similar professional consultants | Personal data need to be disclosed for the purpose of supporting, providing advice, and representing us in relation to claims and/or court proceedings. |
| Law enforcement authorities (e.g. police, courts) | Personal data need to be shared or may be shared to law enforcement authorities (e.g., police, courts), to comply with a legal obligation, or our legitimate interest in providing data when a severe crime is suspected, or when is necessary to establish, exercise or defend ourselves against legal claims. |
| Marketing and advertising suppliers | Personal data is shared with companies who provide us with marketing services or with digital advertising providers. |
| Providers of financial services, financial service partners | If you make a payment online, you may give your data directly to the payment service provider. Where this happens, your data is controlled by the payment service provider, and we will not see it, except to the extent that they need to share it as part of payment confirmation. We share your data with providers of financial services or our financial service partners for the purposes of management of business operations, e.g., to prepare and administer your contract, handle service-related communications and customer support and in order for the financial service partner to exercise their rights. Also, to help improve the product and service offering, manage complaints, ensure compliance and for training purposes. |
| Other service providers (such as mobile network operators, customer care service partners, connectivity providers, roadside assistance operators and charging operators) | We can share information about you, the vehicle and subscription information to enable the services, for fault tracing and service improvement purposes or to support you in case you face any issues. In some markets we use and share information with a third-party provider for customer care services. |
| Insurance partner(s) | We may share your personal data with our insurance partner(s) to e.g., be able to meet your request for an insurance quote, as applicable. Each insurance partner is a controller for its processing of personal data after such transfer and you can read about how the insurance partner(s) process personal data by visiting their respective websites or contact them directly. |
| Any party approved by you | For example, you may ask us to share vehicle data with an insurer or a legal authority. |
| Potential investors/buyers of Volvo Cars and our business or part of business | If we intend to transfer all or part of our business, personal data may be disclosed to a potential investor/buyer. |
4. How we obtain your personal data
We receive personal data directly from you, from the company that you represent and in some cases third parties with whom we do business.
We also receive your personal data from companies within the Volvo Cars group where you have provided information to a group company in connection with the use of the cars and connected services, e.g., Volvo Cars App.
In certain situations, we process personal data collected from publicly available sources in relation to your professional role for marketing and advertisement purposes. In those cases, we always ensure your ability to exercise your rights in our first interaction with you.
If you have a vehicle with connected services and have enabled transmission of certain vehicle data, we will also collect information directly from your vehicle, for example information about the status of your vehicle and your driving behaviour. Please read more about this in our Vehicle Privacy Notice.
Some of the personal data you provide to us is necessary for us to be able to fulfil our obligations, either legal or contractual, in providing the products and services to you or the company that you represent. Where you choose not to provide certain necessary personal data, we will not be able to fulfil our legal or contractual obligations towards you or the company that you represent.
5. International transfers
As an international company we share your personal data with group companies, subcontractors, and business partners worldwide, specifically we transfer personal data to India and Turkey for IT-support, the United States for hosting services, IT-support and customer service.
Whenever we conduct international transfers of personal data, we use tools and safeguards to make sure that such transfers comply with applicable law and that your personal data is granted the same level of protection as in the EU/EEA. Typically, we use tools and safeguards such as:
- ensuring that the relevant country is subject to an adequacy decision by the European Commission, or
- ensuring the implementation of so-called standard contractual clauses issued by the European Commission (available at the European Commission’s website) and,
- ensuring the implementation of technical safeguards like encryption and pseudonymisation.
If you’d like more information about our international transfers, you can get in touch with us using the contact information provided below.
6. How long we keep your personal data
Volvo Cars will only retain your personal data for as long as it is required for one or more of the purposes listed above, or where we are otherwise legally obligated to keep the data (including but not limited to: contractual periods, warranty and product liability requirements, legal reporting obligations, retention requirements necessary for anticipated disputes, and/or to prevent fraud). Where we no longer have a legitimate business need for the data, we will either anonymise it so that it is no longer capable of being associated specifically to you, or your vehicle, or we will delete it.
The following standard retention periods apply to the types of personal data referenced in this privacy notice. These retention periods are subject to certain rights available to you (such as your right to erasure), choices and permissions you have selected, periodic changes to other legal obligations we must comply with or where we have otherwise notified you of a different retention period. For specific information about data retention requirements in your country, or for a certain type of personal data, please see contact information.
- Contact details customers: for the duration of the period in which you are a customer and for an additional period of up to 5 years.
- Contact details for non-customers: up to 12 months following our last interaction with you or any request for a product or service. This period will begin again following any new interaction with us.
- Online identifiers: up to 36 months from the date of your last interaction with us. Please refer to our cookie policy and cookie banner for their specific duration times.
- Customer Care interactions: the retention period depends on your country of residence and ranges between 1 to 10 years from the date the case is closed. For details connected to your market please contact us.
- Call recordings and chat transcripts: up to 1 year from the date of the call or the chat.
- Volvo ID: during the time that you maintain an active Volvo ID account and for an additional period of up to 30 days.
- Information about, and from, your vehicle: up to 10 years from the date of vehicle manufacture. For specific information on retention periods for connected vehicles, please see our Car Privacy Notice.
- Contract data: for the duration of the agreement and for an additional period of up to 5 years.
- Financial information: in case of a negative credit or subscription decision up to 5 years and in case we conclude a contract with you as long as your contract with us is active or up to 10 years according to our legal obligations to store information after the contract was terminated.
7. Profiling
We use automated processing to gain a better understanding about you and your personal preferences. We use this, for example, when we carry out profiling on you in order to:
- Customize and tailor marketing shown to you by analysing or predicting your personal preferences based on information we hold about you.
- Customize and tailor your experience when you interact with our various channels such as our website.
Using automated processing in this manner does not carry any significant effect on you as an individual. Please note that you always have the right to object to our use of profiling as mentioned above. To do so or should you have any questions about our profiling processes, please contact us.
8. Your rights and controls
You have specific legal rights relating to the personal data we process about you. The rights may differ depending on which jurisdiction you are in and the nature of the processing. Generally, your rights concern the possibility to:
- withdraw your consent (the most common is the opt-out from marketing)
- object to our processing of your data
- ask for a copy of the data we hold about you (so-called subject access right)
- ask for the data to be transferred to another entity (so-called data portability)
- ask for the data to be corrected or restricted
- ask for the data to be deleted (so-called right to be forgotten)
As mentioned, these rights are not absolute and in some cases data protection law limits their application. Should this be the case for a request you make to us, we will always explain why we cannot fulfil your request.
If you would like to submit a rights request, you can get in touch with us by completing this form. We kindly ask that you use the form as it sets out the information that we need to verify your identity and effectively process your request. However, should you prefer not to use the form, you are always welcome to contact us and submit your request using the contact information in the next section.
You also have a right to submit a complaint to your local data protection authority should you have concerns about how we use your personal data. However, we would appreciate it if you reached out and raised your concerns directly with us first to allow us to try to resolve them together. You can find our contact information here.
9. Contact information
If you have any questions about how we use your personal data, you can contact us at dataprotection@volvocars.com, or Volvo Car Corporation Data Protection Officer as follows:
Postal Address: Volvo Car Corporation, Attention: The Data Protection Officer, avd 50092, VAK, 405 31 Gothenburg, Sweden.
Email: globdpo@volvocars.com
10. Updates to this notice
We continuously develop our products and services and will review and update this Privacy Notice as a result. As such we encourage you to revisit this Privacy Notice regularly. The date at the top of this Privacy Notice lets you know when it was last updated. We will handle your personal data in a manner consistent with the Privacy Notice under which it was collected unless we have your consent to handle it differently.
11. Glossary
| Contact details | First name, last name, salutation, email address, postal address, phone number. |
| Vehicle details | Vehicle model, vehicle identification number (‘VIN’) and registration number. |
| Volvo ID | First name, last name, phone number, preferred language, country, email address and chosen password. |
| Contract details | Contract type, subscription number (if applicable), contract start and end date. |
| Information from the vehicle | Data and status from sensors, settings, connections, data related to the use of the vehicle, etc. (this kind of data is related to the car VIN and may therefore be connected to you). For more information, please read our Vehicle Privacy Notice. |
| Financial information | This may include your bank account details, credit card or debit card details. |
| Proof of personal identification | This may include a copy or a photo of a valid national identification document or driver’s license. Your personal identity number or date of birth and/or additional documents that we may request to verify your identity. |
| Online identifiers | This includes a variety of data collected via cookies and similar technologies that are placed on our website. This can include cookie Ids, IP address, website visits, web activity. |
| Engagement metrics | This includes information about your interactions with our marketing communications in the various channels which we can attribute to you or your device. This can include open and click rates, date, and time of interactions with our e-mails, links a recipient clicked on. For social media, this can include reach, engagements and clicks on our advertisements, opening of our advertisements and leads and video playback. |