Effective from: October 5, 2023
This document describes how Volvo Cars and Zenseact (as defined below) process your personal data obtained by our Data Collecting Vehicles (DCVs) when driving on public roads for collection of traffic data (hereinafter "Public Traffic Environment Data"). These vehicles, equipped with a reference platform mounted on the roof containing different sensors, collect this data in Europe, Asia and North America.
You can find the following information below:
The entities jointly responsible for the processing of personal data in relation to the scope of the notice are:
Unless its specified, hereinafter this joint responsibility referred to as "we," or "us." Under the Joint Controllership, Volvo Cars has responsibility regarding transparency duties, as well as fulfilling the data subject's rights.
The processing of the Public Traffic Environment Data, which involves the processing of personal data, is necessary for us for the purposes of developing safe and reliable software and sensors for advanced driver assistance systems (ADAS) and autonomous drive (AD) systems, with the overall purpose of protecting all life on the road. Such data consists of the following data categories:
The above data, though collected in the US, is transferred to Volvo Cars in Sweden for storage and processing as explained in this Notice. The personal data included in the Public Traffic Environment Data above will be processed based on our legitimate interests (EU General Data Protection Regulation, Article 6.1.f) for the purposes mentioned above.
We limit our locations of interest to exclude hospital entrances, accident locations with injured individuals, beaches or public parks, private areas such as interior of a house, its garden or balcony, and other places that might be sensitive for the persons being recorded.
We will not process the personal data included in the Public Traffic Environment Data for any purposes other than the purposes explicitly described in this privacy notice. We also have taken measures to limit access to the Public Traffic Environment Data, as well as implementing relevant security and privacy measures, such as removal of non-relevant material.
Public Traffic Environment Data will not be processed after more than 10 years for being able to reuse the data to test new versions of the software during the lifetime of the components. We will regularly sort out and erase data that is no longer needed in order to keep only relevant traffic situations. Data that is not complete or corrupted due to technical errors is also a candidate to be removed. The driver will also make annotations of recorded material when the data needs manual review and potential removal if the data can be considered intrusive or harmful for the individuals recorded by the sensors.
We will share your personal data with the following categories of third parties on a need-to-know basis:
All suppliers act as processors and are bound by contractual arrangements with us and in line with the purpose set out in this notice. Transfer of the Public Traffic Environment Data to third parties outside EU will be made using Standard Contractual Clauses approved by the EU Commission.
We can share sets of data with other parties when it has been properly anonymized prior to sharing. Such data cannot be attributed to a natural person and is no longer personal data.
We might share data that is anonymized or not attributed to a natural person with research entities for their traffic-related research purposes, and with road traffic authorities for road safety improvements, such as helping them to know the quality of lane markings.
5.1 Your rights under the EU General Data Protection Regulation
You have specific legal rights granted by the General Data Protection Regulation relating to the personal data we process about you. These are explained below.
Details about your rights is Volvo Cars' responsibility – what they mean, when and how you can exercise them – can be found in our Customer Privacy Policy.
To exercise your subject rights, please use our form available here and clearly state that your request refers to our Data Collecting Vehicle.
Your right to be informed and your right to access: You have the right to receive information about how we process your personal data.
In addition, you have the right to receive information about what personal data we store about you and how your personal data is used and processed, free of charge and upon written request.
You are entitled to request, in writing and free of charge, a copy of the personal data that we have registered about you.
If your request is unfounded or your request is excessive, e.g., should you frequently and within short intervals ask to receive information on or a copy of your personal data, we have the right to refuse to act on your request or to charge a reasonable fee which covers the administrative costs of the action requested by you.
Your right to rectification and erasure: If your personal data is inaccurate or incomplete, you have the right to request that we correct or remove the personal data, including the right to have incomplete personal data completed.
You have the right to request the erasure of your personal data under certain circumstances (set forth in the GDPR). Provided that your request falls within one of those circumstances, we will erase your personal data.
Your right to object: You have the right to object to your personal data being processed for the purpose defined in this Privacy Notice.
Your right to restrict processing: Under certain circumstances (set forth in the GDPR) you have the right to request the restriction of processing of your personal data. In such a case, your personal data shall only be processed with your consent, with the exception of storage and processes needed for that, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.
Your right to file a complaint: We encourage you to contact us if you have any questions regarding this Privacy Notice or if you are unhappy with the way we are processing your personal data.
You also have the right to file a complaint with the supervisory authority regarding our processing of your personal data or handling of any inquires related to it. You will find the contact details of the relevant supervisory authority, Integritetsskyddsmyndigheten (IMY), below.
5.2 Your rights under US State Laws
Laws in various states provide rights to you with respect to your personal information. Our General Privacy Statementoutlines these rights and how you can exercise those rights in the US.
In order to exercise your rights, please use the applicable web form mentioned above. If you have any other questions regarding the subject matter of personal data protection, you can contact us at the following contact details:
DPO Volvo Car Corporation
Jan Wellergård
Volvo Car Corporation
Avdelning 50092 / HABVS
405 31 Göteborg
Sweden
Integritetsskyddsmyndigheten (IMY)
Box 8114
104 20 Stockholm
Sweden
Phone: +46 (0)8-657 61 00
Email: imy@imy.se
You can find contact information and other information regarding Zenseact's processing of personal data in its Privacy Policy, https://www.zenseact.com/privacy-policy/
We reserve the right to modify our privacy practices and update and make changes to this privacy notice at any time and at our discretion. 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.