VOLVO VALET PRIVACY POLICY

Last Updated: November 23, 2021

SCOPE AND PURPOSE

This Service Privacy Notice describes how Volvo Car USA, LLC (referred to as “Volvo Car USA”, “we”, “our”, or “us”) collects and processes your personal information when you use Volvo Valet to schedule a service appointment, onsite or at-home test drive, or the delivery of your new Volvo vehicle (collectively referred to as “Services”) directly with a Volvo Car authorized retailer (“Retailer”) through the Volvo Valet App or Web Booking Portal (found at https://www.volvocars.com/us/studios), as well as when provided by drivers through the Birdseye Mobile App. “Personal information” is defined as any factual or subjective information, recorded or not, that identifies, relates to, describes, references, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, household or device.

This Service Privacy Notice does not apply to Retailers or third parties to whom you directly provide your information including, but not limited to, subscription services, insurance companies, or other third parties who may offer special rates or products to Volvo Car USA customers, nor to content posted on social media channels. These entities are independent of Volvo Car USA and responsible for their own collection of information. Please refer directly to those entities and their particular privacy policies for more information.

You can find below:

  • What personal information we collect;
  • How we share your personal information;
  • How we address the security of personal information;
  • Your privacy rights and choices; and
  • Additional information about our privacy notices.

INFORMATION WE COLLECT AND WHY

When you use our Services, we collect personal information from you and use it as follows.

When you:

  1. Create an Account: As a customer or as a driver, we collect from you your identifiers (such as your first and last name, email address, and phone number) in order to allow you to access and use the Volvo Valet App, Web Booking Portal, or Birdseye Mobile App, as well as to communicate with customers or drivers as the case may be. For drivers, we also collect visual information (your photograph) from you so that customers can recognize you when you arrive to pick up or drop off their vehicle.
  2. Access and Use the Volvo Valet App, Web Booking Portal, or Birdseye Agent App: As a customer or as a driver, we automatically collect your internet and other electronic network activity (such as your usage, browsing actions or patterns, and crash data or other system activity). We use this information to understand user behavior on and improve the usability of the Volvo Valet App, Web Booking Portal, or Birdseye Agent App.
  3. Use the Web Booking Portal: As a customer, we collect from you your identifiers (such as your first and last name, postal address, email address, and phone number). We use this information to book your service appointment, onsite or at-home test drive, or facilitate the delivery of your new Volvo vehicle.
  4. Request Your Web Tracking Link: As a customer, if you do not have access to the Volvo Valet App, we will send you a unique website link when you book a Service. To send you the link, we collect from you your identifiers (such as your email address or phone number). By providing your phone number, you will receive automated SMS text messages from Volvo Car USA and/or the relevant Retailer with respect to your Service. Message and data rates may apply. You may unsubscribe from texts at any time by typing ‘STOP’ and from emails by clicking the ‘Unsubscribe’ link.
  5. Provide Feedback After a Service is Completed: As either a customer or a driver, we collect from you your identifiers (such as your name), as well as any personal information you choose to include in your feedback. We use this information to review the actual services performed and determine if and what improvements should be made to our Services, the Volvo Valet App, Web Booking Portal, or the Birdseye Agent App.
  6. Request General Services: As a customer, we collect from you your identifiers (such as your name, pick-up address, drop-off address, license plate number, VIN, IP address, unique device identifier, push notification token, and vehicle make, model, and color) and commercial information (such as your pickup and delivery service history), as well as any additional personal information you choose to provide in your request. We use this personal information to provide you with the requested Service, identify you and your vehicle during the performance of the requested services, and to send you push notifications through the Volvo Valet App to inform you of the status of your requested service and the particular driver who will be performing the service.
  7. Request a Loaner Vehicle: As a customer, we collect from you a copy of your driver’s license and insurance card to provide you with the requested loaner vehicle.
  8. Request an Onsite or At-home Test Drive: As a customer, we collect from you your commercial information (such as the Volvo vehicle you’re interested in), as well as any inferences drawn from that selection (such as any related vehicles you may be interested in) to provide you with access, where applicable, to test drive that particular vehicle or a similar vehicle if the requested vehicle is unavailable.
  9. Request to Exchange a Leased Vehicle: For customers, we collect from you your commercial information (such as the Volvo vehicle you’re interested in) and any photos of the vehicle you are exchanging from you, as well as any inferences drawn from that selection (such as any related vehicles you may be interested in). We use this information to determine the suitability of your trade-in vehicle, and to make arrangements, where applicable, for the new leased vehicle or, if the specific requested vehicle is not available, provide you with alternative options based on the requested vehicle.
  10. Otherwise Contact Us Through the Volvo Valet App: As a customer, we collect from you your identifiers (such as your name and email address), as well as any other personal information you choose to include in our contact form. We use this information to communicate with you and provide you with technical assistance based on your submission.
  11. Respond to a General Service Request: As a driver, we collect from you your identifiers (name, unique device identifier, and push notification token) to send you push notifications through the Birdseye Mobile App about requests, as well as to send updates to customers about the status of their request and inform customers about the particular driver who will be performing the service.
  12. Perform a Requested Service: As a driver, if you enable this option, we automatically collect location information (such as your geolocation coordinates) from your mobile device. We use this information when we perform a requested Service at a Retailer (such as a request related to loaner vehicle booking or when performing vehicle pickup and delivery services) and to provide an estimated time for service to Volvo Valet customers. We stop collecting your location information as soon as your request has been completed. As a customer, you may enable/disable location service permissions in the settings of your mobile device but doing so may affect our ability to provide you with the requested Volvo Valet Service. We also collect from you any personal information you, as a driver, choose to include in any service notes as part of performing the requested service. We use this information to provide customers with the information related the customer’s service request. In addition, we collect photos of the vehicle during the performance of the service by drivers to protect our legal rights and those of our drivers.
  13. When You Visit Our Website: When you visit our website, we collect personal information from you automatically through cookies and similar technologies. Specifically, we collect your personal identifiers (such as your IP address), location information (such as may be determined from your IP address), internet activity information (such as usage information), and device information (such as hardware model, operating system, browser, and your Website preferences) to provide our website to you. For information on how we use cookies across our digital platforms, please see our Cookie Notice.

HOW WE SHARE YOUR PERSONAL INFORMATION

For information about how we share your information generally throughout our services, please see our Privacy Statement

We have shared your personal information for a business purpose:

  1. For customers, your identifiers, commercial information, driver’s license information (if provided), insurance information (if provided), vehicles you are interested in, inferences drawn from your commercial information and vehicles you are interested in, photos of your vehicle, and any personal information you choose to include in a service request or communication with drivers who perform requested Services, as well as with Retailers who employ the drivers and otherwise assist in fulfilling to Service requests.
  2. For customers, your identifiers and commercial information with our service providers who train Retailers and their drivers who use the Birdseye Mobile App to perform requested Services.
  3. For customers requesting a at-home test drive, your identifiers and commercial information with Retailers and service providers who facilitate the booking and delivery of your test drive vehicle to your home or preferred test drive location.
  4. For customers requesting an onsite test drive, your identifiers and commercial information with our Volvo Cars Studio Stores, Retailers, and service providers who facilitate the booking of your test drive at the Studio, your preferred Retailer, or if you choose to take a test drive at one of our Volvo vehicles events, roadshows, or showcases.
  5. For drivers, your identifiers with customers using the Volvo Valet App in the course of responding to customers’ requests for Volvo Valet Services.
  6. Identifiers and Internet and other electronic network activity with our service providers to support and maintain the security and functionality of the Volvo Valet App, Web Booking Portal and Birdseye Mobile App.

We may also share the personal information in the following circumstances:

  • As a result of a change in our corporate structure: in the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any part of our business, assets, or stock, we would share any personal information collected about you with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
  • To prevent harm: we will share personal information if we believe it is necessary to detect, investigate, prevent, or act against illegal activities, fraud, or situation(s) involving potential threats to the rights, property, or personal safety of any person.
  • For legal purposes: we will share personal information where we are legally required to do so such as in response to court orders, law enforcement, or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of service or other contracts; to defend against legal claims or demands; or to comply with the requirements of any applicable law.
  • With your consent: apart from the reasons identified above, we may ask for your permission to share your personal information for a specific purpose for which we do not already have your consent.

Sale of personal information within the preceding 12 months.

Identifiers and commercial information with your preferred authorized Volvo retailer and to contact you with marketing communications on Volvo products and services that may be of interest to you, based on our analysis of your information and the inferences we make from it (e.g. the type of vehicle in which you expressed interest or the state in which you live). This sharing may be deemed a sale under the California Consumer Privacy Act. To opt-out of the sharing of your personal information see Do Not Sell My Personal Information.

INFORMATION SECURITY

To help protect your personal information from loss, theft, and unauthorized access, use, or disclosure, we have implemented technical, administrative, and physical security measures including 256-bit encryption, access controls, and secure development processes. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure or impenetrable. We cannot ensure or warrant the security of any information you provide to us. Your personal information is stored on secure servers with restricted access.

YOUR RIGHTS UNDER CALIFORNIA LAW

Under California law, consumers residing in California are granted the right to access or delete the personal information that we have collected about them, to opt-out of the sale of their personal information by us to a third party, and not to be discriminated against for exercising these rights. To learn more about your rights with respect to your personal information and how to exercise those rights, please see our Privacy Statement.

MORE INFORMATION

For information about how we: share your information generally throughout our services, protect your information, process children’s information, address Do Not Track, make changes to our Privacy Statement and Services Privacy Policies, and can be contacted, please see our Privacy Statement.