Article version 2021.60.0

Privacy Notice – Public traffic environment data

Effective from:

Published at:

This document describes how Volvo Cars and Zenseact (as defined below) processes 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 below:

1. Who we are

The entities jointly responsible for the processing of personal data in relation to the scope of the notice are:

  • Volvo Car Corporation, having its registered office at 405 31 Göteborg, company registration number 556074-3089, hereinafter referred to as “Volvo Cars”, and
  • Zenseact AB, having its registered office at Lindholmspiren 2, 417 56 Göteborg, company registration number 559228-9358, hereinafter referred to as “Zenseact”.

Unless its specified, hereinafter this joint responsibility referred to as “we”, or “us”. Under the Joint Controllership Volvo Cars have the responsibility regarding transparency duties as well as fulfilling the data subject’s rights.

2. What personal data we collect and why

The processing of the Public Traffic Environment Data, which involves the processing of personal data, is necessary for us with 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:

  1. Sensor Data such as camera, lidar (light detection and ranging), radar and ultra-sonic sensors which can detect persons and objects moving around in the public traffic environment where the collection takes place. The data is used for evaluating sensors, the output from software interpreting the sensor data, and the software used in ADAS and AD systems. The cameras will record pedestrians, cyclists, people in or on vehicles, vehicles having license plates that is in the vicinity of the vehicle. We need to collect data on real-world traffic environment and real-world traffic situations in order to be able to accomplish our purposes. Thus, this data must be authentic and cannot be modified by blurring for example. We are not interested in and does not in any way attempt to identify the individuals present in the Public Traffic Environment Data. Nor do we extract any other personal data from the collected data.
  2. GPS Geolocation data from the vehicle will be collected and stored in order to be able develop our functionalities and also to find relevant recorded data based on location.
  3. Annotations Information will be amended to the data to be able to find relevant recorded data, such as annotations of sensitive places. These annotations can be made by the driver or when the data is processed afterwards.

The personal data included in the Public Traffic Environment Data above, will be processed based on our legitimate interests (Article 6.1.f) for the purposes mentioned above.

We limit our locations of interest to exclude hospitals’ entrances, accident location with injured individuals, beaches or public parks, private area such as interior of the 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 other purposes, than the purposes explicitly described in this privacy notice. We also have taken measures to limit the access to the Public Traffic Environment Data as well as implementing relevant security and privacy measures such as removal of non-relevant material.

3. How long we keep your data

Public Traffic Environment Data will not be processed longer than maximum of 10 years for being able to reuse the data for test of new versions of 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 corrupt due to technical errors is also 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.

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:

  • We will share the data with our suppliers that provides the IT-infrastructure for the means to provide us with storage and data handling.
  • We will share the data with the suppliers providing the sensors or technology used in order to facilitate finding and correcting errors in the technology they provide.
  • We will share the data with our intragroup entities in order to support the development of similar functionalities on their vehicle platforms.

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 set of data with other parties that have been properly anonymized prior to sharing. Such data can’t be attributed to a natural person and is no longer personal data.

We might share anonymised or non-attributed to a natural person data 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. Your rights in relation to the data processing we perform

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 excercise your subject rights please use our form available here and clearly state 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, free of charge, upon written request, receive information about what personal data we store about you and how your personal data is used and processed.

You are entitled to request in writing, 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 case, your personal data shall, with the exception of storage and processes needed for that, only be processed with your consent or for the establishment, exercise or defence 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 find the contact details of the relevant supervisory authority, Integritetsskyddsmyndigheten (IMY), below.

6. Contact information

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

Integritetsskyddsmyndigheten (IMY)

Box 8114

104 20 Stockholm

Phone: +46 (0)8-657 61 00


You can find contact information and other information regarding Zenseact’s processing of personal data in their Privacy Policy,

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.