Privacy Notice – Consumer surveys
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
The entity responsible for the processing of personal data in relation to the Consumer Surveys is Volvo Car Brasil Importação e Comércio de Veículos Ltda, having its registered office at Surubim Street, 577, Sets 101, 102 e 103, São Paulo, Brazil hereinafter referred to as “Volvo Cars”, “we”, or “us”.
In the terms established in the Brazilian General Data Protection Law (Law No. 13,709/2018) and its amendments (“LGPD”), we act as the controller of your personal data.
Throughout this Privacy Notice, we will use terms such as "personal data", “data”, "processor", “controller”, “Brazilian National Authority”, "processing", “international transfer of data”. All such terms, including its variations, are used by us in accordance with the definitions provided in the LGPD.
2. Data Processing Principles
Processing your personal data is an important part of our provision of products and services to you. We appreciate the trust you place in us by providing your personal data and consider your privacy an essential part of the services we offer.
To protect your personal data, while increasing customer value, we are guided at all times by the ten (10) principles set forth in the LGPD. They are: purpose, adequacy, necessity, free access, data quality, transparency, security, non-discrimination, responsibility and accountability, and prevention.
3. What personal data we collect and why
In order to send you a Consumer Survey and provide any subsequent service/clarification relating to said survey, we will process the following categories of data about you:
- Identifiers such as name, e-mail address, telephone number, salutation, age, gender, postal code, and city.
- Vehicle data such as vehicle type, Vehicle Identification Number, and registration number.
- Contract type, subscription number, vehicle relationship (contract/sales type starting and end date), and any other information provided directly by you in the context of your communication with us. We process this data in order to send the Consumer Survey, provide any subsequent service/clarification relating to said 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 Volvo Cars’ legitimate interest and is stored within Volvo Cars (as detailed below in Section 5). You can opt-out from receiving the survey at any time, either by using the web form indicated under “Your rights” below or by replying Volvo Car’s message with the standard opt-out keyword indicated in each message or by clicking directly on the unsubscribe link in the survey send-out.
- 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. The data is processed based on Volvo Car’s legitimate interest to improve the overall business operations and the consumer experience.
4. 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 platform 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 and Volvo Cars’ trusted processors (as detailed below in Section 5) have access to the personal information you provide us. They have access only for case handling, data analysis and quality control purposes.
5. 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:
- Provision of Consumer Surveys.
- WhatsApp text Communication.
- Care Operations.
- Parties involved in Corporate operations, such as a result of eventual corporate restructuring, mergers, acquisitions, incorporations and similar;
- Your selected retailer (if applicable) and companies within the same group of companies as Volvo Cars; and
- Authorities and other legal or administrative agents.
We may disclose or share your personal information if we believe, in good faith, that the access, use, preservation or disclosure of the information is reasonably necessary to (i) comply with any law, regulation, court order or governmental request; (ii) investigate possible violations of rights; (iii) detect or prevent fraud as well as resolve technical or security issues; (iv) ensure our, yours or any third parties safety; (v) protect rights and prevent liabilities of Volvo Cars; (vi) investigate, prevent or take measures related to illegal, suspected or actual activities, or to cooperate with public agencies, and; (vii) comply with legal obligations or any other determination before government and judicial bodies.
Personal data will be disclosed by Volvo Cars on a strict need-to-know basis, and all data processors will be required to ensure, at least, the same level of protection to said data as performed by Volvo Cars when processing your data directly (see Section 6, below), this includes the obligation not to process your personal data for any purpose other than the purpose contracted by Volvo Cars, in addition to confidentiality and security standards obligations, among others.
Please remember that certain processors, or companies within the same group of companies as Volvo Car Brazil, may be located in or have facilities that are located outside of the Brazilian territory. We will only transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission as long as there are no specific directives from the Brazilian National Authority contradicting said international data transfer mechanism.
6. Your rights in relation to the data processing we perform
You have specific legal rights granted by the LGPD relating to the personal data we process about you. They include:
- Access to the personal data Volvo Cars process and maintains about you, which will be provided in readable electronic format, in accordance with the provisions of the LGPD.
- Confirmation of the existence of data processing carried out by Volvo Cars.
- Correction of incomplete, inaccurate, or outdated personal data processed by Volvo Cars.
- Elimination of personal data processed based on your consent.
- Right to oppose to the processing of personal data carried out in non-compliance with the provisions of the LGPD.
- Anonymization, blocking or elimination of unnecessary or excessive personal data or of personal data being processed in non-compliance with the LGPD.
- Portability of the personal data to other service providers or suppliers, as set forth by the LGPD.
- Withdrawal of consent given to the processing of your personal data, by means of a free and facilitated procedure.
- Information on the possibility of not providing consent for the processing of your personal data and the consequences of the denial.
- Information about the shared use of your personal data.
Exceptions: We may not be able to immediately comply with your request if the processing of your personal data is necessary and legitimate under a specific legal basis, including: (i) for exercising the right of freedom of expression and information; (ii) for compliance with a legal obligation or order from a competent authority; (iii) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; (iv) for the establishment, exercise or defense of legal claims.
You have the right to lodge a complaint to the Brazilian Data Protection Authority. However, we will appreciate if you first contact us to try and solve your problem.
If you wish to exercise any of the rights listed in this Section or if you have doubts regarding the above, please refer to Section 8, below.
7. Contact information
Volvo Car Brasil Importação e Comércio de Veículos Ltda
Postal address: Surubim Street, 577, Sets 101, 102 e 103, São Paulo, Brazil
E-mail address: firstname.lastname@example.org
Phone number: 0800 70 775 90
8. Data Security
Volvo Cars strives to implement appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access or any other unlawful forms of processing. Our goal is to ensure that the level of security and measures taken to protect your personal data are appropriate to the risks presented by the nature and use of your personal data.
9. 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.