Privacy Notice – Digital Retail Service
This Privacy Notice describes the privacy practices of Volvo Car Canada LLC (referred to as “Volvo Car Canada,” “we,” “our,” or “us”) with respect to processing related to our Digital Retail Service, which allows you to obtain an estimate of the trade-in value of your vehicle, build a vehicle model, make a deposit for a vehicle, and apply for credit (the "Digital Retail Service"). In this context, "personal information" is defined as any factual or subjective information, recorded or not, about an identifiable individual.
You can find the following information below:
- How we obtain your meaningful consent;
- What personal information we collect;
- How we share your personal information;
- How we address the security, storage, and retention of personal information;
- How we address international transfers of personal information;
- Your privacy rights and choices;
- Links to external websites;
- How we make changes to our Privacy Notice; and
- How you can contact us.
YOUR MEANINGFUL CONSENT
We provide this disclosure in order to provide you with the information you need to make an informed decision before giving us your personal information. Subject to legal and contractual restrictions, your consent is voluntary and can always be withdrawn. Such withdrawal will not operate retroactively and may affect your continued ability to use the services. We will inform you of the consequences of withdrawal at the time you make your request.
We collect your personal information through web forms that you submit at different points throughout the Digital Retail Service, such as when you ask to 'Save for Later' a model or deal you have built, request a valuation of your trade-in vehicle, book an appointment, submit information for the credit application process, and other forms available on the Digital Retail Service. By using our Digital Retail Service, you give Volvo Car Canada, our affiliates, and authorized retail partners your meaningful consent to process your personal information for the purposes for which you provide it, and as described in this Privacy Notice.
INFORMATION WE COLLECT AND WHY
The Digital Retail Service gives our customers the ability to complete some of the steps required or often taken to commence the purchase a Volvo car in an online, digital format. When you use our Digital Retail Service, we will collect personal information from you and use your information for the legitimate business purposes described in this Privacy Notice.
- Submit a Conditional "Trade-In" Offer: When you submit a conditional “trade-in” offer, we collect from you your vehicle information (Vehicle Identification Number [VIN]), personal identifiers (phone number), location (either automatically based on your IP address, if this is enabled in your browsers, or directly from you when you enter a location), financial information (ownership status, lease and finance information related to your conditional trade-in vehicle, such as lease buyout amount, number of remaining payments, and amount of each remaining payment) and Commercial Information (the year, make, model, trim, mileage, vehicle history, vehicle condition and mechanical issues, if your vehicle has been in an accident or damaged, and if so, the damage amount and insurance payout, if your vehicle has been modified, if anyone smokes in your vehicle, and, at your option, interior and/or exterior photographs of your conditional trade-in vehicle) and the value of the vehicle, as determined by you. We use this information to allow the retailer to contact you in order to give you an appraisal value for your trade-in vehicle. If you choose to upload photographs of your vehicle to improve the accuracy of your trade-in vehicle's appraisal value, we will send you an SMS text with a file upload link to your mobile phone.
- Apply for a Credit Application: We collect your identifiers (title, first and last name, phone number, e-mail address, date of birth, Social Insurance Number [SIN] (optional), gender, marital status, residential history), employment information (employment history, including your employment status, length of your employment, and current employer and business address, occupation, work phone number), and financial information (current income information, including your gross employment income, income frequency, and other sources of income, information relating to your residence, including its address, your monthly payments, ownership status, and how long you have lived there). We use this information to submit your credit application to our financial institution partner for review and, if your credit application is approved, process your lease or finance option for your vehicle. If you add a co-applicant to your credit application, you must obtain consent from the co-applicant prior to providing their personal information to us. If you have opted into our marketing communications, we also use this information to help deliver more relevant product information and marketing materials to you.
- Make a Deposit Using our Online Checkout: When you make a deposit using our online checkout, we collect your identifiers (first and last name, mailing address, city, province, postal code, and phone number) and your financial information (credit card number and expiration date). We use this information to reserve your vehicle for a limited time (for 7 days at the vehicle's price), to collect your deposit towards the purchase of your vehicle on behalf of your preferred authorized Volvo retailer, to facilitate the processing of your payment with our third-party payment processors, and for logistical planning with respect to delivery of the vehicle.
- Visit the website: When you visit our website to do any of the actions explained above, 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.
HOW WE SHARE YOUR PERSONAL INFORMATION
We have shared your personal information for with our service providers and business partners in order to deliver the services to you, as follows:
- Identifiers, financial information and Commercial Information with our service providers which assist in our provision of services to you. Examples include our financial institution partner and providers that integrate our systems with those of authorized Volvo retailers.
- Identifiers and Commercial Information with your authorized Volvo retailer to process the purchase or lease of your vehicle and, if you will trade-in your current vehicle, allow the retailer to give you an estimated appraisal value and update your new vehicle's payment information.
- Identifiers and Financial Information with your financial institution, authorized Volvo retailer, and adjudicating partners to process your credit application and give you credit adjudicating for the lease or finance of your vehicle from the retailer.
- Identifiers and Financial Information with our credit card processor (Stripe) to process your deposit and, on your behalf, submit your deposit to your authorized Volvo retailer.
We may also share the personal information collected from the Digital Retail Service 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, in accordance with the requirements of applicable law. 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.
INFORMATION SECURITY, STORAGE, AND RETENTION
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. In addition, your personal information is stored on secured servers with restricted access. 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.
Volvo Car Canada retains information related to your credit application for a maximum of 14 days. We otherwise retain your information for the length of time needed to fulfill the purposes outlined in this Service Privacy Notice, unless a longer retention period is required or permitted by provincial law.
INTERNATIONAL DATA TRANSFERS
Our primary server is located in Montreal, Quebec. Personal information that we collect may be stored and processed in Canada or any other country in which we or our service providers maintain facilities, including in the United States and Sweden. Personal information processed and stored in another country may be subject to disclosure or access requests by the governments, courts, or law enforcement or regulatory agencies in that country according to its laws. By giving us your meaningful consent to collect your personal information, you agree to the transfer and storage of your information on our and our service providers' servers. Personal information may be accessed by persons within our organization or our third-party service providers who require such access to carry out the purposes described in this Privacy Notice, or as otherwise permitted or required by applicable law.
PRIVACY RIGHTS AND CHOICES
Accessing and correcting your personal information:
You have a right to request access to your personal information and to request a correction to it if you believe it is inaccurate. If you would like to have access to the personal information we have about you, or if you would like to have it corrected, please contact us using the contact information below. In some cases, we may not be able to allow you to access certain personal information in certain circumstances: for example, if it contains personal information of other persons, or for legal reasons. To help protect against fraudulent requests for access to your personal information, before granting access we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information. You will need to provide us with sufficient information that allows us to reasonably verify that you are the person whose personal information we collected, and you must describe your request in sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and correction requests using the information provided, we may ask you for additional pieces of information.
Right to withdraw consent:
Subject to legal and contractual restrictions, if you have given consent for the processing of your personal information, you may withdraw your consent; however, such withdrawal will not operate retroactively. Please note that if you withdraw consent that is necessary for us to provide you with products or services, we may no longer be able to provide those products or services to you. We will inform you of the consequences of the withdrawal of your consent at the time you make your request. You may withdraw any consent you have provided to our use of personal information to market to you (i.e. secondary marketing use) without withdrawing consent needed to provide our goods and services.
We have designated a Privacy Officer responsible for data privacy compliance and adherence to the fair information principles. At your request, our Privacy Officer can provide you with further information regarding our processing and protection of your personal information (see "Contact Information" below).
This website may contain links to other sites that Volvo Car Canada does not own or control and is not responsible for. Please be aware that Volvo Car Canada is not responsible for the privacy practices of such other sites. You should read the privacy statements of every website that you visit. This Privacy Notice applies solely to information collected through the Digital Retail Services.
HOW WE MAKE CHANGES TO OUR PRIVACY NOTICE
Volvo Car Canada may change this policy from time to time by updating this page. You should periodically check this page to ensure that you are happy with and agree to any changes. If the changes allow us to use personal information in ways that materially affect your rights, we will post a special note on our digital platforms and, if required by law, will prompt you for your consent for certain changes. Your continued access to and/or use of our services after any such changes constitutes your acceptance of and agreement to this Privacy Notice, as revised.
This Privacy Notice is current as of the date which appears at the top of the document.
Mailing address: Volvo Car Canada Limited,
9130 Leslie Street, Suite 101,
Richmond Hill, Ontario, Canada
Attention: Privacy Officer
You can also approach local data protection authorities.