Privacy Notice– Consumer Surveys
This document describes how Volvo Cars (as defined below) processes your personal information when you engage with one of our consumer surveys (hereinafter “Consumer Survey”).
You can find below:
- Who we are
- What personal information we collect and why
- How we protect your personal information
- How long we keep your data
- How we share your personal information
- Your rights in relation to the personal information we collect
- Contact Information
- Changes to our Privacy Notice
1. Who we are
For the purposes of GDPR, Volvo Car Corporation (”VCC”), having its registered office at Assar Gabrielssons Väg, 40531 Gothenburg, Sweden, company registration number 556074-3089, and Volvo Car Canada Limited, having its registered office at 9130 Leslie St. Suite 101, Richmond Hill, Ontario Canda (“Volvo Canada”), are joint controllers. For the purposes of Canadian law and as pertaining to information of Canadian residents, Volvo Canada facilitates the Consumer Survey and and collects the information on behalf of VCC as part of the global survey and uses the information for its own purposes for the improvement of its services. VCC and Volvo Canada are hereinafter referred to as “Volvo Cars”, “we”, or “us”.
2. What personal information we collect and why
A. Information Collected From You
Volvo Cars collects certain personal information from you when you participate in a Consumer Survey. “Personal Information” is information about an identifiable individual. Specifically, Volvo Cars collects the following personal information for the corresponding purposes described below:
- To Administer the Consumer Survey: We collect from you your identifiers (name, e-mail address, telephone number). To the extent GDPR applies and in Canada, the data is processed based on your consent (Art. 6(1)(a) GDPR and Art. 13(1) of the ePrivacy Directive (2002/58/EC)) and is stored within Volvo Cars.
- Survey Responses We collect the responses you provide to the questions we ask in the Consumer Survey. These may vary from survey to survey. Whether you respond to a particular survey is your choice.
- To classify the answers: We collect additional identifiers (salutation, age, gender, postal code, and city); commercial information (contract type, subscription number, vehicle relationship (contract/sales type starting and end date)) and Vehicle information (vehicle type, Vehicle Identification Number (VIN), and registration number (REG)). We use this information to conduct segmentation analysis of the substantive answers in the Consumer Survey based on age, gender, location, city of residence, vehicle type; relationship type etc in order to: inform and improve our customer service practices; inform and improve our products; determine and adapt supply to various markets and to analyze the performance of our warranty. To the extent GDPR applies, we process this information based on your consent (Art. 6(1)(a) GDPR and Art. 13(1) of the ePrivacy Directive (2002/58/EC)). Volvo Canada facilitates the conduct of the survey on behalf of VCC and conveys the information to VCC to be used as part of a global survey for improvement of the product, customer services, supply, and warranty. Volvo Canada uses the information collected in Canada and uses the information for its own purposes in the improvement of customer services, supply, and warranty in a manner which does not include building or modifying household or consumer profiles.
You can opt-out of receiving survey messages at any time by clicking on the “unsubscribe” link in the survey correspondence to you. You may also choose not to respond to a particular survey without opting out of future ones. This will not affect our ability to use information you had already provided in survey responses before you unsubscribed. Please note that Volvo Cars will continue to send you emails necessary to the Services, your account, your purchase, or any assistance you request.
B. Information Collected Automatically
When you fill out the survey, we automatically collect identifiers (IP address) and internet or other electronic network activity information (device time, browser type, operating system). We use this information for functional purposes to project the Consumer Survey in the correct format.
In addition to the personal information you provide, when you interact with the email invitation for the Consumer Survey we automatically collect information via web beacons or tracking pixels that tells us whether you have opened the Consumer Survey. We collect this data for statistical analysis and to understand the interests of our consumers. You can prevent this tracking by adjusting your emails settings to prevent the download of pictures.
3. How we protect your personal information
In order to help keep your responses secure, the invitation for feedback provides you with an individualised questionnaire that no other person can access. The survey web site and our data storage facilities have security measures in place to help protect the loss, misuse, and alteration of the information under our control. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure or impenetrable.
Only certain employees have access to the personal information you provide us. They have access only for case handling, data analysis and quality control purposes.
4. How long we keep your personal information
Your survey feedback responses will be kept up to seven (7) years after you are no longer registered as an owner or driver of a Volvo Cars vehicle. Your personal information is anonymized after six (6) months or, if your answers creates a case or initiates a communication between you and Volvo Cars Customer Care or its Business Partners, twelve (12) months after the resolution of the issue.
5. How we share your personal information
In connection with the Consumer Survey, we have shared your:
- Personal identifiers, internet and other electronic activity information, commercial information and vehicle information with our service providers to support delivery of the Consumer Survey and Care Operations, including our data hosting provider, communications provider, and IT support.
- Personal identifiers and internet and other electronic network activity information with our IT support to identify and repair errors, and to maintain and improve the Consumer Survey;
- We share with VCC (on behalf of whom we collect it) the customer feedback results to be used for inform and improve our and their customer service practices; inform and improve our products; determine and adapt supply to various markets and to analyze the performance of our warranty.
If your responses to the survey lead us to believe that there are issues to follow up and improve, you personal information will also be disclosed to your selected retailer , to conduct such follow up with you.
6. Your rights in relation to the information we collect
6.1 Your rights under GDPR
6.2 Your rights under Canadian Law
If our processing of your personal data is subject to Canadian law, you the following section applies to you:
- Accessing and correcting your personal data: For residents of Canada, you have a right to request access to your personal data and to request a correction to it if you believe it is inaccurate. If you would like to have access to the personal data we have about you, or if you would like to have it corrected, please fill out this form (first, choose your country or region, then open and fill out the online form), which will help us to deal with your request properly. In some cases, we may not be able to allow you to access certain personal data in certain circumstances, for example if it contains personal data of other persons, or for legal reasons. To help protect against fraudulent requests for access to your personal data, 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 before granting access. You will need to provide us with sufficient information that allows us to reasonably verify that you are the person whose personal data we collected and 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 with the information provided, we may ask you for additional pieces of information.
- Right to withdraw consent: Where you have given consent for the processing of your personal data, you may withdraw your consent with effect for the future. Please note that if you withdraw consent that in necessary for us to provide you with products or services, we may no longer be able to provide those products or services to you. You may withdraw any consent you have provided to our use of personal data to market to you without withdrawing consent needed to provide our goods and services. Your withdrawal of consent does not have retroactive effect, and there may be cases where we are permitted under the applicable law to process certain personal data without consent.
- Security: In order to help prevent unauthorised access or disclosure of personal data, we have put in place physical, electronic and organizational procedures to help safeguard and secure the personal data we collect. Personal data 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 otherwise permitted or required by applicable law. Personal data we collect is managed from our offices in Canada and European Union. Even though we have taken steps to help protect the personal data in our control, you should know that we cannot fully eliminate security risks associated with personal data. No security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.
- International Data Transfers: Personal data that we collect may be stored and processed in Canada and the European Union. Personal data 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 providing us with personal data, you consent to any such transfer of information outside of your country.
7. Contact information
To exercise your individual rights under GDPR, see Section 6.1 above and under Canadian law see Section 6.2 above. To contact us with any questions about this notice:
Volvo Car Canada Limited
9130 Leslie St. Suite 101
Richmond Hill, Ontario Canda
8. 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 information in a manner consistent with the privacy notice under which they were collected, unless we have your consent to treat them differently.