Article version 2021.182.0

Privacy Notice – Care by Volvo subscription

Effective from:

Published at:

This document describes how your personal data is processed when you sign up to our car subscription service Care by Volvo.

You can find below:

  1. Who we are;
  2. What personal data we process and why;
  3. How long we keep your data;
  4. Who we share your personal data with;
  5. What are your rights in relation to the personal data processing we perform;
  6. Contact information;
  7. Changes to our Privacy Notice.

1. Who we are

When you sign up for a Care by Volvo subscription, the legal entity responsible for the processing of your personal data is Care by Volvo Car AB (company registration no 556746-9407) a company registered in Sweden, with address 405 31 Gothenburg, and a legal entity within the Volvo Car Group (hereinafter referred to as ‘we’, ‘our’ or ‘us’).

2. What personal data we process and why

As further described below, we will process the personal data that you provide to us through the online platform, or as we otherwise collect, when you sign up for a Care by Volvo subscripton.

1. When you sign up for a Care by Volvo subscription

When you sign up for a Care by Volvo subscription, we will process your:

  • your personal identity number
  • your first and last name
  • your address
  • your contact detals (email address and phone number).

The personal data is collected partly through your login with BankID, whereby we receive your personal identity number, your first and last name and your population registration address from SPAR (‘Swedish state personal address register’), and partly by asking you to provide other contact information.

This personal data is processed in order to (i) verify your identity when you sign up for a Care by Volvo subscription, (ii) perform a credit worthiness and affordability check (as further described below), and (iii) communicate with you about your subscription order or about other practical matters, such as the delivery of your car, before your Care by Volvo subscription has started.

The legal basis for processing your personal data in connection with us communicating with you according to point (iii) is to enable us to conclude your subscription order and/or meet our obligations under the agreement we have entered into with you.

If you do not conclude your subscription order by making the prepayment, we will retain your personal data for thirty (30) days in order for you to be able to complete your subscription order during that period.

Prepayment

If you choose to do a prepayment with a bank- or creditcard, your personal data will be collected and processed by Stripe Payments Europe, Ltd (‘Stripe’), a company registered in Ireland. Stripe is the controller of the personal data processed in connection with the bank- or credit cards payment and you can read Striepe’s privacy notice here.

If you choose to do a prepayment with Klarna by direct bank transfer, your personal data will be collected and processed by Klarna Bank AB publ (‘Klarna’), a company registered in Sweden. Klarna is the controller of the personal data processed in connection with a direct bank transfer via Klarna and you can read Klarna’s privacy notice here.

2. Performance of credit eligibility and know-your-customer checks

When you sign up for a Care by Volvo subscription, we will perform a creditworthiness and affordability check on you. Thus, we will process the follwoing types of personal data:

  • your personal identity number
  • your first and last name
  • your financial information.

The purpose of this processing is to assess your creditworthiness and ability to pay the monthly subscription fee that you have signed up to under the Care by Volvo subscription, and to perform a know-your-customer check to prevent fraud, money laundering and to perform a check against selected sanction lists. The legal basis for this processing is our legitimate interest in knowing who we are entering into agreements with and to ensure that you have the ability to pay the monthly subscription fee that you have signed up to. We also process the data specified above on an anonymous basis for statistics and analysis in order to optimise our risk assessment model.

In connection with carrying out a credit eligibility check, we will share your personal identity number and you first and last name with Creditsafe i Sverige AB (‘Creditsafe’) which will perform the credit worthiness and affordability check. Creditsafe is the controller for the personal data that the company processes in connection with performing the credit eligibility and you can read Creditsafe’s privacy notice here.

We will also share your personal identity number and your fist and last name with Schufa Holding AG, a company registered in Germany, (‘Schufa’) in order to perform a know-your-customer check and perform a check against selected sanctions lists. Schufa is the controller for the personal data that the company processes in connection with performing these checks and you can read Schufa’s privacy notice here.

If we do not approve your subscription order after having performed the worthiness and affordability check, or the other checks specified above, we will retain the specified personal data for three (3) months from the time at which we decided not to approve your subscription order in case you come back to us with questions.

3. When you become our customer

During the subscription period, i.e. once your Care by Volvo subscription has started (hereinafter ’the Subscription’), we will process the following personal data:

  • your personal identity number
  • your first and last name
  • your contact details (address, email address and phone number)
  • your Volvo ID
  • your Volvo customer number
  • the car’s Vehicle Identification Number (“VIN”) and registration number
  • your bank details, if you have provided them to us in connection with a repayment
  • financial information from the credit eligibility check.

The purpose of this processing is to be able to (i) administer the Subscription and the services included as a part of it; (ii) send monthly invoices and (if applicable) make repayments; (iii) deliver and manage the return of the car and provide the other services included in the Subscription; (iv) communicate about the service and maintenance of the car; (v) communicate about future services and/or updates of services during the Subscription and communicate other relevant information associated with the Subscription, and (vi) identify you as a returning Volvo customer in order to provide you with a better user experience. The legal basis for the above processing is to be able to meet the agreement we have entered into with you which is connected to your Subscription.

We also process the personal data specified above to be able to communicate with you about any recall of your car that may arise. The legal basis for such processing is to meet our legal obligation regarding the recall of cars.

We will also process data such as your age and gender for statistical and analytical purposes in order to understand market interest in Care by Volvo and its products and offerings and how they are used. The legal basis for this processing is our legitimate interest in improving our products, services and offerings.

We will share your personal data with the following parties, which will manage the personal data on our behalf as processors. These parties have an obligation under data processing agreements not to use your personal data for any purpose other than to provide services to us, and they are obliged to process the information confidentially and in a secure and proper manner:

  • Volvo Car Sverige AB (and its subcontractors) – financial services such as invoicing and refunds and other administrative support services.
  • Selected authorised Volvo retailer(s) (and its subcontractors) – delivery and return of cars and other services under the Subscription.
  • Bilvision AB (and its subcontractors) – vehicle registration services.
  • Arvato Finance AB (and its subcontractors) – debt collection services

Some of your personal data (such as personal identity number, first and last name, contact details and the car’s VIN and registration number) will be shared with the Swedish Transport Agency in order to register you as a driver of the car in the national road trafic register. The Swedish Transport Agency is the controller of the personal data in the national road trafic register and you can read its privacy notice here.

We also share some of your personal data (such as personal identity number, first and last name, contact details and the car’s VIN and registration number) with our insurance partner If Skadeförsäkring AB (Volvia) through which the car may be insured during the subscription period . If Skadeförsäkring AB is the controller of the personal data which is processed in connection with the insurance and you can read its privacy notice here.

If fines, fees or other costs for which you are responsible are addressed to us, then we may also share your personal data with the third party which issued them. The legal basis for such sharing is our legitimate interest.

4. If you sing up for a Care by Volvo subscription as a business customer

If you sign up to a Care by Volvo subscription on behalf of a legal entity, we will process:

  • your date of birth
  • your fist and last name
  • contact details (email address and phone number)
  • if necessary, a copy of a valid ID to check whether you’re a signatory of the company or in order to handover the car.

This personal data is collected from you when applying for a Care by Volvo subscription on behalf of the legal entity and will be processed in order to (i) verify you as an authorized person to sign on behalf of the legal entity, (ii) administer the Care by Volvo subscription application and to administer the Care by Volvo subscription during the subscription period, (iii) send monthly invoices and (if applicable) make repayments, (iv) communicate regarding delivery of the car and to administrate the handover of the car and to provide other services included in the Care by Volvo subscription, (v) communicate about service and maintenance of the car, and (vi) communicate about upcoming services and/or updates on the services under the Care by Volvo subscription and communicate other relevant information connected to the subscription. The legal basis for this processing is to conclude and fulfill the Care by Volvo subscription contract with the legal entity.

We will also process the aforementioned data to be able to communicate with you regarding potential car recalls. The legal basis for such processing is to comply with our legal obligation.

We will share your personal data with the following parties, which will manage the personal data on our behalf as processors. These parties have an obligation under data processing agreements not to use your personal data for any purpose other than to provide services to us, and they are obliged to process the information confidentially and in a secure and proper manner:

  • Volvo Car Sverige AB (and its subcontractors) – financial services such as invoicing and refunds
  • Selected authorised Volvo retailer(s) (and their subcontractors) – delivery and return of cars and other services under the Care by Volvo subscription.

5. Collecting data from cars

We collect the following categories of data from the car you drive during the Subscription (and under the Care by Volvo subscription, if you are a business customer). Since the data is inked to the car’s VIN it can be associated with you:

  1. Service status for various car parts, in order to assess the car’s status and, if necessary, carry out maintenance. We use this data to plan the service and maintenance and also predictive maintenance of the car, and to reduce the number of workshop visits and make them as efficient as possible during the subscription period. We also save the car’s maintenance history to be able to better plan future maintenance. The legal basis for the processing specified above is to be able to provide the service and maintenance and predictive maintenance services that are included in your Subscription contract. Volvo Car Corporation also processes the data specified above for statistics, research and development (this processing is anonymised and it cannot be linked to you).
  2. Mileage, in order to contact you and offer an amendment to the agreed mileage during your Subscription. This means that you can avoid paying an additional charge for exceeding your mileage limit at the end of the Subscription. The legal basis for the processing specified above is our legitimate interest in monitoring compliance with the agreement.
  3. Position data, in order to be able to locate the car in the event of:
    1. a crime; in order to comply with our statutory obligation, at the request of a law enforcement authority, we will share the position data of the car with that authority;
    2. an accident; we will share position data (if required) with vehicle recovery firms to meet our contractual obligations under the Subscription to provide roadside assistance; in the event of a serious accident, we will also share position data with emergency services in order to save your life or protect your health, or that of another person, or;
    3. to be able to safeguard our rights and recover the car (which we own) if you breach our agreement to a material extent, the legal basis in such case is our legitimate interest to recover our asset. In such cases, we will share the position data from the car with Arvato Finance AB (and their subcontractors), which will process the data in order to recover the car on our behalf. Arvato Finance AB has an obligation under a data processing agreement not to use personal data it receives for any purpose other than to provide services to us, and the company is obliged to process the information with confidentially and in a secure and proper manner.

3. How long we keep your data

We will retain the personal data mentioned above, which we process under the Subscription, up to twelve (12) months after your termination of the Subscription, unless we have a legal obligation to retain the for a longer period of time.

We process your personal data for statistics and for research and development for twelve (12) months after the date on which we collected them. After this date, the personal data are pseudonymised and stored for up to ten (10) years.

4. Who we share your personal data with

In addition to the processor named in point two above, we will share your personal data with the following processors:

  • Volvo Car Corporation (and their subcontractors) – provision of the Customer Care team and services related to planning service and maintenance of the car, operation of the website and provision of IT systems for business support and data storage.
  • IT suppliers (and their subcontractors) who supply general business support systems to us, e.g. software and data storage providers such as:
    • Salesforce UK Limited (and their subcontractors) – CRM systems and data storage.
    • Adobe Systems Software Ireland Limited (and their subcontractors) – digital signatures and data storage.
    • SAP Svenska AB (and their subcontractors) – ERP business system and data storage.
    • Fair Isaac Services Limited (and their subcontractors) – data storage.
  • Our advisors, to be able to provide advice and to represent us in the event of any disputes or court proceedings.
  • We may also disclose your personal data to meet a statutory obligation, e.g. on the request of an authority.

We enter into data processing agreements with all our processors who are limited by contract in their ability to use your personal data for any purpose other than to provide services for us. Each processor has an obligation to keep the information confidential and only process the personal data in compliance with the data processing agreement in place.

Your personal data may be transferred to a country outside of EU/EEA. If so, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission. The general text used in the standard contractual clauses can be found in a number of different languages on the European Commission's website.

Please contact us (in accordance with Section 6 below), should you have any questions about transfers of personal data to countries outside of the EU/EEA.

5. What are 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. You can withdraw your consent or object to our processing of your data, access the data we hold about you, ask for rectification or restriction of your data, request to have your data ported to another entity, request that we delete your data, and finally you can file a complaint with a data protection supervisory authority.

In Volvo Cars - Customer Privacy Policy you can read more about your data protection rights.

6. Contact information

In order to exercise your rights (in accordance with Section 5 above), please use the web form available here. If you have any other questions regarding the subject matter of personal data protection, please contact us (details below):

Care by Volvo Car AB

Postal address: c/o Volvo Car Corporation, VAK HB2N, 405 31 Göteborg

E-mail address:

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 read this privacy notice and our Volvo Cars - Customer Privacy Policy thoroughly and to refer to them on an ongoing basis. This privacy notice is valid from the date which appears at the bottom of the document. We will process your personal data in a manner consistent with the privacy notice applicable at the time we collected the personal data, unless we have your consent to treat it differently.