Volvo Cars App Privacy Notice

Effective from: 2024-04-24

Published at: 2024-04-24

This privacy notice explains how your personal data is processed by Volvo Cars (hereinafter defined) and, at times, other organizations when you use the Volvo Cars mobile application (hereinafter referred to as the "Volvo Cars App") in accordance with the Turkish Data Protection Law No. 6698 (hereinafter referred to as the "Law") and informs you about your rights.

In accordance with Article 10 titled "Obligation to Inform Data Controller" and Article 11 titled "Rights of the Data Subject" regulated in the Law, this Privacy Notice ("Privacy Notice") is provided to inform and enlighten you regarding the purposes for which your personal data will be processed, to whom and for what purposes your processed personal data may be transferred, the method and legal reason for collecting your personal data, and your other rights specified in Article 11 of the Turkish Data Protection Law. For more detailed information about the processing of your personal data, we recommend visiting our Customer Privacy Policy and Customer Information Notice available at https://www.volvocars.com/tr/. This privacy notice only concerns data processed in the context of membership in the Volvo Car App mobile application.

The Volvo Cars App has various functions that enable you to stay connected to your Volvo branded vehicle, and these functions have different types of personal data processing requirements as explained below. Depending on the country market you belong to and the type of subscription you have, these functions can be summarized as follows:

Volvo Cars Services - This includes the aspects described in sections 2.1 (When you use the Volvo Cars App), 2.2 (Your Subscription), 2.3 (Volvo Cars Remote Vehicle Services), 2.4 (Driving Journal), 2.5 (Public Charging), 2.6 (When You Contact Us), 2.7 (Marketing Communications and Surveys), 2.8 (App Analytics), and 2.9 (Research and Development).

The services mentioned in this privacy notice may change over time as the application is developed to meet your needs, and the services listed above set out the minimum service conditions and data processing purposes that Volvo will provide during the membership process. You can view our current services through the Volvo Car App.

Topics covered in this notice:

1. Who is Responsible for Processing Your Personal Data as the "Data Controller"?

The responsibility for the processing of your personal data in the Volvo Cars App is divided as follows:

The primary organization responsible for the main processing of your personal data related to your subscription, Volvo Cars remote vehicle services, Driving Journal, Digital Key, Public Charging, App Analytics, and Research and Development is Volvo Car Corporation, registered at "Assar Gabrielssons Väg, SE-405 31, Gothenburg, Sweden" with company registration number 556074-3089, hereinafter referred to as "Volvo Cars".
When it comes to processing your personal data related to communication with us and marketing communication, the joint controllers are:
Volvo Car Corporation and
Volvo Car Turkey Otomobil Limited Şirketi, registered under the Istanbul Chamber of Commerce with registration number 422515 and Mersis number 0925011785500014, with its registered office at "Fatih Sultan Mehmet Mahallesi Poligon Caddesi Buyaka 2 Sit. 2. Kule No:8 B/14 K:4 34771 Tepeüstü Ümraniye-İstanbul."
The services reserved through the Volvo Cars App, such as digital service reservations and Pick-up & Delivery Service, are jointly controlled by Volvo Cars, Volvo Car Turkey Otomobil Limited Şirketi, and the authorized Volvo retailer you request the service from, hereinafter referred to as "Volvo Authorized Retailer" or "Authorized Retailer."

2. Collected Personal Data, Data Collection Method, Legal Basis, and How Long Personal Data Will Be Retained

As mentioned earlier, the Volvo Cars App has different functions depending on your vehicle model and market, and these functions have different requirements for processing users' personal data. Your personal data is obtained electronically during the membership process through the Volvo Car App mobile application. Below, we explain the different functions of the Volvo Cars App and the personal data processed within these functions, along with their legal basis, purpose, and retention periods:

2.1 When you use the Volvo Cars App

When you use the Volvo Cars App, we automatically collect data about your use of the Volvo Cars App in order to monitor its functioning and undertake troubleshooting measures when necessary. In order to do this, we use information such as device information (e.g., device manufacturer, app installation ID), general vehicle information (e.g., vehicle model and type, year, user country) and usage data (e.g., clicks, views and potential issues or errors). This processing is necessary for our legitimate interest to provide you with a secure and functioning Volvo Cars App. The information used for this purpose is retained for 30 days from collection.

2.2 Your Subscription

If you have a subscription for Volvo Cars remote vehicle services or other Volvo-related services, you can renew this service through the Volvo Cars App. When you sign up for an existing subscription or extend it, we process your identity information (name, surname, phone number, email address, VIN), purchase status, and history to manage your purchase (from purchase to delivery), handle requests related to the services you purchased, track delivery, and provide updates regarding the services you purchased, including necessary official reporting. We use a third-party payment provider to process your payments, and this involves separate processing of your personal data. More information about the privacy practices of the payment processing provider can be found in section 3. After your subscription ends, we will retain your personal data, including details associated with this service, for ninety (90) days so that you can continue the service if you choose to resubscribe or need access to invoices or receipts. Additionally, we will archive data related to your purchase for ten (10) years to comply with accounting and financial reporting regulations, which is a legal obligation.

2.3 Volvo Cars Remote Vehicle Services

To provide Volvo Cars remote vehicle services, we collect identity information such as your name, surname, phone number, Volvo ID (email address), vehicle identification number - "VIN," unique device identifiers, and notification tokens, as well as purchase history. We use this information to offer remote vehicle services, including the ability to remotely control your vehicle (e.g., pre-conditioning, locking/unlocking doors, remote starting/stopping the engine, receiving theft alarm notifications), view your vehicle's status (e.g., fuel levels, windshield washer fluid levels, brake fluid levels, door lock status, tire pressures, maintenance alerts, battery status, or other vehicle condition indicators). We also use this information to send notifications within the Volvo Cars App, including upcoming service reminders and service notifications. For electric and hybrid vehicles, we record the location of the charging point for scheduling charging times. We also use your location information to allow you to use map functions within the Volvo Cars App and display the location of your Volvo on the map if you grant permission. When a specific data processing operation does not specifically ask for your consent, we process this data based on the legal grounds of Article 5/2-c of the Law, which states that processing personal data is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract and Article 5/2-e of the Law, which states that processing is necessary for the establishment, exercise, or protection of a right. After your Volvo Cars subscription ends, your personal data associated with this service will be deleted after ninety (90) days. Please note that if ownership of the vehicle changes, it is your responsibility to disconnect your vehicle from the Volvo Cars App and delete your data. This also applies to titleholders in vehicle leasing. You can follow this link for instructions.

2.4 Driving Journal

The Driving Journal automatically records all your journeys. For example, it can be useful to review your past driving information and manage your expenses related to these journeys. If you do not activate the Driving Journal, no data is collected. When you activate the Driving Journal, we collect your identity information (name, surname, phone number, and email address), your vehicle's VIN number, and location data. We also collect other journey-related information such as route, duration, distance, fuel and/or electric consumption, and kilometers traveled. Depending on your vehicle model, we may collect only the starting and ending positions or record the entire route during the entire journey. We use this data for purposes you personally determine in accordance with Article 5/2-e of the Law, which states that processing is necessary for the establishment, exercise, or protection of a right. We may also anonymize and aggregate this data for better understanding and improving our services, conducting research, and performing statistical analyses. For instance, Volvo Cars can use such data to calculate average driving distances or consumption in specific models or regions. Your Driving Journal data will not be shared or sold unless we personally identify it. When you stop using the Driving Journal or delete your account, this data will be retained for one (1) year from the date of deletion and then deleted.

2.5 Public Charging

You can locate and use public charging stations for your vehicle through maps in your car or with the assistance of an application. If you choose to use this service, we collect your identity information (name, surname, phone number, and email address), your vehicle's VIN number, and the necessary information for the charging process (such as the location of the charging station, pricing information, and charging process duration). We use this information to arrange and bill for your charging, and to facilitate communication with the station operator. We process this data based on the legal grounds of Article 5/2-c of the Law, which states that processing personal data is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract and Article 5/2-e of the Law, which states that processing is necessary for the establishment, exercise, or protection of a right. After you complete the charging process or cancel it, this data will be retained for ninety (90) days from the date of deletion and then deleted.

2.6 Contacting Us

When you contact us through the Volvo Cars App (e.g., when submitting a support request or providing feedback), we process the personal data you provide in your communication based on the legal grounds of Article 5/2-c of the Law, which states that processing personal data is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract and Article 5/2-e of the Law, which states that processing is necessary for the establishment, exercise, or protection of a right. In addition to communication purposes, we may record and track this communication and its outcomes. This helps us improve the user experience and resolve issues.

2.7 Marketing Communication and Surveys

Through the Volvo Cars App, we may send marketing communications and surveys. We process your personal data for these purposes if you agree to receive and give clear consent for such communications. Our processing aim is to communicate with you, provide you with personalized offers and content, receive feedback to improve our products and services, and conduct market research. You have the right to refuse to receive these communications at any time, in which case we will stop sending such communications. Additionally, you can manage your preferences and permissions for marketing communications through your personal profile.

2.8 App Analytics

The Volvo Cars App uses analytical tools to help us understand how the application is used. These analytical tools collect data such as usage statistics and device information. This data helps us monitor the performance of the application, fix errors, and enhance the user experience.

2.9 Research and Development

Volvo Cars continuously conducts research and development to improve our products and services. For this purpose, we may analyze feedback, experiences, and requests from users of the Volvo Cars App. Such analysis helps us better understand our products and services and improve them for your benefit. Data collected for research and development purposes is used only when it cannot be personally identified and is not shared with third parties.

3. Sharing Your Personal Data with Third Parties

We share your personal data with third parties only for the purpose of ensuring the realization of the purposes specified in this information text, in accordance with the security and privacy principles specified in the legislation, provided that sufficient and effective measures are taken. We may share your personal data with third parties in the following ways:

Third-party service providers: We may share your personal data with third-party service providers that we may use to assist Volvo Cars in providing or managing its services. These providers offer services such as server hosting, database management, communication management, email sending, and similar services.
Relevant authorities: We may disclose your personal data to relevant authorities, public institutions, and organizations for the purpose of fulfilling certain legal requirements or protecting public safety.
Other organizations collaborating with us: Volvo Cars collaborates with various business partners, and we may share your personal data as part of these collaborations. These business partners may participate in collaborations by offering special offers or services, or by participating in research and development activities.
Third-party social media platforms: The Volvo Cars Application may be integrated with specific social media platforms. These integrations allow us to access social media platforms and use certain functions. Integrated social media platforms provide privacy policies and terms for the use of such functions.
Sharing with foreign countries within the scope of explicit consent: Personal data processed through the Volvo Cars Application may be shared with Volvo Car Corporation located in Sweden, storage, archiving, information technology support (server, hosting, software, cloud computing) located abroad, and Volvo group companies located abroad within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Turkish Personal Data Protection Law (KVKK). Please note that you can always withdraw your explicit consent for the transfer of your data abroad.

4. Your Rights

You have certain rights to control and protect your personal data. These rights are subject to local data protection laws and regulations.

According to Article 11 of Law No. 6698 on the Protection of Personal Data, your rights as a data subject are as follows:

To learn whether your personal data has been processed,
To request information if your personal data has been processed,
To learn the purpose of processing your personal data and whether they are used in accordance with that purpose,
To know the third parties to whom your personal data have been transferred, whether domestic or abroad,
To request the correction of your personal data in case it is incomplete or incorrectly processed, and to request that the transaction made within this scope be notified to the third parties to whom your personal data have been transferred,
To request the deletion or destruction of your personal data if the reasons requiring its processing disappear despite being processed in accordance with Law No. 6698 and other relevant laws, and to request that the transaction made within this scope be notified to the third parties to whom your personal data have been transferred,
To object to the emergence of a result against you by analyzing the processed data exclusively through automated systems,
To demand compensation if you incur damages due to the illegal processing of your personal data in violation of Law No. 6698 and other related laws.

For your requests regarding the exercise of your rights under Article 11 of the Law, you can send your written request, along with the necessary information to identify yourself and your explanations regarding the right you want to exercise, to the address "Fatih Sultan Mehmet Mah. Poligon Cad. Buyaka2 Sitesi No:8B Kule2 Kat:4 Tepeüstü Ümraniye – İstanbul" with a wet signature, or via email to kvkktr@volvocars.com, indicating that the subject is "Information Request for the Protection of Personal Data Law".

5. Updates to This Information Text

This information text may be updated from time to time, and each update will be published on this page. If changes are significant or affect legal requirements, we may inform you of these changes through appropriate means. You can always find the latest version of this information text here.