Privacy Notice – Volvo Cars App
This document describes how Volvo Cars (as defined below), and sometimes other entities, processes your personal data when you use the Volvo Cars mobile application (hereinafter “Volvo Cars App”), that keeps you connected to your Volvo vehicle.
The Volvo Cars App has several functionalities, which entail different types of personal data processing, as we will explain below. Depending on your market and the type of subscription you have, these functionalities can be summerised as follows:
- The Volvo Cars services – this includes the aspects mentioned under sections 2.1 (Your subscription), 2.2 (The Volvo Cars remote vehicle services), 2.3 (Driving Journal), 2.4 (Digital Key), 2.7 (Public charging), 2.8 (When you get in touch with us), 2.9 (Marketing communications and surveys), 2.10 (App analytics), 2.11 (Research and development) below.
- Value added services, provided in collaboration with retailers – such as 2.5 (Digital service booking) and 2.6 (Pick-up & Delivery Service).
You can find below:
1. Who is responsible for the processing of your personal data
The responsibility for the processing of your personal data in the Volvo Cars App is divided according to below:
- The entity responsible for the main processing of personal data in relation to Your subscription, The Volvo Cars remote vehicle services, Driving Journal, Digital Key, Public Charging, App Analytics, as well as Research and Development, is Volvo Car Corporation, having its registered office at Assar Gabrielssons Väg, SE-405 31, Gothenburg, Sweden, company registration number 556074-3089, hereinafter referred to as “Volvo Cars”.
- The entities responsible for the processing of personal data when you get in touch with us as well as for Marketing communications are, jointly:
- Volvo Car Corporation, and
- Volvo Car Ireland Ltd, company registration number 182538, having its registered office at 5 Riverwalk, Citywest Business Park, Citywest, Dublin, D24 TW13, Ireland.
- The retailer services booked through the Volvo Cars App (Digital service booking and Pick-up & Delivery Service), are jointly performed as joint controllers by Volvo Cars, the National Sales Company, and the Volvo Cars retailer where you request the retailer service (hereinafter “Volvo retailer” or “retailer”).
2. Personal data collected, why and for how long
As mentioned previously, Volvo Cars App comes with several different functions depending on your car model and your market – some of the functions described below might not be applicable for you.
2.1 Your subscription
If you have a subscription for the Volvo Cars remote vehicle services or other Volvo connected services, you may get the opportunity to renew this service in the Volvo Cars App. When signing up for or extending an existing subscription, and for us to manage your subscription, we process your identifiers (such as first and last name, phone number, e-mail address, VIN) and your purchase status and history. The purpose of our processing is to administer and monitor your purchase (from purchase to delivery) including any necessary contacts with authorities for official reporting, administration of your request for related services, follow up on the delivery, and to communicate updates related to the services that you have purchased. We use a third-party payment provider to process your payments, and that is a separate processing of your personal data by them; you can read more about the privacy practices of our payment processor in Section 3 below.
The legal basis for our processing of your personal data in relation to subscriptions is that this processing is necessary for the performance of our contract with you.
We will retain your personal data for ninety (90) days after your last subscription has expired in order to enable continuation of the service if you choose to resubscribe or for you to access invoices or receipts. In addition, we will archive the data relating to your purchase for ten (10) years to comply with accounting and financial reporting legislation – this is a legal obligation.
2.2 The Volvo Cars remote vehicle services
We collect identifiers (such as your first and last name, phone number, Volvo ID (e-mail address), vehicle identification number - “VIN”, unique device identifier, and push notification token) and purchase history (ownership period, any subscription services in which you are enrolled, and the model and year of your vehicle and corresponding vehicle specifications).
We use this information to provide the Volvo Cars remote vehicle services, such as the ability to control your vehicle remotely (e.g. pre-climatisation, unlock/lock doors, remote start/stop of engine, current outside temperature, receive theft alarm notifications), viewing the status of your vehicle (e.g. fuel level, windshield washer fluid levels, brake fluid levels, door lock status, tire pressure or maintenance warnings, battery status, or other vehicle status indicators).
We also use this information to send push notifications within the Volvo Cars App related to upcoming maintenance and service reminders for your vehicle. For hybrid and full electric cars, we store charging location to be able to offer a convenient way to schedule the charging. We collect your vehicle location information as well as, if you allow this, location of your mobile device, for you to use the map functionalities in the Volvo Cars App, and to show you your position relative to your Volvo on the map.
Wherever you are not asked specifically whether you agree to any data processing, the reason why we process this data is in order to perform our contract with you.
If, through your mobile settings, you grant us access to your location data, calendars and contacts, we will process this data to supply an easy way for you to send location of a point of interest from your phone to the car based on your contact list, calendars events or search results. The legal basis for this processing is your consent.
When your Volvo Cars subscription comes to an end, the details linked with this service, including your personal information, will be deleted after ninety (90) days. Note that the Volvo Cars subscription follows the car, therefore if there is a change of ownership you as a seller are responsible to disconnect your car from the Volvo Cars App and get your data deleted. This also applies for registered primary driver in case of car lease. Follow this link for instructions.
2.3 Driving Journal
The Driving Journal automatically log all your trips. This may be useful if, for example, you want to manage your mileage expenses. The Driving Journal must be activated by you, otherwise the data is not collected.
If you enable the Driving Journal, we will collect your identifiers such as first and last name, phone number and E-mail address, your vehicle’s VIN and its location as well as other trip related information such as your routes, time, distance, fuel and/or electric consumption and mileage. Depending on your vehicle model only start and finish position is collected or the full route.
We process this data based on your consent.
As a rule, the Driving Journal’s data is stored for up to 400 days depending on car model. You can disable the Driving Journal at any time, and by doing so the data will stop being collected. This does not however trigger the deletion of previously collected information.
2.4 Digital Key
Digital Key can fully replace the conventional car key, and allows you to conveniently lock, unlock, or start your vehicle with your smartphone or smart watch. In addition, it is also possible to share your key with additional users through various digital channels.
Digital Key only requires network connection during the initial one-time set-up, for sharing of keys, or revoking keys. Once set-up, the key will work via Bluetooth, Near Field Communication (NFC), and Ultra-Wideband Technology (UWB). During set-up, your key will be added to your wallet app in your smart device. From your wallet app you can share your key through messaging apps, mail, or via Airdrop®. You can also easily revoke keys you have shared, either through the wallet app, or in the vehicle infotainment system.
The following data is processed when using Digital Key:
- Vehicle identification number (VIN)
- Vehicle details
- Vehicle status
- Volvo ID
- Friendly name
The legal basis for us to process the data mentioned above is performance of the contract.
We will retain your data as long as you have a valid contract.
2.5 Digital service booking
The Volvo Cars App makes it possible for you to book various services for your car with selected retailers. When you do this, the processing of personal data involved in this booking (as explained below) is performed jointly by Volvo Cars, the National Sales Company and the Volvo Cars retailer you select.
When you book a service through the Volvo Cars App, Volvo Cars collects:
- your identifiers (such as first and last name, phone number, e-mail address)
- depending on the service requested, car related information such as vehicle identity, license plate, diagnostic trouble codes, warnings, mileage, fluid levels, as well as your own description of the purpose of the booking (if any), which will be distributed to the National Sales Company and the retailer executing the service you requested (which might be service/repair workshop, body paint workshop, car reconditioning specialists and car logistics services)
This information will be used to book the service, organise performance, contact you in matters regarding the service booked or as direct consequences of using the service such as sending confirmations and notifications. This data is processed in order to perform the booking you request (in other words, our legal basis for this processing is your contract with us.
Booking details (time and location of requested appointment, used contact channel, booking status, booking content) will be stored in system logs for solving errors that might occur in the system. The booking details will also be processed for analysis and evaluation of the service. This processing is performed by Volvo Cars, and the legal basis for the data processing is our legitimate interest in performing these activities. We will keep your service-related personal data up to two (2) years from last time using the service. In addition, we will archive pseudonymized booking details in system logs for five (5) years for statistics reasons.
2.6 Pick-up & Delivery Service
The Volvo Cars App makes it possible for you to book the Pick-up & Delivery Service. When you do this, the processing of personal data involved in this booking (as explained below) is performed jointly by Volvo Cars, the National Sales Company and the Volvo Cars retailer performing the service.
If you use the Pick-up & Delivery Service, the following information is processed about you: your pickup & delivery service history – in order to know which services have been completed; driver's license and insurance details– if you use a loaner vehicle; license plate and VIN number - needed to identify vehicle; pickup and/or drop-off address - needed to provide the service; pickup and/or drop-off notes inserted by you (if any); IP address. When we send push notifications with the status updates of the service, we use the following categories of data in order to keep track of notifications sent: unique device identifier; push notification token; push notification title and body; IP address. This processing is based on performance of a contract to which you are a party.
If you leave feedback after performance of the service, we collect your name, the rating and comments given. The legal basis of the data processing is for the purposes of our legitimate interests to continuously improve our services for the customer. Furthermore, it is the customer's decision whether to give feedback.
The quality of our service is essential and because liability issues may arise regarding alleged damages to the car, we keep photos of the vehicle, along with timestamps and location, in our interest to defend our (and our partners and drivers involved in the service) rights and interests. The legal basis of the data processing is for the purposes of our legitimate interest that in case of damage we want to clarify as simply as possible whether the damage was caused by drivers during the performance of the service.
We will retain your data related to the service up to three (3) years from last time using the service, unless disputes arise – in that case we keep the necessary data for as long as needed to defend our rights. In addition, we will archive pseudonymized booking details in system logs for five (5) years for statistics reasons.
2.7 Public charging
The Volvo Cars App is integrated with Digital Charging Solutions (DCS) to make it easy for drivers to charge their electric cars. When you use this service, we process the following personal data to fulfill the contract you have signed:
- Contact details
- Volvo ID
- Vehicle details
- DCS charging card ID
- Vehicle position data - to help you find a charging station near you
- Financial information
In order to present session information and invoicing of the public charging service we process the additional information received from DCS:
- Charging session ID
- Charging session start time
- Charging session duration
- Charging session price
- Energy added during charging session
- Charging station connector type
- Charge point operator name
Digital Charging Solutions (DCS) GmbH, a company registered in Germany, having its registered office in Rosenstraße 18-19, 10178 Berlin, Germany with company registration number 211155 B, act as a separate controller in providing the charging service to you. The data related to public charging will be retained as long as you are a Volvo Cars App user and for an extra period of one (1) year.
2.8 When you get in touch with us
When you use the contact options in the Volvo Cars App, we will process your personal identifiers relevant for the channel you use (such as first and last name, phone number/E-mail address, VIN, unique device identifier, and push notification token) as well as any data you supply in connection with your enquiry. We do this under the legitimate interest to administer your request.
If your question concerns our public charging service powered by DCS we may additionally process the personal data mentioned in Section 2.7 above.
The data related to your requests will be retained for three (3) years from the receipt of your enquiry.
2.9 Marketing communications and Surveys
Through the Volvo Cars App you can receive marketing communications related to the Volvo Cars products, if you have consented to this. Then we process your identifiers (such as first and last name, phone number, E-mail address), your vehicle specification (such as model, engine, VIN), Volvo ID, device ID, and subscription information.
The legal basis for this is your consent. If you withdraw your consent, the processing of your data will be restricted to operating a suppression list in order to make sure you don’t unintentionally receive marketing communication.
Through your Volvo Cars app you can also receive surveys about our products and services. We process the same data as above, based on our legitimate interest to improve our services. This data is processed until you opt-out.
2.10 App Analytics
We measure how you use the Volvo Cars App and related services to gain a better understanding of user behaviour, to improve the usability, reliability and reduce malfunctions of the Volvo Cars App as well as to gain insights into how our services are used for continuously improvement.
This is done by processing user identifiers (such as cookie identifier, IP -address, device information, Volvo ID, country from which you access the Volvo Cars App, your operating system), Vehicle Identification Number (VIN), vehicle connection status, and usage data (such as clicks in app, features used, pages viewed and potential issues or errors).
To do this, we rely on service providers which give us insights into how you use the Volvo Cars App. Please see Section 3 below for information regarding sharing and disclosure of personal data.
The legal basis for this data processing is your consent. You may withdraw your consent at any time by changing your preferences in your profile in the Volvo Cars App, under the section “Privacy Settings”.
As a main rule, this data will be stored for fourteen (14) months from collection. In some cases, app instance identifiers will be stored for the duration of the lifespan of the Volvo Cars App on your device.
2.11 Research and development
For research and development purposes to better understand how to improve our products and services and which new ones to develop, we use a data-driven approach and leverage vehicle (such as VIN), product (such as Volvo Cars App usage), customer (such as Volvo ID) and sales data (such as selling or servicing retailer) to inform the direction of the development of our products and services. The processing spans a wide range of analytics, modelling and research performed by our analysts and data scientists.
The legal basis for this processing is our legitimate interest. Where possible, we restrict analyses to anonymized or pseudonymized data. The processing does not include any automated decision concerning you.
We retain this data for ten (10) years.
3. Sharing of your personal data
We share data with various organisations to run our business, to maintain our relationship with you, and to provide you with products and services. We describe these situations below.
Where we refer to these organisations as our ‘suppliers”, ‘processors’ or ‘sub-processors’, each one of these organisations is limited by contract in their ability to use your personal data for any purpose other than to provide services to us or on our behalf, as instructed by us. In each case, we only share the personal data we deem necessary to achieve the respective purpose.
Our categories of processors supporting the delivery of the Volvo Cars App are:
- Cloud connectivity service provider
- Data hosting
- Push notifications
- Distribution of emails
- Chat functionality and customer care handling
- Analytics insights and statistics
- Selected Volvo Car retailers for digital service booking and Pick-up & Delivery Service
- Subscription invoice handling provider
Some of these situations the use of the processors involves limited transfers of personal data outside of the European Union. We have taken precautions that such transfers are limited to the minimum necessary, and only involve data that cannot directly identify you and thus poses a very low risk in case of unauthorized disclosure.
Sharing with other members of the Volvo Car Group
Data mentioned under Section 2.1 is shared with our national sales company in the country where the data originates from, for the following purposes:
- Assessing retailer performance
- Customer care
- Marketing segmentation
- Assessing subscription extensions and reactivations
Sharing with other third parties (separate controllers)
We process payments through third parties that collect payment data directly from you and do not share it with us:
4. Your rights and controls
You have specific legal rights relating to the personal data we process about you. The rights may differ depending on which jurisdiction you are in and the nature of the processing. Generally, your rights concern the possibility to:
- withdraw your consent
- object to our processing of your data
- ask for a copy of the data we hold about you (so-called subject access right)
- ask for the data to be transferred to another entity (so-called data portability)
- ask for the data to be corrected or restricted
- ask for the data to be deleted (so-called right to be forgotten)
As mentioned, these rights are not absolute and in some cases data protection law limits their application. Should this be the case for a request you make to us, we will always explain why we cannot fulfil your request.
If you would like to submit a rights request, you can get in touch with us by completing this form. We kindly ask that you use the form as it sets out the information that we need to verify your identity and effectively process your request. However, should you prefer not to use the form, you are always welcome to contact us and submit your request using the contact information in the next section.
You also have a right to submit a complaint to your local data protection authority should you have concerns about how we use your personal data. However, we would appreciate it if you reached out and raised your concerns directly with us first to allow us to try to resolve them together. You can find our contact information below.
5. Contact information
If you have any questions about how we use your personal data, you can contact us at firstname.lastname@example.org, or Volvo Car Corporation Data Protection Officer as follows:
Postal Address: Volvo Car Corporation, Attention: The Data Protection Officer, dep 50099, VAK, 405 31 Gothenburg, Sweden.
6. Updates to this notice
We continuously develop our products and services and will review and update this privacy notice as a result. As such we encourage you to revisit this privacy notice regularly. The date at the top of this privacy notice lets you know when it was last updated. We will handle your personal data in a manner consistent with the privacy notice under which it was collected unless we have your consent to handle it differently.