Article version 2021.182.0

Privacy Notice – Care by Volvo subscription

Effective from:

Published at:

This document describes how your personal data are 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. Your rights in relation to the personal data processing we perform;
  6. Contact information; and
  7. Changes to our Privacy Notice.

1. Who we are

The legal entity responsible for the processing of personal data in relation to the Order is Care by Volvo Car UK Limited (company registration no 11734379) a company registered in United Kingdom and with address Scandinavia House, Norreys Drive, Maidenhead, United Kingdom, SL6 4FL a legal entity within the Volvo Car Group and hereinafter referred to as, “we”, “us” or “our”.

2. What personal data we process and why

We will process the personal data you provide when you sign up for a Care by Volvo subscription online in accordance with the description below.

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

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

  • your date of birth
  • your first and last name
  • your address
  • your contact details (email address and telephone number)

The personal data are collected from you through the application form and we will validate it with a credit reference agency. The personal data is processed in order to be able to (i) confirm your identity when you sign up to a Care by Volvo subscription and to perform a check against sanction lists, (ii) perform a credit worthiness and affordability check (described below) and (iii) communicate with you about your subscription order or about other practical issues, 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 point (i) to confirm your identity and point and to perform a check against sanction lists, and (ii) to perform a credit eligibility check, is our legitimate interest in knowing who we are entering into a contract with and to check your ability to pay the monthly subscription fees associated with your chosen car.

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.

2. Performing credit eligibility and know-your-customer checks

When you sign up to a Care by Volvo subscription, we will prior to accepting and confirming your application perform (i) a creditworthiness and affordability check on you, and (ii) a check against the sanctions list imposed by the UN, UK and US. We will in connection therewith process:

  • your date of birth
  • your first and last name
  • your address
  • your financial information
  • a copy of valid driving licence or other valid ID in case required to finalise the check against the sanction lists.

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 terrorist financine and to ascertain any potential customers that are Politically Exposed Persons. 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 date of birth and your first and last name with Experian Ltd, a company registered in UK, (“Experian”) which will perform the credit worthiness and affordability check. Experian is the controller for the personal data that the company processes in connection with performing the credit eligibility and you can read their privacy policy here.

We will also share your personal identification number and your first 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 imposed by the UN, UK and US. Schufa is the controller for the personal data that the company processes in connection with performing these checks and you can read their privacy policy here.

If we do not approve your subscription order after having performed the worthiness and affordability check and the other checks specified above, we will retain the specified personal data for three (3) months from the time at which we decide 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 date of birth
  • your first and last name
  • your contact details (address, email address and telephone 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) supply and manage the return of the car and provide the other services included in the Subscription; (iv) communicate about the servicing 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 and 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 UK Limited (and its sub processors) – financial services such as invoicing and refunds and other administrative support services
  • Care by Volvo Car AB (and its sub processors) – services in relation to administration of the subscription order
  • Selected authorised Volvo retailer(s) (and their subcontractors) – delivery and return of cars and other services under the Subscription
  • Arvato Financial Solution Limited (and their subcontractors) – debt collection and car repossession services

Some of your personal data (such as your first and last name, contact details and the car’s VIN and registration number) will be shared with United Kingdom Vehicle and LicenSing Agency (“DVLA”) to register the car in the vehicle register. The DVLA is the controller for data that they process in relation to the vehicle register.

We also share some of your personal data (first and last name, contact details and the car’s VIN and registration number) with our insurance partners Lloyd Latchford Group through which the car may be insured during the subscription period. Lloyd Latchford Group is the controller of for the personal data processed in connection with the insurance.

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 sign up as a business customer

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

  • your first and last name
  • your date of birth
  • your contact details (home address, email address and telephone number)

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, (iii) provide payment instructions, and (iv) communicate regarding delivery of the car and to administrate the handover of the car. 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 processors, which are limited by contract in their ability to use your personal data for any purpose other than to provide services to us in compliance with each respective data processing agreement in place:

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

5. Collecting data from cars

We collect the following categories of data from the car you drive during the Subscription (and since the data are linked to the car’s VIN they can be associated with you):

  1. the service status for various car parts, in order to assess the car’s status and, if necessary, carry out maintenance. We use these data to plan the servicing 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 plan future maintenance better. The legal basis for the processing specified above is to be able to provide the servicing 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 Financial Solution Limited (and their subcontractors), which will process the data in order to recover the car on our behalf. Arvato Financial Solution Limited 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 confidentially and in a secure and proper manner.

3. How long we keep your data

We store the personal data specified above and which we process during the Subscription for up to five (5) years after the end of your Subscription under our statutory obligation to retain them.

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 servicing and maintenance of the car, operation of the website and provision of IT systems for business support and data storage.
  • Care by Volvo Car AB (and their subcontractors) – administration of the Subscription.
  • 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 the United Kingdom in line with UK GDPR. Restricted transfers from the United Kingdom to other countries , including to the EEA, are now subject to transfer rules under the UK regime. These UK transfer rules broadly mirror the EU GDPR rules, but the UK has the independence to keep the framework under review. Curenlty if, such transfers occur they will be based on the standard contractual clauses approved by the EU Commission. The general text of the standard contractual clauses used can be found in various languages on the homepage of the EU Commission: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010D0087.

Please contact us (in accordance with section six below) if you have any questions in relation to the transfer of your personal data outside the European Economic Area.

5. Your rights in relation to the personal data processing we perform

You have specific legal rights granted by the UK General Data Protection Regulation (GDPR) 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 UK’s information Commisions Office.

You will find more information about your rights, what they mean and when and how you can exercise them in our Customer Privacy Policy.

6. Contact information

In order to exercise your rights under section five above, please use this web form. If you have any other questions regarding the subject matter of personal data protection, you can contact us at:

Care by Volvo Car UK Limited

Post address: Scandinavia House, Norreys Drive, Maidenhead SL6 4FL

E-mail address: carebyvolvo-uk@volvocars.com

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 Customer Privacy Policy thoroughly and to refer to them on an ongoing basis. This privacy notice is current as of the date which appears at the bottom of the document. We will treat your personal data in a manner consistent with the privacy notice under which they were collected, unless we have your consent to treat them differently.