CONSUMER SURVEYS PRIVACY NOTICE

Last updated: June 17, 2022

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:

  1. Who we are
  2. What personal information we collect and why
  3. How we protect your personal information
  4. How long we keep your data
  5. How we share your personal information
  6. Your rights in relation to the personal information we collect
  7. Contact information
  8. Changes to our Privacy Notice

For information about how Volvo Cars: (1) shares your information generally throughout our services, (2) protects your information, (3) collects and processes children’s information, and (4) addresses Do Not Track, please see our Privacy Statement.

  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 USA LLC, having its registered office at 1800 Volvo Place, Mahwah, New Jersey 07430 ("VCUSA"), are joint controllers. For the purposes of CCPA and as pertaining to information of US residents, Volvo Car USA LLC facilitates the Consumer Survey and collects the information on behalf of VCC as a service provider. VCC and Volvo Car USA LLC are hereinafter referred to as "Volvo Cars", "We", or "Us".

    If you agree to a video recording of your survey answers, Volvo Car USA LLC is the business for the purposes of data protection laws.

  2. What Personal Information We Collect And Why

    1. Information Collected From You

      Volvo Cars collects certain personal information from you when you participate in a Consumer Survey. "Personal Information" is information that identifies, relates to, describes, references, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, household, or device. 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, salutation, age, gender, postal code, and city). To the extent the GDPR applies, the data is processed based on our legitimate interest to improve the business purpose and customer experience that your survey response concerns.
      • 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 the extent the GDPR applies, the data is processed based on our legitimate interest to improve the business purpose and customer experience that your survey responses concern.
      • 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)). In addition, if you agree to participate in a survey conducted via video call, we may record that video. 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 analyze the performance of our warranty. To the extent GDPR applies, we process this information based on our legitimate interest to assess filed action and warranty performance, to improve the business purpose and customer experience that your survey response concerns, and to understand overall survey performance and survey interaction. VCUSA processes the information on VCC’s behalf 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. VCUSA 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 participating in surveys at any time by clicking on the "unsubscribe" link in the survey correspondence to you or by informing the Volvo representative conducting the survey. 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 opted to discontinue participation in the survey. Please note that Volvo Cars will continue to send you emails necessary to the Services, your account, your purchase, or any assistance you request.

    2. 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). The data is processed based on our legitimate interest of projecting the Consumer Survey in the correct format and to ensure proper functionality.

      We process this data for statistical analysis and range measurement, and to understand the interests of our consumers. For this analysis, the e-mail invites contain so-called web beacons or tracking pixels, which display single-pixel image files which measure whether emails were opened and whether there have been clicks leading to our website. The data is processed based on our legitimate interest to understand overall survey performance and survey interaction. If you do not wish to have this measurement performed, you can set your email program to not download pictures/media automatically.

  3. How We Protect Your Personal Information

    In order to keep your responses secure, the invitation for feedback provides you with an individualized questionnaire that no other person can access. The survey web site and our data storage facilities have security measures in place to prevent the loss, misuse, and alteration of the information under our control.

    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 five (5) years from the time you submit your response, after which it will be anonymized.

  5. How We Share Your Personal Information

    For information about how we share your information generally throughout our services, please see our Privacy Statement.

    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 customer feedback results with VCC 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 programs.

    Your personal information will also be disclosed to your selected retailer (if applicable).

    Should you agree to participate in a video survey, recordings will not be shared with anyone outside of VCUSA.

  6. Your Rights In Relation To The Information We Collect

    1. Your rights under GDPR

      If applicable, you have specific legal rights granted by the General Data Protection Regulation relating to the personal data we process about you. These are briefly explained below, and you can exercise them by filling out the dedicated form provided in the link at the end of this section.

      Right to withdraw consent: Where you have given consent for the processing of your personal data, you may withdraw your consent at any moment with effect for the future.

      Right to access your personal data: You may ask us for information regarding personal data that we hold about you. We will provide you with a copy of your personal data upon request. If you request further copies of your personal data, then we can charge you a reasonable fee that we base on administrative costs. You have the right to information about our safeguards for the transfer of your personal data to a country that is outside the EU and the EEA if you request that we confirm whether or not we process your personal data and we transfer your personal data to a country that is outside the EU and the EEA.

      Right to rectification: You may obtain from us rectification of incorrect or incomplete personal data concerning you. We make reasonable efforts to keep personal data in our possession or control which are used on an ongoing basis accurate, complete, current and relevant, based on the most recent information available to us.

      Right to restriction: You may obtain our restriction of the processing of your personal data, if:

      • you contest the accuracy of your personal data, for the period we need to verify the accuracy,
      • the processing is unlawful and you request the restriction of processing rather than erasure of your personal data,
      • we no longer need your personal data for the processing purpose but you require them for the establishment, exercise, or defense of legal claims, or
      • you object to their processing while we verify whether our legitimate interests override yours.

      Right to portability: You have the right to receive your personal data that you have provided to us and, where technically feasible, to request that we transmit your personal data (that you have provided to us) to another organization, if:

      • we process your personal data by automated means;
      • we base the processing of your personal data on your consent or our processing of your personal data is necessary for the execution or performance of a contract to which you are a party;
      • your personal data are provided to us by you; and
      • your right to portability does not adversely affect the rights and the freedoms of other persons.

      You have the right to receive your personal data in a structured, commonly used and machine-readable format. Your right to receive your personal data must not adversely affect the rights and the freedoms of other persons. Your hold the right to have your personal data transmitted from us to another organization if such transmission is technically feasible.

      Right to erasure: You have the right to request that we delete the personal data we process about you. We must comply with this request if we process your personal data, unless processing is necessary:

      • for exercising the right of freedom of expression and information;
      • for compliance with a legal obligation that requires processing by European Union or Member State law or other applicable law to which we are subject;
      • for archival purposes in the public interest, for scientific or historical research purposes, or for statistical purposes; or
      • for the establishment, exercise, or defense of legal claims.

      Right to object: You may object to the processing of your personal data at any time due to your particular situation, provided that the processing is not based on your consent but on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing, or for the establishment, exercise, or defense of legal claims. If you object to the processing, please specify whether you also request the erasure of your personal data; otherwise we will only restrict it. You also have the right to object at any time, regardless of the reason, to the processing of your personal data for direct marketing (which includes profiling to the extent that it is related to such direct marketing), if such processing was based on our legitimate interest. If the marketing was based on your consent, you can withdraw consent (see above).

      Right to lodge a complaint: You can lodge a complaint to your local data protection supervisory authority or with any other data protection authority in the EU. However, we would appreciate it if you first contact us to try and solve your problem – you can find our contact details below.

      You can exercise your rights in relation to us by filling out this form, which will help us to deal with your request properly. The online form contains the information that we need to verify your identity and review your request. For requests submitted by telephone or email, 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 deletion requests with the information provided, we may ask you for additional pieces of information.

    2. Your rights under California Law

      Under California law, consumers residing in California have certain rights with respect to the personal information about them that we collect and/or sell. If our collection of your personal information is subject to California law, you are entitled to the following rights:

      Right To Access: You have the right to request what personal information we have collected, used, disclosed, shared for a business purpose, and sold about you within the preceding 12 months. Once we receive your request and confirm your identity, we will disclose to you the information we have collected about you.

      Right To Deletion: You have the right to request the deletion of your personal information that we collect about you, subject to certain exceptions. Once we receive your request and confirm your identity, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies under applicable law.

      Right To Opt-Out: You have the right to opt-out of the sale of your personal information by us to third parties for monetary or other valuable consideration. Each of the individual Service Privacy Policies sets out whether or not we sell personal information as such action is defined under California law in connection with such service. We do not sell your personal information collected through a Consumer Survey. Across all of our digital properties, our collection and sharing of personal information through the use of certain cookies may be deemed a sale under the California Consumer Privacy Act. To exercise your right to opt-out of the sharing of your personal information to advertising partners through cookies, please use our OneTrust Cookie Manager.

      Right To Non-Discrimination: You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out. For example, this means we cannot deny goods or services to you or charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, due to you having exercised your rights.

      To exercise your right to access, correct, or delete your personal information, you may submit a request through our online form here, via e-mail at vcuscare@volvocars.com, or by calling us at 1(800) 550-5658. You may only make a request for access twice within a 12-month period. To exercise your right to opt-out of the sharing of your personal information to advertising partners, which may be a sale under the California Consumer Privacy Act, please use our OneTrust Cookie Manager.

      If you are a resident of California, an authorized agent may make a verifiable consumer rights request related to your personal information. If you are an authorized agent making a request on behalf of a consumer, you must provide us with signed permission by the consumer that you are authorized to act on behalf of that consumer. If you are a legal entity, you must also provide us with documentation of your registration with the California Secretary of State. To submit such a request, please contact us via e-mail at vcuscare@volvocars.com.

      The online form for access, correction, and deletion requests contains the information that we need to verify your identity and review your request. For requests submitted via telephone or e-mail, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. We aim to respond to your request for access, correction, or deletion within the time required by applicable law. If we need more time to respond to your request, we will let you know of the reason and the extension period in writing.

    3. Your Rights Under Nevada Law

      We do not sell personal information collected through the website hosting the Consumer Survey for monetary consideration. Under Nevada law, you may opt-out of future sales of your personal information collected through our website for monetary consideration. If you want to opt-out of any potential future sales, please e-mail us at: vcuscare@volvocars.com with "Opt-Out of Future Sale of Personal Data" in the subject line and body of your message.

  7. Contact Information

    To exercise your individual rights under GDPR, see Section 6.A above. You can also contact the Volvo Car Corporation Data Protection Officer as follows.

    Volvo Car Corporation

    Assar Gabrielssons Väg, SE-405 31 Gothenburg, Sweden

    Email: globdpo@volvocars.com

    To exercise your individual rights under CCPA see, Section 6.B above. You may also contact the company for other questions or requests as indicated below.

    Volvo Car USA LLC

    1800 Volvo Place,

    Mahwah, New Jersey 07430

    Email: vcuscare@volvocars.com

  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.