DIGITAL RETAIL SERVICE PRIVACY NOTICE

Effective Date: September 6, 2021

SCOPE AND PURPOSE

This Service Privacy Notice describes how Volvo Car USA, LLC (referred to as “Volvo Car USA”, “we”, “our”, or “us”) collects and processes your personal information when you use our Digital Retail Service (“Service”) available at https://www.volvocars.com/us/shop/. This Service allows you to commence the purchase of a Volvo vehicle in an online, digital format. This includes, for example, obtaining an estimate of the trade-in value of your vehicle, building a vehicle model, and making a deposit for a vehicle. “Personal information” is defined as any factual or subjective information, recorded or not, 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.

This Privacy Policy applies only to the Service. This Service Privacy Policy does not apply to authorized Volvo Cars retailers, or third parties to whom you directly provide your information including, but not limited to, subscription services, insurance companies, or other third parties who may offer special rates or products to Volvo Car USA customers, nor to content posted on social media channels. These entities are independent of Volvo Car USA and responsible for their own collection of information. Please refer directly to those entities and their particular privacy policies for more information.

You can find below:

  • What personal information we collect;
  • How we share your personal information;
  • How we address the security of personal information;
  • Your privacy rights and choices; and
  • How we make changes to our Privacy Notice.

INFORMATION WE COLLECT AND WHY

When you use our Service, we collect personal information from you and use it as follows.

When you:

  1. “Save for Later”: When you choose your vehicle of interest, its make and configuration, whether you are seeking financing or leasing, and options related to the payment, you can save your progress for later (which we call your “deal”). To do so, we collect from you your personal identifiers (first and last name, e-mail address, and phone number) and your location (either, automatically based on your IP address, if this is enabled in your browsers, or directly from you when you enter a location). We use this information to allow you to edit and review your deal in our online store, have a copy of your deal sent to you by e-mail, and give you updates related to your deal, such as discounted pricing by the retailer. With your consent, we will also use these identifiers to send you marketing communications we feel may be of interest to you and, through the placement of cookies, present to you, in other websites, advertising that may be of interests to you based on this information. You may unsubscribe from the marketing communications by clicking the unsubscribe link in each e-mail. You may opt out of the sharing of information via cookies, please see our Cookie Notice. Note that when you share your deal on social media the information will be visible to people and may be used by the social medial platform – all subject to the privacy policy of such social medial platform.
  2. Submit a Conditional “Trade-In” Offer: When you submit a conditional “trade-in” offer, we collect from you your vehicle information (Vehicle Identification Number (VIN)), personal identifiers (phone number), location (either, automatically based on your IP address, if this is enabled in your browsers, or directly from you when you enter a location), commercial information (the year, make, model, trim, mileage, vehicle history, vehicle condition and mechanical issues, if your vehicle has been in an accident or damaged, and if so the damage amount and insurance payout, if your vehicle has been modified, if anyone smokes in your vehicle, and, at your option, interior and/or exterior photographs of your conditional trade-in vehicle) and the value of the vehicle, as determined by you.
  3. Make a Deposit Using our Online Checkout: When you make a deposit using our online checkout, we collect from you your personal identifiers (first and last name, mailing address, city, province, postal code, and phone number) and your financial information (credit card number and expiration date). We use this personal information to reserve your vehicle for a limited time (for 7 days at the vehicle’s price) and collect your deposit towards the purchase of your vehicle on behalf of your preferred authorized Volvo retailer and facilitate the processing of your payment with our third-party payment processors.
  4. Visit the Website: When you visit our website, we collect personal information from you automatically through cookies and similar technologies. Specifically, we collect your personal identifiers (such as your IP address), location information (such as may be determined from your IP address), internet activity information (such as usage information), and device information (such as hardware model, operating system, browser, and your Website preferences) to provide our website to you. For information on how we use cookies across our digital platforms, please see our Cookie Notice.

HOW WE SHARE YOUR PERSONAL INFORMATION

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

We have shared your personal information for a business purpose:

  1. Identifiers and Commercial Information with your authorized Volvo retailer to process the purchase or lease of your vehicle and, if you will trade-in your current vehicle, allow the retailer to give you an estimated appraisal value and update your new vehicle’s payment information.
  2. Identifiers and Financial Information with our credit card processor (Stripe) to process your deposit and, on your behalf, submit your deposit to your authorized Volvo retailer.
  3. Identifiers, internet and other electronic network activity information, and commercial information with our service providers that assist us with the Service, including data hosting and our CRM provider.
  4. Identifiers with our marketing providers that assist us in our direct marketing efforts.

In the preceding 12 months we have also shared identifiers, location information, and internet activity information with our marketing and advertising partners to serve you with relevant advertising. Such sharing may be deemed a sale under the California Consumer Privacy Act. To opt-out of the sharing of your personal information through cookies, see Do Not Sell My Personal Information.

If you opted into this – we also shared your identifiers with your authorized Volvo retailer for their marketing purposes.

We may also share the personal information collected from the Digital Retail Service in the following circumstances:

  • As a result of a change in our corporate structure: in the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any part of our business, assets, or stock, we would share any personal information collected about you with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
  • To prevent harm: we will share personal information if we believe it is necessary to detect, investigate, prevent, or act against illegal activities, fraud, or situation(s) involving potential threats to the rights, property, or personal safety of any person.
  • For legal purposes: we will share personal information where we are legally required to do so such as in response to court orders, law enforcement, or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of service or other contracts; to defend against legal claims or demands; or to comply with the requirements of any applicable law.
  • With your consent: apart from the reasons identified above, we may ask for your permission to share your personal information for a specific purpose for which we do not already have your consent.

Sale of personal information within the preceding 12 months

Identifiers and purchase history with your preferred authorized Volvo retailer and to contact you to inquire about the cancelation of your order or to give you offers and information and marketing communications on Volvo products and services that may be of interest to you, based on our analysis of your information and the inferences we make from it (e.g. the type of vehicle in which you expressed interest or the state in which you live). This sharing may be deemed a sale under the California Consumer Privacy Act. To opt-out of the sharing of your personal information see Do Not Sell My Personal Information.

INFORMATION SECURITY

To help protect your personal information from loss, theft, and unauthorized access, use, or disclosure, we have implemented technical, administrative, and physical security measures including 256-bit encryption, access controls, and secure development processes. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure or impenetrable. We cannot ensure or warrant the security of any information you provide to us. Your personal information is stored on secure servers with restricted access.

YOUR RIGHTS UNDER CALIFORNIAL LAW

Under California law, consumers residing in California are granted the right to access or delete the personal information that we have collected about them, to opt-out of the sale of their personal information by us to a third party, and not to be discriminated against for exercising these rights. To learn more about your rights with respect to your personal information and how to exercise those rights, please see our Privacy Statement.

MORE INFORMATION

For information about how we: share your information generally throughout our services, protect your information, process children’s information, address Do Not Track, make changes to our Privacy Statement and Services Privacy Policies, and can be contacted, please see our Privacy Statement.