Effective from: October 5, 2023

This document describes how Volvo Cars and Zenseact (as defined below) process your personal data obtained by our Data Collecting Vehicles (DCVs) when driving on public roads for collection of traffic data (hereinafter "Public Traffic Environment Data"). These vehicles, equipped with a reference platform mounted on the roof containing different sensors, collect this data in Europe, Asia and North America.

You can find the following information below:

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

    The entities jointly responsible for the processing of personal data in relation to the scope of the notice are:

    • Volvo Car Corporation, having its registered office at 405 31 Göteborg, Sweden, company registration number 556074-3089, hereinafter referred to as "Volvo Cars," and
    • Zenseact AB, having its registered office at Lindholmspiren 2, 417 56 Göteborg, company registration number 559228-9358, hereinafter referred to as "Zenseact."

    Unless its specified, hereinafter this joint responsibility referred to as "we," or "us." Under the Joint Controllership, Volvo Cars has responsibility regarding transparency duties, as well as fulfilling the data subject's rights.

  2. What personal data we collect and why

    The processing of the Public Traffic Environment Data, which involves the processing of personal data, is necessary for us for the purposes of developing safe and reliable software and sensors for advanced driver assistance systems (ADAS) and autonomous drive (AD) systems, with the overall purpose of protecting all life on the road. Such data consists of the following data categories:

    • Sensor Data such as camera, lidar (light detection and ranging), radar, and ultrasonic sensors that can detect persons and objects moving around in the public traffic environment where the collection takes place. The data is used for evaluating sensors, the output from software interpreting the sensor data, and the software used in ADAS and AD systems. The cameras will record pedestrians, cyclists, people in or on vehicles, vehicles with license plates that are in the vicinity of the vehicle. We need to collect data on real-world traffic environments and real-world traffic situations in order to be able to accomplish our purposes. Thus, this data must be authentic and cannot be modified by blurring, for example. We are not interested in and do not in any way attempt to identify the individuals present in the Public Traffic Environment Data. Nor do we extract any other personal data from the collected data.
    • GPS Geolocation data from the vehicle will be collected and stored in order to be able develop our functionalities and also to find relevant recorded data based on location.
    • Annotations Information will be amended to the data to be able to find relevant recorded data, such as annotations of sensitive places. These annotations can be made by the driver or when the data is processed afterwards.

    The above data, though collected in the US, is transferred to Volvo Cars in Sweden for storage and processing as explained in this Notice. The personal data included in the Public Traffic Environment Data above will be processed based on our legitimate interests (EU General Data Protection Regulation, Article 6.1.f) for the purposes mentioned above.

    We limit our locations of interest to exclude hospital entrances, accident locations with injured individuals, beaches or public parks, private areas such as interior of a house, its garden or balcony, and other places that might be sensitive for the persons being recorded.

    We will not process the personal data included in the Public Traffic Environment Data for any purposes other than the purposes explicitly described in this privacy notice. We also have taken measures to limit access to the Public Traffic Environment Data, as well as implementing relevant security and privacy measures, such as removal of non-relevant material.

  3. How long we keep your data

    Public Traffic Environment Data will not be processed after more than 10 years for being able to reuse the data to test new versions of the software during the lifetime of the components. We will regularly sort out and erase data that is no longer needed in order to keep only relevant traffic situations. Data that is not complete or corrupted due to technical errors is also a candidate to be removed. The driver will also make annotations of recorded material when the data needs manual review and potential removal if the data can be considered intrusive or harmful for the individuals recorded by the sensors.

  4. Who we share your personal data with

    We will share your personal data with the following categories of third parties on a need-to-know basis:

    • We will share the data with our suppliers that provide the IT infrastructure for the means to provide us with storage and data handling.
    • We will share the data with the suppliers providing the sensors or technology used in order to find and correct errors in the technology they provide.
    • We will share the data with our intragroup entities in order to support the development of similar functionalities on their vehicle platforms.

    All suppliers act as processors and are bound by contractual arrangements with us and in line with the purpose set out in this notice. Transfer of the Public Traffic Environment Data to third parties outside EU will be made using Standard Contractual Clauses approved by the EU Commission.

    We can share sets of data with other parties when it has been properly anonymized prior to sharing. Such data cannot be attributed to a natural person and is no longer personal data.

    We might share data that is anonymized or not attributed to a natural person with research entities for their traffic-related research purposes, and with road traffic authorities for road safety improvements, such as helping them to know the quality of lane markings.

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

    5.1 Your rights under the EU General Data Protection Regulation

    You have specific legal rights granted by the General Data Protection Regulation relating to the personal data we process about you. These are explained below.

    Details about your rights is Volvo Cars' responsibility – what they mean, when and how you can exercise them – can be found in our Customer Privacy Policy.

    To exercise your subject rights, please use our form available here and clearly state that your request refers to our Data Collecting Vehicle.

    Your right to be informed and your right to access: You have the right to receive information about how we process your personal data.

    In addition, you have the right to receive information about what personal data we store about you and how your personal data is used and processed, free of charge and upon written request.

    You are entitled to request, in writing and free of charge, a copy of the personal data that we have registered about you.

    If your request is unfounded or your request is excessive, e.g., should you frequently and within short intervals ask to receive information on or a copy of your personal data, we have the right to refuse to act on your request or to charge a reasonable fee which covers the administrative costs of the action requested by you.

    Your right to rectification and erasure: If your personal data is inaccurate or incomplete, you have the right to request that we correct or remove the personal data, including the right to have incomplete personal data completed.

    You have the right to request the erasure of your personal data under certain circumstances (set forth in the GDPR). Provided that your request falls within one of those circumstances, we will erase your personal data.

    Your right to object: You have the right to object to your personal data being processed for the purpose defined in this Privacy Notice.

    Your right to restrict processing: Under certain circumstances (set forth in the GDPR) you have the right to request the restriction of processing of your personal data. In such a case, your personal data shall only be processed with your consent, with the exception of storage and processes needed for that, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.

    Your right to file a complaint: We encourage you to contact us if you have any questions regarding this Privacy Notice or if you are unhappy with the way we are processing your personal data.

    You also have the right to file a complaint with the supervisory authority regarding our processing of your personal data or handling of any inquires related to it. You will find the contact details of the relevant supervisory authority, Integritetsskyddsmyndigheten (IMY), below.

    5.2 Your rights under US State Laws

    Laws in various states provide rights to you with respect to your personal information. Our General Privacy Statementoutlines these rights and how you can exercise those rights in the US.

  6. Contact information

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


    DPO Volvo Car Corporation

    Jan Wellergård

    Volvo Car Corporation

    Avdelning 50092 / HABVS

    405 31 Göteborg



    Integritetsskyddsmyndigheten (IMY)

    Box 8114

    104 20 Stockholm


    Phone: +46 (0)8-657 61 00


    You can find contact information and other information regarding Zenseact's processing of personal data in its Privacy Policy,

  7. Changes to our Privacy Notice

    We reserve the right to modify our privacy practices and update and make changes to this privacy notice at any time and at our discretion. 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.