Effective Date: June 1, 2021
This document describes how Volvo Cars (as defined below), and sometimes other entities, processes your personal data or personal information (collectively referred to in this document as “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 grouped as follows:
You can find below:
The responsibility for the processing of your personal data in the Volvo Cars App is divided according to below:
To activate the remote vehicle services through the Volvo Cars App, we collect personal 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 commercial information such as 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-climatization, unlock/lock doors, remote start/stop of engine, current outside temperature, receive theft alarm notifications), allowing you to view 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 data of the 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.
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 the location of a point of interest from your phone to the car based on your contact list, calendars events or search results. For the purposes of GDPR, the legal basis for this processing is your consent (Art. 6.1.(a) GDPR). This data is not stored in the Volvo Cars App and we do not see it. When allowing access from your phone to other people’s data make sure that they have consented to this.
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 unless there is a legal requirement for us to retain certain data. 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 app and get your data deleted. This also applies for the registered primary driver in case of a car lease. Follow this link for instructions: https://www.volvocars.com/mt/support/topics/car-systems/volvo-on-call/volvo-on-call-change-of-ownership.
The Volvo Cars App allows you to choose to log your driving journal. This may be useful to you if, for example, you expense mileage. The Driving Journal must be activated by you, otherwise it stays inactive and the data is not collected.
If you do activate the Driving Journal, we collect from you your personal identifiers (such as first and last name, phone number, E-mail address, and VIN) and collect automatically through your vehicle telematics your vehicle location information (start and stop, or continuously depending on type of car as described below) to identify each trip including trip related information (time, distance, fuel and/or electricity consumption, electricity generation if hybrid) and mileage. For petrol and diesel cars, the driving journal only contains the start and finish positions of each driving cycle. However, if you have a hybrid/twin engine model, the driving journal also includes information about routes taken.
For the purposes of GDPR, we process this data based on your consent (Art. 6.1.(a) GDPR).
As a rule, the Driving Journal data is stored for 100 days. In special situations, such as cars benefiting from the Recharge Refund, the Driving Journal data is stored for 500 days.
You can at any time deactivate the Driving Journal, and in this case the data will stop being collected. This does not however automatically trigger the deletion of the previously collected information which is retained and subject to deletion as previously described.
When using the car sharing with Guest functionality available through the Volvo Cars App, Volvo Cars collects and processes the following personal data on behalf of the National Sales Company:
For the purpose of GDPR, the legal basis for the processing of your data is your contract with us (Art. 6.1. (b) GDPR), while the legal basis for the processing of the guest’s personal data is our legitimate interest (Art. 6.1. (b) GDPR) to give you the benefit of the car sharing functionality. When providing a guest’s information make sure that they have consented to this.
We will retain this personal data until 1) the guest is removed by the primary driver, 2) according to driver journal retention rules or 3) until the subscription comes to an end, whichever comes first.
We measure how our app is being used in order to better understand user behavior and improve the usability and reliability of the app, as well as to gain insights into how the services are used and improve your experience of these services. We do this by using Google Analytics (in restricted processing mode), and we automatically collect and process personal identifiers including your device ID, device IP address (pseudonymized immediately after collection), Volvo ID and vehicle connection status. For more information on how Google Analytics collects and processes information, please visit: www.google.com/policies/privacy/partners. For information about how to opt out of having certain of your information used by Google Analytics, visit: https://tools.google.com/dlpage/gaoptout/.
For the purposes of GDPR, the legal basis for this data processing is our legitimate interest ((Art. 6.1.f) GDPR) to improve the usage and experience of our app and our services.
This data will be stored by us for fourteen (14) months from collection.
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 automatically collected vehicle information (such as VIN), product (such as Volvo Cars App usage e.g. how often the Volvo Car App is used and when), customer personal identifiers (such as Volvo ID, email, phone number) and commercial information being 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.
Volvo Cars conducts analytics for trends, to model or improve its services, which does not involve building consumer profiles to use in providing services to another business.
The National Sales Company conducts analytics for trends and models, as above and also uses customer personal identifiers (such as Volvo ID, email, phone number) and commercial information being sales data (such as selling or servicing retailer) to model or improve its services and also to make determinations and inferences from your information for the purpose of marketing.
For the purpose of GDPR, the legal basis for this processing is our legitimate interest ((Art. 6.1.f) GDPR). 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.
If you have a subscription for the Volvo Cars remote vehicle services, you will get the opportunity to renew this service in the Volvo Cars App. When you do this, as well as to manage your subscription, we collect from you and process your personal identifiers (such as first and last name, phone number, e-mail address, VIN) and commercial information being 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 facilitate payments processing thought another third-party payment processor, 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.
For the purpose of GDPR, the legal basis for our processing of your personal data is that this processing is necessary for the performance of our contract (Art. 6.1. (b) GDPR) with you.
We will retain your personal data for ninety (90) days after your Volvo Cars subscription has expired, in order to enable continuation of the service if you choose to resubscribe. In addition, we will archive the data relating to your purchase for ten (10) years in order to comply with accounting and financial reporting legislation – this is a legal obligation (Art. 6.1. (c) GDPR).
When you use the contact option in the Volvo Cars App, the National Sales Company will collect from you and 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.
The data related to your requests will be retained for thirty-six (36) months from the receipt of your enquiry.
Through the My Volvo App you can receive marketing communications related to the Volvo Cars products if you have consented to this. To do this the National Sales Company collects from you and processes your personal identifiers (such as first and last name, phone number, E-mail address), your vehicle specification information (such as model, engine, VIN), and personal identifiers such as Volvo ID data and device ID, in order to tailor the marketing to the products and services you use.
You can opt-out of receiving emails at any time by clicking the “unsubscribe” button included in all marketing e-mails, or by contacting us at the contact information provided here. You can opt-out of receiving phone or SMS marketing communications by [opt-out method] or replying STOP to such SMS marketing communications.
If you withdraw your consent, as described above, the processing of your relevant data will be restricted to operating a suppression list in order to make sure you don’t unintentionally receive marketing communication.
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) the Volvo Cars App facilitates the transmission of your information to the relevant Volvo Cars retailer you select.
When you book a service through the Volvo Cars App, Volvo Cars collects:
This information will be used to book the service, organize 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, for the purposes of GDPR, our legal basis for this processing is your contract with us (Art. 6.1. b) GDPR).
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 for the purpose of GDPR, the legal basis for the data processing is our legitimate interest (Art. 6.1.f) GDPR) 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.
When you use the digital service booking, Volvo Cars collects automatically statistical data through Google Analytics (in restricted processing mode) to better understand user behavior and improve the usability. We thus process your online personal identifiers, including cookie identifiers, internet protocol addresses and device identifiers, as well as client identifiers. For GDPR purposes, the legal basis for the data processing is our legitimate interest (Art. 6.1.f) GDPR)) in measuring the usage and behavior of our app. This data will be stored for fourteen (14) months from collection.
The Volvo Cars App makes it possible for you to book the Volvo Valet service. When you do this, the Volvo Cars App facilitates the transmission of your information to the relevant Volvo Cars retailer you select (as explained below).
If you use the Volvo Valet service, the following information is automatically collected and processed about you: commercial information such as your pickup & delivery service history – in order to know which services have been completed; identifiers such as driver's license and insurance details– if you use a loaner vehicle; vehicle information such as 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); identifier being 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 ((Art. 6.1. b) GDPR).
If you leave feedback after performance of the service, we collect from you your name, the rating and comments given. The legal basis of the data processing is for the purposes of our legitimate interests ((Art. 6.1.f) GDPR) to continuously improve our services for the customer. Furthermore, it is the customer's decision whether to give a 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 ((Art. 6.1.f) GDPR) 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.
The processing for purposes 1-7 above by Volvo Car Corporation involves processing of your personal data with the following categories of third parties, on a need-to-know basis:
Processing by processors
Our categories of processors / service providers supporting delivering the Volvo Cars App are:
They are limited by contract in their ability to use your personal data for any purpose other than to provide services for us in compliance with each data processing agreement in place. In some of these situations the use of the processors involves limited transfers of personal data outside of the European Union (EU). We have taken precautions that such transfers are limited to the minimum necessary.
Sharing with other members of the Volvo Car Group
Data mentioned under section sections 2.5 and 2.6 as well as 2.9 and 2.10 above is collected via the Volvo Cars App on behalf of the National Sales Company, for the following purposes:
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:
We may share the personal data collected from the Volvo Cars App in the following circumstances:
Sharing in the preceding 12 months
In the preceding 12 months, we have shared, for a business purpose:
Sale of personal data
The disclosure of information to Google maps may constitute a sale under CCPA. You can opt out of this sharing of information by disabling the location settings on your mobile device.
As a data subject you have specific legal rights granted by the General Data Protection Regulation (GDPR) 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 indicated below.
We will share your personal data with the following categories of third parties, on a need-to-know basis:
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 right to have your personal data transmitted from us to another organization is a right you have if such transmission is technically feasible.
You also have the right to object at any time, regardless of any 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).
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.
Under California law, consumers residing in California have certain right with respect to the personal data about them that we collect and sell. These rights include:
To exercise your right to access, correct, or delete your personal data, you may submit a request through our online form here, via e-mail at email@example.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 data to advertising partners, which may be a sale under the CCPA, 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 data. 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 firstname.lastname@example.org.
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 data 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.
We do not sell personal data collected through our website for monetary consideration. Under Nevada law, you may opt-out of future sales of your personal data collected through our website for monetary consideration. If you want to opt-out of any potential future sales, please e-mail us at: email@example.com with “Opt-Out of Future Sale of Personal Data” in the subject line and body of your message.
Our products and services are not intended to be used by children. We do not knowingly solicit or collect any personal data about children under the age of sixteen (16) nor knowingly allow children to order our products, communicate with us, or use any of our online services or mobile applications. If a child has provided us with personal data, a parent or guardian of that child may contact us to have that data deleted from our records. If you believe that we might have any data from a child under the age of sixteen (16), please tell us using the Contact Information listed below. We will take all reasonable steps to delete the child’s data as soon as possible except where necessary to protect the safety of the child or others as required by law. We do not have actual knowledge that we sell personal data of minors under the age of sixteen (16) years.
To protect your personal data from loss, theft, and unauthorized access, use, or disclosure, we have implemented technical, administrative, and physical security measures including, for certain data, 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.
In order to exercise your rights, please see section 5 above. If you have any other questions regarding the subject matter of personal data protection, you can contact us at the following contact details:
Volvo Car Corporation
Post address: Assar Gabrielssons väg, SE-405 31, Gothenburg, Sweden
E-mail address: firstname.lastname@example.org
We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this privacy notice at any time. Whenever we make substantial changes to this notice, and in particular when this notice underlies your consent, we will inform you of the changes.
This privacy notice is current as of the date which appears at the top of the document.