This version was published, and is valid from, 2023/09/01
This notice provides information on processing of personal data of its customers and prospects representative by a company which is part of the Volvo Group (“Privacy Notice”). If you are, or have been, an individual, or the employee of a company, that has bought, or rented,leased or hired a product or service or asked for an offering in a role as prospect by a Volvo Group company, we may process personal data about you.
For the purpose of this notice, the “Volvo Group” means AB Volvo (publ.) and entities directly or indirectly controlled by AB Volvo including but not limited to entities belonging to any of the Volvo Group principal Business Areas and Truck Divisions (as may exist from time to time) such as Volvo Trucks, Volvo Buses, Volvo Construction Equipment, Renault Trucks, Arquus, Volvo Penta, Mack Trucks, Volvo Financial Services, Volvo Group Connected Solutions,
Volvo Technology, Volvo Group Purchasing, Volvo Group Real Estate, Volvo Treasury, Volvo Information Technology, Volvo Group Trucks Operation, Volvo Autonomous Solutions and Volvo Energy.
This Privacy Notice applies only when a company which is part of the Volvo Group is collecting or otherwise processing personal data for its own purposes (i.e., when a company of the Volvo Group (either alone or in common with other entities) is a controller and therefore determines the purposes for which and the manner in which any personal data is processed).
Please note that the processing of vehicle related personal data is not covered by this Privacy Notice but by the Privacy Notice for Operators and Drivers.
This Privacy Notice does not apply when a company of the Volvo Group is collecting or otherwise processing personal data on behalf of another company, such as Volvo Group’s independent dealers, importers, suppliers and customers.
In addition to this Privacy Notice, some systems, applications, and processes of a company of the Volvo Group may contain their own privacy notices, which provide additional details about what specific personal data is collected and how it is stored, used, and transferred.
For the purposes of this Privacy Notice, “personal data” is any information about a specific individual or that identifies or may identify a specific individual. In other words, it is any piece of information than can be linked to you.
For the purposes of this Privacy Notice, the term "process” or “processing” means any use of personal data, including but not limited to the collection, recording, organization, storing, adaptation, alteration, transferring, making available, blocking, deletion or destruction of personal data.
Legal basis
Volvo may process your personal data based on any one or more of the following legal grounds, see also further details below.
Volvo may process the following categories of data which, in itself or in combination with other data, may constitute personal data and for the general purposes stated in Table 1 below.
Volvo will not necessarily process all the data listed below about you, and some of the purposes for processing will overlap and there may be several purposes which justify our use of your personal data.
Table 1 – Categories, Purpose and Legal Ground for Processing
Categories of Personal Data | Purposes of Processing | Legal Ground for Processing |
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Contact data, such as name, e-mail address and telephone number, next of kin, passport and ID data
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Organizational data, such as company name, company’s management, job position, place of work and country
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Individual data, such as preferred language, photo/video, clothing size and food preferences |
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IT-related data, such as user-ID, passwords, permissions, settings and other attributes associated with your user account, log-in details as well as data and logs about your use of Volvo’s IT equipment, application or services
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Manufacturing / repair / service data, such as tracking and logging of activities (including warranty claims) undertaken by you in connection with manufacturing, maintenance, repair or service on products
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Image material, such as video footage that is being recorded on a Volvo Group company closed-circuit television system (“CCTV”) installed on the applicable Volvo Group company premises or other video and related security/monitoring systems whether on Volvo Group premises or not.
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Contractual data, such as purchase orders, contracts and other agreements between you and Volvo |
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Data linked with the rental/lease/hire/use/loan of a Vehicle like driver’s license number and status, license plate |
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Crime and fraud related data (mostly received from fraud prevention agencies and credit reference agencies) |
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Screening and sanctions related data including adverse media reports, presence on sanction lists, watchlists, political exposure, ultimate beneficial owners of the customer’s company, gift/hospitality recipient information (such as name, company/employer, involvement of any public official, role). |
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Usage data: data about the use that you make of a product or a service including routines and habits (that does not come from telematics data) |
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Insurance related data including accidents, insurance company’s name, etc. |
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Specifically about special categories of personal data
It is specifically noted that some aspects of health and safety data may be regarded as special categories of personal data under applicable data privacy laws and shall be handled with extra care and require additional protective measures.
Volvo will only process special categories of personal data if Volvo has a legal obligation or a legitimate business need to process such data (including but not limited to prudent practices to help manage widespread health emergencies). In such cases, we will inform you and (if required by law to do so) we will seek your explicit consent to process such data.
You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Specifically about CCTV monitoring
Volvo may use CCTV monitoring (as defined above) where permitted by law. CCTV monitoring is generally used to control and prevent unauthorized access to Volvo’s premises and equipment, however in some countries it may also be used for the purpose to ensure compliance with health and safety guidelines and procedures and for overall production improvement purposes. CCTV images and recordings are securely stored and only accessible on a need-to-know basis (for example, to look into an incident).
Specifically about automated decision-making
Volvo does not regularly and systematically perform automated decision making producing a legal effect concerning individuals or that would have a similarly significant effect. In the event that you are interacting with a Volvo company that is performing such automated decision making you should receive a specific notice that outlines the details of the automated decision making.
Volvo will primarily obtain your personal data from yourself or your employer or third parties with whom we do business (brokers, dealers, sales representative etc) or from which we get the data like for example financial and credit data and crime related data we get from credit reporting body, credit reference agencies, fraud prevention agencies. Such third parties are responsible for ensuring that they have the rights to use and share your data with others before sharing with us.
Some personal data might also be automatically generated from Volvo’s IT-system, or equivalent, for example when creating your user-id to Volvo systems.
Except for certain information that is required by law, your decision to provide any personal data to Volvo is voluntary.
However, please note that it is necessary for Volvo to process certain personal data to interact with its customers for business purposes and contractual obligations. Not providing personal data may hinder the handling and delivery of the products and services that you or your employer might expect from Volvo.
Your personal data may be shared with other Volvo Group companies and with certain categories of third parties (as further detailed below), which may involve transferring your personal data to other countries.
Sharing of personal data within the Volvo Group
The Volvo Group is a global organization with offices and operations throughout the world, and your personal data may be transferred or be accessible internationally throughout the Volvo Group’s global business and between its various entities and affiliates.
Any transfers of your personal data to other Volvo Group companies (including transfers from within the EU/EEA to outside the EU/EEA) will be governed by an intercompany agreement based on EU approved Standard Contractual Clauses or such other mechanisms as have been recognized or approved by the relevant authorities from time to time. Such agreement reflect the standards contained in European data privacy laws (including the EU General Data Protection Regulation).
Having this agreement in place means that all Volvo Group entities have to comply with the same internal rules. It also means that your rights stay the same no matter where your data are processed by Volvo Group.
Sharing of personal data with third parties outside of the Volvo Group
In addition to the sharing of personal data between Volvo Group companies as set out above, Volvo may also share your personal data with certain categories of third parties, including:
Governmental authorities:
Financial partners and other stakeholders:
Any third party service providers and professional advisors to whom your personal data are disclosed, are expected and required to protect the confidentiality and security of your personal data and may only use your personal data in compliance with applicable data privacy laws and regulations.
Further, in the event that any Volvo Group company that is located within the EU/EEA transfers personal data to external third parties that are located outside of the EU/EEA the relevant Volvo Group company will satisfy itself that there are appropriate safeguards in place which provide adequate levels of protection of your personal data as required by applicable data privacy laws (including the EU General Data Protection Regulation).
For example, this may include the use of EU approved Standard Contractual Clauses or such other mechanism as have been recognized or approved by the relevant authorities from time to time.
If you have questions about how Volvo will share your personal data, please contact the VOLVO Group Privacy Officer via the contact details set out above
Volvo utilizes appropriate and reasonable legal, technical and organizational security measures, including information technology security and physical security measures, to adequately protect personal data.
These measures are appropriate to the risks posed by the processing of personal data and to the sensitivity of the personal data and take into account the requirements of applicable local law. In addition, the measures are continuously improved in line with the development of available security products and services.
Volvo requires all persons to abide by applicable security policies related to personal data when using Volvo systems.
Volvo will keep your personal data as long as a legitimate business purpose exists for doing so (including but not limited to taking into account contractual periods, warranty and product liability requirements, legal reporting obligations and/or retention requirements necessary for anticipated disputes).
You may be entitled, where provided for under applicable data privacy laws and regulations, to:
Please note that Volvo may not always be obliged to comply with a request of deletion, restriction, objection or data portability. Assessment may be made on a case by case basis of Volvo’s legal obligations and the exception to such rights.
You also have the right to lodge any complaints you may have regarding Volvo’s processing of your personal data to a supervisory authority. For more information about these rights and how to exercise them, please contact the Volvo Group Privacy Officer via the contact details set out above.
Volvo encourages the periodic review of this Privacy Notice to stay aware of any changes to it.
We reserve the right to amend this Privacy Notice as needed. When we do, we will note near the top of this Privacy Notice the date that any such changes are made and/or when they become effective.