Vehicle generated data is information that is generated by a Volvo Vehicle, including data related to the condition and performance of the vehicle itself and data related to the actual operation of the vehicle by the driver or operator and other vehicle related data is data that is otherwise related to a Volvo Vehicle.
If certain Vehicle generated data or other vehicle related data can, by itself or in combination with other data, be connected to you as an individual, such data is considered as personal data.
Volvo processes the following categories of vehicle generated data and other vehicle related data, which may constitute personal data (please note that Volvo will not necessarily process all the data listed below):
- Vehicle performance data, such as technical vehicle data, information from vehicle components, battery usage, engine data, energy consumption, power/torque data, fault codes (with times stamps and operating hours).
- Vehicle usage data, such as brake usage, gear shifting, acceleration/deceleration, dashboard settings, power/torque utilization, technical data generated from the engine; (with time stamps and operating hours).
- Vehicle service and repair data as well as emergency assistance data, such as geographic position, data for remote diagnostics.
- Vehicle surroundings data, such as road and ambient conditions data, video recordings and/or recordings generated by optical-electronic instruments or comparable equipment of the outside of the truck and/or the truck’s surroundings (with time stamps and operating hours).
- Vehicle or non-vehicle related unique identifiers, such as the vehicle-ID (including VIN and chassis ID), IP number, MAC address, SIM card number, IMEI.
- Driver/operator behavior and location data, such as speed data, driving pattern; seatbelt usage, driver alerts, instantaneous geo-positioning data and location data (with time stamps and operating hours).
- Driver/operator related data that may be manually provided by the driver/operator in connection with the use of certain Volvo Vehicles, such as driver ID, dashboard settings.
Further, with regards to personal data processing performed in connection with studies, clinics and research and development projects you participate in, the categories of personal data that will be collected may include additional categories of personal data if so stated in a consent form, separate privacy notice or project specific information provided to you prior to the start of your participation in the project, if any.
Legal basis and purposes of the processing
Volvo may process vehicle generated and other vehicle related personal data based on legitimate interest. Volvo’s legitimate interest include the interest to manage its daily operations, including to enhance and further develop its products, solutions and services offering and to secure the overall management of sold products, solutions and services.
Therefore, Volvo may process vehicle generated and other vehicle related personal data for the following purposes:
- perform research and development to enhance and maintain products, solutions and services and to develop new products, solutions and services, e.g. through innovation and data analytics.
- solve quality issues (quality related development).
- perform accident research investigations.
- manage warranty and product liability claims.
- verify contract compliance or to be able to deliver services contracted for (e.g. confirming that required maintenance and servicing is being done throughout the lifetime of a lease; or to verify mileage for usage based contracts; or to verify location for compliance with contract terms and/or trade sanction restrictions);
- perform proactive maintenance and diagnostics (including deliver software updates to the vehicle and contact the driver/operator with service recommendations).
- manage routine floorplan audits (wholesale/dealer financing) and other inventory audits for legitimate business purposes,
- manage repossessions and recovery and credit underwriting.
- manage structured financing solutions for Volvo.
- provide joint customer service offerings together with co-operation partners.
- operation of autonomous transport solutions.
- to exercise Volvo’s legal rights and to defend Volvo towards legal claims.
Volvo may process vehicle generated and other vehicle related personal data if Volvo considers such processing as necessary in order to comply with:
- court orders and other legitimate requests from law enforcement agencies, regulatory authorities as well as other public or judicial bodies.
- regulatory compliance surveillance (e.g. compliance with trade sanctions).
- legal requirements under applicable laws and regulations e.g. to demonstrate compliance with applicable type approval regulations or to enable reporting of emission data to competent authorities.
Volvo may use or share vehicle generated and other vehicle related personal data with credible third parties if Volvo has valid reasons to believe that the use or sharing of such data may prevent or reduce any significant potential harm to you or others.
In exceptional cases and only when no other legal ground can be applied, Volvo may ask separately for your consent to process your personal data.
Further, if Volvo’s processing of your personal data pertains to certain studies, clinics or research and development projects, such processing may in certain cases be based on consent provided by you in connection with your participation in such studies, clinics or research and development project.