Privacy Notice for Operators and Drivers of Volvo Vehicles

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 

Legitimate interest

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.

Legal obligation

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.

Vital interest

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.

Your consent

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.

Volvo generally obtain vehicle generated and other vehicle related personal data;

• interactively over the wireless network in connection with the use of Volvo Vehicles (e.g. via the telematics gateway) or
• using diagnostic tools (e.g. in connection with proactive maintenance and repair services).

Further, Volvo may obtain certain additional data from you if you manually enter personal data in connection with your use of a Volvo Vehicle, e.g. dashboard settings such as language preferences, radio preferences, seat inclination settings.

In connection with various studies, clinics and research and development projects, Volvo may process the personal data provided by you to Volvo during the study, clinic or project, including the personal data which has been generated during the study, clinic or project (e.g. by the vehicle or the equipment which was mounted in the vehicle for the purpose).

Volvo will normally not share vehicle generated and other vehicle related personal data with anyone outside of Volvo. However, Volvo may, if required by applicable laws or regulation, if necessary for the purpose of a legitimate interest pursued by Volvo or if necessary to fulfill the purpose for processing the personal data, share your personal data with certain categories of third parties, including:

Business partners, such as

• Volvo’s authorized dealers and service centers for the purpose of ensuring service and repair of Volvo Vehicles and for purposes connected with our finance and insurance offerings.
• Volvo’s trusted suppliers and service providers who support Volvo in the delivery of its products, solutions and services, including IT suppliers and service providers.
• Volvo’s trusted business and co-operation partners for purposes such as business intelligence and analytics purposes (however, in most cases the data is only shared on an anonymized and aggregated basis).
• Third parties with whom we transact or collaborate to provide products, solutions or services (including but not limited to third party lenders such as syndication or securitization partners to whom we may transfer an interest in and to our receivables) and other third parties with whom we seek to innovate, develop and deliver new or improved products, solutions and services to our customers or new or improved internal processes and operations, all of which ultimately enhance how we can support our customers.

Law enforcement, regulatory authorities, other public and judicial bodies in connection with legal requirements, legal orders and other legitimate requests relating to Volvo, its customers or drivers/operators of Volvo Vehicles.

Emergency service providers, such as the police, ambulance and roadside assistance providers (e.g. in connection with the use of Volvo Action Services);

Professional advisors, such as Volvo accountants, lawyers, insurers, bankers, and other professional advisors.

Other legitimate third parties, such as potential buyers and their professional advisors in connection with merger and acquisition projects.

If Volvo shares your vehicle generated and other vehicle related personal data with third parties, Volvo will use all reasonable endeavors to ensure that those third parties keep your personal data secure and confidential as required by applicable data protection laws.

Further, Volvo may transfer personal data outside of the EU/EEA to other Volvo Group companies as well as third parties within the categories and for the purposes set out above. In such case, if the country is not offering an adequate level of protection for the processing of personal data according to EU standards, Volvo will use all reasonable endeavors to secure that appropriate safeguards are in place, which provide adequate levels of protection of your personal data as required by applicable data protection laws. For example, this may include the use of intercompany or external data processing agreements based on EU approved Standard Contractual Clauses or EU-US Privacy Shield or such other mechanisms 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 Volvo’s group privacy officer as per the contact details set out above.

Volvo will not keep your personal data longer than necessary given the purpose of the processing, unless otherwise required or permitted by law.

Please note that vehicle generated and other vehicle related personal data connected to a certain vehicle may be processed for the entire expected life of the vehicle type, which could be up to 25 years (e.g. to ensure that Volvo can manage product liability claims).

Concerning clinics, studies and research and development projects, your personal data may be kept for up to 25 years from the date of collection.

You have the right to request from Volvo information about the personal data processed about Volvo and access to such personal data.

You also have a right to request rectification of your personal data if this is incorrect and request erasure of your personal data.

You also have a right to request restriction of the processing of your personal data meaning that you request Volvo to limit its processing of your personal data under certain circumstances.

Please note that restrictions on processing certain vehicle generated or other vehicle related personal data may have negative consequences for your use of Volvo Vehicles. If certain vehicle generated or other vehicle related personal data is disabled you may not be able to use all the features and functionality of the Volvo Vehicle and Volvo may not be able to notify you about issues with the vehicle in real time. This may cause reduced functionality of the vehicle and could result in the damage or inoperability of the vehicle.   

Please note that if you have given a consent for the processing of your personal data you have the right to withdraw your consent at any time. Upon such withdrawal Volvo will cease the further processing of the related personal data, but it does not affect the legality of the processing activities prior to the withdrawal.

You also have a right to object to the processing of your personal data based on legitimate interest or processing for direct marketing.

Further, you have a right to data portability (transfer of your personal data to another controller) if Volvo’s processing of your personal data is based on consent or contractual obligation and is automated.  

Please note that Volvo may not always be obliged to comply with a request of deletion, restriction or data portability. Assessments will be performed 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’s group privacy officer as per the contact details set out above.

More information about Data Subject Rights