This version was published, and is valid from, 2021/05/13
This notice provides information on the Volvo Group’s processing of personal data of operators and drivers of Volvo Group products (“Privacy Notice”). If you are or have been the driver or operator of a truck, bus, coach, construction machine, marine engine or any other applicable product or solution integrating such product sold or produced by any of the companies belonging to the Volvo Group (below jointly referred to as “Volvo Vehicles”), we may process data about you or that can be linked to 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’s principal Business Areas and Truck Division (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 Operations ,Volvo Autonomous Solutions and Volvo Energy.
This Privacy Notice applies only when Volvo Group is collecting or otherwise processing personal data for Volvo Group’s purposes (i.e., when 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).
This Privacy Notice does not apply when 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.
For the sake of clarity, please note that this Privacy Notice only covers the Volvo Group’s processing of personal data in relation to operators and drivers of Volvo Vehicles. We will explain more about the categories of data we process in section “What categories of personal data may Volvo process, on which legal ground(s) and for what purposes?” below.
The processing of any other personal data that are provided by you, or on your behalf, in connection with the purchase, rental or leasing of products, solutions and services from the Volvo Group or its third party dealers/distributors are covered by the Customer Representative Privacy Notice, please see here: Customer Representative Privacy Notice.
Further, in addition to this Privacy Notice, some Volvo Group systems, applications, and processes as well as applicable Volvo Group research and development projects may have their own privacy notices, which provide additional details about what specific personal data is collected and how it is stored, used, and transferred.
The Volvo Group company that has sold and/or delivered the Volvo Vehicle that you are driving or operating (below referred to as “Volvo”) is the controller or processor of the personal data that Volvo obtains from you and the other sources described below.
“Controller” means that it is Volvo that decides on the purpose and means for the processing of your personal data. Volvo is responsible for the processing of your personal data under applicable data privacy laws and regulations.
If you have questions regarding the processing of your personal data, please contact the Volvo Group Privacy Officer at email@example.com or by post or phone at:
Att: Group Privacy Office, Dept AA14100, VGHQ
+46 (0)31 66 00 00
Volvo process various types of data either generated in or by a Volvo Vehicle, including what we refer to as vehicle related data, which includes (i) data related to the condition and performance of the Volvo Vehicle itself, (ii) data related to the actual operation of the Volvo Vehicle, (iii) data related to the surroundings of the applicable Volvo Vehicle, and (iv) data that either are related to the identification of a Volvo Vehicle or provided /generated by an individual. When this data, either alone or in combination with other data, can be linked to you as a driver or operator of a Volvo Vehicle, this becomes personal data.
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.
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.
Please note that the below list is a list of examples only and not intended as an exhaustive list, and that Volvo will not necessarily process all the data listed below about you. 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
Vehicle performance data, such as information from vehicle components, battery usage, engine data (including exhaust emission data and fuel consumption), 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 (exhaust emission data, fuel consumption); (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
Volvo generally obtain your personal data;
In addition to the above, Volvo may obtain certain additional data from your employer, or from you if you have manually entered personal data in connection with your use of a Volvo Vehicle (e.g. dashboard settings such as language preferences, radio preferences, seat inclination settings).
If and when you use a Volvo Vehicle, Volvo will automatically obtain vehicle generated and other vehicle related data relating to your use of the Volvo Vehicle. The processing of certain vehicle generated and other vehicle related data is necessary if you want to use all features and functionalities of Volvo Vehicles, such as real time notices and remote diagnostic services.
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:
- 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 suppliers and service providers who support Volvo in the delivery of products, solutions and services, including IT suppliers and service providers;
- Volvo’s 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); and
- Third parties with whom we transact or collaborate to provide products, solutions or services 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.
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 not process your personal data longer than necessary given the purpose of the processing, unless otherwise required or permitted by law.
Please note that, unless shorter retention times apply due to legal or contractual obligations, 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. for research and development projects or to ensure that Volvo can manage product liability claims).
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.
Please further note that restrictions or objections on processing certain data may have negative consequences for your use of Volvo Vehicles. If certain 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.
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.