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Private Dealer and Importers Privacy Notice

 

This version was published, and is valid from, 2026/02/09

 

This notice provides information on processing of personal data of its private dealer, and private importers and their representatives by a company which is part of the Volvo Group (“Privacy Notice”). If you are, or have been, employed or engaged by a company, that is a private dealer or private importer or a potential private dealer or private importer of 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’s principal Business Areas and Truck Divisions (as may exist from time to time) such as Volvo Trucks, Volvo Buses, Volvo Construction Equipment, Renault Trucks, 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 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).

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.

The Volvo Group company that you or your employer may be a private dealer or private importer for, (below referred to as “Volvo”) is the controller 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 Chief Privacy Officer at gpo.office@volvo.com or by post or phone at:

AB Volvo,
Att: Group Privacy Office, Dept AA14100, VGHQ
SE-405 08
Göteborg, Sweden
+46 (0)31 66 00 00

If you are in the United Kingdom, Volvo Group UK Limited is Volvo’s representative in the United Kingdom, contact details below:

Volvo Group UK Limited,
Att: Legal Department
Wedgnock Lane
Warwick
United Kingdom
CV34 5YA

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 that 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 ground

Volvo may process your personal data based on any one or more of the following legal grounds, see also further details below.

  • Contractual obligation. Volvo may process your data if such processing is necessary to fulfil a contractual obligation towards you e.g. to fulfill the terms and conditions of a contract for the provision of products and/or services signed with you or your employer.
  • Legal obligation. Volvo may process your personal data if such processing is necessary to comply with a legal obligation, e.g. to comply with court orders and legal reporting requirements.
  • Legitimate interests. Volvo may process your personal data if such processing is necessary for the purposes of a legitimate interest pursued by Volvo or a third party. It is generally considered to be in Volvo’s legitimate interest to manage its daily operations according to lawful and fair business practices, including managing its relationships with its dealers and importers in order to perform contract(s) to which you or your employer is a party and/or to take steps necessary prior to entering into a contract with you or your employer. As an example, Volvo will need to know your preferred language, to be able to communicate properly with you in day-to-day activities
    Where it is stated herein that Volvo relies on its legitimate interests for a given processing purpose, Volvo is of the opinion that its legitimate interests are not overridden by your interests, rights or freedoms given (i) the transparency Volvo provides on the processing activity, (ii) Volvo’s privacy by design approach, (iii) Volvo’s regular privacy review and (iv) the rights you have in relation to the processing activity. If you wish to obtain further information on this balancing test approach, please contact the Volvo Chief Privacy Officer via the contact details set out above.
  • Consent. In exceptional cases or if no other legal ground can be applied, Volvo may ask for your explicit consent to process certain personal data. Such consent is your choice and is entirely voluntary.

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

Contact data, such as name, e-mail and telephone number

 

  • Enabling keeping an up-to-date record of dealer and importer representatives in Volvo’s CRM and Dealer systems enabling communication with the dealer and/or importer.
  • Enabling creation of quotes, orders and invoices.
  • Management of customer complaints and warranty claims.
  • Enabling management of technical support requests
  • Support claim validation process
  • Legitimate interest (to manage the provision of products and services and warranty claims and interest to reduce time to answer claim and increase fairness).

 

Organizational data, such as job position, place of work and country

 

  • Enabling trainings of dealer and importer contacts and mechanics.
  • Training of AI
  • Support claim validation process
  • Legitimate interest (to manage dealer and importer performance, maintain and develop products, solutions, services and applications and to reduce time to answer claim and increase fairness)

Individual data, such as hourly rate and names
  • Analyze performance of dealer and importer contacts
  • Training of AI model to support claim validation process
  • Legitimate interest (to manage dealer and importer performance and to reduce time to answer claim and increase fairness)

 

 

 

Individual data, such as preferred language, photo, clothing size and food preferences

 

 

  • Event and customer meetings and exhibitions

 

 

 

  • Legitimate interest (to manage dealer and importer relationship)
  • Consent with the individual (for individual preferences and photos)


IT-related data, such as user-ID, passwords, log-in details as well as data and logs about use of Volvo’s ITequipment, application or services
 
  • Enabling the use of Volvo’s dealer and importer related applications and systems · 
  • User-ID is used for training of AI-model to support claim validation process

 

  • Legitimate interest (to manage user access, data protection and cyber security in general)

 

 

Individual data, Audio recordings

 

 

  • Enabling the provision of breakdown services

 

  • Legitimate interest (to deliver customer services)

 

 

Location data, such as technicians location; Country, City, County, Province, Region, State, Street

 

 

  • Enabling provision of breakdown services
  • Performing research and development to verify, validate, enhance and maintain products, solutions, services and applications and to develop new products, solutions, services and applications

 

 

  • Legitimate interest (to deliver customer services and maintain and develop products, solutions, services and applications)



CCTV monitoring

 

 

  • Monitoring safety and of workshop personnel on Volvo owned premises

 

  • Legitimate interest (to ensure safe workplace)

 

 

 

Free text fields data

 

  • Training of AI-model · Support claim validation process

 

  • Legitimate interest (to maintain and develop products, solutions, services and applications and to reduce time to answer claim and increase fairness

 

 

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. In such cases, Volvo will inform you and (if required by law to do so) seek your explicit consent to process such data. You should be aware that it is not the condition of your contract with us that you agree to any request for consent from us.

Specifically, about CCTV monitoring

Volvo may use company closed circuit television (CCTV monitoring) on its premises where permitted by law. Please note that the processing of CCTV-related personal data is not covered by this Privacy Notice but by the Privacy Notice for Visitors.

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 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 the company you work for.

Some personal data might also be automatically generated from Volvo’s IT-system, including any applicable dealer and importer management systems, or equivalent, for example when creating quotes, breakdown cases and your user-id to Volvo systems.

Except for certain information that is required by law or according to contractual obligations, 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 dealers and importers for business purposes. Not providing personal data may potentially hinder you or your employer from purchasing products and services 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

Volvo 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 and/or from the UK to outside of the UK) 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, and other required jurisdictional safeguards. Such agreement reflects 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 must comply with the same internal rules. It also means that your rights stay the same no matter where your data is processed by Volvo Group.Sharing of personal data with third parties outside of the 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:

  • Business partners, such as Volvo Group’s suppliers and service providers in connection with their provision of products and services to the Volvo Group, such as IT service providers.
  • Professional advisors, such as insurers, lawyers and other professional advisors in connection with insurance claims, audits and the receipt of advisory services.
  • Counterparties and their advisors, in connection with merger and acquisition projects.
  • Emergency service providers, such as the police, fire brigade, ambulance and roadside assistance to protect the vital interest of you and other such as in connection with emergency assistance.
  • Governmental authorities:
    • In the field of law enforcement: regulatory authorities, governmental agencies and other public and judicial bodies in connection with legal obligations such as court orders or legal reporting requirements or if considered necessary in exceptional cases to protect the vital interest of you or others.
    • Public authorities in charge of export control and customs

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 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 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 the VOLVO Chief 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 consider 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 people to abide by applicable security policies related to personal data when using Volvo systems.

Volvo will keep your personal data as long as required to fulfill its legal rights and obligations taking into account for example the contractual term and the warranty periods. After that Volvo will only process your personal data for such time as it may be required to comply with local legal obligations or to satisfy any legal requirements in the event of an actual, threatened or anticipated dispute or claim

You may be entitled, where provided for under applicable data privacy laws and regulations, to:

  • Request access to the personal data Volvo process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of the specific pieces and categories of personal data.
  • Request a rectification of your personal data: this right entitles you to have your personal data corrected if it is inaccurate or incomplete.
  • Object to the processing of your personal data: this right entitles you to request that Volvo no longer processes your personal data.
  • Request the erasure or deletion of your personal data: this right entitles you to request the erasure or deletion of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
  • Request the restriction of the processing of your personal data: this right entitles you to request that Volvo processes your personal data only in limited circumstances, including with your consent.
  • Request portability of your personal data: this right entitles you to receive a copy (in a portable and, if technically feasible, readily usable format) of your personal data, or request Volvo to transmit such personal data to another data controller.
  • In the event that our processing of your personal data or part thereof is based on your consent, to withdraw at any time your consent, in which case Volvo will cease any further processing activities of your personal data or the relevant part thereof (however such withdrawal will not affect the legality of the data processing activities prior to the withdrawal).

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 Chief 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.

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