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Privacy Notice

Vehicle mounted Camera Equipment

This notice provides information on the Volvo Groups processing of personal data about you, if you are an individual who has been recorded or detected by cameras, optical-electronic instruments, equipment that is able to record audio and/or other similar equipment (“Camera Equipment”) installed in or mounted on a machine such as a vehicle, construction equipment or other type of machinery (a “Vehicle”) and where recordings and detections have been made of a Vehicle’s surroundings, (“Privacy Notice”).

 

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, Arquus, Volvo Penta, Mack Trucks, UD 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 and Volvo Autonomous Solutions. 

 

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.

 

Identity and contact details of the controller and group privacy officer

 

The Volvo Group company who process personal data from the Camera Equipment for the below mentioned purposes (“Volvo”) is the controller of the personal data that Volvo obtains from the sources described below and thus responsible for the processing of such personal data under applicable data protection laws and regulations.

 

“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 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


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.

  • 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 as well as European and international standards.
  • 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, including to enhance and further develop its products, solutions and services offering and to secure the overall management of sold products, solutions and services.

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 Group Privacy Officer via the contact details set out above.

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

Camera Equipment recordings of a Vehicle’s surroundings (vehicle registration numbers or individuals, faces, distinctive clothing, specific body movements, specific anatomy, other elements which may be used to identify a natural person).

Research and development purposes (including but not limited to the development of automatic functions in Vehicles), such as to analyse the behaviour and functions of Vehicles and other Volvo Group products and the behaviours of drivers in order to use the information to further develop and make improvements from a safety, efficiency, environmental and ergonomics perspective as well as to comply with current and future legislations and standards regarding these purposes;

 

Validation and verification of Volvo Group products, services and systems.

 

The above-mentioned purposes include the following sub-purposes:

- managing product portfolios,

- managing product projects,

- developing new technology,

- performing feasibility studies,

- developing new concepts,

- developing solutions, and

- industrializing & launching of total offers;

 

Prevent, identify and solve quality issues related to Volvo Group products and services. To identify such quality issues, personal data is collected through accident research investigations and root cause analysis.

Prevention of quality issues include e.g. the following sub-purposes;

- developing products and aftermarket product portfolios, and

- analysing customer feedback for quality improvements;

Operate autonomous Vehicles, such as to analyse the behaviour and functions of Vehicles and other Volvo Group products and the behaviours of drivers in order to use the information to operate the autonomous Vehicles from a safety, efficiency, environmental and ergonomics perspective as well as to comply with current, future legislations and standards including any contractual obligations regarding these purposes; and

 

Defend and/or establish legal claims (to defend and maintain Volvo’s assets and property as well as defend Volvo from any third party claims)

Legitimate interest

Comply with legal obligation

 

Camera Equipment material in real time (meaning that no recordings are made and stored) of a Vehicle’s surroundings.

Research and development purposes (including but not limited to the development of automatic functions in Vehicles), such as to analyse the behaviour and functions of Vehicles and other Volvo Group products and the behaviours of drivers in order to use the information to further develop and make improvements from a safety, efficiency, environmental and ergonomics perspective as well as to comply with current and future legislations and standards regarding these purposes;

 

Validation and verification of Volvo Group products, services and systems.

 

The above-mentioned purposes include the following sub-purposes:

- managing product portfolios,

- managing product projects,

- developing new technology,

- performing feasibility studies,

- developing new concepts,

- developing solutions, and

- industrializing & launching of total offers;

 

Prevent, identify and solve quality issues related to Volvo Group products and services. To identify such quality issues, personal data is collected through accident research investigations and root cause analysis.

Prevention of quality issues include e.g. the following sub-purposes:

- developing products and aftermarket product portfolios, and

- analysing customer feedback for quality improvements;

Operate autonomous Vehicles, such as to analyse the behaviour and functions of Vehicles and other Volvo Group products and the behaviours of drivers in order to use the information to operate the autonomous Vehicles from a safety, efficiency, environmental and ergonomics perspective as well as to comply with current, future legislations and standards including any contractual obligations regarding these purposes; and

Defend and/or establish legal claims (to defend and maintain Volvo’s assets and property as well as defend Volvo from any third-party claims)

Legitimate interest

Comply with legal obligation

 

Lidar images.

Research and development purposes (including but not limited to the development of automatic functions in Vehicles), such as to analyse the behaviour and functions of Vehicles and other Volvo Group products and the behaviours of drivers in order to use the information to further develop and make improvements from a safety, efficiency, environmental and ergonomics perspective as well as to comply with current and future legislations and standards regarding these purposes;

 

Validation and verification of Volvo Group products, services and systems.

 

The above-mentioned purposes include the following sub-purposes:

- managing product portfolios,

- managing product projects,

- developing new technology,

- performing feasibility studies,

- developing new concepts,

- developing solutions, and

- industrializing & launching of total offers;

 

Prevent, identify and solve quality issues related to Volvo Group products and services. To identify such quality issues, personal data is collected through accident research investigations and root cause analysis.

Prevention of quality issues include e.g. the following sub-purposes:

- developing products and aftermarket product portfolios, and

- analysing customer feedback for quality improvements;

Operate autonomous Vehicles, such as to analyse the behaviour and functions of Vehicles and other Volvo Group products and the behaviours of drivers in order to use the information to operate the autonomous Vehicles from a safety, efficiency, environmental and ergonomics perspective as well as to comply with current, future legislations and standards including any contractual obligations regarding these purposes; and

Defend and/or establish legal claims (to defend and maintain Volvo’s assets and property as well as defend Volvo from any third-party claims)

Legitimate interest

Comply with legal obligation

Volvo processes personal data that we have collected from you by using Camera Equipment that is mounted onto specific Vehicles. The personal data may therefore be obtained by Volvo when a Vehicle owned or operated by either Volvo, you, or, you as a driver of a Vehicle, passenger or pedestrian, pass or get passed by such Volvo Group branded Vehicle that uses Camera Equipment. 

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:

  • Business partners, such as third parties with whom we transact or collaborate with to provide and deliver products, solutions or services, third parties with whom we seek to innovate, develop and deliver new or improved products, solutions, services or internal processes and operations with, all of which ultimately enhance how we can support our customers.
  • 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 others such as in connection with emergency assistance.

 

  • Law enforcement, regulatory authorities 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.

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.

If Volvo is not able to either automatically or manually anonymize (blur) or delete your personal data in connection with the creation of the recordings, the personal data will be kept by Volvo in accordance with the following retention periods:

-  For the purposes of R&D, validation and verification as well as to solve quality issues, for five (5) years. When the R&D activity or any activities under “solving quality issue” are based on a legal obligation, the retention period is as required by applicable law.

-  For the purposes of operating autonomous Vehicles, Volvo will process the personal data for the time necessary for the purpose or for a maximum of five (5) years.

-   Volvo will process the personal data for the time necessary for the purpose of defending and/or establishing legal claims or for a maximum of 10 years after a claim has been addressed or at the latest 10 years after a claim otherwise has been finally settled by agreement, by competent authority or in a court of law.

Your data protection rights

 

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 Group Privacy Officer via the contact details set out above.