This notice provides information on VOLVO BUS CORPORATION 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 vehicle and where recordings and detections have been made of a Vehicle’s surroundings, (“Privacy Notice”).
For the purpose of this notice, Volvo Buses means VOLVO BUS CORPORATION incorporated with company registration number 556197-3826.
This Privacy Notice applies only when Volvo Buses is collecting or otherwise processing personal data for Volvo Buses’ purposes (i.e., when Volvo Buses (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 Buses is collecting or otherwise processing personal data on behalf of another company, such as Volvo Buses’ independent dealers, importers, suppliers, and customers.
Volvo Buses process personal data from the Camera Equipment for the below mentioned purposes. Volvo Buses is the controller of the personal data that Volvo Buses 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 Buses that decides on the purpose and means for the processing of your personal data. Volvo Buses 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 Gothenburg, Sweden +46 (0)31 66 00 00
Refer to “Volvo Buses usage of vehicle mounted camera”
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 basis
Volvo Buses may process your personal data based on any one or more of the following legal bases, see also further details below.
· Legal obligation. Volvo Buses 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 Buses may process your personal data if such processing is necessary for the purposes of a legitimate interest pursued by Volvo Buses or a third party. It is generally considered to be in Volvo Buses’ 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 Buses relies on its legitimate interests for a given processing purpose, Volvo Buses is of the opinion that its legitimate interests are not overridden by your interests, rights or freedoms given (i) the transparency Volvo Buses provides on the processing activity, (ii) Volvo Buses’ privacy by design approach, (iii) Volvo Buses’ 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.
· Performance of a contract. Volvo Buses may process your personal data if the processing is necessary in order for Volvo Buses to provide you with products, services or otherwise perform a contract between you and Volvo Buses (this applies if you conduct your business in a sole proprietorship), or to take steps at your request prior to entering into a contract.
Volvo Buses may process the following categories of data which, in itself or in combination with other data, may constitute personal data, and for the purposes stated in the tables below.
What we do and why:
We will use your personal data for research and development purposes (including but not limited to the development of functions in Vehicles), such as to analyse the behaviour and functions of Vehicles and other Volvo Buses 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. We will also use your personal data to comply with current and future legislations and standards regarding these purposes.
Please note that the below list is a list of examples only and not intended as an exhaustive list, and that Volvo Buses 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.
The personal data that we process:
Volvo Buses 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 Buses when a Vehicle owned or operated by either Volvo Buses, you, or, you as a driver of a Vehicle, passenger or pedestrian, pass or get passed by such Volvo Buses branded Vehicle that uses Camera Equipment.
· 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).
· 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).
· Light Detection and Ranging (“LiDAR”) images (high resolution LiDAR which are of such quality that the images contain elements which may be used to identify a natural person).
We will share your personal data to the following recipients;
· 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.
How we transfer data:
We will transfer personal data to countries outside the European Union (“EU”)/European Economic Area (“EEA”) to the recipients listed below, you can find more information on how we transfer your data by clicking here.
Other Volvo Group entities - as Volvo Buses is a part of the Volvo Group which is a global organization with offices and operations throughout the world, your personal data may be transferred or be accessible internationally throughout the Volvo Group’s global business and between its various entities and affiliates outside the EU/EEA.
How long we keep your data:
If Volvo Buses 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 Buses for a limited time, assessed versus privacy impact in each case, or the period required by applicable law.
We may also process your personal data in addition to what is described above so that you, or the company you represent, we ourselves, or any relevant third party can establish, exercise or defend its legal claims, e.g., to defend and maintain Volvo Buses assets and property as well as defend Volvo Buses from any third party claims.
Volvo Buses will process the personal data for the time necessary for the purposes described above or for a maximum of ten (10) years after a claim has been addressed or at the latest ten (10) years after a claim otherwise has been finally settled by agreement, by competent authority or in a court of law.
You have the right to request access to your personal data. You also have the right to request VOLVO to rectify or erase your personal data or restrict the processing of the same. You may also object to VOLVO’s processing of your personal data or request data portability. However, please note that VOLVO may not always be obliged to comply with a request of deletion, restriction, objection or data portability. Assessment will be made on a case by case basis of VOLVO’s legal obligations and the exception to such rights. You can read more about your rights here.
Please note that Volvo Buses 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 Buses’ legal obligations and the exception to such rights.
You also have the right to lodge any complaints you may have regarding Volvo Buses’ processing of your personal data to a supervisory authority. The data protection authority in Sweden is ‘Integritetsskyddsmyndigheten’.