Volvo Cars Privacy Notice – Vehicle Connectivity Services

1. How we collect and use your personal information

1.1 Information you provide to us

1. To create your head unit login account

When you use the in-vehicle infotainment of Volvo Vehicle Connectivity Services, you may need to provide us with your avatar, nickname, for creating your head unit’s account. We collect the above information to help you log in to your in-vehicle infotainment and its applications. We will use your nickname and avatar as the account name and icon for the in-vehicle infotainment, and the personal information collected is only stored in the in-vehicle head unit.

If you refuse to provide the above information, we will not be able to create a head unit login account for you, but you can use the functions of Volvo Vehicle Connectivity Services as a visitor.

1.2 Information collected in your use of products or services

1. To provide you with Digital Key Sharing service

In order to facilitate the digital key sharing service, you can share your digital key with other users via the Wallet function of “Volvo Cars App”. We will collect your digital key sharing rights, the shared user’s phone number, and digital key data. When the shared user approaches the vehicle with the NFC device containing the digital key, vehicle doors can be opened and closed.

2. To provide you with Vehicle Location service

In order to provide vehicle location service, we need to collect Vehicle location information (current GPS location of the vehicle), Vehicle Identification Number (VIN), and transmit above information to your “Volvo Cars App” to help you find your vehicle quickly by using audible and visual signals.

3. To provide you with Remote Vehicle Anti-theft Alerts, Locking and Stolen Vehicle Tracking service

In order to prevent unauthorized access to your vehicle, the vehicle will activate warning signals with dual flashing lights and horn and sends an unauthorized alert signal (including the vehicle location and time) to your “Volvo Cars App” upon detecting unauthorized access.

When you send a lock request to the customer service center, the center will send a lock command to the vehicle, resulting in all keys ineffective. Meanwhile, the customer service center will collect vehicle location information and store it in the cloud. After you locate the vehicle, the customer service center will send a key activation signal to your vehicle to unlock it and activate all the keys. During this process, we will collect your vehicle location information, locking status information, and key deactivation/activation signals to fulfill your request.

If your vehicle is removed without authorization, you may make a tracking request to our customer service center. Our customer service center will collect time-stamped vehicle location information and Vehicle Identification Number (VIN) to help you recover your vehicle.

4. To provide you with Trip Reservation service

When you make a trip on reservation on the Volvo Cars Head unit or “Volvo Cars App”, we will collect the settings of your reservation, including reservation time, the cycle conditions of the reservation, battery status information, information about the cabin environment settings during the trip to facilitate battery charging, and prepare the cabin in advance according to your settings.

5. To provide you with Driver Fatigue and Distraction Detection service

In order to ensure driving safety, when you enable the “Driver Status Monitoring” function, we will monitor your driving status to assess your fitness for driving and provide you with alerts when necessary. For this purpose, we will collect your face image information and analyze features such as your head position, eye position, and whether your eyes are closed, and convert them into assessment values to determine your fatigue or distraction level and provide you with appropriate alerts.

The “Driver Status Monitoring” function processes all video images only within the cabin of your car. After converting them into assessment values, the collected facial images will be deleted and there is no storage of the facial images within the vehicle or uploading them to cloud servers. You can enable or disable this function via the consent switch.

6. To provide you with Vehicle Control service

When your vehicle is connected with the “Volvo Cars App” and managed or controlled through the app, including functions such as locking or unlocking the vehicle, keyless entry, unauthorized entry alert, battery status management, scheduled charging, driver mileage calculation, window switches, rear door switches, steering wheel heating control, maximum defrosting, cabin air pre-adjustment, parking environment display, parking comfort mode activation, remote dashboard control, low tire pressure monitoring (the display of vehicle control service “Volvos Cars App” shall prevail). We will collect relevant information of your vehicle (e.g., Vehicle Identification Number (VIN), range, battery power information, battery temperature, average speed, mileage information, tire pressure, ECU abnormality information, headlight blinking information, door/window/trunk/ventilation system switching status information, status of other functions such as locks, doors, windows, etc.) and synchronize the above information in the “Volvo Cars App” for display.

7. To provide you with Vehicle Personal Settings and Vehicle Document Management

In order to facilitate the management of your cabin settings, we will collect your Vehicle Identification Number (VIN) and the head unit login account. Specifically, through the personal settings function, you can adjust seat position, steering wheel position, rearview mirror position, personalized lighting settings, driver seat entry and exit settings, unit and general settings, reverse-linked wiper settings, as well as mode-switching linked sound switch. Throughout this process, we will collect relevant setting information.

To enable you to view and edit your vehicle document information on the "Volvo Cars App" and the head unit central control screen, we will collect and display your vehicle's basic attributes information (vehicle color, type, license plate number, Vehicle Identification Number (VIN)), after-sales certificate authentication, vehicle health status, basic user information (phone number, emergency contact name, driver's license number, photo, real-name authentication information), vehicle personal settings, and service subscription information.

8. To provide you with Vehicle User Manual

In order to provide you with the corresponding vehicle user manual for your specific car model and display the comprehensive vehicle features, we will collect your Vehicle Identification Number (VIN).

9. To provide you with Vehicle Maintenance Reminders

In order to send you timely Vehicle Maintenance Reminders, we will collect data such as the actual mileage since your last maintenance reset, total mileage, remaining time until the next scheduled maintenance after the last full vehicle maintenance reset, and remaining mileage. Through data analysis, we calculate appropriate intervals and push maintenance reminder messages to your "Volvo Car App" or the central control screen in your vehicle.

In order to ensure timely maintenance of your vehicle, we will collect information such as the actual mileage since your last maintenance reset, total mileage, the remaining time and mileage for the next full vehicle maintenance after the last reset. Through data analysis, we calculate and send maintenance reminder messages to your “Volvo Car App” or the head unit central control screen at the appropriate times.

10. To provide you with Vehicle Log service

When you use the Vehicle Log inquiry function on the “Volvo Cars App”, we need to collect information from your vehicle, including its location, speed, total mileage, and battery consumption. This data is collected for the purpose of summarizing and sending it to your “Volvo Cars App” for display.

If you wish to remove the location information from the Vehicle Log, you may do so in the “Volvo Cars App”.

11. To provide you with Event Data Recorder service

To comply with the related legal requirements, we may collect and store safety-related information relating to crash or near-crash situations in an Event Data Recorder (EDR) – also known as the car’s “black box”. The safety-related information includes data:

Please noted that recording only takes place if a non-trivial collision situation occurs, and no data is recorded under normal driving conditions. Furthermore, the recording does not include who is driving the vehicle or the geographical location of the (near) crash. Please understand that the Event Data Recorder service is a core business functions we provide. Your refusal of our collection may hinder us to provide you with relevant services with Volvo Vehicle Connectivity Services.

12. To provide you with Vehicle Diagnostic Service

In order to remotely assist in diagnosing the cause of vehicle malfunctions, we will collect the vehicle data based on specific trigger conditions, which includes the Vehicle Identification Number (VIN), vehicle diagnostic data, time of the data collection, and metadata related to the collected data (such as the chassis number, vehicle model, vehicle production cycle, and the name of the system providing vehicle diagnostic data). All of the aforementioned data will be uploaded to the cloud platform for market operation and maintenance personnel to diagnose vehicle malfunctions.

13. To meet the national requirements for data collection on new energy vehicles

According to the laws and regulations in China, we will collect data including the vehicle's speed, location, electric drive, battery, and alarm events and transmit the data to a platform established by Volvo, designed to provide safety operation services and management in compliance with legal requirements.

14. To provide you with Over the Air Update service

In order to be able to maintain and update necessary vehicle software and hardware directly, we may collect the following data:

If you refuse Over the Air Update service, this will prevent you from being able to use our updated services. Failure to update may also increase the risk of cybersecurity incidents, much like in the case of all other smart devices. Note that you can also opt to have the updates installed in one of our 4S shops. Your refusal of our collection may hinder us to provide you with Over the Air Update service, without impacting on the basic functions of Volvo Vehicle Connectivity Services.

If you have enabled the Over the Air Update service, you can disable this service by going to Over the Air interface of “Volvo Cars App” to terminate our collection of your personal information.

15. To provide you with Emergency Call (eCall) function

In order to ensure your safety, we have developed Emergency Call (eCall) function, which is made automatically to customer Service center in the event of a severe accident, detected by activation of one or more sensors within the vehicle, so that we can more quickly initiate rescue measures in the most appropriate manner after an accident.

When an emergency call is made, we need collect the following data:

Please understand that Emergency Call (eCall) is a mandatory service, and your refusal of our collection may hinder us to demonstrate or provide the basic functions of Volvo Vehicle Connectivity Services.

16. To provide you with Roadside Assistance service

When you use Roadside Assistance service, in order to send suitable help to you whenever you may need assistance, such as sending out a tow truck, we may collect and provide to customer service center your following data:

Your refusal of our collection may hinder us to provide you with Roadside Assistance service, without any impact on the basic functions of Volvo Vehicle Connectivity Services.

17. To provide you with Intelligent Driving Assistance System function

Please note that you must consult and comply with the Chinese laws and regulations, as well as the relevant regulations on specific locations of external cameras on the vehicle, and assume full responsibility on your own.

1.3 Collect your information from third parties

In order to provide real-time traffic information and vehicle diagnostic services, we may obtain your personal information or other information from our partners (authorized 4S shops) to the extent permitted by law and authorized by you.

We will use your personal information strictly for the purposes set forth in this Notice, and your personal information will only be used for the purposes that were determined, specified and obtained your consent at the time of collection. We will ask for your consent in advance if we use the personal information collected for purposes not specified in this Notice, or when information collected for a particular purpose is used for other purposes. We will not provide your personal information and other vehicle data to third parties without your consent, unless required by law or regulation.

2. Exceptions to consent to collection and use of personal information

You are fully aware that, under applicable laws, we may not need your consent to collect and use your personal information where one of the following circumstances is met:

1.

We will determine the duration of retention of your personal information only to the extent required by laws or regulations, and as necessary to achieve the purposes of this Notice. Upon the expiry of the above period, we will delete or anonymize your personal information.

2.

If we terminate our services or operations, we will notify you at least 30 days in advance, and delete or anonymize your personal information upon such termination.

1. How we entrusted process your personal information

Some specific modules or functions in our products or services are provided by external suppliers. For example, we will engage service technology service providers to assist us in providing customer support. For companies, organizations and individuals that we entrust to process personal information, we will sign strict confidentiality agreements or other data protection related agreements with them, requiring them to comply with laws, regulations and our requirements, and take other measures that can ensure the confidentiality and security of personal information to process personal information.

2. How we share and transfer your personal information

We may, from time to time, share some of your personal information with our affiliates and strategic partners in cooperation with us in product and service offerings, or share or transfer your personal information in other circumstances to offer products or services you request. Volvo Cars may share your personal information to the following extent:

3. How we publicly disclose your personal information

We may publicly disclose your personal information only:

4. Exceptions to authorized consent to sharing, transfer or public disclosure of personal information

You are fully aware that, under applicable laws, we may share, transfer or publicly disclose your personal information without your prior consent where one of the following circumstances is met:

1.

Our products and services are mainly intended for adults. If you are a minor under the age of 18, you must obtain prior consent from your guardian before using our products and/or services. In the case of collection of children’s personal information with the consent of their parents, we will only use or publicly disclose such information to the extent permitted by law, expressly consented by their guardian or necessary to protect the children. For the personal information of children under the age of 14, we will, in addition to comply with the provisions of this Notice on users’ personal information, adhere to the principles of legitimate necessity, informed consent, clear purpose, security assurance and lawful use, store, use, and disclose children’s personal information, and protect the legitimate rights of children and their guardians concerning the relevant children’s personal information in strict accordance with the Personal Information Protection Law, the Provisions on the Network Protection of Children’s Personal Information and other laws and regulations.

2.

We will erase the relevant personal information as soon as possible if we are aware that we have collected the personal information of a minor without the prior verifiable consent of his or her guardian.

3.

If you are the guardian of a minor, please contact us through the contact information below when you have questions about the processing of the information of the minor under your guardianship, or if you have evidence to prove that the minor has used Volvo Vehicle connectivity services without the consent of a guardian.

1.

This Notice will be updated to provide you with better services and to keep pace with our business development. We will not, however, reduce your rights under this Notice without your explicit consent. We will issue updates on our website and Volvo Cars App, and remind you of such updates by website announcements or any other proper way before they take effect. Please visit Volvo Cars’ website to keep abreast of the latest Notice. By using or continuing to use our products and/or services after we have updated this Notice (in such event that we will promptly remind you of the updates), you agree to the content of this Notice (including the updated version) and consent to the collection, use, storage and sharing of your information in accordance with this Notice.

2.

For material changes, we will also provide a more prominent notice (we will explain specific changes to this Notice by means including but not limited to emails, text messages or a special notice on the browser page).

Material changes referred in this Notice include, but are not limited to the following:

3.

We will also keep the old version of this Notice in archives for your reference.

1.

If you have any questions, comments or suggestions about this Notice or matters related to your personal information, please send your comments to: Volvo Cars Asia Pacific Headquarters, Attention: 2088, Luyi Road, Jiading District, Shanghai, or contact us by calling our customer service number (10108666) or via our contact for user rights matters (Xu Yaqin, 16621032398).

2.

We will usually reply within 15 working days, unless otherwise provided by laws and regulations. If you are not satisfied with our reply, especially if you believe our personal information processing has harmed your legitimate rights and interests, you may also file a complaint with or report to the cyberspace, telecommunications, public security, industry and commerce and other regulatory authorities, or take proceedings in the court of competent jurisdiction.