Privacy Notice – Consumer surveys

Effective from: 2021-07-05

Published at: 2021-07-05

This document describes how Volvo Cars (as defined below) processes your personal data when you engage with one of our consumer surveys (hereinafter “Consumer Survey”).

You can find below:

1. Who we are

The entity that is responsible for processing of personal data in relation to the consumer surveys is Volvo Car Turkey Otomobil Ltd. Şti., having its registered office at Fatih Sultan Mehmet Mah. Poligon Cad. Buyaka 2 Sitesi 2 Kule No:8/B K:9 Tepeüstü Ümraniye-İstanbul, Turkey, company registration number 422515, hereinafter referred to as “Volvo Cars”, “we”, or “us”.

2. What personal data we collect and why

In order to send you a request for a Consumer Survey, we will process the following categories of data about you:

Identifiers such as name, e-mail address, telephone number, salutation, age, gender, postal code, and city. We process this data in order to send the Consumer Survey and assess consumer performance by segmentation allowing us to improve the overall business operations and the consumer experience. The data is processed based on your consent (Art. 6(1)(a) GDPR, KVKK Art.5. and Art. 13(1) of the ePrivacy Directive (2002/58/EC)) and is stored within Volvo Cars. You can withdraw your consent to the processing of your data for receiving the survey at any time, either by using the web form indicated under “Your rights” below or by clicking directly on the unsubscribe link in the survey send-out.
Your Vehicle data such as vehicle type, Vehicle Identification Number (VIN), and registration number (REG). We process this data for field action and warranty performance, based on your consent (Art. 6(1)(a) GDPR, KVKK Art.5. and Art. 13(1) of the ePrivacy Directive (2002/58/EC)).
Contract type, subscription number, vehicle relationship (contract/sales type starting and end date). We process this data in order to send the Consumer Survey and assess consumer performance by segmentation allowing us to improve the overall business operations and the consumer experience. The data is processed based on your consent (Art. 6(1)(a) GDPR, KVKK Art.5. and Art. 13(1) of the ePrivacy Directive (2002/58/EC)).
Opening/clickthrough rates. We process this data for statistical analysis and range measurement, and to understand the interests of our consumers. For this analysis, the e-mail invites contain so-called web beacons or tracking pixels, which display single-pixel image files that are also embedded in our website. The data is processed based on your consent (Art. 6(1)(a) GDPR, KVKK Art.5. and Art. 13(1) of the ePrivacy Directive (2002/58/EC)).

3. How long we keep your data

Your survey feedback responses will be kept up to five (5) years from the time you submit your response, after which time it will be anonymized.

In order to keep your responses secure, the invitation for feedback provides you with an individualised questionnaire that no other person can access. The survey web site and our data storage facilities have security measures in place to protect the loss, misuse, and alteration of the information under our control.

Only certain employees have access to the personal information you provide us. They have access only for case handling, data analysis and quality control purposes.

4. Who we share your personal data with

In accordance with the explicit consent given by you according to Art. 9 of the KVKK, we will share your personal data with the following categories of third parties, on a need-to-know basis:

Our processors supporting our activity in general, such as providers of IT solutions;
Our processors supporting delivering the Consumer Surveys, which are limited by contract in their ability to use your personal data for any purpose other than to provide services for us in compliance with each data processing agreement in place:
- Provision of Consumer Surveys.
- WhatsApp text Communication.
- Care Operations.

Your personal data will be disclosed to and processed by your selected retailer (if applicable) and companies within the same group of companies as VCC. In relation to companies within the same group of companies as VCC located outside EEA, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

5. Your rights in relation to the data processing we perform

Under the GDPR, you have specific legal rights relating to the personal data we process about you. These are briefly explained below, and you can exercise them by filling out the dedicated form indicated below.

Right to withdraw consent: Where you have given consent for the processing of your personal data, you may withdraw your consent at any moment with effect for the future.
Right to access your personal data: You may ask from us information regarding personal data that we hold about you. We will provide you with a copy of your personal data upon request. If you request further copies of your personal data, then we can charge you with a reasonable fee that we base on the administrative costs. You have the right to the information about our safeguards for the transfer of your personal data to a country that is outside the EU and the EEA if you request that we confirm whether or not we process your personal data, and we transfer your personal data to a country that is outside the EU and the EEA.
Right to rectification: You may obtain from us rectification of incorrect or incomplete personal data concerning you. We make reasonable efforts to keep personal data in our possession or control which are used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to us.
Right to restriction: You may obtain from us restriction of processing of your personal data, if:
1. you contest the accuracy of your personal data, for the period we need to verify the accuracy,
2. the processing is unlawful and you request the restriction of processing rather than erasure of your personal data,
3. we do no longer need your personal data for the processing purpose but you require them for the establishment, exercise or defense of legal claims, or
4. you object to the processing while we verify whether our legitimate grounds override yours.
Right to portability: You have the right to receive your personal data that you have provided to us, and, where technically feasible, request that we transmit your personal data (that you have provided to us) to another organization, if:
1. we process your personal data by automated means;
2. we base the processing of your personal data on your consent, or our processing of your personal data are necessary for the execution or performance of a contract to which you are a party;
3. your personal data are provided to us by you; and
4. your right to portability does not adversely affect the rights and the freedoms of other persons.
You have the right to receive your personal data in a structured, commonly used and machine-readable format. Your right to receive your personal data must not adversely affect the rights and the freedoms of other persons. Your right to have your personal data transmitted from us to another organization is a right you have if such transmission is technically feasible.
Right to erasure: You have the right to request that we delete the personal data we process about you. We must comply with this request if we process your personal data, unless processing is necessary:
1. for exercising the right of freedom of expression and information;
2. for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject;
3. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or
4. for the establishment, exercise or defense of legal claims.
Right to object: You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing or for the establishment, exercise or defense of legal claims. If you object to the processing, please specify whether you also wish the erasure of your personal data, otherwise we will only restrict it. You also have the right to object at any time, regardless of any reason, to the processing of your personal data for direct marketing (which includes profiling to the extent that it is related to such direct marketing), if such processing was based on our legitimate interest. If the marketing was based on your consent, you can withdraw consent (see above).
Right to lodge a complaint: You can lodge a complaint to your local data protection supervisory authority or with any other data protection authority in the EU. However, we will appreciate if you first contact us to try and solve your problem – you can find our contact details below.

You can exercise your rights in relation to us by filling out this form, which will help us to deal with your request properly. The online form contains the information that we need to verify your identity and review your request. For requests submitted by telephone or email, you will need to provide us with sufficient information that allows us to reasonably verify that you are the person whose personal data we collected and describe your request in sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.

You can exercise these rights in relation to all of the joint controllers mentioned in this notice.

6. Your rights under KVKK

We would like to remind you that you have rights to apply our company and request the following as per Article 11 of the Law on the Protection of Personal Data No. 6698:

To learn whether your personal data are processed or not,
To have information on such processing if you personal data are processed,
To learn the purpose of your data processing and whether such data are used for intended purposes,
To know the third parties to whom your personal data are transferred within the country or abroad,
Rectification of the data which has not been completely or accurately processed, if any, and notification of third parties to whom such personal data have been transferred to within that scope,
in the event that the reasons requiring processing dissappear, erasure or destruction of your personal data and notification of third parties about such transactions to whom your personal data have been transferred, despite beign processed under the provisions of Law No. 6698 and other legislations,
To object to the processing, exclusively by automatic means, of your personal data, which leads to an unfavourable consequence for you,
To request compensation for the damage arising from the unlawful processing of your personal data

7. Contact information

In order to exercise your rights, please use the web form mentioned in the Customer Privacy Policy above. If you have any other questions regarding the subject matter of personal data protection, you can contact directly Volvo Car UK Ltd that is indicated as a joint controller in this privacy notice, at the contact details mentioned here: https://www.volvocars.com/uk/support/contact-us.

You can also contact the Volvo Car Corporation Data Protection Officer as follows:

Company: Volvo Car Corporation

Postal address: Volvo Car Corporation, Assar Gabrielssons Väg, SE-405 31 Gothenburg, Sweden

Email: globdpo@volvocars.com

Company: Volvo Car Turkey Otomobil Ltd. Şti

Postal address: Fatih Sultan Mehmet Mah. Poligon Cad. Buyaka 2 Sitesi 2 Kule No:8/B K:9 Tepeüstü Ümraniye-İstanbul,Turkey

E-Mail: kvkktr@volvocars.com

Website: https://www.volvocars.com/tr

8. Changes to our Privacy Notice

We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this privacy notice at any time. For this reason, we encourage you to refer to this privacy notice on an ongoing basis. This privacy notice is current as of the date which appears at the top of the document. We will treat your personal data in a manner consistent with the privacy notice under which they were collected, unless we have your consent to treat them differently.