Privacy Notice - Marketing Communication
Effective from:
Published at:
This document describes how Volvo Cars (as defined below) processes your personal data as part of our marketing practices described below.
You will find below:
1. Who we are
When you receive and respond to Marketing Communications from Volvo about our products, offers and services, Volvo Car Corporation and Gasan Zammit Motors Ltd. are jointly responsible for the processing of your personal data in relation to those Marketing Communications.
The legal entities jointly responsible for the processing of personal data are Volvo Car Corporation, headquartered in Assar Gabrielssons Väg, 40531 Gothenburg, Sweden, company registration number 556074-3089, and Gasan Zammit Motors Ltd. Mriehel ByPass Mriehel BKR, Malta, company registration number C57642, hereinafter referred to as "Volvo cars", "we" or "us".
2. What personal data we collect and why
Individuals who have provided us with their consent to receive marketing communications receive such communications through multiple channels (such as postal mail, phone, e-mail, Volvo Cars app, social media channels).
As part of our marketing communications, we work with digital advertising partners to create and show marketing content on social networks and online advertising networks, hereinafter referred to as “Advertising Partners”. These providers use personal data provided by us and from other technologies such as cookies to display relevant and tailored advertisements. You can find more information on this below.
Our marketing activities involve the processing of the following categories of personal data:
| PURPOSE | DATA CATEGORIES | LEGAL BASIS |
|---|---|---|
| In order to record and manage your choices. | A record of your choices (date and time of your choice, and originating system). | Our legal obligation to document and demonstrate whether you have consented to receiving marketing communications and to register when and what you have opted out from. |
| To send marketing communications that you have requested or that may be of interest to you. | Contact information including name, email address, phone number, postal address. | Your consent to receiving marketing from us or, in the case you have bought a product or service from us, our legitimate interest to send you marketing. |
To show relevant marketing communications to you. To help us better understand your specific interests and preferences so that we can tailor communications to you. | Contact information including name, email address, phone number, postal address. Online identifiers including IP address. Purchase history, preferred dealer, vehicle information (e.g., model, model year, VIN, telematics data, mileage, etc.), service history, interactions with customer care, contract details such as contract type and duration, status of connectivity subscription (previously Volvo on Call subscription), email open/click rates, activity in our app and on our website (to the extent this can be linked to you. This would be the case for app usage when you are logged in with your Volvo ID and in the case of web browsing, when you follow a link provided to you in an email and when you request a service linked to your phone number or email address, such as making a booking for a service or registering for a test drive). | Our legitimate interest in creating relevant advertisements. Where applicable, your consent to advertising cookies. |
To show you relevant and tailored Volvo Cars advertisements, when you visit our Advertising Partners’ sites, on third party websites and within social media channels and direct communications (this is commonly referred to as retargeting). To make it possible for us to find and engage with the right audiences and to provide advertising to those individuals. | Email open/click rates, email address, phone number, advertising cookie data. | Your consent to advertising cookies on our website. Your consent to receiving marketing from us or, in the case you have bought a product or service from us, our legitimate interest to display and send you marketing. We consider our Advertising Partners such as Meta and Google as jointly responsible with us (joint controllers) in these scenarios. |
| Statistical performance analysis of our marketing communications. | Consumer engagements, consumer feedback and complaints made by phone to our call centre. Email open and click rates, date and time of interactions with our e-mails, and which links the recipient clicked on. The e-mails and our website contain tracking pixels which measure the opening and click frequency. Volvo Cars app downloads, activations, engagements, un-installations, license status, unsubscriptions, Social media channel(s) reach, engagements, clicks, opens, leads, video playback based on IP´s, tracking pixels and third party connectors. | Our legitimate interest to measure the efficiency of our marketing activities whenever web activity is concerned, subject to the user having accepted advertising cookies on our website. |
3. How long we keep your data
We process your personal data as above until you have withdrawn your consent or opted out from receiving marketing from us. If you withdraw your consent or opt-out, we will limit our processing of personal data to keeping a suppression list in order to ensure that we do not continue to send marketing to you inadvertently. Our legal basis for doing so is our legal obligation to respect your choices.
4. Who we share your personal data with
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 direct marketing, 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.
We will process your personal data and we will also share your personal data with the following organizations (who process the personal data on our behalf or to provide you with Volvo branded products and services):
- Our parent company Volvo Car Corporation (and their subcontractors) to operate our website and for data storage;
- IT suppliers (and their subcontractors) who supply general business support systems to us, e.g. software and data storage providers such as Salesforce (and their subcontractors) that we use for our CRM systems and data storage.
We have entered into a data processing agreement with each processor who is limited by contract in their ability to use your personal data for any purpose other than to provide services for us or to provide you with Volvo branded products or services. Each organization has an obligation to keep the information confidential and only process the personal data in compliance with the data processing agreement in place.
Your personal data may be transferred to a country outside Malta / Sweden. In such cases we will ensure that robust contractual measures are in place, which in accordance with the local GDPR, ensure an adequate level of protection for the rights of data subjects in that location.
Please contact us (in accordance with section six below) if you have any questions in relation to the transfer of your personal data outside the European Economic Area.
5. Your rights in relation to the data processing we perform
As a data subject you have specific legal rights relating to the personal data we hold about you including the right to, withdraw your consent or object to our processing of your data, access the data we hold about you, ask for rectification or restriction of your data, request to have your data ported to another entity, request that we delete your data, and finally you can file a complaint with a data protection supervisory authority. For more information about your rights please see contact information below.
You can exercise your rights in relation to:
- our collection and use of your personal data, and
- the collection and use of your personal data in relation to activities with our Advertising Partners when joint controllers. (In some cases we may forward your request where our Advertising Partners take responsibility for managing these requests).
Click here to complete your request (first, choose your country or region, then open and fill out the online form), which will help us to deal with your request properly. 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.
6. Contact information
In order to exercise your rights, please see section 5 above. If you have any other questions regarding the subject matter of personal data protection, you can contact us at the details mentioned under Business Information.
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
E-mail address: globdpo@volvocars.com
7. 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. Whenever we make substantial changes to this notice, and in particular when this notice underlies your consent, we will inform you of the changes.
This privacy notice is current as of the date which appears at the top of the document.