Privacy Notice

Machine mounted Camera Equipment

This notice provides information on Volvo Autonomous Solutions’ 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 “Machine”) and where recordings and detections have been made of a Machine’s surroundings, (“Privacy Notice”).

For the purpose of this notice, “Volvo Autonomous Solutions” means Volvo Autonomous Solutions AB incorporated with company registration number 559285-4219.

This Privacy Notice applies only when Volvo Autonomous Solutions is collecting or otherwise processing personal data for Volvo Autonomous Solutions’ purposes (i.e., when Volvo Autonomous Solutions (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 Autonomous Solutions is collecting or otherwise processing personal data on behalf of another company, such as Volvo Autonomous Solutions’ independent dealers, importers, suppliers, and customers.

Identity of the controller and contact details to the group privacy officer

Volvo Autonomous Solutions process personal data from the Camera Equipment for the below mentioned purposes. Volvo Autonomous Solutions is the controller of the personal data that Volvo Autonomous Solutions 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 Autonomous Solutions that decides on the purpose and means for the processing of your personal data. Volvo Autonomous Solutions 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

What categories of personal data will Volvo Autonomous Solutions process, on which legal ground(s) and for what purposes?

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 Autonomous Solutions may process your personal data based on any one or more of the following legal bases, see also further details below.

Legal obligation. Volvo Autonomous Solutions 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 Autonomous Solutions may process your personal data if such processing is necessary for the purposes of a legitimate interest pursued by Volvo Autonomous Solutions or a third party. It is generally considered to be in Volvo Autonomous Solutions’ 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 Autonomous Solutions relies on its legitimate interests for a given processing purpose, Volvo Autonomous Solutions is of the opinion that its legitimate interests are not overridden by your interests, rights or freedoms given (i) the transparency Volvo Autonomous Solutions provides on the processing activity, (ii) Volvo Autonomous Solutions’ privacy by design approach, (iii) Volvo Autonomous Solutions’ 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 Autonomous Solutions may process your personal data if the processing is necessary in order for Volvo Autonomous Solutions to provide you with products, services or otherwise perform a contract between you and Volvo Autonomous Solutions (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 Autonomous Solutions 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.

Please note that the below list is a list of examples only and not intended as an exhaustive list, and that Volvo Autonomous Solutions 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.

Information about our processing activities

Research and development

What we do and why:	The personal data that we process:
We will use your personal data for research and development purposes (including but not limited to the development of automatic functions in Machines), such as to analyse the behaviour and functions of Machines and other Volvo Autonomous Solutions 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.	Camera Equipment recordings of a Machine’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 Machine’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).
Our legal basis for processing:
Legitimate interest and legal obligation, where our legitimate interest in conducting research and development work by analysing the behaviour and functions of Machines and other Volvo Autonomous Solutions products as well as the behaviours of drivers is necessary for this purpose. We will also process your personal data to fulfil our legal obligations to comply with current and future legislations and standards including but not limited vehicle and/or work place safety legislation.
How we share your data:
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 your data:
We will transfer your 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 entities, as Volvo Autonomous Solutions 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 Autonomous Solutions 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 Autonomous Solutions for five (5) years, or the period required by applicable law.

Validation and verification

What we do and why:	The personal data that we process:
We process your personal data for validation and verification of Volvo Autonomous Solutions products, services and systems. To be able to do this we will conduct the following activities; managing product portfolios, managing product projects, developing new technology, performing feasibility studies, developing new concepts, developing solutions, and industrializing & launching of total offers.	Camera Equipment recordings of a Machine’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 material in real time (meaning that no recordings are made and stored) of a Machine’s surroundings. LiDAR images, (high resolution LiDAR which are of such quality the images contain elements which may be used to identify a natural person).
Our legal basis for processing:
Legitimate interest and legal obligation, where our legitimate interest is to be able to validate and verify Volvo Autonomous Solutions’ products, services and systems. We will also process your personal data to fulfil our legal obligations to comply with current and future legislations and standards including vehicle safety legislation.
How we share your data:
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 your data:
We will transfer your personal data to countries outside EU/EEA to the recipients listed below, you can find more information on how we transfer your data by clicking here. Other Volvo entities, as Volvo Autonomous Solutions 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 Autonomous Solutions 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 Autonomous Solutions for five (5) years.

Quality improvement

What we do and why:	The personal data that we process:
We will process your personal data to prevent, identify and solve quality issues related to Volvo Autonomous Solutions products and services. To be able 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 activities; developing products and aftermarket product portfolios, and analysing customer feedback for quality improvements.	Camera Equipment recordings of a Machine’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 material in real time (meaning that no recordings are made and stored) of a Machine’s surroundings. LiDAR images (high resolution LiDAR which are of such quality the images contain elements which may be used to identify a natural person).
Our legal basis for processing:
Legitimate interest and legal obligation, where our legitimate interest is to be able to handle quality issues related to Volvo Autonomous Solutions’ products and services. We will also process your personal data to fulfil our legal obligations to comply with current and future legislations and standards including vehicle safety legislation.
How we share your data:
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 your data:
We will transfer your personal data to countries outside the EU/EEA to the recipients listed below, you can find more information on how we transfer your data by clicking here. Other Volvo entities, as Volvo Autonomous Solutions 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 Autonomous Solutions 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 Autonomous Solutions for five (5) years, or the period required by applicable law.

Operation of autonomous Machines

What we do and why:	The personal data that we process:
We will process personal data collected when you operate autonomous Machines. Your personal data is used to analyse the behaviour and functions of Machines and other Volvo Autonomous Solutions products and the behaviours of drivers in order to use the information to operate the autonomous Machines 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.	Camera Equipment recordings of a Machine’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 material in real time (meaning that no recordings are made and stored) of a Machine’s surroundings. LiDAR images (high resolution LiDAR which are of such quality the images contain elements which may be used to identify a natural person).
Our legal basis for processing:
Legitimate interest, performance of contract and legal obligation; where our legitimate interest is to enable you to operate our autonomous machines. If you are operating autonomous Machines in connection with a contract Volvo Autonomous Solutions has entered into with you, we will base our processing of your personal data to perform our contractual obligations. We will also process your personal data to fulfil our legal obligations to comply with current and future legislations and standards including vehicle safety legislation.
How we share your data:
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 your data:
We will transfer your personal data to countries outside the EU/EEA to the recipients listed below, you can find more information on how we transfer your data by clicking here. Other Volvo entities, as Volvo Autonomous Solutions 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 Autonomous Solutions 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 Autonomous Solutions for as long as you are continuously operating our autonomous Machines, however no longer than five (5) years.

Legal obligations, defense and claims

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 Autonomous Solutions’ assets and property as well as defend Volvo Autonomous Solutions from any third party claims.

Volvo Autonomous Solutions 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.

From where will Volvo Autonomous Solutions obtain your personal data?

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

How will Volvo Autonomous Solutions share and transfer your personal data?

Third country transfers

We strive to always process your personal data within the EU or EEA but third country transfers will be conducted as communicated in the tables describing our processing activities above.

Further, in the event that Volvo Autonomous Solutions transfers personal data to external third parties that are located outside of the EU/EEA, Volvo Autonomous Solutions will ensure 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).

In such cases, we are responsible for ensuring that the transfer is made in accordance with applicable data protection legislation before it occurs, e.g. by ensuring that the country in which the recipient is located ensures an adequate level of data protection according to the European Commission, or by ensuring appropriate safeguards based on the use of standard contractual clauses that the European Commission has adopted and other appropriate measures to safeguard your rights and freedoms.

You may access a list of the countries that the European Commission has decided provide an adequate level of data protection at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.

You may access the European Commission’s standard contractual clauses at https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32021D0914.

Sharing of personal data within the Volvo Group

Volvo Autonomous Solutions is part of the Volvo Group which 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

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.

If you have questions about how Volvo Autonomous Solutions will share your personal data, please contact the Volvo Group Privacy Officer via the contact details set out above.

Your data protection rights

You have rights in relation to us and our processing of your personal data. You may be entitled, where provided for under applicable data privacy laws and regulations, to:

Request access to the personal data Volvo Autonomous Solutions 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 Autonomous Solutions no longer processes your personal data, when it is based on legitimate interest. If you object, we must demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms in order to be allowed to continue with our processing.
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. This right applies to the following circumstances:
The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
Our processing is based on your consent and you withdraw your consent to the relevant processing;
You object to processing that we carry out based on a legitimate interest, and your objection overrides our or another party’s legitimate interest of the processing;
The processed personal data is unlawfully processed;
The processed personal data has to be erased for our compliance with one or more legal obligations.
Request the restriction of the processing of your personal data: this right entitles you to request that Volvo Autonomous Solutions processes your personal data only in limited circumstances, subject to your consent. The right of restriction applies in the following circumstances:
If you challenge the accuracy of the personal data we process, the processing will be restricted during a period enabling us to verify the accuracy of such personal data;
If our processing is unlawful and you oppose erasure of the personal data and request restriction instead;
The personal data is no longer needed for the purposes of the processing, but is necessary for you for the establishment, exercise or defense of legal claims;
You have objected to the processing of the personal data which we carry out based on a legitimate interest, pending the verification whether your objection overrides our or another party’s legitimate interest to continue with the processing.
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 Autonomous Solutions 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, you can withdraw your consent at any time, in which case Volvo Autonomous Solutions 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 Autonomous Solutions 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 Autonomous Solutions’ legal obligations and the exception to such rights.

You also have the right to lodge any complaints you may have regarding Volvo Autonomous Solutions’ processing of your personal data to a supervisory authority. The data protection authority in Sweden is ‘Integritetsskyddsmyndigheten’. 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 by clicking here.