Roadside Assistance
This document describes how Volvo Cars (as defined below) processes the personal data that you provide in connection with your competence development within Volvo Cars using Thrive LXP at Volvo (hereinafter “THRIVE”). You can find below: 1. Who is responsible for the processing of your personal data 2. Volvo Car Corporation 2.1. What personal data we process and why 2.2. How long we keep your data 2.3. Who we share your personal data with 3. National Sales Company 3.1. What personal data we process and why 3.2. How long we keep your data 3.3. Who we share your personal data with 4. What rights you have in relation to the data processing we perform 5. How to contact us 1. Who we are The entities responsible for the processing of personal data are Volvo Car Corporation, having its registered office at 405 31, Göteborg, Sweden, company registration number 556074-3089, and the respective National Sales Company in your market, hereinafter referred to as “Volvo Cars”, “we”, or “us”. The above-mentioned parties are separate controllers for the data processing activities as described below. 2. Volvo Car Corporation 2.1 What personal data we collect and why The personal data that we will process is your contact information such as name, e-mail address, CDSID, training information such as certification history (pass result), and professional information such as Employer information/dealer code, job start day & end day, job roles, managers name as well as your login name, preferred language and articles/courses viewed, search words used, comments added to the platform and up-downloaded content. Technical information about your sessions (login, logout, time stamp) will also be collected. The purpose of our processing is to provide you with a centralised learning platform and valuable learning experience. This includes the administration of the learning platform (such as system administration and user management). Furthermore, it will also be used for providing you access to other relevant supporting applications for training and technical documentations. Your data is also processed to conduct centrally managed trainings (especially for Volvo Cars employees) and in case a general communication to the users or specific user groups is necessary. The usage data will also be processed to optimize the platform and content for the purpose of ideal competence development. Also, for the same purpose of your competence development you can on a voluntary basis use platforms or applications that we provide to upload pictures, videos, audio recordings or similar which can contain personal information. The legal basis for the data processing as described above is our legitimate interest (GDPR Art. 6.1.f) to provide a learning platform and thereby enable a valuable and standardised competence development within Volvo Cars Group and for the people that work together with us. 2.2 How long we keep your data We will retain your personal data until the training course is deleted from our learning catalogue or at the latest up to five (5) years after your account has been inactivated. Thereafter, your personal data will be anonymized. 2.3 Who we share your personal data with Your personal data will be disclosed to and processed by employees at Volvo Cars and employees at our national sales companies/ importers in the market you are from (master trainer, course developer and admin resources) as well as your manager/employer. In case you are also working for a Polestar partner, we will need to share personal data about you with Polestar to be able to identify you and provide you with relevant trainings (e. g. CDSID, e-mail-address, achievements). When you register on THRIVE, your profile information will be visible to all on THRIVE to enable a social learning effect. We will also 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 providing training and documentation material as well as event organizers, 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; • Watershed – the USA – Analytics. Personal data will be transferred to the USA, on the basis of the adequacy decision in place for data transfers to the USA. Additionally we concluded Standard Contractual Clauses approved by the EU Commission, in accordance with Art. 46(2)(d) GDPR. The general text of the standard contractual clauses used can be found in various languages on the homepage of the EU Commission at EUR-Lex - 32021D0914 - EN - EUR-Lex (europa.eu); a copy of the agreement may be provided upon request. 3. National Sales Company 3.1 What personal data we collect and why We will process the personal data which results from using THRIVE (as described above in section 2.1) for the below mentioned purposes. In addition to that, we process personal data when it comes to competence development interactions outside THRIVE (e. g. when you participate in an event or training course booked via THRIVE). In this relation we process personal data which you provide to us (such as dietary habits) or which originate (such as audio-visual material) from our interactions. The purpose of our processing is to manage (schedule, book, conduct and follow up) training courses and to communicate updates and surveys related to your training experience. Furthermore, it will also be used for providing you access to other relevant supporting applications for training, technical documentations and for statistical purposes (e. g. to be able to offer relevant training courses). The personal data is also processed for the monitoring of contractual obligations of our Volvo Partners and of their fulfilment of requirements for bonus payments. The legal basis for the data processing as described above is our legitimate interest (GDPR Art. 6.1.f) to fulfil the contract that we have with your employer about providing training courses, relevant product information and to further develop the competences for the people that work together with us. In case we process sensitive personal data (such as allergies), we use this information based on your consent (GDPR Art. 6.1.a). Some of our physical events are documented via photo and video recordings. We primarily create photos and videos that are not focused on individual persons, but on the documentation of the event. It cannot be excluded that individual participants may also be recorded. We create and publish pictures in which you may be clearly depicted but are not in focus (e.g. in large groups) internally (e.g. on the intranet) and externally (e.g. on social media platforms) on the basis of our legitimate interests (GDPR Art. 6.1.f) in documenting the event and related marketing activities. We will only take photos and videos of you as an individual clearly depicted person (e.g. in portraits) if you imply that you agree to this (e.g. by posing accordingly). When creating and processing these individual recordings for internal documentation purposes, we rely on our legitimate interests (GDPR Art. 6.1.f). The publication of these recordings in external media (e.g. on social media platforms) takes place exclusively on the basis of your consent (GDPR Art. 6.1.a). 3.2 How long we keep your data For the retention periods for data stored within THRIVE, please see section 2.2 above. Beyond the data within the system, personal data will be retained locally for up to three (3) years in order to follow up our interactions and to have a proper documentation of training courses and events or in case you have given your consent, until withdrawal of your consent. 3.3. 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 providing training and documentation material as well as event organizers, 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; • Personal data might also be shared with other third parties in case this is relevant to conduct training courses (such as accommodations). 4. Your rights in relation to the data processing we perform You have specific legal rights granted by the General Data Protection Regulation relating to the personal data we process about you. You can 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. Details about your rights – what they mean, when and how you can exercise them – can be found in our Customer Privacy Policy. 5. 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 following contact details: Company: Volvo Car Corporation Postal Address: Assar Gabrielssons Väg, SE-405 31 Gothenburg, Sweden E-Mail: globdpo@volvocars.com You can find the contact details of the respective National Sales Company here. 6. 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.