California Consumer Privacy Statement

Effective: January 1, 2020

This California Consumer Privacy Statement supplements the VFS US LLC Privacy Policy and applies solely to California consumers.  This Statement does not apply to Volvo Financial Services (“VFS”) personnel or job applicants.  This Statement also does not apply to personnel of our business customers or dealers.

This California Consumer Privacy Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1.      Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

  • Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, and other similar identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, state identification card number, insurance policy number, education, bank account number, credit card number, and other financial information
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as age, sex, gender, marital status, citizenship status, and military and veteran status
  • Commercial Information: commercial information, including records of personal property
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Sensory Information: audio, electronic, visual, and similar information
  • Employment Information: professional or employment-related information
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of personal information listed above for the purposes described in our VFS Privacy Policy.  In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table: 

Purposes

Categories of Personal Information

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance

  • Identifiers
  • Protected Classifications
  • Online Activity
  • Sensory Information
  • Inferences

Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction

  • Identifiers
  • Protected Classifications
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

Debugging to identify and repair errors that impair existing intended functionality

  • Identifiers
  • Online Activity
  • Sensory Information
  • Inferences

Undertaking internal research for technological development and demonstration

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

1.      Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in Section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement.  For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.

a.      Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Categories of Sources of Data Collection

Categories of Personal Information

Directly from you, for example, when you act as a guarantor on a business loan or lease agreement and provide us with your contact information

 

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Sensory Information
  • Employment Information
  • Inferences

From your devices, such as when you visit our website

  • Identifiers
  • Online Activity
  • Sensory Information
  • Inferences

From other individuals, for example, when one of our business customers lists you as a credit reference, guarantor or includes you on a joint personal financial statement

 

  • Identifiers
  • Employment Information

From banks and other creditors and lenders

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Commercial Information
  • Inferences

From our affiliates and subsidiaries

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

Government entities

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

Consumer data resellers

  • Identifiers
  • Commercial Information
  • Online Activity
  • Employment Information
  • Inferences

a.      Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties

Categories of Personal Information

Our affiliates and subsidiaries

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

Vendors who provide services on our behalf

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

Syndication banks

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Sensory Information
  • Employment Information
  • Inferences

Professional services organizations, such as auditors and law firms

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

Advertising networks and online advertising services

  • Identifiers
  • Protected Classifications
  • Online Activity
  • Sensory Information
  • Inferences

Government entities

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

Internet service providers

  • Identifiers
  • Protected Classifications
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

Data analytics providers

  • Identifiers
  • Protected Classifications
  • Online Activity
  • Sensory Information
  • Inferences

Operating systems and platforms

  • Identifiers
  • Online Activity
  • Sensory Information
  • Inferences

Social networks

  • Identifiers
  • Online Activity
  • Sensory Information
  • Inferences

Consumer data resellers

  • Identifiers
  • Online Activity
  • Inferences

a.      Sale of Personal Information

We do not sell your personal information in exchange for monetary compensation. We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies on our Site in exchange for non-monetary consideration (such as an enhanced ability to serve you content and advertisements that may be of interest to you).  You have the right to opt out of this disclosure of your information, as detailed below.

During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have sold the following categories of personal information:

  • Identifiers such as a unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, and other similar identifiers
  • Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.

b.      Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties for a business purpose the following categories of personal information:

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

1.      California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months. 

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.

How to Submit a Request. To submit an access or deletion request please contact us at vfs.us.dataprivacy@vfsco.com  or call us at 877.865.8623, extension 3905.  To opt-out of the sale of your personal information please contact us at vfs.us.dataprivacy@vfsco.com  or call us at 877.865.8623, extension 3905.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.  If you do not have an email address or other direct contact information on file with us (e.g., if you passively visit our website), then there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA.  The reason for this is that VFS historically has not linked IP addresses, device identifiers or other information collected through automated means to named actual persons.  Accordingly, if you do not have an email address or other direct contact information on file with us, and you request access to or deletion of your personal information, we will not be able to process your request at this time. 

If you have an email address or other direct contact information on file with us, and request access to or deletion of your personal information, we may require you to provide any of the following information: last four digits of SSN, billing address, business phone number, guarantors/co-makers listed on the account, and/or name of customer’s dealer.  In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.  If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above). 

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.  This Statement is available in alternative formats upon request.  Please contact please contact us at vfs.us.dataprivacy@vfsco.com  or call us at 877.865.8623, extension 3905 Monday through Friday between 8:00 a.m. and 5:00 p.m. Eastern Time to request this Statement in an alternative format.