Last updated: 07 October 2019
The Autoliv Driving Avatar mobile application (‘Application’) is made available to you by the Autoliv Development AB, Wallentinsvägen 22, Vårgårda, 447 37, Sweden (hereinafter referred to as “Autoliv”, “we” or “us”). We comply with data protection legislation such as the EU General Data Protection Regulation, which regulates the processing of personal data relating to you and grants you various rights in respect of your personal data. The aim of this Privacy Policy is to inform you about how we will use your personal data you provide through this Application and about your rights. Please read it carefully before you proceed.
A. Use of Personal Data in Connection with the Application
I. What is Personal Data?
For the purposes of this privacy policy personal data is defined as under the Regulation (EU) 2016/679 (General Data Protection Regulation) for EU residents, it in particular means information which identifies you as an individual, whether directly or indirectly through the combination with other information held by Autoliv and/or any other party.
II. Downloading the Application
1. You can download the Application onto your mobile device from the respective app store (e.g. AppStore, Google Play Store). When you download the Application all personal data that is necessary to facilitate the download will be transferred to the app store you are downloading the Application from. This especially applies to your user name, email address, account number, time of download, payment information and unique device number
2. We do not have any influence on this collection of data by the app store and we are not responsible for it. We solely process this data to the extent necessary to download the Application onto your mobile device. We do not otherwise store or use this data.
III. Installing the Application
1. In order for you to use the Application, you need to create a user account with Autoliv. This requires you to provide your email address, to confirm that you do not fall under the age restriction, country of residence and to choose a password and a user name. You do not have to use your real name as user name. We allow a pseudonymized use of the Application. We verify the e-mail address you provided.
2. After verification of your e-mail address, Autoliv will store an ID number which it will use for automated profiling as explained in section IV below.
3. Furthermore, we store and process information that you voluntarily provide to us (e.g. information about your vehicle), unless you delete this information.
4. You may change some of the information using the settings function at any time.
5. You can delete your account and uninstall the application at any time. If you delete your account, we will remove all identifiers we collected, so that we can no longer link your data to you.
IV. Using the Application
1. Technical Information
To enable you to use the Application and to make its functions available to you, we collect, store and process the following information: type of device, type of operating system, type of mobile browser, and similar. Further, depending on your device make and type and your permissions, Autoliv may also collect the following data supplied by the device’s operating system: Bluetooth information and battery information.
2. Usage data
(a) Location data
When first installing the Application we ask you to allow that we may collect and use your location data even when you are not actively using the Application. If you click “Don’t allow” you will not be able to use the functionality that require geolocation tracking. If you click “Allow” your geolocation information is regularly transferred to us. We use your real-time and previous location data to create an accurate profile of your location and movements (“Trips”). You can stop the collection of your real-time location data by changing the operation system settings of your device. Please be aware that stopping the collection and use of your location data may result in your profile becoming inaccurate and unreliable. To stop any further collection of information without removing all identifiers of information you previously collected, uninstall the Application but keep your account. Download the Application again and reuse your account when you want to continue collecting information. This will allow you not to track individual Trips or all Trips during a particular period of time.
(b) Motion & Fitness Activity Information
When first installing the Application we ask you to allow that we may collect and use your motion and fitness activity information. If you click “Don’t allow” you will not be able to use the functionality that require your motion and fitness activity information. If you click “Allow” your motion and fitness activity information is regularly transferred to us. Depending on your device make and type and your permissions, Autoliv may collect the following data supplied by the device’s operating system: activity information, step detection and step count. We use this data to create an accurate profile of your movements. You can restrict or enable the types of data collected in the settings of your operating system.
(c) Application use-related data; Sensor Data
We also collect, store and process information on your use of the Application, accelerometer data and gyroscope data (“Sensor Data”). You can restrict or enable the types of data collected in the settings of your operating system.
B. Purpose of collection and use of usage data
I. General
The overall purpose of the application is to increase road safety. Autoliv collects and uses usage data for the following specific purposes:
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Purpose |
Legal Ground |
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to build user profiles that can be used to increase overall road safety for example by providing feedback on driving style (e.g., through the provision of an overall SafetyScore, its sub-scores and other relevant information). |
Agreement / Terms and conditions – It is necessary for the performance of our agreement / terms & conditions with you. |
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to share: i) your overall SafetyScore; ii) its sub-scores; and iii) geographical route information for the trips underlying said scores, with those third party service providers, which you have linked to your account by entering an activation code provided to you by such third party service providers. For clarity, any further processing of data so shared (if any) is performed under the sole responsibility of the relevant third party service provider and we recommend you consult their privacy policy, and other relevant agreements you may have with them, in particular with regards to their processing purposes and retention practices. |
User's consent – Your consent is required for us to share this data. You give your consent in connection with the entering of the activation code provided to you by a third party service provider in the Application. Currently you can only withdraw your consent by uninstalling or deleting the Application and your account as further described in Section B IV. (Stopping the Collection and Use of Data; Deletion of Data) of this privacy policy. |
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to build user profiles that may allow Autoliv to detect places you visit and frequent, when and by what means you are travelling and to make an estimated guess of your age, gender and routine behavior, which are taken into consideration to build more accurate user profiles. |
Legitimate interest - It is necessary to achieve our legitimate interests to properly base your user profile on correct and meaningful data that define you as a driver. |
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to send you adequate information regarding the Application, for example information about updates and new features. |
User's consent – Your consent is required for us to process this data. You provide consent separately, but it is entirely voluntary to give such consent. |
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to respond to your comments and problems. |
Legitimate interest - It is necessary to achieve our legitimate interests in order to optimize the solution and resolve issues and feedback quickly. |
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for Autoliv’s data analysis to increase road safety. |
Legitimate interest - It is necessary to achieve our legitimate interests to over time tweak the algorithms giving you the driving insights as to continually improve on quality and speed of service. |
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Research and development activities for purposes compatible to those listed above |
Legitimate interest - It is necessary to achieve our legitimate interests to over time grow the service and create more value for you as an end user. |
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to investigate potentially unlawful use of the application. |
Agreement / Terms and conditions – It is necessary for the performance of our agreement / terms & conditions with you. |
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to refine the algorithms that detect transportation modes. |
Legitimate interest - It is necessary to achieve our legitimate interests in better detecting when you drive a car and thereby increase quality of service. |
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to find battery-efficient triggers for the start and stop of transport detection logging. |
Legitimate interest - It is necessary to achieve our legitimate interests in order to optimize the hardware for the service used. |
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to conduct analytics in order to improve the profiling algorithms and Application. |
Legitimate interest - It is necessary to achieve our legitimate interests in order to create more safety features that will benefit the driver. |
II. Sales and Marketing Purposes
Autoliv may also use your pseudonymized profile to build an interactive map and may share such map with third parties for sales presentation purposes.
III. Relevancy
Autoliv only collects personal data that is adequate, relevant and limited to what is necessary for the above purposes. Collection and processing of real-time and continuous location data is necessary to build an accurate profile.
In order to improve its profiling algorithms, Autoliv may request and collect your feedback on assumptions made by Autoliv based on the collected information. You may answer to our requests for feedback voluntarily. If you do choose to answer to our requests, we will use the information you provided to improve our profiling algorithms.
IV. Stopping the Collection and Use of Data; Deletion of Data
You may at any time immediately stop any collection and processing of personal data by Autoliv by uninstalling or deleting the Application and your account. In this case Autoliv will not keep any personal data of you. Uninstalling the Application will also delete the ID number from your mobile device.
C. Transfer of Data to Third Parties and International Transfer of Data
I. We may disclose:
1. Your: i) overall SafetyScore; ii) its sub-scores; and iii) the geographical route information for the trips underlying said scores, with those third party service providers which you have linked to your account by entering an activation code as described in further detail in Section B (Purpose of collection and use of usage data) of this privacy policy; and
2. your personal data to third party service providers (data processors) who process your data on our behalf. Autoliv’s third party service providers (data processors) include development hubs and service providers, hosting providers (including Amazon Web Services), and providers of data analysis, IT services, and other similar services requested by Autoliv to provide the Application to you. Any data processing on our behalf complies with the applicable laws.
II. Except as set forth above, we will not transfer your personal data to third party recipients, unless you consent to such transfer of data or such transfer is permitted or required under applicable law.
III. Personal data will be stored and processed within the European Economic Area (“EEA”). When personal data is transferred outside the EEA, appropriate safeguards (e.g. EU model clauses) will be used to ensure an adequate level of protection of your personal data.
IV. Transfers only relate to personal data which is adequate, relevant and limited to what is necessary in relation to the purpose for which it is transferred.
D. Security, reliability and retention of information
I. Security
1. Autoliv has implemented appropriate technical and organizational measures, which are designed to implement data-protection principles (such as transparency) in an effective manner and integrated the necessary technical safeguards into the processing in order to protect information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data, and against all other unlawful forms of processing.
2. For the avoidance of doubt, Autoliv defines pseudonymous data as personal data processed in such a manner that they can no longer be attributed to you without the use of additional information, which Autoliv keeps separately and subject to technical and organizational measures to this effect.
II. Reliability
Autoliv takes reasonable steps to ensure that any personal data in its possession is accurate, current and reliable for the purposes set out above.
III. Retention
Autoliv will only retain your personal data for the minimum period necessary to serve the purposes as set out above, unless a longer retention period is required by law. Non-personal data may be retained without limitation in time.
E. Your rights
1. I. In respect of the collection and use of your personal data, you may:
§ withdraw your consent at any time for example by de-installing the Application or by changing the settings of your operating system;
§ ask Autoliv whether it processes personal data about you, for which purposes, the categories of personal data concerned, to which categories of recipients the information has been disclosed, where possible, the envisaged period for which the personal data will be stored (or, if not possible, the criteria used to determine that period);
§ inquire with Autoliv about the appropriate safeguards relating to the transfer of personal data outside the EEA (if applicable);
§ ask Autoliv for a copy of the personal data undergoing processing (including for data portability purposes)
§ have inaccurate data rectified;
§ object against the further processing and request erasure of your personal data;
§ request that the processing of your personal data is restricted by Autoliv;
§ request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;
§ ask to receive your personal data in a structured, commonly used and machine-readable format and to transmit those data to another controller without any hindrance from us.
II. In order to exercise your rights, you should send Autoliv a letter on the address provided below or an e-mail to [email protected] with a copy of your identity card or other proof of your identity. Autoliv will undertake the necessary action without undue delay and provide information on action taken (or the absence of any such action) within 30 days as of receiving your complaint.
Autoliv Development AB
Wallentinsvägen 22;
Vårgårda, 447 37;
Sweden
III. You may also lodge a complaint with a supervisory authority in case of a breach of the applicable privacy laws.
F. Data controller information
Autoliv Development AB
Wallentinsvägen 22;
Vårgårda, 447 37;
Sweden
G. Amendments
Autoliv reserves the right, in its sole discretion, to amend this Privacy Policy at any time by posting amendments on its website. You will be notified about any significant changes in advance.