Volvo Financial Services Global

This Safe Harbor Privacy Policy (“Policy”) covers customers’ personal information (as defined below) that is subject to the European Union Data Protection Directive. Volvo Financial Services LLC (“VFS”, “we “ or “us”) has prepared this privacy statement to describe its approach to meeting the seven principles of the Safe Harbor agreed to by the European Commission on July 27, 2000. VFS adheres to the Safe Harbor Principles as administered by the U.S. Department of Commerce (for more information, visit http://www.export.gov/safeharbor).

Scope

This Policy applies to all personal information received by VFS from the European Economic Area (EEA), in any format including electronic, paper or verbal.

“Personal information” means any information or set of information received by VFS from the EEA that identifies or could be used to identify an individual covered by the Safe Harbor Framework.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions religious or philosophical beliefs, or trade union membership, or that concerns or the health or sex life of an individual.

Notice

When personal information is collected from individuals in the EEA, they will be informed of the purpose for which the information is collected and how the information will be used. Any non-agent third parties to whom any information will be disclosed will be disclosed to the individual. Notice will be provided in clear language when individuals are first asked to provide personal information, or as soon as practicable thereafter, and in any event before VFS uses the information for a purpose other than that for which it was originally collected. VFS may disclose personal information if required to do so by law or to protect and defend the rights and property of VFS.

Choice

VFS will offer individuals the opportunity to choose (opt out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Affirmative or explicit (opt in) choice will be given if sensitive personal information is to be disclosed to a non-agent third party or used for a purpose other than its original purpose or the purpose authorized subsequently by the individual.

Data Integrity

VFS will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. VFS will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.

Transfer to Agents

VFS may share an individual’s information with agents, contractors or partners of VFS in connection with services that these entities perform for, or with, VFS. VFS may, for example, provide an individual’s personal information to contractors or business partners for performing customer surveys, hosting our databases, for data processing or to send that individual the information that he or she requested. Where VFS has knowledge that an agent is using or disclosing personal information in a manner contrary to this policy, VFS will take reasonable steps to prevent or stop the use or disclosure.

Access and Correction

Upon request, individuals will be granted to reasonable access to personal information that VFS holds about them, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question. If you become aware that personal information VFS maintains about you is inaccurate or if you would like to correct, amend or delete the information, you may contact us as indicated below and request a change.

Security

VFS will employ reasonable safeguards to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. For personal information subject to electronic storage or transmission, VFS utilizes an internal, secure global network maintained by the Volvo Group that is protected from computer virus infection and monitored for unauthorized access. Both electronic and paper based records holding personal information are maintained in access controlled facilities for which business continuity plans are required.

Enforcement

VFS will conduct audits of its relevant privacy practices to verify adherence to this Policy. All reported breaches will be investigated by the Privacy Officer and the agents he assigns, who will take such actions as they deem appropriate in the investigation and remediation of the situation. We encourage you to raise any concerns or complaints directly with us at the address listed below.

Dispute Resolution

Any questions or concerns regarding the use or disclosure of personal information should be directed to the VFS Privacy Officer at the address listed below. VFS will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of personal information in accordance with the principles stated in this policy. For complaints that cannot be resolved between VFS and the complainant, (you may contact (the US Federal Trade Commission. or) VFS has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.

Contact Information

VFS has designated Scott Rafkin, its Sr. VP of Global Operations and Business Excellence, as the Privacy Officer responsible for its compliance with and enforcement of this Policy. You may reach him by mail at

Scott Rafkin
Volvo Financial Services
Hunderenveldlaan 10
B – 1082 Brussels
Belgium
scott.rafkin@vfsco.com

Please include your name, address, and phone number or email in all communications and clearly state the nature of your request.

Effective Date and Changes to this Policy

The practices described in this Policy are the current personal information protection policies as of October 1, 2007. VFS reserves the right to modify, amend or terminate this Policy at any time consistent with the requirements of the Safe Harbor Principles. Appropriate public notice (e.g., on our website) will be given concerning such changes.

Limitation on Application of Principles

Adherence by VFS to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation, and (b) to the extent permitted by applicable law.

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