Volvo Accident Assistance
Privacy policy

This Privacy Notice explains how Your personal data is used and what rights You have in relation to it.

It will:

• Explain how We collect, use, and share Your personal data when You use the Accident Assistance service.
• Help You make an informed decision about providing Your data and, where relevant, giving Us additional permissions for how it is used.
• Set out Your data protection rights and explain how You can raise concerns with the Information Commissioner’s Office if You are unhappy with the way Your data has been handled.

You can update Your consent or contact Us at any time using the details provided in this Privacy Notice.

Volvo Car UK Limited (Volvo) has appointed Wrisk Transfer Limited (WTL) to provide the Accident Assistance service. Wrisk has overall responsibility for the service and has appointed Axitech Limited (Axitech) and Broker Direct Plc (trading as Proficient) to deliver specific elements of accident management and claims handling.

For the purposes of this Privacy Notice, “We/Us/Our” refers collectively to Wrisk Transfer Ltd, Axitech Limited, and Broker Direct Plc (Proficient). We work as a team of specialists to provide an end-to-end service that ensures customers are able to obtain the support required in the event they are involved in an accident.

Wrisk Transfer Ltd. (WTL) is the primary controller of Your data for the Accident Assistance service, appointed by Volvo to deliver the service.

To deliver Accident Assistance, WTL works in partnership with Axitech Limited and Broker Direct Plc (Proficient). The purpose of processing Your personal data, and the way it is used within the service, is defined and coordinated by WTL together with these partners to provide accident management and claims-handling services.

• In most cases, Axitech and Broker Direct act as Processors, handling Your data on WTL’s instructions.
• In certain situations, Axitech and Broker Direct may act as independent controllers. For example:
• Broker Direct, when carrying out its own regulatory or claims management responsibilities.
• Axitech, when enabling accident management services under its own statutory duties.

Where this occurs, each company is responsible for its own processing activities and provides a separate privacy notice explaining how it manages Your data.

For more information, please refer to:

• Wrisk Transfer Ltd Privacy Policy:
  https://www.wrisk.co/privacy-policy
• Axitech Privacy Policy:
  https://www.axitech.co/privacy-and-legal/privacy-notice/
• Broker Direct Privacy Policy:
  https://www.brokerdirect.co.uk/index.php/privacy-statement/

You/Your means anyone whose personal information We collect, including:

• Anyone who has opted into being transferred to the Volvo Accident Assistance program following utilisation of the Emergency Call, e-Call, b-Call, or SOS Button.
• Anyone referred to Us who may have been rerouted to the Volvo Accident Assistance team through the Volvo Roadside Assistance program.
• A website user on this website.
• Any user of the Volvo Accident Assistance phone lines.
• Any user calling the Volvo Roadside Assistance phone line to report a crash who has been redirected to the Volvo Accident Assistance Program.
• Any person requesting a vehicle repair managed by Us as part of an accident assistance service.
• Any person You authorise to act on Your behalf in dealing with any of the services that We provide.
• A user of the “Volvo Cars app”, which is the smartphone application (“App”) that You have downloaded from the Online Store onto Your smartphone or handheld device (collectively referred to as “Device”).
• Any official Volvo website that references the Volvo Accident Assistance service.
• A subscriber to any official Volvo services that deliver the Volvo Accident Assistance service.

When utilising the Accident Assistance Service, You may provide details of third parties, witnesses, and passengers, including sensitive personal data. You should make any third parties, witnesses and passengers aware of this Privacy Notice. By providing Your details, You are confirming to Us that this is the case.

Data You Provide

We collect the information You give Us when You use Our Accident Assistance service, and at any other time that We communicate with You. This may include sensitive personal data relating to an accident, such as:

• details of any injuries sustained
• the circumstances of the accident

This information may also be shared with Us by our upstream partners (including Volvo and Your franchise retailer), to whom You have voluntarily provided Your data. We may receive it via telephone call or digital form to facilitate the Accident Assistance service. In some cases, data may be automatically collected from Your vehicle’s systems and transmitted to an upstream provider, which may then pass it to Us to support Accident Assistance.

We record Our telephone calls with You, and these recordings form part of Your personal data. Recording calls helps Us to:

• ensure the quality of Our service
• check the accuracy of the information provided
• support the effective management of Your claim

Interaction data

We also store information about how You interact with Us, such as:

• the time, length, and source of calls
• the IP address You use to access Our website
• whether You open or reply to emails We send You

This data is used to improve Our services, prevent fraud, and handle complaints.

Cookies

Our websites use cookies (small text files stored on Your device) to track and record Your online activity. This helps Us tailor Our websites to better suit Your preferences and enhance Your overall experience.

We use both essential cookies (needed for the operation of the site) and non-essential cookies (which require Your permission). Non-essential cookies are not used to identify You personally, but to provide Us with useful knowledge about how the site is used, so We can keep improving it.

Google Analytics

We use Google Analytics, a popular web analytics service provided by Google, Inc. Google Analytics helps Us analyse how users use the site by counting visitors and measuring behaviours such as average visit length and number of pages viewed.

The information generated by these cookies (including Your IP address) is transmitted to and stored by Google on servers in the United States. Google uses this information to:

• evaluate Your use of Our website
• compile reports on website activity
• provide other services relating to website activity and internet usage

Google may also transfer this information to third parties where required by law, or where such parties process information on Google’s behalf. Google does not associate Your IP address with any other data it holds.

If You have Adobe Flash installed on Your computer and use Our audio or video players, Google Analytics may store additional “Flash cookies” on Your device. These allow us to analyse the popularity of media files, for example:

• how many times a file is played
• how many people watch a video through to the end
• how many stop midway

Adobe provides tools to manage Flash cookies on Your computer. You can also delete cookies through Your file management software or web browser. More information on cookies, including how to block or delete them, can be found at AboutCookies.org.

Data from franchise retailers

In some cases, You may ask Your franchise retailer to share certain information with Us to facilitate the Accident Assistance Service. When this happens, We treat that information as if You had provided it directly, and consider the franchise retailer to be acting on Your behalf.

Data We Collect from Others

We may have initially made contact with You after being provided with Your details by a third party, such as the Roadside Assistance provider or Emergency Call operator provider. In such cases, they may provide Us with data they hold that is relevant for the purpose of Us providing You with accident assistance services.

We will only receive this data where We are satisfied that the provider has Your consent or another lawful reason to share it with Us.

In the course of providing accident assistance services, We may collect data from third parties about You, including:

• Audatex: To obtain estimates for vehicle repair costs.
• Car web VRM look-up: To verify vehicle registration details.
• Car web Indicative value: To obtain an indicative market value of Your vehicle.
• CAPS: To streamline the claims and repair process, reduce duplication of work, and tracking repairs status.
• DVLA and MyLicence: To verify Your driving licence details.
• Motor Insurance Database (MID): To check insurance details related to the vehicle involved in the accident.
• Vehicle Valuation: To assess the current valuation of Your vehicle.
• Vehicle Provenance: To check the history and provenance of Your vehicle.
• SIRA (Synectics Solutions Insurance Fraud Prevention): To verify information against known fraud indicators.

We will use Your data to fulfil requests You make of Us and to meet the requirements of any services We provide to You.

For instance:

• If You request the Accident Assistance service, We will use Your data to manage and coordinate Your claim, including providing Your details to repairers or other service providers as necessary to facilitate the repair of Your vehicle. We will also use Your information to communicate with You about the status of Your claim and to provide updates on the repair process.
• If You ask Us to manage the repair of Your car after an accident, We will appoint a repairer and provide them with Your and Your car's details so they can carry out the repair and communicate back to Us information about the repair.
• In the event of an accident, We may use data You have provided to assist in the management of any related services We offer, such as vehicle recovery, to ensure that Your experience is as smooth as possible.
• To improve our Accident Assistance service, We may use Your data to review the efficiency and effectiveness of the service provided, including how repairs are managed and customer service is delivered.
• Managing Our relationship with You, addressing any feedback or complaints, and resolving any issues that may arise during the provision of Our Accident Assistance services.

Please note that We operate in compliance with UK data protection regulations, ensuring that Your information is handled lawfully and securely at all times.

Additionally, We will process Your data to fulfil Our legitimate interests, provided these are not overridden by Your interests. This includes:

• Assisting You when You are using Our online services, such as navigating Our website or accessing features related to Accident Assistance.
• Administering Our business, which includes:
• Fraud prevention and detection to protect both Our interests and Yours.
• Debt recovery, where necessary.
• Verifying Your identity to ensure the security of Your personal data.
• Conducting customer satisfaction surveys to improve the quality of Our services.
• Resolving effectively any complaints that may arise.
• Researching new service offerings that may benefit You.
• Evaluating the performance and efficiency of Our services.
• Analysing Our services to enhance and develop them further, and to personalise Our offerings to Your preferences.
• Should We engage with partners or affiliates in providing Our Accident Assistance services, We may share necessary data with them to ensure a seamless service experience.

You have the right to ask Us not to process Your data for these purposes, and We will consider Your request in line with Your rights under data protection laws (see Your rights to object to processing of Your data below).

In relation to the Accident Assistance services that You request from Us, We may provide Your data to certain third parties and sub-processors necessary to fulfil these services. These parties include law firms, independent assessors, and subcontractors of repair shops, to assist in providing the Accident Assistance service. These sub-processors are contractually obligated to protect Your data and ensure compliance with applicable data protection laws. Data shared with sub-processors and third parties is governed by Data Sharing Agreements (DSAs) where applicable, ensuring that Your data is handled securely and in compliance with data protection regulations.

Categories of Third Parties and Sub-processors We Use:

• Your vehicle manufacturer and Your franchise retailer, to facilitate repairs or other related services.
• Approved claim administrators, loss adjusters, and recovery agents who assist in managing Your claim.
• Approved repairers and network managers who are responsible for the physical work on Your vehicle.
• Approved car hire firms and vehicle replacement providers, to supply You with a courtesy or replacement vehicle where required as part of Accident Assistance.
• Companies that conduct customer satisfaction surveys, which help Us improve Our service quality.
• IT providers who support Our data management and infrastructure.
• Providers of Regulatory Compliance Services, ensuring that Our services remain compliant with legal standards.
• The Motor Insurance Database (MID), the Claims and Underwriting Exchange (CUE), and the Motor Insurance Anti-Fraud and Theft Register (MIAFTR) to verify and manage claims in an efficient and fraud-free manner.
• Emergency services, police, medical, and legal practices, if necessary, to support Your claim or the Accident Assistance service.
• Our professional advisers who guide Us in providing a compliant and customer-focused service.
• In certain cases, MSX International Limited (MSXI) may act as a data processor, to manage data related to total loss avoidance services, ensuring accurate and compliant processing under Axitech's instructions.

Please note that We share data with these third parties only to the extent necessary for the provision of Our Accident Assistance services and in compliance with data protection regulations.

We use servers located in the UK to store Your personal information, or elsewhere in the EU where it is protected by laws equivalent to those in the UK. Some of Our suppliers and partners who are involved in the Accident Assistance service may transfer Your personal information outside of the EU. In such cases, Our contracts with these suppliers require them to provide equivalent levels of protection for Your personal information as it would have in the EU.

We will retain the personal information We collect from You when there is an ongoing legitimate business need to do so (for example, to provide You with a service You have requested or to comply with applicable legal, tax, or accounting requirements).

As outlined in this Privacy Notice, personal information will be kept for as long as necessary to achieve the purposes for which it was collected, unless a longer retention period is required or permitted by law.

You have the right to request deletion of Your personal information at any time, and We will assess such requests in line with applicable legislation (please refer to "What are Your data protection rights?" in this Notice).

We will maintain Your personally identifiable information, data You directly input into Our web application, and information gathered from Our partners, in accordance with Our data retention policy (7 years after the expiry or settlement of the service provided). Throughout this period, Your information will be held securely. After this term expires, We will either delete or anonymise Your information. We may retain aggregate data beyond this period for research and to enhance our services. This anonymised data cannot be used to identify You and may be kept indefinitely for these purposes.

Exceptions to the standard retention period include:

• Legal obligations that require Us to retain personal data for a specific period or to delete it sooner.
• Instances where You have made a legal claim, lodged a complaint, or raised concerns about a product or service We provide. Here, We may retain Your information for 7 years from the date of expiry or settlement of the service provided.
• Circumstances where You have exercised Your right to data erasure, and We do not require holding it due to any reasons permitted or required by law.

As a data subject whose personal data We process, You have certain rights regarding the processing of Your data:

The Right to Be Informed

You have the right to be informed about the processing of Your data in a clear, transparent way. This Privacy Notice is intended to fulfil that right. If You have further questions about data processing, please contact Us using the details in the ‘Contact Us’ section of this Notice.

The Right of Access

You have the right to access Your data and receive a copy of the personal data We process about You. This can be requested at any time and is known as a Subject Access Request. We aim to respond to Your request within one month.

The Right to Rectification

You are entitled to have any incorrect or incomplete data We hold about You corrected.

The Right to Be Forgotten

You can request the deletion of Your data where there is no compelling reason for its continued processing. This includes situations where the data is no longer necessary, consent has been withdrawn, or there is no legitimate interest in processing.

The Right to Restrict Processing

You may request that We restrict processing Your data, meaning we will store it but not process it further if:

• The accuracy of the personal data is contested.
• Processing is unlawful, and You oppose its deletion.
• We no longer need the data, but You require it for a legal claim.
• You have objected to processing, pending verification of that objection.

The Right to Object

You have the right to object to processing based on Our legitimate interests unless Our reasons for the processing outweigh any prejudice to Your data protection rights.

Your Right to Lodge a Complaint with the Information Commissioner

If You are dissatisfied with the way We are processing Your personal data, You have the right to raise a complaint with the Information Commissioner’s Office (ICO). You can do this through their website at https://ico.org.uk, by calling 0303 123 1113 or 01625 545 745, or by writing to:

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

If You have any further questions on how We process Your data or anything further in this document, You can contact Our Data Protection teams as follows:

Wrisk Transfer Limited - privacy@wrisk.co

Broker Direct Plc Trading as Proficient - compliance@brokerdirect.co.uk

Axitech Limited - privacy@axitech.co

We may update this Privacy Notice from time to time to reflect changes in Our services or feedback from customers. We encourage You to review it periodically so that You remain informed about how We protect and use Your personal information.