Customer Privacy Policy

1. Introduction

This privacy policy covers all processing of personal data performed by Polestar Performance AB and/or Polestar Automotive Canada Inc. ("Polestar", “our”, “us” or "we"), except for:

• processing of your data relating to our cars, which is explained in our Car Privacy Notice [coming soon], and

• processing of your data in relation to our apps, which is explained in our privacy notice for each app.

It is important to us that you always feel safe and informed about how we process your personal data. In this privacy policy, you can learn more about what personal data we collect and process about you, why we do it, how we use the personal data and how we ensure that your personal data is handled in accordance with applicable legislation, and what rights you have. You can of course contact us, or our privacy officer, if you have questions about our processing of your personal data. See contact details.

This policy is updated continuously to reflect the measures taken by Polestar in relation to your personal data. Read more.

This privacy policy does not apply to authorized Polestar retailers, or third parties to whom you directly provide your information including, but not limited to, subscription services, or other third parties who may offer special rates or products to Polestar Automotive Canada Inc. customers, nor to content posted on their websites or social media channels. These entities are independent of Polestar Automotive Canada Inc. and responsible for their own collection of information. Please refer directly to those entities and their particular privacy policies for more information.

The concepts “controller” and “joint controllers” are terms used in the EU GDPR. A controller is the company that determines the purposes (why) and the means (how) of personal data processing – in other words, the controller is responsible for the processing of the personal data. When two or more companies jointly determine the purpose and means of the personal data processing, those companies are called joint controllers. The term “processor” refers to service providers or third parties who processes personal data on behalf of the controller. In the text and in each of the tables below you will find who the controller or joint controllers is/are for each processing. You will also find out where Polestar Performance AB or Polestar Automotive Canada Inc. acts as a processor. Each controller, joint controller, or processor is an “Organization” under Canadian privacy law and we explain their respective roles below.

2. When do we process your personal data?

2.1 Overview

In this section, we will inform you about what personal data we process about you, for what purposes, what our legal basis for the processing is, how long we will process your personal data for, and who the controller/controllers are for each processing purpose. We may process your personal data for several of the following purposes at once. The information is divided into the following parts:

1. 1.

   Polestar website, which includes information about our processing of personal data related to our chat function, your account on polestar.com and our processing of personal data collected using cookies. Read more.

2. 2.

   When providing our products and services, which includes information about our processing of personal data relating to your Polestar ID accounts, your purchase of products and services, your reservation of a build slot for a vehicle and our waiting list for such build slots, test drive bookings, service bookings, our referral program, our Polestar Fleet Portal, our administration of request for change of ownership of a vehicle and our Guest Wi-Fi. Read more.

3. 3.

   When we are in contact with you, which includes information about our processing of personal data relating to our customer support, our contacts with you on social media and on Polestar Community, our virtual and digital consultations, our events and competitions and our contact with you to remind you of non-completed orders. Read more.

4. 4.

   When marketing our business, brands, products and services, which includes information about our processing of personal data relating to marketing through telephone, e-mail, websites, social media and press releases and our use in marketing material of photos and videos of participants at events. In this section you will also find information about our profiling for marketing purposes. Read more.

5. 5.

   When developing our business, products and services, which includes information about our processing of personal data relating to our use of surveys and market research, training of our employees and our continuous work with developing our business, systems, products and services. Read more.

6. 6.

   E-mail analyses. We use technologies such as tracking pixels or click-through links when sending you e-mails. The purpose of using tracking pixels is to analyse if and how many emails are delivered and opened. The purpose of using click-through links is to analyse which links in our emails are clicked, to understand what interest there is in specific content. We use the result to make our e-mails more relevant or to stop them from being sent. By deactivating the display of images in your e-mail client, we will not be able to measure the opening rate of our e-mails using tracking pixels and the e-mail will not be displayed completely. However, if you click on text or graphic links in the e-mail, we will still be able to track whether the e-mail has been opened. To avoid that such data is collected and tracked, do not click on text or graphic links in the e-mails.

7. 7.

   When you apply for a job at Polestar. Read more.

8. 8.

   To comply with laws, legal obligations and voluntary undertakings and in the event of claims, disputes, supervision etc. This part includes information about our processing of personal data relating to recalls, claims and complaints, data subject requests, data subject complaints, data breaches and supervision, disputes, bookkeeping, financial reporting, transfer of data in the event om merger and acquisition and sharing of personal data with authorities. Read more.

2.2 Polestar’s website

2.2.1 Web analytics/cookies

When you visit our website, we collect certain information about you using cookies and other tracking technologies. This is for our website to function, to improve the user experience of our website, to collect visitor statistics and to provide you with relevant marketing in various channels (see more details regarding the marketing purpose). For more information on how we manage cookies, see our Cookie Policy. Polestar Performance AB is controller for the processing relating to web analytics/cookies.

2.2.2 The chat

To chat with you and answer your questions and provide you with requested information, products and services, we process your personal data. Read more about our processing related to the chat under customer support. Polestar Performance AB and Polestar Automotive Canada Inc. are joint controllers for processing relating to the chat.

2.2.3 Your Polestar ID account on polestar.com

For you to be able to create and log in to your account on our website and use those web services that require a Polestar ID, we will process your name, email address, phone number, password, relevant market and preferred language. Our legal basis for processing your personal data is to perform the contract (GDPR, article 6.1 (b)). We will continue to process your personal data for up to thirty (30) days after you have terminated your account. Polestar Performance AB is controller for the processing relating to your Polestar ID account.

2.5.1 Profiling

3. Where do we get your personal data from?

We mainly collect your personal data directly from you, but in some cases, we also collect personal data from other sources, namely when:

• you decide to finance your vehicle through leasing or a loan: we collect information about the status of your finance or leasing application from the finance or leasing company.

• service is performed on your vehicle: we collect information about the services performed on your vehicle in the workshop.

• we need to verify the registered owner with the authorities in case of a recall: we collect your name, address, phone number and e-mail address from the authority.

• we receive a request for change of ownership from the registered owner of the vehicle: we collect the new owner’s e-mail address from the registered owner.

• we create some personal data about you, such as Vehicle Identification Number (VIN) and individual license plate of your purchased vehicle, which will be personal data about you. We may also observe and infer personal data about you, such as your online behaviour and segment affiliation. Read more.

4. Disclosure of your personal data

4.1 How we disclose your personal data and who we disclose it to

To provide our products and services and to comply with laws and regulations, we need to share your personal data with others, including other companies within the Polestar Group and third parties assisting us in various parts of our business and helping us to deliver our products and services. In each table you can find information about whom the data is shared with, and you can also find the categories of recipients listed below.

• IT providers, e.g. companies that manage the necessary operation, technical support and maintenance of our IT solutions,

• Polestar affiliates,

• Subcontractors: mail and messaging services, banks and payment service providers, providers of analytics services,

• Authorities, in certain circumstances, we may be legally required to disclose information to government or law enforcement authorities, e.g. the police, the privacy protection authority, tax authorities, public courts, authorities for official registering of the vehicle, or enforcement agencies. This may be in response to valid and lawful requests, such as subpoenas, court orders or other legal processes. We may also disclose information when necessary to protect the rights, property, or safety of you, us, or others.

  We comply with all applicable laws and regulations regarding the disclosure of information to government authorities. We carefully review each request to ensure its validity and legality, as well as the impact of the data disclosure on the subjects concerned by the request before disclosing any information. We strive to protect your privacy and rights to the extent permitted by law.

  In the event of a government request for information, we will make reasonable efforts to notify you unless prohibited by law or court order. If you have any questions or concerns about our practice of disclosing information to authorities, please contact us.

• Business partners, e.g. workshops, finance and leasing companies, insurance companies, legal counsels, printing companies (marketing purposes), advertising agencies/companies, market research companies, and

• Providers of social media platforms.

4.2 Processing of your personal data outside of the province it was collected

Because we use service providers that are located in the US, and our service providers in the US also rely on the services of our affiliates in the US and the European Union or United Kingdom, your personal data will be transferred outside the Canadian province where it was collected for these purposes.

Polestar Automotive Canada Inc. transfers personal data to the European Union, the US and the United Kingdom.

In providing its services to Polestar Automotive Canada Inc., Polestar Performance AB also sometimes transfers the personal data to service providers outside if EU/EEA or to the US. Under EU privacy law this constitutes a reverse transfer. Transfers to the United Kingdom are carried out pursuant to its adequacy decision. For transfers to other countries outside of EU/EEA and the US, that do not have an adequacy decision, we use EU Model Clauses entered into by all relevant third parties (article 46 of the GDPR) or they are certified under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S Data Privacy Framework and/or the Swiss-U.S. Data Privacy Framework with the U.S. Department of Commerce. In addition, we take additional technical and organizational security measures when needed, such as encryption and pseudonymization.

5. Your rights

Below, you can find a list of your rights related to our processing of your personal data under the GDPR and privacy laws in Canada e.g. PIPEDA.

To exercise your right, you may submit a request by using our web form, call (800) 806-2507 or email us at dpo@polestar.com. For requests submitted via telephone or email, you must provide us with information to allows us to reasonably verify that you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.

5.1 Right to lodge complaints

You always have the right to lodge a complaint with the supervisory authority where you live, work or where you believe an infringement has taken place. In Sweden, you have the right to lodge a complaint with the Swedish Supervisory Authority for Privacy Protection (IMY). A list of European supervisory authorities is available here.

Under PIPEDA, you have the right to complain directly to us regarding our alleged noncompliance with PIPEDA. We will review and respond to your complaint. PIPEDA-related complaints can be directed to our Privacy Officer at dpo@polestar.com c/o Polestar Automotive Canada Inc.

5.2 Right to information and a copy of your personal data

You have the right to know if we process personal data about you. If we do, you also have the right to receive information about the personal data we process and why we do it. If we collect your personal information from another person or entity (i.e. not you), you have the right to be informed of our source for your data. Similarly, if we share your information with another person or entity, you have the right to request we disclose to you those parties. Furthermore, you have the right to receive a copy of all personal data we have about you.

If you are interested in specific information, please indicate it in your request. For example, you can specify if you are interested in a certain type of information, such as what specific contact details we have about you, or if you want information from a certain period.

5.3 Right to have erroneous or outdated personal data corrected, updated or completed

If the personal data we hold about you is incorrect, you have the right to have it corrected. You also have the right to supplement incomplete information with additional information that may be needed for the information to be correct.

Once we have corrected your personal data, or it has been supplemented, we will inform those we have shared your data with (when applicable) about the update - if it is not impossible or too cumbersome. If you ask us, we will of course also tell you who we have shared your data with.

If you request to have data corrected, you also have the right to request that we restrict our processing during the time we investigate the matter.

5.4 Right to have personal data deleted

In some cases, you have the right to have your data deleted, namely when:

1. 1.

   the data is no longer needed for the purposes for which we collected it,

2. 2.

   you withdraw your consent and there is no other legal ground for the processing (if applicable),

3. 3.

   the data is used for direct marketing and you unsubscribe from it,

4. 4.

   you oppose use that is based on our legitimate interest and we cannot show compelling grounds for the processing which override your interests and rights,

5. 5.

   the personal data has been used unlawfully, or

6. 6.

   deletion is required to fulfil a legal obligation.

If we delete personal data following your request, we will also inform those we have shared your data with (when applicable) - if it is not impossible or too cumbersome. If you ask us, we will also tell you who we have shared your data with.

5.5 Objecting to our use

You have the right to object to processing that is based on our legitimate interest. If you object to the use, we will, based on your situation, evaluate if our interests in using the personal data outweigh your interests in the personal data not being used for that purpose. If we are unable to provide compelling legitimate grounds that override yours, we will stop using the personal data you object to – provided we do not have to use the data to establish, exercise or defend legal claims. If you object to the use, you also have the right to request that we restrict our use during the time we investigate the matter.

You always have the right to object to, and unsubscribe from, direct marketing.

5.6 Right to withdraw your consent

You have the right to withdraw your consent for a specific processing at any time. You can withdraw your consent by contacting us. If you withdraw your consent, we will also instruct our processors to, if possible, end any processing of relevant information that we have shared with them.

Your withdrawal will not affect processing that has already been carried out.

5.7 Right to request restriction

Restriction means that the data is marked so that it may only be used for certain limited purposes. The right to restriction applies:

1. 1.

   when you believe the personal data are incorrect/inaccurate and you have requested correction. If so, you can also request that we limit our use while we investigate if the data are correct or not.

2. 2.

   if the use is unlawful but you do not want the personal data to be erased.

3. 3.

   when we no longer need the data for the purposes for which we collected it, but you need it to be able to establish, exercise or defend legal claims.

4. 4.

   if you object to the use. If so, you can request that we limit our use while we investigate if our interest in processing your data outweighs your interests.

Even if you have requested that we restrict our use of your data, we have the right to use it for storage, if we have obtained your consent to use it, to assert or defend legal claims or to protect someone’s rights. We may also use the information for reasons relating to an important public interest.

We will let you know when the restriction expires.

If we limit our use of your data, we will also inform those we have shared your data with (when applicable) - if it is not impossible or too cumbersome. If you ask us, we will also tell you who we have shared your data with.

5.8 Right to data portability

If the processing is based on your consent or an agreement between us, you have the right to obtain personal data that you have provided to us in a structured, commonly used and machine-readable format and transfer it to another controller (“data portability”).

6. Rights under Quebec 64

If you are a resident of Quebec, you have some additional rights as described below:

Decisions based on automated processing. If we use your personal information to render a decision based exclusively on automated processing, you have the right to be informed of this at or before the time of the decision.

7. Contacts

Polestar Performance AB is the primary point of contact for data subjects that wish to exercise their rights and the main responsible for providing information to data subjects, for the uses of data where the controller is a company in the Polestar Group. You are of course entitled to exercise your rights under the GDPR in respect of and against each controller mentioned in this policy.

Each controller’s identity and contact details are listed below.

Polestar Performance AB is a Swedish legal entity with company registration number 556653-3096, with mailing address Assar Gabrielssons Väg 9, 405 31 Gothenburg, Sweden, and visiting address Polestar HQ, Assar Gabrielssons Väg 9, 418 78 Göteborg.

Polestar Automotive Canada Inc. is a Canadian legal entity with company registration number 2021859588 having its address at 2500, 10303 Japser Avenue, Edmonton, Alberta, T5J 3N6, Canada. Polestar Automotive Canada Inc. is – within the joint controllership – generally responsible for marketing, sales and customer relations as well as market specific services in its market.

Polestar has appointed a Privacy Officer for the Polestar Group who can be reached via email or via post as set out below:

• E-mail address: dpo@polestar.com

• Postal address: Polestar Performance AB, Attention: The Privacy Officer, 405 31 Göteborg, Sweden

Prominate Ltd., a UK legal entity with company registration number 07795532, with address 21 Lombard Street, London, ECV3 9AH, United Kingdom.

8. Changes to this privacy policy

We reserve the right to change this privacy policy from time to time. We will inform you of any changes by posting the updated privacy policy on our website (including clarification of updates). If we make any material changes to our privacy policy, we will send a notification by e-mail. We encourage you to contact us if you have any questions about the privacy policy or about how we process your personal data.