Data protection notice
Data protection notice of Robert Bosch Limitada
A Robert Bosch Ltda (hereinafter “Bosch” or “We” or “Us”) welcomes you to our internet pages and mobile applications (together also referred to as “Online Offers”). We thank you for your interest in our company and our products.
1. Bosch respects your privacy
The protection of your privacy throughout the course of processing personal data as well as the security of all business data are important concerns to us. We process personal data that was gathered during your visit of our Online Offers confidentially and only in accordance with statutory regulations.
Data protection and information security are included in our corporate policy.
2. Controller
Bosch is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows:
Robert Bosch Limitada
Via Anhanguera, km 98
Vila Boa Vista
13.065-900 – Campinas – SP
Email: sac@br.bosch.com
Phone: + 55 0800 704 5446
3. Collection, processing and usage of personal data
3.1. Processed categories of data
The following categories of data are processed:
- Communication data (e.g. name, telephone, e-mail, address, IP address)
- Client history
- Transaction data
3.2. Principles
Personal data consists of all information related to an identified or identifiable natural person, which includes, e.g. names, addresses, phone numbers, email addresses, contractual master data, contract accounting and payment data, which is an expression of a person's identity.
We collect, process and use personal data (including IP addresses) only when there is a statutory legal basis to do so, e.g., for compliance with a legal or regulatory obligation or when you have given your consent for the processing of your personal data.
3.3. Processing purposes
We as well as the service providers commissioned by us; process your personal data for the following processing purposes:
3.3.1. Advertisements and/or market research (including web analysis, no customer surveys)
Self-promotion and promotion by others as well as market research and reach analysis done within the scope statutorily permitted or based on consent.
3.3.2. Raffles/ discount campaigns
Conducting raffles or discount campaigns in accordance with respective terms and conditions for raffles or discount campaigns.
3.3.3. Newsletter (Email, SMS/MMS)
In the context of our online offer, you can subscribe to receive newsletter with focus on informative report and products information, further information please check chapter – 8. [Newsletter with opt-in; Right of withdrawal].
3.3.4. Safeguarding and defending our rights
Legal basis: Legitimate interest on our part for safeguarding and defending our rights.
3.3.5. Survey
Online pop-up survey among website users w/r to their information needs.
Participation is voluntary and completely anonymous, personal information will not be collected or shared.
The survey will be conducted by the research agency OPINION Market Research & Consulting GmbH.
3.4. Registration
If you wish to use or get access to benefits requiring to enter into the fulfillment of a contract, we request your registration. With your registration we collect personal data necessary for entering into the fulfillment of the contract (e.g. first name, last name, date of birth, email address, if applicable, details on the preferred payment method or on the account holder) as well as further data on voluntary basis, if applicable. Mandatory information is marked with an *.
3.5. Log files
Each time you use the internet, your browser is transmitting certain information which we store in so-called log files.
We store log files to determine service disruptions and for security reasons (e.g., to investigate attack attempts) for a period of 06 and delete them afterwards. Log files which need to be maintained for evidence purposes are excluded from deletion until the respective incident is resolved and may, on a case-by-case basis, be passed on to investigating authorities.
In log files, the following information is saved:
- IP address (internet protocol address) of the terminal device used to access the Online Offer;
- Internet address of the website from which the Online Offer is accessed (so-called URL of origin or referrer URL);
- Name of the service provider which was used to access the Online Offer;
- Name of the files or information accessed;
- Date and time as well as duration of recalling the data;
- Amount of data transferred;
- Operating system and information on the internet browser used, including add-ons installed (e.g., Flash Player);
- http status code (e.g., “Request successful” or “File requested not found”).
3.6. Children and Teenagers
This Online Offer is not meant for data subjects under 16 years of age.
3.7. Shared use of data
Principally, your personal data is forwarded to a third party only if required for the fulfillment of a contractual obligation, or if we ourselves, or a third party, have a legitimate interest in the data transfer, or if you have given your consent. Particulars on the recipients or categories of recipients can be found in the Section – 3.3. Processing purposes.
Additionally, data may be transferred to a third party when we are obliged to do so due to statutory regulations or enforceable administrative or judicial orders.
3.7.1. Service providers (general)
We involve external service providers with tasks such as sales and marketing services, contract management, payment handling, programming, data hosting and hotline services. We have chosen those service providers carefully and monitor them on a regular basis, especially regarding their diligent handling of and protection of the data that they store. All service providers are obliged to maintain confidentiality and to comply with the statutory provisions. Service providers may also be other Bosch group companies.
3.8. Transfer to recipients outside Brazil
We might transfer personal data to recipients located outside Brazil into so-called third countries. In such cases, prior to the transfer we ensure that either the data recipient provides an appropriate level of data protection or that you have consented to the transfer.
3.9. Duration of storage, retention periods
Principally, we store your data for as long as it is necessary to render our Online Offers and connected services or for as long as we have a legitimate interest in storing the data (e.g. we might still have a legitimate interest in postal mail marketing after fulfillment of our contractual obligations). In all other cases we delete your personal data with the exception of data we are obliged to store for the fulfillment of legal obligations (e.g. due to retention periods under the tax and commercial codes we are obliged to have documents such as contracts and invoices available for a certain period of time).
4. Raffles or discount campaigns
In case you participate in one of our raffles or discount campaigns, we use your data to inform you about any prize won and for the purpose of advertising our products to the extent allowed by law or as far as you have consented. Information on raffles or discount campaigns can be found in the respective terms of participation.
5. Usage of
In the context of our online service, cookies and tracking mechanisms may be used.
Cookies are small text files that may be stored on your device when visiting our online service.
Tracking is possible using different technologies. In particular, we process information using pixel technology and/or during log file analysis.
5.1. Categories
We distinguish between cookies that are mandatorily required for the technical functions of the online service and such cookies and tracking mechanisms that are not mandatorily required for the technical function of the online service.
It is generally possible to use the online service without any cookies that serve non-technical purposes.
5.1.1. Technically required cookies
By technically required cookies we mean cookies without those the technical provision of the online service cannot be ensured. These include e.g. cookies that store data to ensure smooth reproduction of video or audio footage.
Such cookies will be deleted when you leave the website.
5.1.2. Cookies and tracking mechanisms that are technically not required
We only use cookies and tracking mechanisms if you have given us your prior consent in each case. With the exception of the cookie that saves the current status of your privacy settings (selection cookie). This cookie is set based on legitimate interest.
We distinguish between two sub-categories with regard to these cookies and tracking mechanisms:
5.2. Comfort cookies
These cookies facilitate operation and thus allow you to browse our online service more comfortably; e.g. your language settings may be included in these cookies.
5.3. Marketing cookies and tracking mechanisms
General
By using marketing cookies and tracking mechanisms we and our partners are able to show you offerings based on your interests, resulting from an analysis of your user behavior:
- Statistics:
By using statistical tools, we measure e.g. the number of your page views.
- Conversion tracking:
Our conversion tracking partners place a cookie on your computer ("conversion cookie") if you accessed our website via an advertisement of the respective partner. Normally these cookies are no longer valid after 30 days. If you visit certain pages of our website and the cookie has not yet expired, we and the relevant conversion partner can recognize that a certain user clicked on the advertisement and thereby was redirected to our website. This can also be done across multiple devices. The information obtained by means of the conversion cookie serves the purpose of compiling conversion statistics and recording the total number of users who clicked on the respective advertisement and were redirected to a website with a conversion tracking tag.
- Social plugins:
Some of the pages of our online service involve content and services of other providers (e.g. Facebook, Twitter) which also may use cookies and active modules. For more details regarding social plugins please refer to the section on social plugins.
- Retargeting:
These tools create user profiles by means of advertising cookies or third-party advertising cookies so called "web beacons" (invisible graphics that are also called pixels or tracking pixels), or by means of comparable technologies. These are used for interest-based advertising and to control the frequency with which the user looks at certain advertisements. The relevant provider is the controller responsible for the processing of data in connection with the tool. The providers of the tools might disclose information also to third parties for the purposes mentioned above. Please note the data protection notices of the relevant provider in this context.
Please note that using the tools might include transfer of your data to recipients outside Brazil where there is no adequate level of data protection pursuant to the LGPD-BR. For more details in this respect please refer to the following description of the individual marketing tools.
5.3.1. Google Analytics
Name: Google Analytics
Provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Function: Analysis of user behavior (page retrievals, number of visitors and visits, downloads), creation of pseudonymous user profiles based on cross device information of logged-in Google users (cross-device tracking), enrichment of pseudonymous user data with target group-specific information provided by Google, retargeting, UX testing, conversion tracking and retargeting in conjunction with Google Ads.
5.3.2. Google Optimize
Name: Google Optimize
Provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Function: Cookie can analyze how users have behaved on a cross-site basis, UX testing.
5.3.3. Google Tag Manager
Name: Google Tag Manager
Provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Function: Administration of website tags via a user interface, integration of program codes on our websites.
5.3.4. Google Ads
Name: Google Ads
Provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Function: Placement of advertisements, remarketing, conversion tracking. Further information is available at: (https://adssettings.google.com/authenticated).
5.4. Management of cookies and tracking mechanisms
You can manage your cookie and tracking mechanism settings in the browser and/or our privacy settings.
Note: The settings you have made refer only to the browser used in each case.
5.4.1. Deactivation of all cookies
If you wish to deactivate all cookies, please deactivate cookies in your browser settings. Please note that this may affect the functionality of the website.
5.4.2. Management of your settings with regard to cookies and tracking mechanisms not required technically
When visiting our websites, you will be asked in a cookie layer whether you consent to our using of any Comfort cookies, marketing cookies or tracking mechanisms, respectively.
In our privacy settings, you may withdraw the consent with effect for the future or grant your consent at a later point in time.
6. Social Plugins
In our Online Offers we use so-called social plugins from various social networks. They are individually described in this section.
When using plugins, your internet browser creates a direct connection to the respective social networks’ server. Hereby the respective provider receives the information that your internet browser accessed from the respective site of our Online Offers - even if you do not have a user account with this provider or are currently not logged into your account. Log files (including the IP address) are, in this case, directly transmitted from your internet browser to a server of the respective provider and might be stored there. The provider or its server may be located outside Brazil (e.g. in the United States).
The plugins are standalone extensions by social network providers. For this reason, we are unable to influence the scope of data collected and stored by them.
Purpose and scope of the collection, the continued processing and usage of data by the social network as well as your respective rights and setting options to protect your privacy can be found by consulting the respective social network's data protection notices.
In case you do not wish social network providers to receive and, if applicable, store or use data, you should not use the respective plugins.
6.1. Facebook plugins
Facebook is operated under www.facebook.com by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, and under www.facebook.de by Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland ("Facebook"). Find an overview over Facebook's plugins and their appearance here: https://developers.facebook.com/docs/plugins
Find information on data protection at Facebook here: https://www.facebook.com/policy.php
6.2. LinkedIn
LinkedIn is provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland (“LinkedIn”). You will find an overview of the plugins from LinkedIn and their appearance here: https://developer.linkedin.com/plugins; you will find information on data protection at LinkedIn here: https://www.linkedin.com/legal/privacy-policy.
7. Communication tools on social media platforms
We use on our social media platform (e.g. twitter) communication tools to process your messages sent via this social media platform and to offer you support.
When sending a message via our social media platform the message is processed to handle your query (and if necessary additional data, which we receive from the social media provider in connection with this message as your name or files).
In addition, we can analyze these data in an aggregated and anonymized form in order to better understand how our social media platform is used.
We will forward the personal data you provide to the Bosch legal entity responsible for the processing of your query (for example, in the event your query refers to a product that is distributed by another Bosch legal entity).
8. Newsletter with opt-in; Right of withdrawal
Within the scope of our Online Offers you can sign up for newsletters. We provide the so-called double opt-in option which means that we will only send you a newsletter via email, mobile messenger (such as, e.g. WhatsApp), SMS or push notification after you have explicitly confirmed the activation of the newsletter service to us by clicking on the link in a notification. In case you wish to no longer receive newsletters, you can terminate the subscription at any time by withdrawing your consent. You can withdraw your consent to email newsletters by clicking on the link, which is sent in the respective newsletter mail, or in the administrative settings of the online offer. Alternatively, please contact us via the contact details provided in the Contact section.
9. External links
Our Online Offers may contain links to internet pages of third parties, in particular providers who are not related to us. Upon clicking on the link, we have no influence on the collecting, processing and use of personal data possibly transmitted by clicking on the link to the third party (such as the IP address or the URL of the site on which the link is located) as the conduct of third parties is naturally beyond our control. We do not assume responsibility for the processing of personal data by third parties
10. Security
Our employees and the companies providing services on our behalf, are obliged to confidentiality and to compliance with the applicable data protection laws.
We take all necessary technical and organizational measures to ensure an appropriate level of security and to protect your data that are administrated by us especially from the risks of unintended or unlawful destruction, manipulation, loss, change or unauthorized disclosure or unauthorized access. Our security measures are, pursuant to technological progress, constantly being improved.
11. User rights
To enforce your rights, please use the details provided in the Contact section. In doing so, please ensure that an unambiguous identification of your person is possible.
Right to confirmation and access
You have the right to obtain confirmation from us about whether or not your personal data is being processed, and, if this is the case, access to your personal data.
Right to correction of incomplete, inaccurate, or outdated data
You have the right to contest the accuracy of any personal data and have it corrected.
Right to anonymization, blocking or elimination
If your data is unnecessary, excessive, or processed in non-compliance with the provisions of the LGPD-BR, you have the right to obtain its anonymization, block, or elimination.
Data portability
You may request to receive data that you have provided to us in a structured, commonly used, and machine-readable format or – if technically feasible – that we transfer those data to a third party.
Right to Erasure
You have the right to request the elimination of your personal data processed with your consent, except in some cases established in the LGPD-BR, such as when your personal data is indispensable for our compliance with statutory or regulatory obligation.
Oppose
If there is noncompliance with the provisions of the LGPD-BR, you have the right to oppose to the processing of your personal data.
Information about Third Parties
You have the right to be informed about the public and private entities with which we have carried out the shared use of your personal data.
Information about Consent
Where the processing of your personal data shall be carried out based on your consent, you have the right to be informed about the possibility of denying such consent and the consequences of this denial.
Withdrawal of consent
In case you consented to the processing of your data, you have the right to revoke this consent at any time with effect for the future. The lawfulness of data processing prior to your withdrawal remains unchanged.
Revision of automated decisions
You have the right to request for the review of decisions made solely based on automated processing of personal data affecting your interests.
12. Right to lodge complaint with supervisory authority
You have the right to lodge a complaint with the Brazilian National Data Protection Authority, which can be contacted through the following channel: https://www.gov.br/anpd/pt-br/canais_atendimento
13. Changes to the Data Protection Notice
We reserve the right to change our security and data protection measures. In such cases, we will amend our data protection notice accordingly. Please, therefore, notice the current version of our data protection notice, as this is subject to changes.
14. Contact
If you wish to contact us, please find us at the address stated in the "Controller" section
For suggestions and complaints regarding the processing of your personal data we recommend that you contact our data protection officer:
Data Security Officer – Latin America
PO Box 954 – Zip Code 13.065-970
Via Anhanguera, Km 98 Campinas
BRAZIL
E-mail: DBBR@br.bosch.com (please do not send commercial request such as Curriculum, Offers, )
Phone number: +55 (19) 2103 4511
Effective date: 07.26.2021