Data protection policy of Robert Bosch Limitada
1. Data Protection Notice
Robert Bosch LTDA (hereinafter "Bosch“ or "We“ or "Us") is delighted about your visit to our internet pages and mobile applications (together also referred to as "Online Offers") and about your interest in our company and our products.
2. 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 is an important concern 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.
Geolocation: In this process, IP addresses are shortened to the last octet before being used in any analysis of user behavior. Your IP address is also only used in its shortened form when establishing an approximate geolocation. Here, the country of origin is determined and this data is then stored. (Provided legal basis: legitimate interests, as long as they are in accordance with the standards determined by data protection laws and competition regulations)
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
Phone :+ 55 0800 704 5446
4. Collection, processing and usage of personal data
4.1. Processed categories of data
The following categories of data are processed:
- Communication data (e.g. name, telephone, e-mail, address, IP address)
- Contractual master data (e.g. contractual relationships, contractual or product interest)
- Client history
- Contract accounting and payment data
Personal data consists of all information related to an identified or identifiable natural person; this 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 either a statutory legal basis to do so, or you have given your consent to the processing or use of personal data concerning this matter, e.g. by means of registration.
4.3. Processing purposes and legal bases
We and service providers commissioned by us process your personal data for the following processing purposes:
- Provision of these Online Offers
(Legal basis: Justified interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law).
- Provision of these Online Offers and fulfillment of a contract under our contractual terms including settlement. Settlement may include the sale of claims.
(Legal bases: Fulfillment of contract and/or our justified interest in efficient claims management regarding the sale of claims).
- To determine disruptions/disturbances and for security reasons.
(Legal bases: Fulfillment of our legal obligations within the scope of data security and justified interest in resolving disruptions/disturbances and in the security of our offers).
- Self-promotion and promotion by others, as well as market research and reach analysis within the scope statutorily permitted or based on consent.
(Legal bases: Consent / justified interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law).
- Dispatch of an email or SMS/MMS newsletter with the recipient’s consent.
(Legal basis: Consent).
- Safeguarding and vindication of our rights.
(Legal basis: Justified interest on our part for the safeguarding and vindication of our rights).
If you wish to use/access benefits that require the formation of a contract, we request that you register. Within the scope of the registration, we collect personal data necessary for the formation and 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, if applicable, additional data on a voluntary basis. Mandatory statements are marked with a *.
4.5. Log files
Every time you use the internet, your browser transmits certain information which we store in so-called log files.
We save log files for a short time solely to determine disturbances and for security reasons (e.g., to clarify attack attempts) and we delete them afterwards. Log files which need to be maintained for evidence purposes are excluded from deletion until the respective incident has been completely resolved and may, on a case-by-case basis, be passed on to investigating authorities.
Log files are also used for analysis purposes (without the IP address or without complete IP address). See module web analysis therefore.
In log files, the following information in particular is being saved:
– IP address (internet protocol address) of the terminal device which is being used to access the Online Offers;
– Internet address of the website from which the Online Offer has been accessed (so-called URL of origin or referrer URL);
– Name of the service provider which is used to access the Online Offers;
– Name of the files or information accessed;
– Date and time as well as duration of retrieval;
– 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”).
This Online Offer is not for children under 16 years of age.
4.7. Data transfer
4.7.1. Data transfer to other controllers
Your personal data is principally forwarded to other controllers only when required for the fulfillment of a contract, in the case where we or the third party have a legitimate interest in the transfer, or when your consent has been given. Particulars on the legal bases can be found in the Section - Purposes of Processing and Legal Bases. Third parties may also be other companies of the Bosch group. When data is transferred to third parties based on a justified interest, this is explained in this data protection notice.
Additionally, data may be transferred to other controllers when we are obliged to do so due to statutory regulations or enforceable administrative or judicial orders.
4.7.2. Service providers (general)
We have commissioned external service providers with tasks such as sales and marketing services, contract management, payment handling, programming, data hosting and hotline services. We have chosen these service providers carefully and review them regularly, especially regarding their diligent handling and protection of the data that they have saved. All service providers are obliged to maintain confidentiality and to abide by the statutory provisions. Service providers may also be other Bosch group companies.
4.7.3. Payment service providers
We use external payment service providers.
4.7.4. Claims management
We reserve the right to have claims collected by external service providers.
Additionally, we have a legitimate interest in selling claims to third parties and in transferring data necessary for the collection of the claim to the respective buyer of the claim. During claim collection, claim buyers act in their own names and are themselves responsible for processing the data. In this respect, the data protection notices of the respective claim buyer apply.
4.8. Transfer to recipients outside the EEA
We can also transfer personal data to recipients located outside the EEA in so-called third countries. In such cases, we ensure prior to the transfer either that the data recipient provides an appropriate level of data protection (e.g., due to a decision of adequacy by the European Commission for the respective country or due to the agreement based on so-called EU model clauses with the recipient), or that you have consented to the transfer.
You are entitled to receive an overview of third country recipients and a copy of the specifically agreed-to provisions securing an appropriate level of data protection. For this purpose, please use the statements made in the section.
4.9. Duration of storage; retention periods
Principally, we store your data for as long as it is necessary to render our Online Offers and the services connected to them, or for as long as we have a justified interest in storing the data (e.g., we might still have a justified interest in postal mail marketing upon fulfillment of a contract). In all other cases, we delete your personal data with the exception of data we must store to fulfill legal obligations (e.g., we are obliged due to retention periods under the tax and commercial codes to have documents such as contracts and invoices available for a certain period of time).
5. Credit assessments
We have a justified interest in performing the credit assessments set forth in this section for the purpose of being protected from bad debts or investments. We can commission companies, which perform mathematical and statistical analysis to assess the risk of payment default and deliver, within the scope of what is allowed under law, information on the probability of payment defaults. For the assessment, address data may be used, but not limited to this.
In case the result of a credit assessment does not satisfy our requirements, we reserve the right to ask for an assured payment method (e.g., credit card) or to refuse the formation of a contract.
A credit assessment is based on automated decision-making. If you disagree with the result, you may submit your point of view in writing to be reviewed by a case handler. In addition, you are entitled to find out about the essential reasons supporting the decision of the respective service provider.
6. Reports made to credit agencies
We report due claims to credit agencies when, despite maturity, no payment has occurred, when the transfer is necessary to preserve our justified interests or justified interests of third parties and when the additional statutory requirements are present. These are
– the enforceability of the claim or the presence of an explicit promissory letter; or
– the issuance of at least two written overdue notices upon maturity of the claim, whereas the first overdue notice must have occurred at least four weeks prior and the debtor has been informed of the possibility of submitting the claim to a credit agency (in this first notice or at least before actual submittal to the credit agency) and the claim has not been disputed; or
– the possibility of the termination of the contractual relationship without previous notice due to arrears and the debtor has been informed about the possibility of submitting the claim to a credit agency.
In addition, we may report behavior contravening the contract (e.g., fraudulent behavior, misuse) to credit agencies as far as this is necessary to preserve our justified interests or the justified interests of third parties and there is no reason to assume that the affected person's interests worthy of protection outweigh or prevail over these justified interests.
7. Cookie usage
Cookies are small text files that are being saved on your computer when an Online Offer is visited. In case you access this Online Offer another time, your browser sends the cookies' content back to the respective offeror and, thus, allows the re-identification of the terminal device. Reading the cookies allows us to design our Online Offers optimally for you and makes it easier for you to use them.
7.2. Deactivation and deletion of cookies
When you visit our internet pages you will be asked in a cookie layer pop up whether you wish to allow the cookies which are being set on our page, or if you want to deactivate them in the settings.
In case you decide to block cookies, an opt out cookie is set in your browser. This cookie exclusively serves the purpose of assigning your objection. Deactivating cookies may disable individual functions of our internet pages. Please note that an opt out cookie may, for technical reasons, only be set for the browser that was used to set it. In case you delete cookies or use a different browser or a different terminal device, you must opt out again.
The preference setting does not apply to cookies that are being set during your visits on third party internet pages by other providers.
Your browser allows you to delete all cookies at all times. To do so, please consult your browser's help functions. This might, however, lead to individual functions no longer being available.
In addition, you are able to manage and deactivate the use of third party cookies on the following web page:
As we do not operate this website, we are not responsible and we are unable to influence content and availability.
7.3. Overview of cookies used by us
In this section, please find an overview of cookies we use:
Absolutely necessary cookies
Certain cookies are necessary so we can securely render our Online Offers. This category includes, e.g.:
- Cookies that identify or authenticate our users;
- Cookies that temporarily save certain user input (e.g., content of a shopping cart or of an online form);
- Cookies that store certain user preferences (e.g., search or language settings);
- Cookies that store data to ensure the unimpeded playback of video or audio content.
We use analytical cookies to record the usage behavior (e.g., ad banners clicked, search queries put in) of our users and to evaluate it statistically.
8. Web analysis
We need statistical information about the usage of our Online Offers to design them to be more user-friendly, to perform range measurements and to perform market research.
For this purpose, we use the web analysis tools described in this section.
The usage profiles created by these tools using analysis cookies or by evaluating log files do not contain personal data. The tools either do not use user IP addresses at all or shorten them immediately after gathering them.
The tool offerors process data only as processors, subject to our directives and not for their own purposes.
In the following, please find information on each tool offeror and how you are able to object to the collection and processing of data through the tool.
Be advised that with regard to tools which use opt out cookies, the opt out function is related to a device or browser and is thus valid for the terminal device or browser used at this time. In case you use several terminal devices or browsers you must opt out on every device and with every browser used.
Beyond this, you can generally avoid the forming of usage profiles by generally deactivating cookie usage; for this please refer to the section Deactivate and delete cookies.
WebTrends is provided by WebTrends Inc., 851 SW 6th Ave., Suite 1600, Portland, Oregon 97206, USA.
8.2. Google Analytics
Google Analytics is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). We use Google Analytics with the additional function offered by Google to anonymize IP addresses. While doing so, Google already shortens IPs within the EU in most cases but only does so for exceptional cases in the United States, and in both regions it only saves shortened IPs.
9. Usage of our mobile applications
In addition to our Online Offers, we offer mobile applications ("Apps"), which you can download to your mobile device. Beyond the data collected on websites, we collect additional personal data through our apps that specifically result from the usage of a mobile device. This occurs only when you expressly grant your consent.
9.1. Data processing by App Store operators
No data collection by us or outside our responsibility includes the transfer of data such as username, email address and individual device identifier to an app store (e.g., Google Play by Google, App Store by Apple, Galaxy Apps Store by Samsung) when downloading the respective application. We are unable to influence this data collection and further processing by the App Store as controller.
These Online Offers use the YouTube video platform which is operated by YouTube, LLC, 901 Cherry Ave. San Bruno, CA 94066, USA („YouTube”). YouTube is a platform which allows the playback of audio and video files.
When you access a respective site of our Online Offers that contains an embedded YouTube player, this establishes a connection to YouTube so the video or audio file can be transmitted and played back. In doing so, data is transferred to YouTube as a data processor. We are not responsible for the processing of such data by YouTube.
Additional information on the scope and purpose of collected data, on further processing and usage of data by YouTube, on your rights and the privacy options available to be chosen by you, can be found in YouTube's data protection notice.
11.1. Newsletter with opt-in; Right of withdrawal
Within the scope of our Online Offers you are able to sign up for newsletters. To do so, we use the so-called double opt-in procedure which means that we will only send you a newsletter via email, mobile messenger (such as, WhatsApp), SMS or push notification after you have explicitly confirmed the activation of the newsletter service to us by clicking the link in a notification. In case you wish to no longer receive newsletters at a later date, you can terminate the subscription at any time by withdrawing your consent. You can withdraw your consent to email newsletters by clicking the link which is sent in the respective Online Offer email, as the case may be. This occurs in the administrative settings. Alternatively, please contact us using the contact details provided in the section.
12. External links
Our Online Offers may contain links to third party internet pages – by providers who are not related to us. Upon clicking the link, we have no influence on collecting, processing and using personal data possibly transmitted by clicking 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 behavior of third parties is naturally outside our supervision. We do not assume responsibility for the processing of such personal data by third parties.
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 is 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.
14. User rights
Right to information 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 and deletion:
You have the right to obtain the rectification of inaccurate personal data concerning yourself without undue delay from us. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
This does not apply to data which is necessary for billing or accounting purposes or which is subject to a statutory retention period. If access to such data is not required, however, its processing is restricted (see the following).
Restriction of processing:
You have the right to demand for – as far as statutory requirements are fulfilled – restriction of the processing of your data.
Objection to data processing:
You have the right to object to data processing by us at any time. We will no longer process the personal data unless we demonstrate compliance with legal requirements to provide provable reasons for the further processing, which are beyond your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
Objection to direct marketing:
Additionally, you may object to the processing of your personal data for direct marketing purposes at any time. Please take into account that, due to organizational reasons, there might be an overlap between your objection and the usage of your data within the scope of a campaign which is already running.
Objection to data processing based on the legal basis of “justified interest”:
In addition, you have the right to object to the processing of your personal data any time, insofar as this is based on the legal basis of justified interest. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements for the processing, which override your rights.
Withdrawal of consent:
In case you consented to the processing of your data, you have the right to object this consent with immediate effect. The legality of data processing prior to your revocation remains unchanged.
You are entitled to receive data that you have provided us in a structured, commonly used and machine-readable format or – if technically feasible – to demand that we transfer those data to a third party.
Right of complaint with supervisory authority:
You have the right to lodge a complaint with a supervisory authority. You can appeal to the supervisory authority which is responsible for your place of residence or your state or to the supervisory authority responsible for us. This is:
State Commissioner for Data Protection and Freedom of Information
Via Anhanguera, Km 98 Campinas
P.O. Box 13.065-970
15. Changes to the Data Protection Notice
We reserve the right to change our security and data protection measures if this is required due to technical development. In such cases, we will amend our data protection notice accordingly. Please therefore observe the current version of our data protection notice, as this is subject to change.
If you want to contact us, please find us at the address stated in the "Controller" section.
To assert your rights and for suggestions and complaints regarding the processing of your personal data as well as for the withdrawal of your consent, we recommend that you contact our group commissioner for data protection:
Data Security Officer – Latin America
Postal address 954 - P.O. Box 13.065-970
Via Anhanguera, Km 98 Campinas
17. Effective date: 26.04.2019