Data Protection Notice
Data Protection Notice of Robert Bosch AB
Robert Bosch AB (hereinafter referred to as “Bosch”, “We” or “Us”) appreciates your visit to our websites and mobile applications (together also “online offer”) and also your interest in our company and our products.
1. Bosch respects your private sphere
The protection of your private sphere during the processing of personal data as well as the security of all business data is a major concern for us that we take into consideration in our business processes. We process personal data, collected during your visit to our online offers confidentially and only in accordance with the legal directives.
Data protection and information security are an integral part of our corporate policy.
2. Responsible authority and contact
Responsible for the processing of your data is Robert Bosch AB:
Robert Bosch AB
164 26 Kista
For suggestions and complaints with regard to the processing of your personal data we suggest to contact our Officer for data protection:
Officer for Data Protection
Information security and data protection Bosch Group
Postfach 30 02 20
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)
- 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.
3.3. Processing purposes and legal bases
We; as well as the service providers commissioned by us; process your personal data for the following processing purposes:
- Provision of these Online Offers including contact form to contact us for the products and services offered by us for the purpose of the fulfillment of a contract.
(Legal basis: Justified interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law; as well as the fulfillment of contractual obligations).
- Provision of these Online Offers and fulfillment of contractual obligation’s under our contractual terms including invoicing and prior credit assessment. Invoicing may include the sale of claims.
(Legal bases: Fulfillment of contractual obligation respectively our justified interest in an efficient claims management and in avoiding claim defaults as regards the sale of claims and the credit assessment.
- Resolving service disruptions as well as 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).
- Sending an email or SMS/MMS newsletter with the recipient’s consent.
(Legal basis: Consent).
- Safeguarding and defending our rights.
(Legal basis: Justified interest on our part for safeguarding and defending our rights).
- Geolocation: In this process, IP addresses are shortened to the last octet as an anonymization factor 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)
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, 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 save log files for a short period of time to determine service disruptions and for security reasons (e.g., to investigate attack at-tempts) and delete them after-wards. 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.
Log files are also used for analysis purposes (without the IP address or without the complete IP ad-dress). Also see module web analysis.
In log files, in particular the following information is saved:
- IP address (internet proto-col address) of the terminal device which is being 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 da-ta;
- Amount of data transferred;
- Operating system and in-formation on the internet browser used, including add-ons installed (e.g., Flash Player);
- http status code (e.g., “Re-quest successful” or “File requested not found”).
This Online Offer is not meant for children under 16 years of age.
3.7. Data transfer
3.7.1. Data transfer to other controllers
Principally, your personal data is forwarded to other controllers only if required for the fulfillment of a contractual obligation, or if we our-selves, or a third party, have a legitimate interest in the data transfer, or if you have given your consent. 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.
3.7.2. 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 to the statutory provisions. Service providers may also be other Bosch group companies.
3.7.3. Payment service providers
We involve external payment service providers.
3.7.4. 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.
3.8. Transfer to recipients outside the EEA
We might transfer personal data to recipients located outside the EEA 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 (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 Contact section.
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 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).
4. Credit assessments
We have a justified interest in per-forming the credit assessments set forth in this section for the purpose to protect ourselves from bad debts or investments. We might commission companies performing 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 exclusively.
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 re-fuse to enter into 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.
5. 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.
6. Usage of cookies
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.
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.
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.
Cookies and tracking mechanisms that are technically not required
We only use such 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:
- 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. Comfort cookies are currently not used.
- Marketing cookies and tracking mechanisms: 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.
Please note that using the tools might include transfer of your data to recipients outside of the EEA where there is no adequate level of data protection pursuant to the GDPR (e.g. the USA). For more details in this respect please refer to the following description of the individual marketing tools.
6.2 Overview of the marketing tools and cookies we use
You will find an overview of the marketing tools and cookies we use in this section.
Cookie name: bosch-privacy-settings-v2
Tool 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.
Tool 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.
Tool 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.
Tool name: New Relic
Provider: New Relic Inc. 111 SW 5th Ave 2700, Portland, OR 97204
Function: Measurement of website availability and downtime
6.3. 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.
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.
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 technically not required 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.
7.1 Google Maps
This page uses the map service Google Maps via an API. The provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
For the use of the functions of Google Maps it is necessary to store your IP address. This information is usually transmitted to a server of Google LLC in the USA and saved there. The provider of this page does not have any influence on this transmission of data.
The use of Google Maps is in the interest of an appealing presentation of our online offers and an easy retrievability of the places listed by us on the website. This represents a predominant legitimate interest on our part within the meaning of article 6 section 1 lit. f GDPR.
7.2 Google reCAPTCHA
In certain cases we use the reCAPTCHA service of the company Google LLC to ensure appropriate data security for the use of contact forms. This serves above all for the differentiation of whether the input has been made by a natural person or fraudulently by machine or automated processing. This represents a predominant legitimate interest on our part within the meaning of article 6 section 1 lit. f GDPR. The service includes the sending of the IP address and if necessary other data required by Google for the reCAPTCHA service to Google.
The deviating data protection regulations of Google LLC are applicable for this purpose.
7.3 Google web fonts
This site uses so-called web fonts of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA for the uniform display of fonts. When you access a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.
For this purpose, the browser you are using has to connect to the servers of Google. This informs Google that our website was accessed via your IP address. The use of Google web fonts is in the interest of a uniform and appealing presentation of our online offers. This represents a predominant legitimate interest on our part within the meaning of article 6 section 1 lit. f GDPR.
Your computer will use a standard font if your browser does not support web fonts.
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)”
9. Social plugins
In our online offer, we use so-called social plugins of different social networks; these will be described individually in this section.
On application of the plugins, your Internet browser will establish a direct connection to the servers of the respective social network. Hereby the relevant provider obtains the information that your Internet browser has called up the corresponding page of our online offer, even if you do not possess a user account with the provider or are not currently logged in with the provider. Log files (including the IP address) are directly transmitted from your Internet browser to a server of the relevant provider where they are stored if necessary. The headquarters of the provider or his/her server could be located outside the EU or the EEA (e.g. in the USA).
The plugins represent independent extensions of the providers of social networks. Therefore, we have no influence on the extent of the data collected and stored by the social network providers via the plugins.
The purpose and extent of the collection, the further processing of the data by the social network as well as your associated rights and setting options for the protection of your private sphere can be taken from the data protection notes of the respective social network.
You should not use the respective plugins if you do not want social network providers to obtain data concerning this online offer or to continue to use this data.
9.1 Social plugins with 2-click solution
With a so-called 2-click solution, we protect you from having your visits to our websites recorded and evaluated by social network providers as standard. When you access a page of our internet offer, which contains such plugins, these are initially deactivated. The plugins are not activated until you click the provided button.
9.2 Social plugins of Facebook
Facebook is provided 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”). You will find an overview of the plugins from Facebook and their appearance here: ; you will find information on data protection at Facebook here: .
9.3 Social plugins from Twitter
Twitter is provided by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter”). You will find an overview of the plugins from Twitter and their appearance here: ; you will find information on data protection at Twitter here: .
9.4 Social plugins from LinkedIn
LinkedIn is provided by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (“LinkedIn”). You will find an overview of the plugins from LinkedIn and their appearance here: ; you will find information on data protection at LinkedIn here: .
10. 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.
10.1. 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.
This online offer uses the video platform YouTube, which is provided 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.
If you access a corresponding page of our offer, the embedded YouTube player will establish a connection to YouTube so that the video or audio file can be transmitted and played. In the process, data are also transmitted to YouTube as the responsible body. We are not responsible for the processing of this data by YouTube.
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 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. Alternatively, please contact us via the contact details provided in the Contact section.
13. External links
Our online offer can contain links to the websites of third parties − to providers who are not affiliated with us. After you click the link, we no longer have any influence on the collection, processing and utilization of any personal data that is transferred to third parties after clicking the link (for example, the IP address or the URL of the site on which the link is located), as our control of the conduct of third parties is then naturally withdrawn. We assume no responsibility for the processing of this kind of personal data by third parties.
Our staff and our delegated service provider companies are obliged to maintain secrecy and to adhere to the regulations of the applicable data protection laws.
We take all necessary technical and organizational measures in order to ensure an appropriate standard of protection and to protect your data that are administered by us especially from the risks of unintentional or unlawful destruction, manipulation, loss, alteration or unauthorized disclosure or unauthorized access. Our security measures are continually improved according to the technological development.
15. Your rights
Please use the information contained in section “Responsible authority and contact” (see no. 2). to assert your rights. Please ensure that an unambiguous identification of your person is possible for us.
15.1 Right to information and disclosure:
You have the right to obtain information from us concerning the processing of your data. For this purpose, you can enforce a right to information in relation to the personal information that we process from you.
15.2 Right of rectification and deletion:
You can demand from us the rectification of false data and – insofar as the legal prerequisites are fulfilled – the completion or deletion of your data.
This does not apply to data which are necessary for invoicing or accounting purposes or are subject to the statutory retention obligation. Insofar as the access to such data is not required, the processing thereof will be restricted (see below).
15.3 Restriction of processing:
You can demand from us the restriction of the processing of your data insofar as the legal prerequisites are fulfilled.
15.4 Data portability:
You will continue to have the right to obtain data that you have provided to us transmitted in a structured, conventional and machine-readable form or as far as this is technically feasible, to demand that the data are transmitted to a third party.
15.5 Right of objection
15.5.1 Case-related right of objection
Insofar as we undertake processing of data on the basis of a predominantly justified interest, as represented in this data protection policy, you have the right to file an objection to this processing, at any time, for reasons resulting from your special situation.
We will then discontinue the processing of your data, unless we can prove, in accordance with the statutory regulations, mandatory reasons worthy of protection for further processing, which outweigh your interests, rights and liberties, or if the further processing serves the assertion, exercising or defending of legal claims.
15.5.2 Objection against the processing of data for direct marketing purposes
Furthermore, you can file an objection to the processing of your personal data for commercial purposes at any time (“objection to advertising”). Please take into consideration the fact that there could be an overlapping between your objection and the utilization of your data in the scope of an ongoing campaign.
15.6 Rights of revocation
If you have given us your consent to the processing of your data, you can revoke this with future effect at any time. This also applies to the revocation of declarations of consent, granted to us prior to the validity of the GDPR, therefore prior to 25. May 2018. The legality of the processing of your data shall remain unaffected unless revoked.
15.7 Right to appeal to the supervisory authority
You have the right to submit an appeal to a data protection supervisory authority. For this purpose, you can refer to the data protection supervisory authority, which is competent for your place of residence of federal state or to the data protection supervisory authority which is competent for our group.
140 20 Stockholm
16. Change of the data protection policy
We reserve the right to make modifications to our security and data protection measures, insofar as this is necessary due to the technical development. In these cases, we will also adapt our data protection policy accordingly. Therefore, please note the currently valid version of our data protection policy.
17. Effective date: