Data protection policy of of Robert Bosch Manufacturing Solutions GmbH (Bosch Industry Consulting)
Robert Bosch Manufacturing Solutions GmbH (hereinafter “Bosch Industry Consulting” 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 Industry Consulting 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.
Bosch Industry Consulting is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows:
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, salutation, telephone, company, country, language, e-mail, address, IP address)
- Contractual master data (e.g. contractual relationships, contractual or product interest)
- Client history
- Contract accounting and payment data
- Planning and regulation data
- Transaction data
- Training data (login data, training progress data, certificates)
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 if 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 basis
We as well as the service providers commissioned by us; process your personal data for the following processing purposes:
3.3.1 Provision of these Online Offers
Legal basis: Legitimate interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law.
3.3.2 Provision of these Online Offers
Legal basis: Fulfillment of contractual obligations. Including contact form to contact us for the products and services offered by us for the purpose of the fulfillment of a contract.
3.3.3 Provision of these Online Offers and fulfillment of a contractual obligations under our contractual terms including invoicing. Invoicing may include the sale of claims
Legal basis: Fulfillment of contractual obligation, respectively our legitimate interest in an efficient claims management as regards the sale of claims.
3.3.4 Resolving service disruptions as well as for security reasons.
Legal basis: Fulfillment of our legal obligations within the scope of data security and legitimate interest in resolving service disruptions as well as in the protection of our offers.
3.3.5 Self-promotion and promotion by others as well as market research and reach analysis done within the scope statutorily permitted or based on consent
Legal basis: Consent / legitimate interest on our part in direct marketing if in accordance with data protection and competition law.
3.3.6 Product or customer surveys by postal mail
Legal basis: Legitimate interest in the improvement of products / services.
Note: In case we involve a market research institute for the purpose of surveys, it shall only act based on our instructions and follow our directives.
3.3.7 Product or customer surveys performed via email and/or telephone subject to your prior express consent.
Legal basis: Consent.
Note: In case we involve a market research institute for the purpose of surveys, it shall only act based on our instructions and follow our directives.
3.3.8 Conducting raffles or discount campaigns in accordance with respective terms and conditions for raffles or discount campaigns.
Legal basis: Fulfillment of contractual obligations.
3.3.9 Sending an email or SMS/MMS newsletter subject to the recipient’s consent
Legal basis: Consent.
3.3.10 Operation of an online community for signed-in members for the purpose of information exchange and information about new products.
Legal basis: Fulfillment of contractual obligations
3.3.11 Safeguarding and defending our rights.
Legal basis: Legitimate interest on our part for safeguarding and defending our rights.
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 short period 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.
Log files are also used for analysis purposes (without the IP address or without the complete IP address) see module “Advertisements and/or market research (including web analysis, no customer surveys)”.
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”).
This Online Offer is not meant for children under 16 years of age.
3.7 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 ourselves, or a third party, have a legitimate interest in the data transfer, or if you have given your consent. Particulars on the legal basis and the recipients or categories of recipients can be found in the Section – Processing purposes and legal basis.
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.
3.8 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.
3.9 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 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-provisions securing an appropriate level of data protection. For this purpose, please use the statements made in the Contact section.
3.10 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 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.
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 such cookies and tracking mechanisms if you have given us your prior consent in each case. We distinguish between two sub-categories with regard to these cookies and tracking mechanisms:
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.
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 behaviour:
- 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.
Provider: WebTrends Inc., 851 SW 6th Ave., Suite 1600, Portland Oregon 97206, USA
Function: Analyses user behaviour (page views, number of visitors and visits, downloads)
Name: Google Analytics
Provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Function: Analyses user behaviour (page views, number of visitors and visits, downloads), UX testing
5.2 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.
5.2.1 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.
5.2.2 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 convenience 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. 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 is subject to your prior consent.
6.1 Processing of your location data
Our offers also include so-called location based services through which we provide you with special offers that are tailored to your respective location. To offer this app function, we collect the last three GPS locations delivered by the mobile device and your IP address when you consent. We do not create a movement profile. You can deactivate this function in the respective app's settings or in the settings of the operating system of your mobile device or pause it temporarily without affecting the basic functionality of the app.
6.2 Processing of the advertising identifier / advertising ID
For advertising purposes, we use, given your consent, the so-called "advertising identifier" (IDFA) for iOS devices and the so-called advertising ID for Android devices. These are not permanent identification numbers for a certain terminal device provided by iOS or Android. The data collected is not brought together with other device-related information. We use identification numbers to provide you with personalized advertisements and to analyze your usage. When you activate (for iOS devices) the option "no ad tracking" in the device settings under "Privacy" - "Advertisements" or (for Android devices) activate "deactivate interest-based advertisements" in the Google settings under "Advertisements", we can only perform the following measures: Measuring your interaction with banners by counting the number of displays of a banner without clicks ("frequency capping"), click rate, assessment of unique usage ("unique user") and security measures, fraud combating and troubleshooting. In the device settings, you are always able to delete your IDFA or advertising ID ("reset ad ID"); a new identification number is generated then which is not combined with data collected earlier. We advise you that you might be unable to use all functions of our app when you restrict the usage of the respective identification number.
Our 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 creates a connection to YouTube so that the video or audio file can be transmitted and played back. In doing so, data is transferred to YouTube as a data controller. 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.
8. 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.
9. 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). The legal basis for the processing of your data is our legitimate interest (Art. 6 para. 1 lit. f GDPR) or, if applicable, an existing contractual relationship (Art. 6 para. 1 lit. b GDPR). The processed personal data is deleted 180 days upon receipt of your message the latest.
10. 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.
We offer you the opportunity of becoming a member of one of our Bosch Industry Consulting Communities (such as Linkedin, YouTube or Twitter Community). There, you can sign up, create a user profile and communicate with other members. Your data generated therein is only used in the scope of the consent granted by you for the respective marketing, market research and service purposes. You can withdraw your consent at any time by the link which is stated in the respective community. Alternatively, please contact us via the contact details provided in the Contact section.
Through an input mask in the respective community you are able to choose whether you want to show particular statements of your user profile to all members of the community or only to your "community friends" or whether they should remain private.
All other data which is generated by you in the communities, e.g. by creating comments or pictures, are automatically publicly accessible and will be linked to your user profile.
12. External links
Our Online Offers may contain links to third party internet pages – by 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.
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.
14. 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.
14.1 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.
14.2 Right to correction and deletion:
You have the right to obtain the rectification or completion of inaccurate personal data or deletion of your data as far as statutory requirements are fulfilled.
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).
14.3 Restriction of processing:
You have the right to demand for – as far as statutory requirements are fulfilled – restriction of the processing of your data.
14.4 Data portability:
You are entitled to receive data that you have provided to 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.
14.4.1 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.
14.4.2 Objection to data processing based on the legal basis of “legitimate interest”:
In addition, you have the right to object to the processing of your personal data at any time, insofar as this is based on legitimate interest. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements which override your rights.
14.4.3 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.
15. Right to lodge 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 of residency or to the supervisory authority responsible for us. This is:
State Commissioner for Data Protection and Freedom of Information
70173 Stuttgart, GERMANY
P.O. Box 10 29 32
70025 Stuttgart, GERMANY
16. 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.
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 Protection Officer
Information Security and Privacy (C/ISP)
Robert Bosch GmbH
Postfach 30 02 20
Effective date: 2019.04.25