Data Protection Notice & CCPA Privacy Policy
For users of this Bosch Corporate Innovation Gateway
1. Data Protection Notice
Robert Bosch GmbH (hereinafter “Bosch” or “We” or “Us”) welcomes you to our internet pages (also referred to as “Online Offers”). We thank you for 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 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.
3. 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 GmbH
Robert-Bosch-Platz 1
70839 Gerlingen-Schillerhöhe
GERMANY
E-mail: kontakt@bosch.de
Telephone: +49 711 400 40990
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 (like Terms of Use), contractual interest)
- Client history (eg. Date and content of communication, documentation of internal distribution/routing)
4.2. Principles
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.
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.
4.3. Processing purposes and legal basis
We as well as the service providers commissioned by us; process your personal data for the following processing purposes:
4.3.1. Provision of these Online Offers (Legal base: Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. The following conditions apply: Terms of Use.).
4.3.2. 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).
4.3.3. In case of a request for deletion of your innovation proposals, the retention period of the innovation proposals for safeguarding and defending our rights consists of three years (Legal basis: Legitimate interest on our part for safeguarding and defending our rights).
4.4. 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 60 days 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).
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”).
4.5. Children
This Online Offer is not meant for children under 18 years of age.
4.6. 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” (see no. 4.3).
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:
ITONICS GmbH
Emilienstr. 9
90489 Nürnberg
Germany
and
Amazon Web Services
Frankfurt
Germany
4.6.1. Service providers (general)
We involve external service providers with tasks such as sales and marketing services, contract management, 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.
4.6.2. 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 (see no. 13).
4.6.3. 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).
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.
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
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” (see no. 7).
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:
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
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
5.4. 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. 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.
7. 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 un-authorized access. Our security measures are, pursuant to technological progress, constantly being improved.
8. 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 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. As far as statutory requirements are fulfilled, you have the right to obtain the completion or deletion of your data.
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
As far as statutory requirements are fulfilled you have the right to demand for restriction of the processing of your data.
Data portability
As far as statutory requirements are fulfilled 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.
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.
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.
9. 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
Address:
Königstrasse 10a
70173 Stuttgart
Postal address:
P.O. Box 10 29 32
70025 Stuttgart, GERMANY
Phone: 0711/615541-0
Fax: 0711/615541-15
Email: poststelle@lfdi.bwl.de
10. 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.
11. Contact
If you wish to contact us, please find us at the address stated in the "Controller" section.
To assert your rights and to notify data protection incidents please use the following link: https://www.bkms-system.net/bosch-dataprotection
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
70442 Stuttgart
GERMANY
or
E-Mail to: DPO@bosch.com.
Effective Date: 05.02.2021
This CCPA Privacy Policy supplements the information contained in Bosch's website "www.innovate-bosch.com" Data Protection Notice (“Bosch” or “we”) and applies solely to all visitors, users, and others of the Corporate Innovation Gateway who reside in the State of California (“you”). We adopt this CCPA Privacy Policy to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this CCPA Privacy Policy.
I. Collection of Personal Information
The Corporate Innovation Gateway has collected the following Personal Information from users of the Corporate Innovation Gateway within the last twelve (12) months.
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Category and sources of information |
Examples | How we use it | How we share it |
|---|---|---|---|
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Category and sources of information
Identifiers
We collect this information from our users, customers, and business partners. We also generate identifiers internally. |
Examples
Real name, Internet Protocol address, email address
|
How we use it
To enable use of our sites, services, and products, to communicate with you, to understand how our users interact with our sites, and to improve our offerings.
|
How we share it
We share this data with our service providers and with business partners, including those whom you instruct us to send this information.
|
|
Category and sources of information
Personal Information under Cal. Civ. Code § 1798.80(e)
We collect this information from our users, customers, and business partners. |
Examples
Name, address, telephone number. Some Personal Information included in this category may overlap with other categories.
|
How we use it
To enable use of our sites, services, and products, to communicate with you, to understand how our users interact with our sites, and to improve our offerings.
|
How we share it
We share this data with our service providers and with business partners, including those to whom you instruct us to send this information.
|
|
Category and sources of information
Internet or other similar network activity
We collect this information from our users and customers. |
Examples
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
|
How we use it
To enable use of our sites, services, and products, to communicate with you, to understand how our users interact with our sites, and to improve our offerings.
|
How we share it
We share this data with our service providers and with business partners, including those to whom you instruct us to send this information.
|
|
Category and sources of information
Geolocation data
We collect this information from our users and customers. |
Examples
Physical location or movements.
|
How we use it
To enable use of our sites, services, and products, to understand how our users interact with our sites, and to improve our offerings.
|
How we share it
We share this data with our service providers.
|
|
Category and sources of information
Professional or employment-related information
We collect this information from our users, customers, and business partners. |
Examples
Current or past job history or performance evaluations.
|
How we use it
To provide services or products you’ve requested
|
How we share it
We share this data with our service providers and with business partners, including those to whom you instruct us to send this information
|
Bosch will continue to collect the Personal Information described above. If any additional Personal Information is collected by Bosch, we will provide any required notice(s), and where applicable obtain any required consent(s), in accordance with applicable laws in the relevant jurisdiction.
II. Sources of Personal Information
Bosch collects Personal Information from the following categories of sources:
1. Directly from you.
For example, when given by you or collected from you through your access to and/or use of the Corporate Innovation Gateway and/or the Services, in context of submitting an innovation proposal or when you contact customer support or otherwise interact or communicate with Bosch, its agents, representatives, suppliers, vendors or consultants through the Corporate Innovation Gateway. This information may include, without limitation, your first and last name, address, phone number, e-mail address and any other information you choose to provide us.
2. Indirectly from you.
For example, from observing your use of the Corporate Innovation Gateway and/or the Services, or services related thereto. The following data may be collected automatically: the website from which you visit Bosch (referrer), pages viewed, files downloaded (downloads), individual links clicked, search words or search phrases (site search), duration of visit, browser used, device data (e.g., unique device identifier, MAC address, IP address, serial number, hardware model, network information and operating system and version), and other relevant details and/or information. If the visit is a result of online advertising such as banners, video ads, search engine advertising, etc., Bosch or its agents, representatives, suppliers, vendors or consultants may record which banner, adware, etc. motivated or assisted with the visit to the Corporate Innovation Gateway.
III. Disclosure or Sale of Personal Information – Past 12 Months
1. Disclosure of Personal Information.
In the preceding twelve (12) months, Bosch has disclosed the following categories of Personal Information for a business purpose:
a. Identifiersb. California Customer Records Personal Information categoriesc. Internet or other similar network activityd. Geolocation datae. Professional or employment-related information
We disclose your Personal Information for a business purpose to the following categories of third parties: Service providers.
IV. Rights of California “consumers” relating to Personal Information collected by Bosch.
Individuals which fall within the definition of a “consumer” under the California Consumer Privacy Protection Act have the following rights relating to their Personal Information collected by Bosch.
1. Right to access specific information and data portability rights.
You have the right to request that Bosch discloses certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see below, V. How to exercise your Rights), we will disclose to you:
a. The categories of Personal Information we collected about you.b. The categories of sources for the Personal Information we collected about you.c. Our business or commercial purpose for collecting or selling that Personal Information.d. The categories of third parties with whom we share that Personal Information.e. The specific pieces of Personal Information we collected about you.f. If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
i. For “sales”, the Personal Information categories that each category of recipient purchased; andii. for disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
2. Deletion Request Rights.
You have the right to request that Bosch delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
a. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
i. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.ii. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.iii. Debug products to identify and repair errors that impair existing intended functionality.iv. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.v. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).vi. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.vii. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.viii. Comply with a legal obligation.ix. Make other internal and lawful uses of that information that are compatible with the context in which you provided it
V. How to exercise your rights
To exercise your rights, please submit a verifiable consumer request or access request, as applicable, to us by either:
Calling us at (888-43-BOSCH (888-432-6724)).
Emailing us at gateway.gdpr@bosch.com
Only you (or in case of a California resident, an authorized agent authorized by you to act on your behalf – see Section VIII., Authorized Agent below for more information) may make a verifiable consumer request or access request, as applicable related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. Your verifiable consumer request or access request, as applicable, must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request or access request does not require you to create an account with us, but if you already have an account with us, you may be required to make your request through that account.
We will only use Personal Information provided in a verifiable consumer request or access request, as applicable, to verify the requestor’s identity or authority to make the request.
VI. Response timing and format
We endeavor to respond to a verifiable consumer request or access request, as applicable, within forty five (45) days of its receipt, or sooner where required by applicable law (including Canadian Privacy Laws). If we require more time (up 90 days in total), where permitted by applicable law, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide in response to a verifiable consumer request will only cover the 12-month period preceding the verifiable consumer request's receipt, unless otherwise required by applicable law. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, where applicable, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request or access request, as applicable, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request
VII. Personal Information Sales: Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the "right to opt-out"). Furthermore, where required by applicable law in the relevant jurisdiction, we will obtain your consent prior to selling your Personal Information. We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you may submit a request to us by Emailing us at Gateway.GDPR@bosch.com. As noted above, certain kinds of third party cookies, such as ad network or analytics cookies, on the Bosch Website could be considered a “sale” of your Personal Information for purposes of the CCPA. In order to opt out of the “sale” of your information via such cookies, turn off the Analytics, Advertising, and Social Media cookies in our Privacy settings.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by: by changing your cookie preferences on Bosch Website www.innovate-bosch.com
You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.
VIII. Authorized Agent
As a California resident you may also exercise your request to know or request to delete through an authorized agent. When you submit your request through an authorized agent we require that you:
1. Provide us a copy of your written permission for the authorized agent to submit the applicable request; and2. Verify your own identity directly with us.
The foregoing does not apply when you have provided your authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465; provided, that we may require a copy of such power of attorney before fulfilling any request.
IX. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
X. Filing a Complaint
Regulatory authorities that oversee the privacy laws and regulations, including the Office of the Privacy Commissioner of Canada, advise individuals to file an objection or challenge with the relevant company before lodging a formal complaint with a regulatory authority. If you are dissatisfied with Bosch’s response to an objection or challenge filed under Article XX above, or you if wish to file a complaint with a regulatory authority first, you may do so as follows:
Under PIPEDA: You may file a complaint with the Office of the Privacy Commissioner of Canada. Depending upon the province where you live, you may also (or instead) have the right to file a complaint with the applicable provincial privacy commissioner/regulator.Under PII Laws: You may file a complaint with the relevant state’s Attorney General’s office.Under the CCPA: You may file a complaint with the California Attorney General’s Office. For additional information regarding consumer complaints against a business/company under the CCPA and to initiate the complaint process, please click on the link.
Effective Date: 22.01.2021