Data Protection Notice
ТОВ «Роберт Бош Лтд»(hereinafter "Bosch Power Tools" 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.
Bosch Power Tools 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.
Controller
Bosch Power Tools is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows:
ТОВ «Роберт Бош Лтд»
вул. Крайня, 1
Київ, 02660, Україна
Tel.: +38 (044) 490-2400
Fax: +38 (044) 230-2020
Please note that in the course of registration "Bosch Power Tools" is "Joint Controller" with other companies of the Bosch Group according to Art. 26 GDPR . For more information on this and your rights in this regard, please refer to Section 4.4 : "Registration".
Collection, processing and us-age 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 pro-duct interest)
• Client history
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, 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.
4.3 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 and fulfillment of a contractual obligations under our contractual terms including invoicing. Invoicing may include the sale of claims.
(Legal bases: Fulfillment of contractual obligation, respectively our justified interest in an efficient claims management as regards the sale of claims).
– 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 service disruptions as well as in the protection of our offers).
– Safeguarding and defending our rights.
(Legal basis: Justified interest on our part for safeguarding and defending our rights).
4.4 Registration
In order to use extended functionalities, registration in our online offers is required. Below you will find more information about the registration and login process.
This is structured as follows:
4.4.1 Integrated Customer Profile Management - enables the integration of various registration options such as Bosch Single Key ID and Social Sign In.
4.4.2 Single Key ID - one of the sign-in options provided by Bosch IO.
4.4.3 Social Sign In - one of the sign-in options provided by the respective provider, e.g. Apple or Google.
4.4.4 iCPM, Joint Controllership, according to Art. 26 GDPR
Bosch "Integrated Customer Profile Management" (iCPM) connects different Bosch applications, with the aim that you as a business partner (user, customer) do not have to provide your data multiple times, thus offering you the best possible customer experience. In addition, iCPM offers the possibility to log in to Bosch applications via different login options.
Within the framework of iCPM,
Robert Bosch Power Tools GmbH
Max-Lang-Strasse 40-46, D-70771 Leinfelden-Echterdingen
hereinafter referred to as "Bosch PT
and
the parties listed in the "List of Parties" (hereinafter referred to as "Parties")
work
closely together. This also applies to the processing of your personal data. The Parties have jointly determined the order in which this data is to be processed in the individual process phases and are therefore to be regarded as joint controllers under data protection law pursuant to Art. 26 GDPR.
Here is a detailed overview of the joint and separate data processing activities and responsibilities of the parties:
|
Data processing: |
Responsibility: |
|
Identity Brokering with Bosch own as well as other, external Identity Providers (Facebook,Apple, Google) for B2C and external B2B users Bosch PT.
|
Bosch PT |
|
Identity brokering with BCD/Bosch ADFS for B2E (Bosch administrators) |
Bosch PT |
|
Capturing, storage and provision of user attributes for connected applications |
The Parties |
What this means for you:
- The parties shall provide you, as data subjects, with the information required by Articles 13 and 14 GDPR in a precise, transparent, understandable and easily accessible form in clear and simple language, free of charge. Each party shall provide the other party with all necessary information from its sphere of activity.
- The parties shall inform each other without delay of the data subject rights asserted by you as a data subject. They shall provide each other with all information required to respond to your requests for information.
- You may assert your data subject rights directly against either party at any time.
4.4.5 Login with SingleKey ID, Joint Controllership
You can log in to our website with SingleKey ID.
SingleKey ID was developed by Bosch.IO GmbH for the Bosch Group to provide users with an overarching login option on Bosch websites, stores, apps and services. Bosch.IO GmbH, Ullsteinstrasse 128, 12109 Berlin, Germany, is responsible for providing SingleKey ID.
Bosch.IO GmbH processes your data for the purposes of "registration and login with SingleKey ID", as well as "overview and maintenance of master data and apps with SingleKey ID" under joint responsibility with us. For more information, please visit: https://singlekey-id.com/data-protection-notice/.
After one-time registration you can use SingleKey ID to log in. For this purpose you will be redirected to a login mask of Bosch.IO GmbH. After successful authentication, Bosch.IO GmbH will provide us with the required personal data (e.g. e-mail address, telephone number, first name, last name, language, country). Your password will not be transmitted to us.
You can terminate your SingleKey ID user contract at any time on the SingleKey ID website by deleting your SingleKey ID: https://singlekey-id.com/myprofile/. Please note that by deleting your SingleKey ID you will lose access to all Bosch websites, stores, apps and services where you have logged in with SingleKey ID.
4.5 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 attempts) 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). Also see module web analysis.
In log files, in particular the following information is saved:
– IP address (internet protocol 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 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”).
4.6 Children
This Online Offer is not meant for children under 13 years of age.
Data transfer
5.1 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 ourselves, 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.
5.2 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.
5.3 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.
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 justified interest in storing the data (e.g. we might still have a justified 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).
Cookie usage
7.1 General
Cookies are small text files that are saved on your computer when an Online Offer is accessed. In case you access this Online Offer another time, your browser sends the cookies' content back to the respective seller 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 visiting our internet pages you will be asked in a cookie layer pop up whether you wish to allow the cookies which are set on our page or if you wish 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 with the actual browser. 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 set during your visit on third party internet pages by other providers.
Your browser allows you to delete any 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 could manage and deactivate the use of third party cookies on the following web page:
http://www.youronlinechoices.com/uk/your-ad-choices.
As we do not operate this website, we are not responsible and we are unable to influence the content and availability.
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 supervision. We do not assume responsibility for the processing of personal data by third parties.
Security
Our employees and the companies providing services on our behalf, are obliged to confidentiality and to compliance with the applicable data protection laws.
We take all necessary technical and organizational measures to ensure an appropriate level of security and to protect your data that are administrated by us especially from the risks of unintended or unlawful destruction, manipulation, loss, change or unauthorized disclosure or unauthorized access. Our security measures are, pursuant to technological progress, constantly being improved.
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 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 at any time, insofar as this is based on a justified 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 with immediate effect. The legality of data processing prior to your revocation remains unchanged.
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.
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 of residency or to the supervisory authority responsible for us. This is:
Ukrainian Parliament Commissioner for Human Right - Department for Personal Data Protection
Valeriya Lutkovska
01008 Kyiv
21/8, Instytutska street
Telefon: +38 044 5176800
Telefax: +38 044 5176800
E-Mail: hotline@ombudsman.gov.ua
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, notice the current version of our data protection notice, as this is subject to change.
Contact
If you wish to contact us, please find us at the address stated in the "Controller" section.
To assert your rights, for data protection breaches as well as for suggestions and complaints regarding the processing of your personal data we recommend that you contact our group commissioner for data protection:
Mr.
Matthias Goebel
Group Commissioner for Data Protection
Information Security and Privacy Bosch Group (C/ISP)
Robert Bosch GmbH
Kronenstrasse 20
70173 Stuttgart
GERMANY
or
mailto: PT.DSO@bosch.com
Effective date: 2018.05.25