Data Protection Notice
Data protection policy of Robert Bosch Middle East FZE
1. Data Protection Notice
Robert Bosch Middle East FZE
(hereinafter "Bosch“ or "We“ or "Us") is delighted about your visit
to our internet pages and mobile applications (together also
referred to as "Online Offers") and about your interest in our
company and our products.
2. Bosch respects your privacy
The protection of your
privacy throughout the course of processing personal data as well as
the security of all business data is an important concern to us. We
process personal data that was gathered during your visit of our
Online Offers confidentially and only in accordance with statutory
regulations.
Data protection and information security are
included in our corporate policy.
3. Controller
Bosch BT is the controller responsible
for the processing of your data; exceptions are outlined in this
data protection notice.
Our contact details are as follows:
Building Technology
Robert Bosch Middle East FZE
Dubai
Airport Free Zone
Phase 5WA, Office 701
P.O. Box 54307
Dubai,
U.A.E
Phone +971 4 2123360
4. Collection, processing and usage of personal data
4.1. Processed categories of data
The following categories of
data are processed:
- Communication data (e.g. name, telephone, e-mail, address, IP address)
- Contractual master data (e.g. contractual relationships, contractual or product interest)
- Client history
- Contract accounting and payment data
- Geolocation
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 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
(Legal basis: Justified interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law). -
Provision of these Online Offers and fulfillment of 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 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)
4.4. Registration
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 *.
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 16 years of age.
4.7. Data transfer
4.7.1. 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 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.
4.7.2. 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.
4.7.3. Payment service providers
We involve external payment
service providers.
Depending on the type of payment method you
choose during the ordering process, we transfer data used for the
processing of payments (e.g., bank account or credit card data) to
the financial institution charged with the payment or to payment
service providers commissioned by us. Sometimes, payment service
providers also collect and process such data as controllers. In this
case (payment service providers are data controllers), the data
protection notice or privacy policy of the respective payment
service provider applies.
4.7.4. Claims management
We reserve the right to have claims
collected by external service providers.
Additionally, we have
a legitimate interest in selling claims to third parties and in
transferring data necessary for the collection of the claim to the
respective buyer of the claim. During claim collection, claim buyers
act in their own names and are themselves responsible for processing
the data. In this respect, the data protection notices of the
respective claim buyer apply.
4.8. Transfer to recipients outside the EEA
We 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.
4.9. Duration of storage; retention periods
Principally, we
store your data for as long as it is necessary to render our Online
Offers and 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).
5. Credit assessments
We have a justified interest in
performing 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
refuse 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.
6. Reports made to credit agencies
We report due claims
to credit agencies when, despite maturity, no payment has occurred,
when the transfer is necessary to preserve our justified interests
or justified interests of third parties and when the additional
statutory requirements are present. These are
- the enforceability of the claim or the presence of an explicit promissory letter; or
- the issuance of at least two written overdue notices upon maturity of the claim, whereas the first overdue notice must have occurred at least four weeks prior and the debtor has been informed of the possibility of submitting the claim to a credit agency (in this first notice or at least before actual submittal to the credit agency) and the claim has not been disputed; or
- the possibility of the termination of the contractual relationship without previous notice due to arrears and the debtor has been informed about the possibility of submitting the claim to a credit agency.
In addition, we may report behavior contravening the contract (e.g., fraudulent behavior, misuse) to credit agencies as far as this is necessary to preserve our justified interests or the justified interests of third parties and there is no reason to assume that the affected person's interests worthy of protection outweigh or prevail over these justified interests.
7. Cookie usage
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.
7.3. Overview of cookies used by us
In this section, please
find an overview of cookies we use:
Absolutely necessary cookies
Certain cookies are
necessary so we can securely render our Online Offers. This category
includes, e.g.:
- Cookies that identify or authenticate our users;
- Cookies that temporarily save certain user input (e.g., content of a shopping cart or of an online form);
- Cookies that store certain user preferences (e.g., search or language settings);
- Cookies that store data to ensure a trouble-fee playback of video or audio content.
Analytical cookies
We use analytical cookies to record
the usage behavior (e.g. ad banners clicked on, search queries put
in) of our users and to evaluate it statistically.
8. Web analysis
We need statistical information about
the usage of our Online Offers to design them to be more
user-friendly, to perform range measurements and market research.
For
this purpose, we use the web analysis tools described in this
section.
The usage profiles created by these tools using
analysis cookies or by evaluating log files are not brought together
with personal data. The tools either do not use user IP addresses at
all or shorten them immediately after gathering them.
The tool
sellers process data only as processors subject to our directives
and not for their own purposes.
In the following please find
information on each tool seller and how you are able to object to
the collection and processing of data by the tool.
Be advised
that with regard to tools which use opt out cookies, the opt out
function is related to that individual device or browser. In case
you use several terminal devices or browsers you must opt out on
every device and with every browser used.
Beyond this, you can
avoid the forming of usage profiles by generally deactivating cookie
usage. Please refer to the section Deactivate and delete cookies.
8.1. WebTrends
WebTrends is provided by WebTrends Inc., 851 SW
6th Ave., Suite 1600, Portland, Oregon 97206, USA.
You may
object to the collection or processing of your data by using the opt
out possibility by clicking the following link:
https://ondemand.webtrends.com/support/optout.asp.
8.2. Google Analytics
Google Analytics is provided by Google
Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
("Google"). We use Google Analytics with the additional function
offered by Google to anonymize IP addresses. While doing so, Google
already shortens IPs within the EU in most cases but only does so
for exceptional cases in the United States, and in both regions it
only saves shortened IPs.
You may object to the collection or
processing of your data by using the following link to download and
install a browser plugin:
http://tools.google.com/dlpage/gaoptout?hl=en
9. Usage of our mobile applications
In addition to our
Online Offers, we offer mobile applications ("Apps"), which you can
download to your mobile device. Beyond the data collected on
websites, we collect additional personal data through our apps that
specifically result from the usage of a mobile device. This occurs
only when you expressly grant your consent.
9.1. Data processing by App Store operators
No data collection
by us or outside our responsibility includes the transfer of data
such as username, email address and individual device identifier to
an app store (e.g., Google Play by Google, App Store by Apple,
Galaxy Apps Store by Samsung) when downloading the respective
application. We are unable to influence this data collection and
further processing by the App Store as controller.
10. YouTube
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 processor. We are not
responsible for the processing of such data by YouTube.
Additional
information on the scope and purpose of collected data, on further
processing and usage of data by YouTube, on your rights and the
privacy options available to be chosen by you, can be found in
YouTube's data protection notice.
11. Newsletter
11.1. 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.
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 supervision. We do not
assume responsibility for the processing of personal data by third
parties.
13. 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 is
administrated by us, especially from the risks of unintended or
unlawful destruction, manipulation, loss, change or unauthorized
disclosure or unauthorized access. Our security measures are,
pursuant to technological progress, constantly being improved.
14. User rights
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 any time, insofar as this is based on the
legal basis of justified interest. We will then terminate the
processing of your data, unless we demonstrate compelling legitimate
grounds according to legal requirements for the processing, which
override your rights.
Withdrawal of consent:
In case you consented to the
processing of your data, you have the right to object this consent
with immediate effect. The legality of data processing prior to your
revocation remains unchanged.
Data portability:
You are entitled to receive data that
you have provided us in a structured, commonly used and
machine-readable format or – if technically feasible – to demand
that we transfer those data to a third party.
Right of complaint with supervisory authority:
You have
the right to lodge a complaint with a supervisory authority. You can
appeal to the supervisory authority which is responsible for your
place of residence or your state or to the supervisory authority
responsible for us. This is:
State Commissioner for Data Protection and Freedom of Information
Ministry Of Economy
10 to 18 floor, Liwa Tower,
Exhibition area
Abu Dhabi
United Arab Emirates
15. Changes to the Data Protection Notice
We reserve
the right to change our security and data protection measures if
this is required due to technical development. In such cases, we
will amend our data protection notice accordingly. Please,
therefore, notice the current version of our data protection notice,
as this is subject to change.
16. 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 the
following link:
https://www.bkms-system.net/bosch-datenschutz
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
17. Effective date: 16.02.2018