Bosch eBike Systems data protection notices

Bosch eBike Systems (referred to as "Bosch eBike" or "We" in the following) would like to thank you for visiting our website for eBike dealers www.bosch-ebike.net/de and showing an interest in our company and products.

Bosch eBike respects your privacy

The protection of your privacy when processing your personal data as well as the security of all business data are important matters that we always take into account in our business processes.

Data protection and information security are part of the Bosch corporate policy.

Bosch eBike Systems is responsible for the processing of your data, exceptions are explained in this privacy policy.
 
Our contact details are as follows:
 
Robert Bosch GmbH
Robert-Bosch-Platz 1
70839 Gerlingen-Schillerhöhe
Germany
E-mail: kontakt@bosch.de
 
You can find the contact details of our data protection officer here.

 

1. Gathering, processing and use of personal data

1.1 Processed data categories

Bosch eBike Systems processes the following categories of data from eBike dealers:

  • Communication data (e.g. name, telephone, e-mail, address, IP address)
  • Contract master data (contractual relationship, product or contractual interest, etc.)
  • Customer history (changes of address, history of service cases, etc.)

1.2 Basic principles

Personal data means any information relating to an identified or identifiable natural person, such as names, addresses, telephone numbers, e-mail addresses, contractual, booking and accounting data, which is an expression of a person's identity.

We collect, process and use personal data (including IP addresses) only if there is a legal basis for doing so or if you have given us your consent, e.g. when registering.

2. Processing purposes and legal basis

We and service providers commissioned by us process your personal data for the following processing purposes:

Provision of this online offer
Legal basis: Predominant legitimate interest on our part in direct marketing, as long as this is performed in compliance with data protection and competition law (Art. 6 para. 1 lit. f DSGVO)

Provision of this online offer (with registration)
Legal basis: Fulfilment of the contract (Art. 6 para. 1 lit. b DSGVO). The following conditions apply

Dispatch of our newsletter (via e-mail)
Legal basis: Consent (Art. 6 para. 1 lit. a DSGVO)

Provision of business relevant information (e.g. Change of T&Cs, Downtime etc.)
Legal basis: Fulfilment of the contract (Art. 6 para. 1 lit. b DSGVO). The following conditions apply

Storage of training information (online training, participation) of the eBike dealers to check the authorisation to receive a dongle or a license (bike diagnosis tool)
Legal basis: Fulfilment of the contract (Art. 6 para. 1 lit. f DSGVO)

Storage of voluntary information provided by the dealer for the provision of our Bike Dealer Self-Service, including Dealer Locator (to increase visibility/reachability for end customers, marketing for the dealer)
Legal basis: Legitimate interest on our part in direct marketing, as long as this is performed in compliance with data protection and competition law (Art. 6 para. 1 lit. f DSGVO). Dealer Locator: Consent (Art. 6 para. 1 lit. a DSGVO)

Inquiries at Bosch eBike Systems, e.g. at our service or end customer hotline and for processing warranty cases
Legal basis: Our and your mutual (justified) interest in answering your enquiries, solving any problems that may arise and thus maintaining and promoting your satisfaction as a customer or user (Art. 6 para. 1 lit. f DSGVO)

Product or customer surveys by e-mail and/or telephone, as well as market research activities
Legal basis: Consent / legitimate interest on our part in direct marketing, as long as this is performed in compliance with data protection and competition law (Art. 6 para. 1 lit. a, f DSGVO)

Statistical surveys and analyses
Legal basis: Consent/legitimate interest on our part in the improvement and further development of our Bosch eBike Systems products and services, as well as fault analysis and troubleshooting using pseudonymised or anonymised data, provided this is done in accordance with data protection regulations (Article 6 (1) lit a, f EU GDPR).

Conducting competitions or discount campaigns in accordance with the respective competition or discount campaign conditions
Legal basis: Consent / legitimate interest on our part in direct marketing, as long as this is performed in compliance with data protection and competition law (Art. 6 para. 1 lit. a, f DSGVO)

Protection and defence of our rights
Legal basis: Predominant legitimate interest on our part in asserting and defending our rights (Art. 6 para. 1 lit. f DSGVO)

3. Registration

If you wish to take advantage of services that require a contract, we ask you to register. During registration, we collect the personal data required for the establishment and fulfilment of the contract (e.g. company name, gender, address, business address, e-mail address, etc.). Telephone number, business e-mail address, preferred language setting). Mandatory details are marked with an *.

Registration via the central Bosch ID

You may register for our online offer [only] using the central Bosch ID. The central Bosch ID was developed by Bosch.IO GmbH for the RB Group in order to enable common users to take advantage of offers of different companies of the group by means of uniform login data and to increase data security.

Bosch.IO GmbH is responsible for providing this registration service, Bosch.IO GmbH, Ullsteinstrasse 128, Germany ("BIO").

If you wish to register with BIO for a central Bosch ID, the General Terms of Use for the registration and use of a central Bosch ID and BIO's Privacy Policy apply. After successful registration, you can also use the login data used for the central Bosch ID to register for this online service. For this purpose, we provide you with a BIO registration mask for the central Bosch ID.

BIO will then confirm your authorisation and provide us with the master data required for the use of our offer (e.g. surname, first name, date of birth, company name, e-mail address, telephone numbers, postal address). Your password will not be transmitted to us.

Regarding further data transfers within the Bosch Group connected with the central Bosch ID, we refer to the data protection information of BIO. You can terminate your usage agreement for the central Bosch ID at any time by unsubscribing. Please click on the following link: https://myaccount.bosch.com/BeaPUssWeb/unregistration.

4. Log files

Whenever you use the Internet, your Internet browser automatically transmits certain information and we store it in log files.

The log files are stored by us for a period of 60 days to investigate malfunctions and for security reasons (e.g. to clarify attempted attacks) and then deleted. Log files whose further storage is necessary for evidentiary purposes are excluded from the deletion until the final investigation of the relevant incident and, in individual cases, may be forwarded to the investigating authorities.

Log files (without or without complete IP address) may also be used for analysis purposes. See section 9: Use of cookies.

The following information is stored in the log files:

IP address (Internet Protocol address) of the terminal device from which the online offer is accessed; Internet address of the website from which the online offer is called up; date and time as well as duration of the call; transferred data volume; http status code; device type (user interface string, e.g. iOS, Android, Nyon, operating system)

5. Service providers (general)

Bosch eBike has commissioned external service providers with tasks such as marketing services, programming and data hosting. Bosch eBike has carefully selected these service providers and monitors them regularly, in particular the careful handling and protection of the data stored with them. All service providers are obliged by Bosch eBike to maintain confidentiality and to comply with legal requirements.

6. Transfer to recipients outside the EEA

We may also transfer personal data to recipients based outside the EEA in what are known as third countries. In this case, we will ensure before disclosure that the recipient either has an adequate level of data protection or your consent to the transfer has been obtained. You can obtain from us an overview of the recipients in third countries and a copy of the specifically agreed provisions to ensure an adequate level of data protection. Please use the information in the contact section.

7. Web Fonts

The Internet pages of the eBike dealer portal use external fonts from Google Fonts. Google Fonts is a service of Google Inc. (“Google”). These web fonts are integrated by a server call, usually a Google server in the U.S. This transfers to the server which of our Internet pages you have visited. The IP address of the browser on the visitor’s device is also stored by Google. You can find more information in the Google privacy policy.

8. Google Maps

We provide our Dealer Locator Service via an interface (API) that uses maps from Google Maps for which Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland is responsible in relation to data protection. Your IP address and the address/coordinates selected by you will be transmitted to Google. Google Maps is used here to provide any necessary location correction. This gives you the opportunity to adjust the location of your shop yourself so that it can be displayed accurately for the end customer during the dealer search. These data are processed on the basis of Article 6 (1) lit. b EU GDPR. Please note that it is possible that data will be transferred by Google to the USA. More information on how user data is handled can be found in Google’s privacy policy: https://www.google.co.uk/intl/en/policies/privacy.

9. Competitions

If you take part in a one of our competitions, we will use your data to notify you if you win a prize and for the purpose of advertising our products to the extent permitted by law, provided you have given your consent. Detailed information about the competitions can be found in the respective conditions of participation.

10. Use of cookies

Cookies and tracking mechanisms may be used in connection with providing our online services.

Cookies are small text files that are stored on your device when you visit an online offering.

Tracking is possible using various technologies. We process information in particular in connection with pixel technology or log file analysis.

10.1 Categories

We make a distinction between cookies that are absolutely essential to the technical functions of the online offer and those cookies and tracking mechanisms that are not absolutely essential to the technical function of online offers.

Use of the online offer is generally possible without cookies that serve no technical purposes.

10.1.1. Technically necessary cookies

By technically essential cookies we mean cookies without which the technical provision of the online offer cannot be guaranteed. This includes, for example, cookies that store data in order to ensure smooth playback of video or audio content.

These cookies are deleted when your session ends.

10.1.2. Technically unnecessary cookies and tracking mechanisms

We only use these cookies and tracking mechanisms if you have given us your prior consent in each case. An exception to this is the cookie that stores the current status of your privacy setting (selection cookie). This is done on the basis of a legitimate interest.

We divide these cookies and tracking mechanisms into two sub-categories:

10.2. Comfort cookies

These cookies facilitate the use of our website and thus enable a more comfortable surfing experience, e.g. your language settings can be stored in these cookies.

10.3. Marketing cookies and tracking mechanisms

General

The use of marketing cookies and tracking mechanisms enables us and our partners to display interest-based offers based on an analysis of your usage behaviour.

- 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 have accessed our website via an ad of the relevant partner. These cookies generally expire after 30 days. If you visit a specific page of ours and the cookie has not expired, we and the Conversion Tracking partner can recognise that a certain user clicked on the ad and was redirected to our site. This can also be done across devices. The information collected using the conversion cookie is used to generate conversion statistics and to determine the total number of users who clicked on the ad and were redirected to a page equipped with a Conversion Tracking tag.

- Retargeting:

These tools use advertising cookies or third-party advertising cookies, so-called web beacons (invisible graphics, which are also called pixels or counting pixels) or comparable technologies to create user profiles. These are used for interest-based advertising and to control the frequency with which the user sees certain ads. The respective provider is responsible for processing data in connection with the tools. The providers of the tools may also pass on information to third parties for the above-mentioned purposes. In this context, please refer to the privacy policy of the respective provider.

Please note that when using the tools, your data may be transferred to recipients outside the EEA where an adequate level of data protection in accordance with the DSGVO does not exist (e.g. USA). For details, please refer to the following description of each marketing tool.

Name: Google Analytics

Provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Function: Analyse user behaviour (page impressions, 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 connection with Google Ads.

10.4. Management of cookies and tracking mechanisms

You can manage your cookie and tracking mechanism settings in your browser and/or in our privacy settings:

Note: The settings you make apply only to the browser you use.

10.4.1. Turn off all cookies

If you wish to disable all cookies, please go to your browser settings and deactivate the placing of cookies. Please note that this may affect the functionality of the website.

10.4.2. Administration of your settings regarding technically unnecessary cookies and tracking mechanisms

When you visit our website, you will be asked in a cookie layer whether you give us your respective consent for the use of comfort cookies and marketing cookies or tracking mechanisms.

In our privacy settings, you can revoke consents already given with future effect or give us your consent at a later date.

11. Newsletter with registration; right of withdrawal

You can subscribe to a newsletter as part of our online service. We use the double opt-in procedure for this purpose, according to which we will only send you a newsletter by e-mail if you have previously expressly confirmed the activation of the newsletter service by clicking on a link in a notification. Should you decide at a later time that you no longer wish to receive newsletters, you can cancel your subscription at any time by revoking your consent. For e-mail newsletters, the revocation takes place via the link printed in the newsletter, or in the administration settings of the respective online offer. Alternatively, please contact us using the information in the Contact Us section.

12. Use of external links

Bosch eBike webpages may contain links to the internet pages of third parties not affiliated with us. After clicking on the link, we no longer have any influence on the collection, processing and use of any personal data transferred to the third party by clicking on the link (such as the IP address or the URL of the page on which the link is located), since the conduct of third parties is of course beyond our control. Bosch eBike assumes no responsibility for the processing of such personal data by third parties.

13. Duration of storage; retention periods

In principle, we store your data for as long as is necessary to provide our online service and the associated services or we have a justified interest in continued storage (e.g. we may still have a justified interest in marketing by post even after fulfillment of a contract). We will thereafter delete your personal data with the exception of data that we are required to retain to comply with legal obligations (e.g. we are required by tax and commercial law to retain documents such as contracts and invoices for a certain period of time).

14. Security

We take all necessary technical and organisational measures to ensure an adequate level of protection and to protect your data managed by us in particular against the risks of accidental or unlawful destruction, manipulation, loss, alteration or unauthorised disclosure or access. Our security measures are constantly being improved in line with technological developments.

15. Your rights as a user of the Bosch eBike dealer portal

Your rights as a user are described in detail in this section. Among other things, you have a right to information, to correction and a right to object to direct marketing as well as a right to revoke your consent.

15.1    Right to information and disclosure

You are entitled to receive information from us about how your data is processed. To this end, you may exercise a right to information regarding your personal information that we process.

15.2  Right of correction and deletion

You can demand from us the correction of false data and - provided the legal requirements are fulfilled - the completion or deletion of your data.

This does not apply to data which is required for invoicing and accounting purposes, or which is subject to a legal obligation to retain. However, if access to such data is not required, its processing will be restricted (see below).

15.3  Restriction of processing

You can demand from us - provided the legal requirements are fulfilled - that we restrict the processing of your data.

15.4 Objection to data processing

You also have the right to object to data being processed by us at any time. We will then suspend the processing of your data unless we can prove - in accordance with the statutory provisions - that there are compelling and legitimate grounds for further processing which outweigh your rights.

15.5 Objection to data processing in the event of legal basis of "legitimate interest"

In addition, you have the right to object to data processing by us at any time, insofar as this is done on the legal basis of legitimate interest. We will then suspend the processing of your dataunless we can prove - in accordance with the statutory provisions - that there are compelling and legitimate grounds for further processing which outweigh your rights.

15.6 Revocation of consent

If you have given us your consent to allow your data to be processed, you can revoke your consent at any time with future effect. This shall be without prejudice to the lawfulness of the processing of your data before consent is revoked.

15.7 Data portability

You also have the right to receive data that you have made available to us in a structured, standard and machine-readable format or - if technically feasible - to demand that the data be transmitted to a third party.

15.8 Right of appeal to the supervisory authority

You have the right to file a complaint with a data protection authority. You can contact the data protection authority responsible for your place of residence or federal state or the data protection authority responsible for us. It is:

The State Commissioner for Data Protection and Freedom of Information Baden-Württemberg

Königstrasse 10a

70173 Stuttgart

GERMANY

16. Changes to this privacy policy

We reserve the right to change our security and privacy practices as necessary due to technical developments. In such cases, we will also modify our privacy policy accordingly. For this reason, please note the latest version of our privacy policy.

17. Contact

If you would like to contact us, you can reach us at the address given in the “Responsible” section.

Use the following link to assert your rights and report data protection incidents:

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  

Department for Information Security and Data Protection Bosch Group (C/ISP)

Postfach 30 02 20

70173 Stuttgart  

GERMANY

Revision: 15. October 2020