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L.OS – Logistics Operating System

Data Protection Notice 

Bosch Mobility Platform & Solutions GmbH (hereinafter “Bosch” 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 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. 

 

Important Notice for U.S. residents: We have updated our Privacy Notice to provide supplemental details regarding certain rights provided under the U.S. Data Protection Requirements. Review updates of the U.S. Privacy Rights/Privacy Notice here

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.  

Controller

In this project different legal entities of the Bosch Group are involved as Joint Controller (defined as two or more controllers jointly determining the purposes and means of processing), with respect to the Processing of Personal Information for the purposes in fulfilling the obligation for a customer relationship management, such as Salesforce. The Controller for the processing of your own personal data is the legal entity that is responsible for your region. The regional responsibilities of the legal entities involved can be found in the Section “Information on joint controllership towards data subjects”.

 

Regardless of who is the controller, you can contact us by e-mail: hello.l-os@bosch.com

Information on joint controllership towards data subjects 

Party 1: Bosch Mobility Platform & Solutions GmbH, P.O Box 10 60 50, 70049 Stuttgart, Germany  

and   

Party 2: Bosch Mobility Platform and Solutions India Private Limited formerly known as Automobility Services and Solutions Private Limited, P.O Box 3000, Hosur Road, Adugodi, Bangalore 560030, India    

and   

Party 3: Bosch Mobility Platform & Solutions LLC, 38000 Hills Tech Drive, Farmington Hills, MI 48331, United States  

 

What is the reason for the joint controllership?

Within the Logistics Operating System, the above named parties shall cooperate closely. This also applies to the processing of your personal data. The parties have jointly determined the order in which this data will be processed at each stage of the process. They are therefore considered joint controllers for the protection of your personal data.

 

What did the parties agree upon?

As part of their joint controllership under data protection law, the above-mentioned parties have agreed which of them will fulfil the respective obligations under the applicable data protection law. This applies in particular to the exercise of the rights of the data subjects and the fulfilment of the information obligation.

 

This agreement is necessary because Logistics Operating System processes personal data in different process sections and systems operated by either Party 1, Party 2 or Party 3.

  1. Processing activity: processing of personal data from origin region Europe
    Fulfilment of duties by: Party 1
  2. Processing activity: processing of personal data from origin region India
    Fulfilment of duties by: Party 2
  3. Processing activity:processing of personal data from origin region North America
    Fulfilment of duties by: Party 3

 

What does this mean for you as a data subject?

Even if there is a joint controllership, the parties fulfil the data protection obligations according to their respective responsibilities for the individual processing activities as follows:

  • Party 1 is responsible for the processing of personal data from origin region Europe; and
  • Party 2 is responsible for the processing of personal data from origin region India; and
  • Party 3 is responsible for the processing of personal data from origin region North America.

The parties shall inform each other immediately of any legal positions asserted by you as a data subject. They shall provide each other with all information necessary to respond to requests for information. You can assert your rights against any party directly.

Processed categories of data 

The following categories of data are processed by using the Logistics Operating System:  

  • Communication data (e.g., name, business telephone, business e-mail, business address, IP address)  

  • Contractual master data (e.g., contractual relationships, contractual or product interest)  

  • Client history (e.g., campaign memberships, meeting notes)  

  • Contract billing and payment data  

  • Contract accounting and payment data  

  • Transaction data  

  • Personal data based on a contract between customer and service provider (partner) are generated and transferred to L.OS  

  • No processing of special categories of personal data according to art. 9 EU GDPR  

  • No Processing of personal data relating to criminal convictions and offences according to art. 10 EU GDPR  

Additional categories of data will be processed when a service is booked and used:  

  • Miscellaneous: The data categories might be extended by booking of additional services. The details will then be provided by the DPN for those services. On request to our support-channels or over the contact form, those additional data categories will also be provided upfront.   

There are situations in which we cannot take action without certain personal data, for instance because this personal data is needed to process your orders or to give you access to a website content or newsletter. In such cases, we unfortunately cannot supply what you desire without the relevant personal data.  

Processing purposes and legal basis 

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

  • Pre-contractual contact to provide you with information about our products and services. Legal basis: Consent by the user / legitimate interest on our part for sharing information about products and services that support users in the evaluation and pre-sales phase  

  • Provision of these Online Offers and fulfillment of a contractual obligations under our contractual terms including invoicing. Invoicing may include the sale of claims. Legal basis: Consent, fulfillment of contractual obligation, respectively our legitimate interest in an efficient claims management as regards the sale of claims  

  • 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.  

  • Self-promotion and promotion by others as well as market research and reach analysis done within the scope statutorily permitted or based on consent Legal basis: Consent / legitimate interest on our part in direct marketing if in accordance with data protection and competition law  

  • Safeguarding and defending our rights. Legal basis: Legitimate interest on our part for safeguarding and defending our rights 

  • Product or customer surveys performed via email and/or telephone subject to your prior express consent. Legal basis: Consent  

  • Sending an email or SMS/MMS newsletter subject to the recipient’s consent. Legal basis: Consent  

Registration 

If you wish to use or get access to benefits requiring to enter into the fulfillment of a contract, we request you to register. On the basis of  your registration, we collect personal data necessary for  fulfillment of the contract (e.g. first name, last name, email address, company information, 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 *. 

Log files 

Each time you use the internet, your browser transmits 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 90 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.  

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”).  

Children 

This Online Offer is not meant for children under 18 years of age.  

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. The recipients are service providers of that platform.  

 

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.   

 

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 with the statutory provisions. Service providers may also be other Bosch group companies.  

 

Payment service providers  

We involve external payment service providers.  

 

Depending on the type of payment method you choose during the ordering process, we transfer the 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 that case (payment service providers are data controllers) the data protection notice or privacy policy of the respective payment service provider applies.  

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 contact information stated above.  

Duration of storage, retention periods 

Principally, we erase your personal data if a purpose and legal basis for data processing does not exist anymore, or we are legally obliged to erase. Please note that we are not allowed to erase personal data, which we have to keep fulfilling a legal obligation (e.g. retention periods under the tax and commercial codes, which require the availability of certain documents such as contracts and invoices for a certain period of time).  

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.  

 

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.  

 

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.  

 

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:  

 

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.  

 

Marketing cookies and tracking mechanisms

 

General  

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  

  • Retargeting: These tools create user profiles by means of advertising cookies or third-party advertising cookies so called "web beacons" (invisible graphics that are also called pixels or tracking pixels), or by means of comparable technologies. These are used for interest-based advertising and to control the frequency with which the user looks at certain advertisements. The relevant provider is the controller responsible for the processing of data in connection with the tool. The providers of the tools might disclose information also to third parties for the purposes mentioned above. Please note the data protection notices of the relevant provider in this context.  

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 Analytics   

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland  

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  

 

Name: Google Tag Manager  

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland  

Function: Administration of website tags via a user interface, integration of program codes on our websites  

 

Name: Google Ads  

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland  

Function: Placement of advertisements, remarketing, conversion tracking  

Further information is available at: (https://adssettings.google.com/authenticated).  

 

Name: Google Doubleclick  

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland  

Function: Placement of advertisements, remarketing, conversion tracking  

 

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.  

 

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.  

 

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 us using any Comfort cookies, marketing cookies or tracking mechanisms, respectively.   

 

In our privacy settings, you may withdraw the consent with effect from the future or grant your consent at a later point in time.  

Social Plugins 

In our Online Offers we use so-called social plugins from various social networks. They are individually described in this section.  

 

When using plugins, your internet browser creates a direct connection to the respective social networks’ server. Hereby the respective provider receives the information that your internet browser accessed from the respective site of our Online Offers - even if you do not have a user account with this provider or are currently not logged into your account. Log files (including the IP address) are, in this case, directly transmitted from your internet browser to a server of the respective provider and might be stored there. The provider or its server may be located outside the EU or the EEA (e.g. in the United States).  

 

The plugins are standalone extensions by social network providers. For this reason, we are unable to influence the scope of data collected and stored by them.  

 

Purpose and scope of the collection, the continued processing and usage of data by the social network as well as your respective rights and setting options to protect your privacy can be found by consulting the respective social network's data protection notices.  

 

In case you do not wish social network providers to receive and, if applicable, store or use data, you should not use the respective plugins.  

 

Facebook plugins  

Facebook is operated by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). Find an overview over Facebook's plugins and their appearance here: https://developers.facebook.com/docs/plugins; find information on data protection at Facebook here: http://www.facebook.com/policy.php.  

 

Twitter plugins  

Twitter is operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA and Twitter International Company, One Cumberland Place, Fenian Street Dublin 2, D02 AX07 Ireland ("Twitter"). Find an overview over Twitter's plugins and their appearance here: https://developer.twitter.com/en/docs/twitter-for-websites/overview.html; find information on data protection at Twitter here: https://twitter.com/privacy.  

 

Instagram plugins  

Instagram is operated by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Instagram"). Find information on data protection at Instagram here: https://help.instagram.com/155833707900388/.  

 

LinkedIn  

When you create or log in to an account on http://www.linkedin.com cookies are stored on your computer in order to remain logged-in to your LinkedIn account when visiting http://www.linkedin.com again. This data is not accessible to us, and is not sent to us by LinkedIn. More information about this cookie and LinkedIn’s Privacy Policy can be found at https://www.linkedin.com/legal/privacy-policy

 

YouTube  

Our Online Offers use the YouTube video platform which is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland („YouTube”). YouTube is a platform which allows the playback of audio and video files.  

 

When you access a respective site of our Online Offers that contains an embedded YouTube player, this creates a connection to YouTube so that the video or audio file can be transmitted and played back. In doing so, data is transferred to YouTube as a data controller. We are not responsible for the processing of such data by YouTube.  

 

Additional information on the scope and purpose of collected data, on further processing and usage of data by YouTube, on your rights and the privacy options available to be chosen by you, can be found in YouTube's data protection notice.  

 

Communication tools on social media platforms  

We use  communication tools on our social media platform (e.g. twitter) to process your messages sent via the social media platform and to offer you support.   

 

When sending a message via our social media platform the message is processed to handle your query (and if necessary additional data, which we receive from the social media provider in connection with this message as your name or files).  
 

In addition, we can analyze these data in an aggregated and anonymized form in order to improve our understanding of how our social media platform is used.  

 

We will forward the personal data you provide to the Bosch legal entity responsible for the processing of your query (for example, in the event your query refers to a product that is distributed by another Bosch legal entity). The legal basis for the processing of your data is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) or, if applicable, an existing contractual relationship (Art. 6 para. 1 s. 1 lit. b GDPR). The processed personal data is deleted within 180 days upon receipt of your message . 

 

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.  

External links 

Our Online Offers may contain links to internet pages of third parties, in particular providers who are not related to us. If you click 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.  

Security  

Our employees and the companies providing services on our behalf, are obliged to maintain confidentiality and to comply 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 to prevent  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. 

Rights of Data Subjects 

To assert your data subject rights please use the following link: https://request.privacy-bosch.com/entity/RB  

 

To notify possible data protection incidents please use the following link: https://www.bkms-system.net/bosch-dataprotection  

 

When assessing data subject rights, please ensure that an unambiguous identification of your person is possible.  

 

You may also contact our Data Protection Officer using the contact information stated below.  

 

To enforce your rights, please use the details provided in the Controller 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 or completion of inaccurate personal data or deletion of your data as far as statutory requirements are fulfilled.    

 

Restriction of processing:  

You have the right to demand for – as far as statutory requirements are fulfilled – restriction of the processing of your data.  

 

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.  

 

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 “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.  

 

Responsible controller for your withdrawal can be found in the Sections “Controller” and “Information on joint controllership towards data subjects”.  

 

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.  

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, take notice of the current version of our data protection notice, as this is subject to changes.  

Contact 

If you wish to contact us, please find us at the address stated in the "Controller" section.  

 

To assert your rights please use the following link: https://request.privacy-bosch.com/entity/RB/  

 

To report a data breach, please use this 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  
P.O. Box 30 02 20   
70442 Stuttgart, GERMANY  

or  

mailto: DPO@bosch.com

Information to be provided to data subjects in accordance with Art. 13 GDPR – Joint controllers

As the party responsible for SingleKey ID, Bosch.IO GmbH exercises joint responsibility, together with third parties responsible for the application(s) you use, for the processing of your data in accordance with the provisions of the General Data Protection Regulation and national data protection laws. In accordance with Art. 26 of the GDPR (Joint controllers), we have agreed in writing to exercise joint responsibility for data processing. In particular, we have determined and agreed upon the responsibilities and liabilities of the parties involved. For detailed information on individual processing operations, please refer to the data protection notice of Bosch.IO GmbH and the information sheet on data processing available at Data Protection Policy.

 

This data protection notice is effective of June 22, 2023.