Data Protection Notice

Data Protection Notice of grow Platform GmbH (CyberCompare, A Bosch Business)

Grow Platform GmbH (hereinafter “CyberCompare, A Bosch Business”, “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.

1. CyberCompare, A Bosch Business 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.

2. Controller

Robert Bosch GmbH is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.

Our contact details are as follows:

grow platform GmbH
CyberCompare, A Bosch Business
Grönerstr. 9
71636 Ludwigsburg

GERMANY

Board of Management

Dr. Karsten Rönner, Xiaojie Ma, Georg Stellmann

Telephone number:

+49 711 811-91494

E-Mail address:

cybercompare@de.bosch.com

3. Collection, processing, and usage of personal data

3.1 Processed data categories

The following data categories are processed:

Communication data (e.g. name, telephone number, e-mail address, address, IP address) are processed.
Contract master data (contractual relationship, product or contractual interest)
Customer history
Planning and control data
Transaction data

3.2 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.

3.3 Processing purposes and legal basis

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

3.3.1 Provision of these online offers

Legal basis: Predominantly, legitimate interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law.

3.3.2 In reply to user inquiries in the framework of a contact form

Legal basis: Predominantly, legitimate interest in direct marketing on our part and in the enhancement of our products and services, as long as this is carried out in compliance with data protection regulations and competition law regulations resp. contractual performance resp. consent.

3.3.3 In reply to user inquiries in the framework of a live chat

3.3.4 Newsletter sending an email or SMS/MMS newsletter subject to the recipient’s consent

Legal basis: Consent.

3.3.5 Resolving service disruptions as well as for security reasons

Legal basis: Fulfillment of our legal obligations within the scope of data security and predominantly, legitimate interest in resolving service disruptions as well as in the protection of our offers.

3.3.6 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 or predominantly, legitimate interest on our part in direct marketing if in accordance with data protection and competition law.

3.3.7 Safeguarding and defending our rights

Legal basis: Legitimate interest on our part in the assertion and defense of our rights.

3.3.7 Event Participation Management

Legal basis: Consent
Data Categories: name, e-mail address

3.3.8 Shopify

We use the store system of the service provider Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland (“Shopify”), for the purpose of hosting and displaying the online store on the basis of processing on our behalf.

When you visit our online store, Shopify collects your IP address and information about the device you are using and your browser. Shopify is also used to analyze visitor numbers, visitor sources and customer behavior and to create user statistics. When you make a purchase on our website, Shopify also collects your name, e-mail address, delivery and billing addresses, payment details and other data related to the purchase (e.g. telephone number, amount of sales made, etc.). Shopify stores cookies in your browser for analysis purposes.

Details can be found in Shopify’s privacy policy: https://www.shopify.de/legal/datenschutz.

The use of Shopify is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in displaying our website as reliably as possible. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.

3.4 Log files

Each time you use the internet, your browser is transmitting certain information which we store in so-called log files.

We store log files to determine service disruptions and for security reasons (e.g., to investigate attack attempts) for a period of 7 days and delete them afterwards. Log files which need to be maintained for evidence purposes are excluded from deletion until the respective incident is resolved and may, on a case-by-case basis, be passed on to investigating authorities.

Log files are also used for analysis purposes (without the IP address or without the complete IP address) see module 3.3.4 “Self-promotion and promotion by others as well as market research and reach analysis done within the scope statutorily permitted or based on consent”

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”).

3.5 Children

This online offer is not meant for children under 16 years of age.

3.6 Data transfer

3.6.1 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 basis and the recipients or categories of recipients can be found in the section “Processing purposes and legal basis” (see no. 3.3).

Additionally, data may be transferred to other controllers when we are obliged to do so due to statutory regulations or enforceable administrative or judicial orders.

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

3.6.3 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 or that you have consented to the transfer. You are entitled to receive an overview of third country recipients and a copy of the specifically agreed-provisions securing an appropriate level of data protection. For this purpose, please use the statements made in the “Contact” section (see no. 13).

3.7 Duration of storage, retention periods

Principally, we store your data for as long as it is necessary to render our online offers and connected services or for as long as we have a legitimate interest in storing the data (e.g. we might still have a legitimate interest in postal mail marketing after fulfillment of our contractual obligations). In all other cases we delete your personal data with the exception of data we are obliged to store for the fulfillment of legal obligations (e.g. due to retention periods under the tax and commercial codes we are obliged to have documents such as contracts and invoices available for a certain period of time).

4. 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.

4.1 Categories

We distinguish between cookies that are mandatorily required for the technical functions of the online service and such cookies and tracking mechanisms that are not mandatorily required for the technical function of the online service.

It is generally possible to use the online service without any cookies that serve non-technical purposes.

4.1.1 Technically required cookies

By technically required cookies we mean cookies without those the technical provision of the online service cannot be ensured. These include e.g. cookies that store data to ensure smooth reproduction of video or audio footage.

Such cookies will be deleted when you leave the website.

4.1.2 Cookies and tracking mechanisms that are technically not required

We use marketing cookies and tracking mechanisms. We only use such 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.

4.1.3 Comfort Cookies

These cookies facilitate the operation and thus enable a more comfortable surfing on our online offer, e.g. your language settings can be stored in these cookies.

4.2 Marketing Cookies and Tracking Mechanisms

4.2.1 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” (see no. 7).

Please note that using the tools might include transfer of your data to recipients outside of the EEA where there is no adequate level of data protection pursuant to the GDPR (e.g. the USA). For more details in this respect please refer to the following description of the individual marketing tools:

Google Analytics

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

We have activated the “Google Signals” function. This means that usage data is collected from you and linked to your Google account by Google, provided that you are logged into your Google account and have activated personalized advertising. By linking data with logged-in users, cross-device reports, cross-device remarketing and the export of cross-device conversions to Google Ads are possible.

Google Tag Manager

Name: Google Tag Manager
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland
Function: Administration of website tags via a user interface, integration of program codes on our websites

Google Optimize

Name: Google Optimize
Provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Function: Cookie can analyze how users have behaved on a cross-site basis, UX testing

Universal Event Tracking Tag (Microsoft Advertising / Bing Ads)

Name: Microsoft Advertising / Bing Ads
Provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland
Function: Analyze actions that users take on our website after clicking on a Bing or Microsoft Advertising ad. If you access our website by clicking on a Bing or Microsoft advertisement, a cookie is set on your computer. A Universal Event Tracking (UET) tag is integrated on our website. This is a code that stores data about the use of the website. That includes, among other things, the length of time spent on the website, which areas of the website were accessed and via which advertisement the user arrived at the website. Further information about privacy and the used cookie of Bing Ads can be found on the Bing Ads or Microsoft website.

HubSpot

Our Site employs HubSpot, which collects personal identifying information by using JavaScript and cookies to help us analyze how visitors use the Site. HubSpot’s products help us to identify Site visitors, analyze email campaigns, track Site contact forms and monitor Google AdWords click through. Anonymous visitor tracking information may be shared with other HubSpot customers.

For more information about HubSpot cookies, please visit https://legal.hubspot.com/privacy-policy.

Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

4.3 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.

4.3.1 Deactivation of all cookies

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

4.3.2 Management of your settings with regard to cookies and tracking mechanisms not required technically

When visiting our websites, you will be asked in a cookie layer whether you consent to our using of any marketing cookies or tracking mechanisms, respectively.

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

5. Social plugins

In our online offer, we use so-called social plugins of different social networks; these will be described individually in this section.

On application of the plugins, your Internet browser will establish a direct connection to the servers of the respective social network. Hereby the relevant provider obtains the information that your Internet browser has called up the corresponding page of our online offer, even if you do not possess a user account with the provider or are not currently logged in with the provider. Log files (including the IP address) are directly transmitted from your Internet browser to a server of the relevant provider where they are stored if necessary. The headquarters of the provider or his/her server could be located outside the EU or the EEA (e.g. in the USA).

The plugins are independent extensions of the providers of social networks. Therefore, we have no influence on the extent of the data collected and stored by the social network providers via the plugins.

The purpose and extent of the collection, the further processing of the data by the social network as well as your associated rights and setting options for the protection of your private sphere can be taken from the data protection notice of the respective social network.

You should not use the respective plugins if you do not want social network providers to obtain data concerning this online offer or to continue to use this data.

5.1 Social plugins with 2-click solution

With a so-called 2-click solution, we protect you from having your visits to our websites recorded and evaluated by social network providers as standard. When you access a page of our internet offer, which contains such plugins, these are initially deactivated. The plugins are not activated until you click the provided button.

5.2 LinkedIn plugins

LinkedIn is provided by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (“LinkedIn”). You will find an overview of the plugins from LinkedIn and their appearance here: https://developer.linkedin.com/plugins
; you will find information on data protection at LinkedIn here: https://www.linkedin.com/legal/privacy-policy.

6. YouTube

This online offer uses the video platform YouTube, which is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (“YouTube”). YouTube is a platform which allows the playback of audio and video files.

If you access a corresponding page of our offer, the embedded YouTube player will establish a connection to YouTube so that the video or audio file can be transmitted and played. In the process, data are also transmitted to YouTube as the responsible body. We are not responsible for the processing of this data by YouTube.

Further information concerning the extent and purpose of the collected data, on the further processing and utilization of your data by YouTube, on your rights and on your selectable data protection options can be found in the privacy policy of YouTube.

7. Kommunikationstools auf Social Media Plattformen

We use communication tools on our pages on social media platforms (e.g. Twitter) to process messages that you send to us via the social media platform and to be able to offer you support.

If you send us a message via a social media platform, the message (and any other data we receive from the social media platform provider with the message, such as your name and file attachments) will be processed by us in order to process your request. In addition, we may analyses the data in an aggregated and anonymized form to better understand the use of our social media platforms.

The personal data you provide to us may be transferred to the Bosch legal entity responsible for the request (for example, if your request relates to a product that another Bosch legal entity distributes). The legal basis for this type of processing results from our legitimate interests (Art. 6 para. 1 p. 1 lit. f DSGVO) or an existing contractual relationship, if applicable (Art. 6 para. 1 p. 1 lit. b DSGVO). Your data will be deleted no later than 180 days after receipt of your message.

8. Newsletter

Within the scope of our Online Offers you are able to sign up for newsletters. To do so, we use the so-called double opt-in procedure 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 at a later date, 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 using the contact details provided in the Contact section.

9. External links

Our online offers may contain links to internet pages of third parties, in particular providers who are not related to us. Upon clicking on the link, we have no influence on the collecting, processing, and use of personal data possibly transmitted by clicking on the link to the third party (such as the IP address or the URL of the site on which the link is located) as the conduct of third parties is naturally beyond our control. We do not assume responsibility for the processing of personal data by third parties.

10. 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.

11. User rights

To enforce your rights, please use the details provided in the “Contact” section (see no. 13). In doing so, please ensure that an unambiguous identification of your person is possible.

11.1 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.

11.2 Right to correction and deletion

You have the right to obtain the rectification of inaccurate personal data. As far as statutory requirements are fulfilled, you have the right to obtain the completion or deletion of your data.

This does not apply to data which is necessary for billing or accounting purposes or which is subject to a statutory retention period. If access to such data is not required, however, its processing is restricted (see the following).

11.3 Restriction of processing

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

11.4 Data portability

As far as statutory requirements are fulfilled you may request to receive data that you have provided to us in a structured, commonly used and machine-readable format or – if technically feasible – that we transfer those data to a third party.

11.5 Right of objection

11.5.1 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.

11.5.2 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.

11.6 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.

11.7 Right to lodge complaint with supervisory authority

You have the right to lodge a complaint with a supervisory authority. You can appeal to the supervisory authority which is responsible for your place of residence or your state of residency or to the supervisory authority responsible for us. This is:

State Commissioner for Data Protection and Freedom of Information

Address:

Postfach 10 29 32
70025 Stuttgart
DEUTSCHLAND

Telephone: +49 (711)/615541-0
Fax: +49 (711)/615541-15
e-mail to: poststelle@lfdi.bwl.de

12. Change of the data protection notice

We reserve the right to change our security and data protection measures. In such cases, we will amend our data protection notice accordingly. Please, therefore, notice the current version of our data protection notice, as this is subject to changes.

13. Contact

If you wish to contact us, please find us at the address stated in the “Controller” section (see no. 2).

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

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

For suggestions and complaints regarding the processing of your personal data we recommend that you contact our data protection officer:

Data Protection Officer
Information Security and Privacy (C/ISP)
Robert Bosch GmbH
Postfach 30 02 20
70442 Stuttgart
GERMANY

e-mail to: DPO@bosch.com

Last updated: 25.01.2024