Data protection policy

Data Protection Notice

The grow platform GmbH (hereinafter “grow” 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.

grow 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.

Controller

grow 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
Grönerstraße 9
71636 Ludwigsburg
Email: support-spexor@bosch.com

Collection, processing and usage of personal data

Processed categories of data

The following categories of data are processed:

• Communication data (e.g. name, telephone, e-mail, address, IP address)
• Contractual master data (e.g. contractual relationships, contractual or pro-duct interest)
• Client history
• Contract accounting and payment data
• Transaction data
• Provision of information (from third parties, e.g. credit reference agencies or from public directories)
• Location data (GPS) of the Spexor device
• Number Plate

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.

Processing purposes and legal basis

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: Legitimate interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law).
• 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).
• Safeguarding and defending our rights (Legal basis: Legitimate interest on our part for safeguarding and defending our rights).
• 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).
• Conducting raffles or discount campaigns in accordance with respective terms and conditions for raffles or discount campaigns (Legal basis: Fulfillment of contractual obligations).
• 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 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 *.

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 1 year 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 “Advertisements and/or market research (including web analysis, no customer surveys)”.

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 16 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, has 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.

Additionally, data might 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.

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 either that 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.

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).

Raffles or discount campaigns

In case you participate in one of our discount campaigns, we use your data to inform you about any prize won and for the purpose of advertising our products to the extent allowed by law or as far as you have consented. Information on discount campaigns can be found in the respective terms of participation.

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 web-site. 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) 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" (invisi-ble graphics that are also called pixels or tracking pixels), or by means of comparable technolo-gies. These are used for inter-est-based advertising and to control the frequency with which the user looks at certain adver-tisements. The relevant provider is the controller responsible for the processing of data in con-nection with the tool. The pro-viders of the tools might disclose information also to third parties for the purposes mentioned above. Please note the data pro-tection 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 mar-keting tools.

Name: Google Analytics

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

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 Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

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

Name: Google Ads

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

Function: Placement of advertisements, remarketing, conversion tracking

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

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 our using of any Comfort cookies, 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.

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 is subject to your prior consent.

Processing of the advertising identifier / advertising ID

For advertising purposes, we use, given your consent, the so-called "advertising identifier" (IDFA) for iOS devices and the so-called advertising ID for Android devices. These are not permanent identification numbers for a certain terminal device provided by iOS or Android. The data collected is not brought together with other device-related information. We use identification numbers to provide you with personalized advertisements and to analyze your usage. When you activate (for iOS devices) the option "no ad tracking" in the device settings under "Privacy" - "Advertisements" or (for Android devices) activate "deactivate interest-based advertisements" in the Google settings under "Advertisements", we can only perform the following measures: Measuring your interaction with banners by counting the number of displays of a banner without clicks ("frequency capping"), click rate, assessment of unique usage ("unique user") and security measures, fraud combating and troubleshooting. In the device settings, you are always able to delete your IDFA or advertising ID ("reset ad ID"); a new identification number is generated then which is not combined with data collected earlier. We advise you that you might be unable to use all functions of our app when you restrict the usage of the respective identification number.

Data processing by App Store operators

We do not collect data, and it is beyond our responsibility, when data, such as username, email address and individual device identifier are transferred to an app store (e.g. Google Play by Google, App Store by Apple) when downloading the respective application. We are unable to influence this data collection and further processing by the App Store as controller.

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 under www.facebook.com by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, and under www.facebook.de by Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, 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.

Instagram plugins

Instagram is operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA ("Instagram"). Find an overview over Instagram's plugins and their appearance here: http://blog.instagram.com/post/36222022872/introducing-instagram-badges; find information on data protection at Instagram here: https://help.instagram.com/155833707900388/.

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 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 on our social media platform (e.g. Facebook) communication tools to process your messages sent via this 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 better understand 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 180 days upon receipt of your message the latest.

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. 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.

Security

Our employees and the companies providing services on our behalf are obliged to confidentiality and to compliance with the applicable data protection laws.

We take all necessary technical and organizational measures to ensure an appropriate level of security and to protect your data that are administrated by us especially from the risks of unintended or unlawful destruction, manipulation, loss, change or unauthorized disclosure or unauthorized access. Our security measures are, pursuant to technological progress, constantly being improved.

User rights

To enforce your rights, please use the details provided in the Contact section. In doing so, please ensure that an unambiguous identification of your person is possible.

Right to information and access
You have the right to obtain confirmation from us about whether or not your personal data is being processed, and, if this is the case, access to your personal data.

Right to correction and deletion
You have the right to obtain the rectification of inaccurate personal data. 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).

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

Data portability

As far as statutory requirements are fulfilled you have the right to demand for 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.

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.

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:
Königstrasse 10a
70173 Stuttgart

Postal address:
P.O. Box 10 29 32
70025 Stuttgart, GERMANY
Phone: 0711/615541-0
Fax: 0711/615541-15
Email: poststelle@lfdi.bwl.de

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, notice 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 and to notify data protection incidents please use the following link: https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=18rbds19&language=eng

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

mailto: DPO@bosch.com
Effective date: 2020.05.12

[status: 11.05.2020]