Data protection policy

Bosch.IO GmbH

Data Protection Notice

Data Protection Notice

Bosch.IO GmbH (hereinafter “Bosch.IO” 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.

1. 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 gath-ered during your usage 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

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

Our contact details are as follows:

Bosch.IO GmbH

Ullsteinstraße 128

12109 Berlin

GERMANY

Email: privacy@bosch.io

Telephone: +49 (0)30 726112-0

3. Collection, processing and usage of personal data

3.1 Processed categories of data

The following categories of data are processed:

• Communication data (e.g. telephone number, name, IP address, postal address, email address)

• Contract data (e.g. active subscriptions)

• Contract billing and payment data

• Customer history (e.g. your support requests)

• Location data (e.g. your current GPS location)

• Telephone numbers of Help Connect contacts you shared with us

• Special categories of data: voluntary entries in your emergency pass

• Recordings of your calls (in case of emergency calls)

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, con-tract 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 follow-ing processing purposes:

• Provision of these Online Offers and fulfillment of contractual obligations (including registration) under our contractual terms including invoicing. Invoicing may include the sale of claims.

Legal basis: Fulfillment of contractual obligation, therefore the following conditions apply (link to GTC), 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.

• Safeguarding and defending our rights.

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

• Self-promotion as well as market research and reach analysis done within the scope stat-utorily permitted.

Legal basis: Legitimate interest on our part in direct marketing if in accordance with data protection and competition law.

• Transfer of emergency pass data in case of a triggered emergency to service providers and third parties (e.g. rescue workers) in order to ensure optimal aid.

Legal basis: consent.

• Registration to the online offers to use the services

Legal basis: Legitimate interest on our part on provision of the services and for protection of legitimate interests of third parties as well for fulfillment of contractual obligations as long as relevant for the offered services.

4. Registration

If you wish to use or get access to benefits requiring to enter into the fulfillment of a contract, we re-quest 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 volun-tary basis, if applicable. Mandatory information is marked with an *.

4.1 Registration via the central Bosch ID

You may register for our online offers exclusively using the central Bosch ID. The centralized Bosch ID was devised by Bosch.IO GmbH for the Bosch Group in order to allow for the joint users to ben-efit from offers of different group companies using centralized application data and increase data safety.

Bosch.IO is responsible for the provision of this single sign-on service.

If you want to apply for a centralized Bosch ID, the General Terms of Use for the Registration and Use of a centralized Bosch ID and the Data Protection Notice of Bosch.IO shall apply.

After successful registration you may utilize the registration data used for the centralized Bosch ID also for registering for this online offer. To this end, we shall provide an BIO registration template for the centralized Bosch ID. Bosch.IO then shall confirm your authorization and provide us with the master data required for using our offers (e.g. surname, first name, email address, telephone numbers, mail address). Your password shall not be communicated to us.

Concerning further data transfers within the Bosch Group associated with the centralized Bosch ID, please refer to the Data Protection Notice. You may cancel your user agreement concerning the centralized Bosch ID at any time by unregistering. To this end, please click on the following link: https://myaccount.bosch.com/BeaPUssWeb/unregistration.

4.2 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 at-tack attempts) for short amount of time 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”).

5. Children

This Online Offer is not meant for children under 16 years of age.

6. Special data categories

This Online Offer processes special data about your person (health data of your emergency pass) only with your explicit consent. You can withdraw your consent at any time for future emergencies.

7. 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.

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.

7.1 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 dili-gent handling of and protection of the data that they store. All service providers are obliged to main-tain confidentiality and to comply with the statutory provisions. Service providers may also be other Bosch group companies.

7.2 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 in-stitution charged with the payment or to payment service providers commissioned by us. Some-times, 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.

7.3 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.

8. 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).

9. Notifications in the app

We use push notifications for Google Firebase Cloud Messaging (Android) and Apple Push Notifications (iOS) services. Google or Apple serve as transmitters only.

Providers:

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

• Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA

10. 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.

10.1 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.

10.2 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.

10.3 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:

10.4 Marketing cookies and tracking cookies

By using marketing cookies and tracking mechanisms we and our partners are able to show you of-ferings 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 ac-cessed 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 ex-pired, we and the relevant conversion partner can recognize that a certain user clicked on the adver-tisement 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 con-version statistics and recording the total number of users who clicked on the respective advertise-ment 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. Face-book, 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 Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Function: Analysis of user behavior (page retrievals, number of visitors and visits, downloads), UX testing

10.5 Data processing by App Store operators

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

11. 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 secu-rity 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.

12. Usage of our mobile application

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.

13. 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 net-works’ 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.

Social Plugins with two-click solution

By using the so-called two-click solution we protect your visit to our web pages from being logged and processed by social network providers by default. When using a page of our internet presence, which contains such plugins, these are initially deactivated. Only when you click on the respective button, the plugins are activated.

Twitter plugins

Twitter is operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA ("Twit-ter"). 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.

14. 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.

15. 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 ad-dress 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.

16. 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 secu-rity 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.

17. 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.

17.1 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.

17.2 Right to correction and deletion

You have the right to obtain the rectification of inaccurate personal data. As far as statutory re-quirements 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 re-stricted (see the following).

17.3 Restriction of processing

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

17.4 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 techni-cally feasible – that we transfer those data to a third party.

17.5 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 be-tween your objection and the usage of your data within the scope of a campaign which is already running.

17.6 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.

17.7 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 re-mains unchanged.

18. Right to lodge complaint with supervisory authority

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

Berliner Beauftragte für Datenschutz und Informationsfreiheit

Friedrichstr. 219

Visitor entrance: Puttkamerstr. 16 – 18 (5th floor)

10969 Berlin

GERMANY

Phone: +49 (30) 13889-0

Fax: +49 (30) 2155050

Email: mailbox@datenschutz-berlin.de

19. 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 da-ta protection notice, as this is subject to changes.

20. 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/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

Email: DPO@bosch.com

Effective date: 2020.06.25