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: Fulfillment of contractual obligations. The following conditions apply: https://developer.bosch-iot-suite.com/legal/ (Portal Terms of Use, SaaS Terms and Conditions, SaaS Service Level Agreement, SaaS Data Processing Under Commission, Terms and Conditions for evaluating Gateway Software)
• Resolving service disruptions as well as for security reasons.
  Legal basis: Fulfillment of our legal obligations within the scope of data security, and justified 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 / justified interest on our part in direct marketing if in accordance with data protection and competition law.
• Registration for usage of services offered on our website.
  Legal basis: Justified interest on our part to execute the services and administration of justified interest of third parties and fulfillment of contractual obligations if relevant for the offered services.
• Safeguarding and defending our rights.
  Legal basis: Justified interest on our part for safeguarding and defending our rights.

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, contact details 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 up to 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.

Log files are also used for analysis purposes (without the IP address or without the complete IP address) see module “Advertisements and/or market re-search (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
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.

Service providers
We involve external service providers with tasks such as contract management, payment handling, and data. 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
When subscribing to one or more services of the Bosch IoT Suite, personal data (such as IP Address and E-Mail address) may be processed by other recipients outside the EEA according to the terms specified in our SaaS Terms and Conditions and Data Processing Under Commission Agreement.

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.

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).

Marketing cookies and tracking mechanisms
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.

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), 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 inter-face, 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

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.

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 of 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:

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Friedrichstr. 219
Visitors: Puttkamerstr. 16 – 18 (5. Etage)
10969 Berlin
Germany
Phone: +49 30 13889-0
Fax: + 49 30 2155050
Email: mailbox@datenschutz-berlin.de

State Commissioner for Data Protection and Freedom of Information
Address Königstrasse 10a, 70173 Stuttgart, Germany
Postal address:
P.O. Box 10 29 32
70025 Stuttgart
GERMANY
Phone +49 711/615541-0
FAX: +49 711/615541-15
Email: poststelle@lfdi.bwl.de

Effective date: 2020-08-06