Data Protection Notice
ETAS GmbH (hereinafter "ETAS“ or "We“ or "Us") welcome 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.
ETAS 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.
ETAS 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:
70469 Stuttgart, Germany
Phone: +49 711 3423-0
Fax: +49 711 3423-2106
Represented by the Management Board: Dr. Thomas Irawan, Mariella Minutolo, Götz Nigge
Chairman of the Supervisory Board: Dr. Walter Schirm
VAT ID No.: DE811679830
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 product interest)
- Client history
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 bases
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).
- Answering user requests within the scope of a contact / repair form (Legal basis: Fulfillment of contractual obligations or legitimate interest in the improvement of products / services).
- 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).
- Product or customer surveys by postal mail and/or via email (Legal basis: Legitimate interest in the improvement of products / services as long as this occurs in accordance with data protection and competition law).
- 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).
- Safeguarding and defending our rights (Legal basis: Legitimate interest on our part for safeguarding and defending our rights).
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, email address, user name) as well as further data on voluntary basis, if applicable. Mandatory information is marked with an *.
Data processed as joint controllers
ETAS GmbH having its registered office in Stuttgart (Germany), ETAS National Subsidiaries and a few Robert Bosch GmbH National Subsidiaries process personal data in jointly used IT systems.
The following personal data are processed as joint controllers:
- Personal data relating to contact persons and/or employees of customers (e.g. name, e-mail, telephone number);
- Information relating to employment and/or education and training of the Companies’ employees (e.g. degrees, professional qualification).
The Companies have regulated the data processing as joint controllers in a contract (Article 26 GDPR).
The Companies have contractually agreed that
- in German-speaking countries (Germany, Austria and Switzerland) ETAS GmbH will fulfil the rights described in the section "User Rights",
- in the other countries, the respective ETAS National Subsidiary or ETAS GmbH if there is no ETAS National Subsidiary in the relevant country, is entrusted with the fulfilment of the "User Rights",
- after conclusion of a contract, the Company concluding the contract is always entrusted with the fulfilment of the "User Rights" and the related task hereto.
Irrespective of the contractual division of responsibilities between the Companies, you may contact another Company to exercise your rights.
For joint services as part of the cooperation with KPMG
The cooperation partners KPMG AG and ETAS GmbH use forms to collect personal data collected in the course of surveys, webinars, and the like as jointly responsible parties within the meaning of Art. 26 GDPR. This means in particular that all data collected by ETAS in the context of the above-mentioned forms will also be passed on to KPMG. All rights of data subjects under Art. 15 et seq. GDPR may be asserted at any time against all cooperation partners and shall be exercised vis-à-vis the data subjects by the cooperation partner to whom the request is addressed.
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 30 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 “Processing purposes and legal bases”.
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”).
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, 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 (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 that either the data recipient provides an appropriate level of data protection (e. g. accepted on the basis of an adequacy decision of the EU Commission for the respective country or the agreement of so-called EU standard contractual clauses of the EU with the recipient) 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).
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.
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.
We need statistical information about the usage of our newsletter to design them to be more user-friendly, to perform range measurements, and market research.
For this purpose, we use analysis tools described in this section.
The usage profiles created by these tools using analysis cookies or by evaluating log files collect information about the usage of our newsletter. Data about opened newsletters and visited links can be stored and connected to a subscriber’s profile.
The tools sellers process data only as processors subject to our directives and not for their own purposes. In the following, please find information on each tool seller.
Evalanche is provided by SC Networks, Enzianstr. 2, 82319 Starnberg, Germany.
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.
By using the so-called two click solution (provided by Heise Medien GmbH & Co. KG) 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.
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 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.
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.
Our Online Offers use the BoschTube video platform which is operated by Robert Bosch GmbH, Robert-Bosch-Platz 1, 70839 Gerlingen-Schillerhöhe („BoschTube“). BoschTube 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 BoschTube player, this creates a connection to BoschTube so that the video or audio file can be transmitted and played back. In doing so, data is transferred to BoschTube as a data controller. We are not responsible for the processing of such data by BoschTube.
Additional information on the scope and purpose of collected data, on further processing and usage of data by BoschTube, on your rights and the privacy options available to be chosen by you, can be found in BoschTube data protection notice (https://media.video.bosch.com/privacy-statement_en).
Monotype fonts (Neo® Sans) and external web fonts from Google Fonts (Noto Sans SC, Noto Sans JP, Nanum Gothic) are used in this online offer to display texts with different character sets. To this effect, a connection to the Monotype or Google Fonts servers is established and personal data such as IP address and browser data is sent to Monotype (Monotype Imaging Holdings Inc., 600 Unicorn Park Drive, Woburn, Massachusetts 01801 USA) or Google Fonts (Google Ireland Limited, incorporated and operating under the laws of Ireland, Gordon House, Barrow Street, Dublin 4, Ireland).
- Monotype uses the data exclusively to register the number of hits
- Google Fonts uses the data exclusively to display the fonts and analyze their popularity
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.
Our Online Offers may contain links to internet pages of third parties, in particular by 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.
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.
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.
As far as statutory requirements are fulfilled you may request to demand 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.
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 Baden-Württemberg
70173 Stuttgart, Germany
P. O. Box 10 29 32
Phone: +49 711 615541-0
Fax: +49 711 615541-15
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.
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
P. O. Box 30 02 20
Effective date: 25 August 2021