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: Friedhelm Pickhard, Bernd Hergert, Christopher White
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), Escrypt GmbH having its registered office in Bochum (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) Escrypt 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.
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 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.
Twitter is operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA ("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.
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
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 November 2019
1. General provisions
2. Purposes of processing personal information and items of personal information to be processed
[Purposes of processing 1] Execution and performance of contract: Identification of the contracting party; performance of contract including supply of product and receipt of payment
[Items of personal information 1]Name, date of birth, address, mobile phone numbere-mail address, name of company, Matters concerning payment of prices; Account number at financial institutions such as banks
[Purposes of processing 2] Performance of legal and administrative obligation of the company: Performance of legal and administrative obligations imposed on the Company, including the followings: report and payment of all sorts of taxes including corporate income tax and value added tax; issuance and delivery of receipts, tax invoices
[Items of personal information 2] Name, date of birth, Resident Registration Number, address, home telephone number, mobile phone number, fax number, e-mail address, name of company, business type, title, purchase history
[Purposes of processing 3]Computerized management of contract terms, transaction status, descriptions of product supply and payment
[Items of personal information 3] Name, gender, address, home telephone number, mobile phone number, fax number, e-mail address, name of company, business type, title, purchase history
[Purposes of processing 4] Promotion of the Company’s products via sending mail (including e-mail), transmitting SMS, telephone, AEM (Automotive Electornics Magazine)
[Items of personal information 4] Name, address, mobile phone number, e-mail address, name of company
[Purposes of processing 5] Receipt of training application, issuance of the training completion certificates, management of education history and recommendation of education program
[Items of personal information 5] Name, mobile phone number, e-mail address, name of company, address for post delivery
[Purposes of processing 6]Customer relation management (CRM); provision of response to the inquiries of discontent customers; provision of after-sales service
[Items of personal information 6] Name, address, mobile phone number, e-mail address, purchase history
[Purposes of processing 7] Handling and responding the inquiries received through ETKR representative contact channels
[Items of personal information 7] Name, company, department, phone number, email address
[Purposes of processing 8] Processing the request for customers’ return, exchange or repair
[Items of personal information 8] Name, company, department, the delivery address (company address), mobile phone number, email address
[Purposes of processing 9] Provision of software license related service (e.g., installation and re-hosting of software)
[Items of personal information 9] Name, name of company and department, mobile phone number, email address, PC Mac address
[Purposes of processing 10] Implementation of due diligence in preparation for the possible transfer, merger and division of Company's business in whole or in part (incl. the transfer of the corporate group which the Company is affiliated to)
[Items of personal information 10] Name, address, home telephone number, mobile phone number, fax number, e-mail address, name of company, business type, title, bank account number
3. Period of processing and destruction of personal information
The Company will immediately destroy personal information when the purposes of processing such personal information are attained and the personal information becomes unnecessary.
When the Company destroys personal information, it will implement measures to ensure that the information is not restored or regenerated. If the personal information to be destroyed by the company is in the electronic file type, it shall be permanently deleted in a way that cannot be restored, and other records, printed materials, written documents, and other recording media shall be shredded or incinerated. However, when the Company has obtained prior approval from the Data subject or when the Company must retain the personal information of the Data subject pursuant to other laws and regulations, the Company will store and manage such personal information or personal information file separately from other personal information.
4. Delegation of Personal Information Processing Services
The Company delegates personal information processing services as follows:
- Provider of Delegated Services : Smart & company
- Contents of Delegated Services : Sending AEM (Automotive Electronics Magazine) to the subscribers, management of the list of subscribers and the delivery address
- Provider of Delegated Services : Robert Bosch Korea Limited Company
- Contents of Delegated Services : Withholding the other income tax and issuing tax invoice for the external partners who are individual business owners
- Provider of Delegated Services : ETAS GmbH
- Contents of Delegated Services : Operation and management of the website of ETAS Korea and the database
5. Limits on processing resident registration numbers
The Company processes resident registration numbers only in following cases:
(1) in case processing resident registration numbers is required or allowed by legal provisions, or
(2) in case there is clear evidence of some urgent need to handle resident registration number, for the sake of the safety or property of the Data subject or of a third party, or
(3) in case there exist special provisions under any other laws or ordinance of the Ministry of the Interior and Safety.
6. Matters concerning the rights and obligations of principal and method of exercise thereof
6.1 Inspection of personal information
(1) The Data subject may request inspection of his/her own personal information processed by the Company.
(2) Within ten (10) days from the receipt of the Data subject’s request for inspection of personal information, the Company will allow the Data subject to inspect his/her personal information. If the personal information cannot be inspected within the above period due to a justifiable reason, the Company may delay inspection after notifying the Data subject of the reason for the delay. When the reason for the delay ceases to exist, the Company will immediately allow inspection of the persona information.
(3) In any of the following cases, the Company may restrict or refuse inspection of personal information after notifying the Data subject of the reason for such refusal or restriction:
1) If inspection is prohibited or restricted by law; or
2) If such an act is likely to inflict damages upon another person’s life or body or Iunfairly infringe upon another person’s property or other rights.
6.2 Correction and deletion of personal information
(1) The Data subject who has inspected his/her personal information may request that the Company correct or delete his/her personal information.
(2) the Company will deliver a report on the results of correction or deletion notifying the Data subject of (i) the fact that the Company has taken necessary measures such as correction or deletion of such information as requested by the Data subject or (ii) the fact that the Company has not complied with the Data subject’s request for deletion because the personal information is specified as items subject to collection under other law. However, if specific procedures for correction or deletion of personal information are stipulated by other laws and regulations, the Company will comply with such laws and regulations.
(3) When the Company deletes personal information in accordance with the Data subject’s request, it will implement measures to ensure that the information is not restored or regenerated.
6.3 Suspension of processing of personal information
(1) The Data subject may request that the Company suspend the processing of his/her own personal information.
(2) In any of the following cases, the Company may refuse the Data subject’s request for suspension of processing of personal information:
1) If there is a special provision in law or if denying the request is necessary to comply with legal obligations;
2) If such an act is likely to inflict damages upon another person’s life or body or unfairly infringe upon another person’s property and other rights; or
3) If performing the contract becomes difficult (i.e. unable to provide the agreed services to the Data subject) unless the personal information is processed, and the Data subject has not expressed a clear intention to terminate such contract.
(3) With regard to the personal information of which processing has been suspended in accordance with the request of the Data subject, the Company will immediately take necessary measures such as destruction of the personal information.
6.4 Methods and procedures of exercising rights
Request for inspection, correction or deletion of personal information or suspension of processing of personal information can be made by the Data subject, his/her legal representative or delegatee. However, in the event that the Data subject is represented by his/her legal representative or delegatee, a power of attorney of the Data subject as prescribed by the ordinance of the Ministry of the Interior and Safety should be submitted to the Company. Data subject shall not infringe on the personal information and privacy of employees or other persons by violation of the Personal Information Protection Act and relate laws.
7. Measures to ensure safety of personal information
The Company takes the following technical, managerial and physical actions necessary for ensuring safety in order to prevent the loss, theft, unlawful leakage, alteration or damage of personal information.
(1) Establishment and implementation of an internal management plan for the safe processing of personal information
(2) Measures to control access to personal information and to limit access rights
(3) Application of encryption technology or equivalent measures that enable safe storage and transmission of personal information
(4) Maintenance of login history to take measures against the infringement incident of personal information and measures to prevent forgery or alteration
(5) Installation and upgrade of security programs for personal information
(6) Physical measures including preparation of storage facilities and installation of locking system for the safe storage of personal information
8. Automatic collection of personal information on websites
- Purposes: It is used to provide optimized information such as functional operation of the website function, improvement of usability, performance and design, constant implementation of the privacy setting, anonymizing of user data
- Rights to refuse: You may reject the storage of cookies by changing the privacy setting in the webbrowser. Tool > Internet Options > Privacy
9. Collection of opinions and handling complaints
The Data subject may file any complaint regarding protection of personal information to the CPO or the department in charge. The Company will provide a prompt and sufficient response with regard to the complaint of the Data subject.
Chief Privacy Officer (CPO)
Name:Youngbum Kim l Tel no: 031-270-4132 / Department: C/DSO-KR / E-mail: Privacy@kr.bosch.co.kr
Data Security Partners (DSP)
Name: Minhee Kim / Tel no: 031-260-9946 / Department: C/DSO-KR / E-mail: Privacy@kr.bosch.co.kr
You may contact the following government agency in case you need consultation about infringement of personal information.
Privacy Infringement Report Center
Site: privacy.kisa.or.kr / Tel no: 118
Cyber Crime Investigation Unit, Supreme Prosecutor’s Office
Site: www.spo.go.kr / Tel no:1301
Cyber Terror Response Center, National Police agency
Site: police.go.kr / Tel no:182
- Issue 1.0 : [2012.02.24] The privacy guideline of Bosch Korea has been established and published. (Editor : RBKR/DSO)
- Issue 2.0 : [2013.08.12] The legal name of Bosch Korea has been changed. Matters regarding delegation of processing PI have been changed. The organization name of the relevant government ministry has been changed. (Editor : RBKR/DSO)
- Issue 3.0 : [2014.06.26] The items of processed PI have been changed. Matters regarding transfer of PI to third parties have been changed. (Editor : RBKR/DSO)
- Issue 4.0 : [2015.11.25] Addition of details on transfer of Company’s Business. Change of organization name of relevant government ministry. Change of Chief Privacy officer in Bosch Korea. (Editor : RBKR/DSO)
- Issue 4.1 : [2017.07.31] Deletion of the matters regarding transfer of PI to third parties. Partial change of matters regarding deletion of personal information processing services. (AEM sending service provider) Deletion of unnecessary items. (Editor : RBKR/DSO)
- Issue 4.2 : [2018.11.01] Addition of the article regarding the automatic collection of personal information on websites. Addition of the purpose and processed items. Addition of the parties to whom the personal information processing is outsourced. (Editor : RBKR/DSO)
- Issue 4.3 : [2019.05.01] Change of the Chief Privacy Officer (Editor : RBKR/DSO)
- Issue 4.4: [2020.04.06] Update of the Chief Privacy Officer and Government Agency (C/DSO-KR)