Data protection notice for the use of our “BoschGlobal” channel on Instagram

1. We respect 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. Data protection and information security are included in our corporate policy.

 

2. Controller

Robert Bosch GmbH is the controller responsible for the processing of your data. Exceptions are outlined in this data protection notice; in particular, Meta Platforms Ireland Limited („Meta“) is also responsible for the processing of your data to the extent described in no. 6 below.

 

3. Contact

If you would like to get in touch with us, you can reach us at the following address:

Robert Bosch GmbH
Robert-Bosch-Platz 1
70839 Gerlingen-Schillerhöhe
GERMANY

kontakt@bosch.de
+49 711 400 40990

To assert your rights or to report data protection incidents, please use the following link: https://www.bkms-system.net/bosch-dataprotection.

If you have 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

e-mail to: DPO@bosch.com

You can reach the Meta data protection officer via an electronic contact form provided by Meta. To do so, please use the following link: https://www.facebook.com/help/contact/540977946302970.

 

4. Processing purposes and legal basis

We, and service providers commissioned by us, process your personal data for the following purposes:

• Self-promotion and promotion by others as well as market research and reach analysis within scope permitted by law
  Legal basis: Predominantly, legitimate interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law.
• Communicating with you in the context of your visit to our social media channel and processing and answering your posts when you contact us via our Instagram channel
  Legal basis: Predominantly, legitimate interest on our part in communicating with you, in responding to your posts and, if applicable, for contract fullfilment.
• Optimization of the offer on our Instagram channel
  Legal basis: Predominantly, legitimate interest on our part in being able to adapt and improve the offer on our Instagram channel as closely as possible in line with the target group.
• Safeguarding and defending our rights
  Legal basis: Predominantly, legitimate interest on our part in the assertion and defense of our rights.
• Resolving service disruptions and for security reasons
  Legal basis: Fulfillment of our legal obligations within the scope of data security and predominantly, legitimate interest in resolving service disruptions as well as in the protection of our offers.

 

5. 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, to access 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 restriction of the processing of your data.

Data portability

As far as statutory requirements are fulfilled, you may request 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 this 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 that 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 that override your rights in accordance with the relevant laws.

Withdrawal of consent

If you have 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 that 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:

Lautenschlagerstrasse 20
70173 Stuttgart
GERMANY

Postal address:

Postfach 10 29 32
70025 Stuttgart
GERMANY

Tel.: +49 711 615541-0
Fax: +49 711 615541-15
E-mail: poststelle@lfdi.bwl.de

 

6. Instagram

For the offers on our channel “BoschGlobal” on Instagram, we utilize the technical platform and the services of Instagram. Our Instagram channel is an online presence within the Instagram platform, which is provided by Meta Platforms Ireland Limited.

6.1 Controllers

The controller responsible for the processing of your data on the Instagram platform is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter “Meta”). The data protection notice of Meta for its Instagram product applies in this case.

In addition, we are jointly responsible with Meta insofar as statistical data (so-called Insights Data) is processed on our Instagram channel. As part of this joint responsibility, your data will be handled on the basis of an agreement with Meta, the contents of which you can access via the following link:
https://www.facebook.com/legal/terms/dataprocessing
https://www.facebook.com/legal/terms/page_controller_addendum

6.2 Processing of personal data

6.2.1 Data processing by Meta

Meta processes your personal data when you open up our Instagram account or interact with one of our posts.

Which personal data is processed by Meta and what data protection rights you possess in relation to Metaare laid out in the Instagram data policy: https://help.instagram.com/519522125107875.

For us as the operator of our Instagram channel we can view only your public profile on Instagram. What information we can see depends on your profile settings.

Please note that Meta collects and processes certain information about your visit to our Instagram channel even if you do not have a Instagram user account or are not logged in to Instagram.

6.2.2 Data processing by us

6.2.2.1 Communicating with you

When you contact us via Instagram, we receive the following data from Meta:

• The message submitted
• Name
• Profile information
• Attachments
• Voice messages

We process this data for the purpose of processing your posts accordingly and answering them if appropriate. (for example, you can send us questions about our products via our Instagram channel so that we can answer them). We also use the data in aggregated and anonymized form to better understand the use of our Instagram channel. For this purpose, we can analyze which group of people (e.g., end customers, private individuals, employees) uses the channel from which country and in which language. Once the purpose of your contact has been achieved, but no later than 180 days after receipt of your message, your personal data will be deleted, unless legal reasons or overriding interest entitle or oblige us to a longer storage period.

We may forward the personal data you have provided to the legal entity within the Bosch Group responsible for the request or to a company associated with it (for example, in the event your query refers to a product that is distributed by another Bosch legal entity). The responsible legal entity may be located outside the European Economic Area (EEA). When this situation arises, we can transfer your personal data to recipients that are located outside the EEA in so-called third countries. In such cases, prior to the transfer we ensure that an appropriate level of data protection exists. 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. You can contact us for this purpose. Please find our contact details under no. 3.

The legal basis for this type of processing is our overriding legitimate interests (Article 6(1)(f) GDPR) and any existing contractual relationship (Article 6(1)(b) GDPR).

6.2.2.2 Instagram Insights

In addition, Meta provides us with so-called Page Insights data. These are anonymous statistics that help us evaluate the quality of our Instagram channel and our posts. These statistics are created based on usage data that Meta collects about your interactions with our Instagram channel. We have no access to this usage data.

The processing carried out here is based on our overriding legitimate interest as per Article 6(1)(f) GDPR, in particular regarding our ability to contact you in response to your queries or posts and our ability to recognize usage preferences (e.g. number of followers; number of times individual page sections are accessed; user statistics by age, geography, and language) and to adapt and improve the offers on our Instagram page so as to meet the needs and interests of target groups as accurately as possible.

 

7. Duration of storage, retention periods

We store your personal data on our systems, i.e. outside of Instagram, if and for as long as they are needed for the purposes for which they were collected or there are statutory retention periods that mandate their storage.

 

8. 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.

 

9. 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.

 

10. Obligation to provide personal data

You are neither contractually nor legally obliged to give your personal data to us. It is possible, however, that we cannot provide certain functions or provide them only to a limited extent if you do not furnish us with the requisite data. Insofar as this is the case when using our Instagram channel, you will receive a separate notification.

 

11. Children

This online offer is not meant for children under 16 years of age.

 

12. Change of 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.

 

Last revised: 25/02/2022