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Privacy Policy

This Privacy Policy is effective from November 2018.
You can find earlier versions in our archive for legal notices and contract documents.

Robert Bosch GmbH “eBike Connect” Data protection notice

Robert Bosch GmbH, (Robert-Bosch-Platz 1, 70839 Gerlingen-Schillerhöhe, Germany) (“Bosch”) thanks you for visiting our website at www.ebike-connect.com and our “Bosch eBike Connect” app, and for your interest in our company and products.

Bosch respects your privacy

Bosch considers seriously the protection of your privacy when processing personal data.
Data protection and information security are an integral part of Bosch’s business policies and processes.

Controller

Robert Bosch GmbH Unit eBike is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details:

Corporate Information

Contact

Collection and processing of personal data

1. Personal data is collected and processed by Bosch exclusively for the purposes of:
- the creation of a user account,
- registering your eBike and/or
- your Bosch eBike on-board computer under this user account
and
- using the functions/services of the portal at www.ebike-connect.com
- using the “Bosch eBike Connect” app and/or
- using further selectable functions (premium services)
as described below.
2. The purpose of collecting and processing this data can be summarised as displaying, as per the needs of the user, information for the user on their eBike and its related components (drive unit, battery, Bosch on-board computer) as well as on trips and activities with the eBike.

Data categories and earmarking

1. User-related master data

The following personal data is collected, saved and processed by Bosch if you open a user account on the portal at www.ebike-connect.com or through the “Bosch eBike Connect” app. When opening the user account, Bosch will first always request the following personal data (“user-related inventory data”):
Mandatory information for opening the account:
- First name and surname,
- E-mail address,
- Password (saved in encoded form)
If registration is done through a Facebook account, this data (including profile pictures) will be imported directly.
1.1. Bosch requires this personal data to manage and process customers’ user accounts as well as to be able to reach users, if necessary.
The user-related inventory data is equally necessary in order to be able to comply with the User Agreement and to comply with possible further user agreements of additional services, in particular chargeable services.
Bosch collects user inventory data in contact forms in order to respond to queries.
1.2. Your personal inventory data is stored by Bosch for as long as necessary for the purpose of implementation and, if necessary, for the fulfilment of additional mandatory storage obligations. Bosch will hereafter delete the personal data from the system.

2. Device data

The following user data is collected, saved, and processed by Bosch if you register your eBike and/or your Bosch eBike on-board computer on your user account (“Device data”). Through linking to your user account, this data is also personal data.
This device data is collected and processed by Bosch to give you an overview of the assigned components for every eBike you register and to provide you with detailed information about your eBike and its equipment if service is required via the Bosch Hotline or your dealer.
This data is:
- Manufacturer and model of the eBike including bike parameters,
- Name, serial number, TTNR type part number, date of manufacture, hard and software version number of following components:
 - Drive unit (motor),
 - Battery,
 - Bosch eBike on-board computer,
- Error codes,
- Travelled km/miles,
- Battery charge status,
- Torque value achieved by rider,
- Pedal frequency achieved by rider,
- Total operating time of drive unit,
- Total mileage,
- Total operating time of system,
- Service intervals (performed and upcoming service intervals),
- Driven speeds,
- Time stamps,
- Position data (GPS data),
- Planned routes.

3. Service-related user data

In the context of the services offered on the Bosch eBike on-board computer with the “Bosch eBike Connect” app and/or the portal www.ebike-connect.com, the user can save, view individual functions, trainings, and route in their profile, import, and arrange their user-specific master data, their device data, and the respective service-specific usage data as well as their IP address as needed.
For services that require payment, Bosch will also use the user’s date of birth from the user-specific master data listed above in order to make sure the user is at least 18 years of age.
3.1. Service - Navigation
With the help of your Bosch eBike on-board computer, you can plan your routes and proceed on them. You can use the navigation and card functions in the process, which save your planned tours and lets you see them on your user account. For this purpose, Bosch collects, saves and processes the following data as personal data:
- Position data (GPS data),
- Planned km/miles,
- Total mileage,
- Speeds and
- Planned routes.
With the registration of your Bosch eBike on-board computer to your user account, Bosch collects, saves and processes the aforementioned service-related usage data for the aforementioned purposes.
In the navigation service you have the option of storing addresses, e. g. home or work addresses. This information is voluntary.
The stored addresses are used for the “Take-me-to” features in the app or on-board computer.
3.2. Service - Fitness
3.2.1. The following personal data is collected, saved, and processed by Bosch so that you can use the Bosch eBike on-board computer’s fitness service. This personal data is collected and processed by Bosch to calculate your riding performance and your current calorie consumption based on pedal frequency and force, and to determine your individual training level.
The Bosch eBike on-board computer is connected by Bluetooth to separate heart rate belts. With the collected data on your heart rate, Bosch calculates your optimal intensity level.
All the service-related usage data collected in this service is processed by Bosch further to give you the possibility to evaluate and analyse your fitness progress in detail, and in order to give you recommendations regarding intensity level for other fitness activities and to calculate the activity level.
- Speed,
- Wattage,
- Distance,
- Pedal frequency,
- Torque value and
- The fitness status and development (training effect) calculated by Bosch.
With the registration of your Bosch eBike on-board computer to your user account, Bosch collects, saves and processes the aforementioned service-related usage data for the aforementioned purposes.
3.2.2. Bosch asks that you separately declare your consent to the collection, saving, and processing of the following user data obtained through the Fitness Service
- Heart rate,
- Calories,
- Height,
- Body weight,
- Fitness level and
- Gender.
Your separate consent relating to these categories of data is required by law because it is health-related data. This consent is voluntary, but it is required for you to be able to use these functions of the Service – Fitness.
3.2.3. In the app and on the e-bike on-board computer you have the possibility to display health data of third-party providers (for example, heart rate monitor, chest strap). For data transmission, the different devices must be connected via Bluetooth.
3.3. Service Activity
You can track all your activities with the eBike using the Bosch eBike on-board computer. For this, the service activity provides overall statistics and statistics related to month and/or year about the distances covered, times ridden, calories burnt calculated from this data, upwards or downwards altitude difference and identifies the best respective month. For this purpose, Bosch additionally gets, saves and processes data related to the device and data from the Navigation Service and the Fitness Service. Data directly related to people or data related to people by linking with your user account is:
- Air pressure
- Topographic height
- Pedalling rates
- Energy utilisation
- Temperature
- System used (DU, BUI)
- Support information
- Service sharing with applications of third parties
- km/miles ridden
- Routes ridden
- Time stamp.

Bosch eBike on-board computer premium services

1. Premium service - individual riding modes

1.1. If you purchase the premium service - individual riding modes, you have the option to modify the motor characteristics of your eBike’s drive unit and access these as well as the associated properties of the drive unit via the “Bosch eBike Connect” app or via the portal on www.ebike-connect.com.
1.2. Once the user agreement has been concluded, Bosch stores and processes the drive units you have registered in your user account in the past, as well as the motor characteristics currently used, in order to give you the opportunity to identify the specific optimised motor curve for you at any time.

2. Premium service - topographic remaining range

If you purchase the premium service - topographic remaining range, Bosch saves and processes the topographic information (elevation gain), your current riding behaviour (support mode) and the battery status of the eBike power pack.
With this data, you can display on your Bosch eBike board computer map how far you will likely be able to travel from your current point. The display always changes if the position or assistance level is changed.

Use of external services

In the eBike Connect Portal and in the app we use various third-party features to enable you to navigate/use the portal intuitively.

1. Features used in Portal

1.1. Google Fonts
This website uses external fonts from Google Fonts.
Google Fonts is a service of Google Inc. (“Google”). These web fonts are integrated by a server call, usually a Google server in the U.S. This transfers to the server which of our Internet pages you have visited. The IP address of the browser on the visitor’s device is also stored by Google. Further information can be found in Google’s privacy policy, which you can access here:
https://fonts.google.com/#AboutPlace:about
https://policies.google.com/privacy
1.2. Explore – Outdooractive
The integration of Outdooractive in the “Explore” area offers the registered user the possibility to search, view and save tour suggestions for selected regions.
When using the Outdooractive tour search, the following data is transferred from the user’s browser to Outdooractive:
- The name of the accessed website
- Referrer-URL
- Date and time of the server request
- Transferred data volume
- Browser type/browser version
- Operating system used by the user
- IP address of the user
- Notification of successful retrieval
Further information can be found in Outdooractive’s data protection declaration https://www.outdooractive.com/de/datenschutz.html

2. Services used in the portal and in the app

2.1. Google Maps API
Within the app and portal, Bosch uses the Google Maps API to display geographical information visually. When using Google Maps, Google also collects, processes and uses data about the use of the Maps functions by portal users. For more information about Google’s data processing, please visit the Google privacy policy from it.
2.2. Skobbler
Within the eBike connect app and the eBike connect portal, map material from Telenav GmbH is used for navigation calculation.
Further information can be found here:
https://www.skobbler.de/
The data protection information of Telenav GmbH can be found under the following link: https://www.skobbler.de/legal#privacy

Use of data in anonymised form

Bosch saves and uses data in an anonymised form particularly to develop applications - or to have Bosch’s development partners make them - as well as to improve applications and to adapt them to user needs. Bosch reserves the right to analyse the data anonymously and publish it in the form of statistics on the portal or in the app as well as to use it in other ways.

Cancellation and termination of user relationship

1. You can revoke your consent to the above-described collection and processing of health data by Bosch at any time, either wholly or in part. Cancellation can be done by e-mail to contact@bosch-ebike.com, or by post to Robert Bosch GmbH (AE-EB), Gerhard-Kindler-Straße 3, 72770 Reutlingen. The cancellation will mean that you can no longer use the corresponding services that require this data.
2. The user has the option of cancelling their user relationship with Bosch without giving reasons at any time and personally deleting their user account on the portal at www.eBike-connect.com or on the “Bosch eBike Connect” app.
3. Personal data that is no longer needed is quickly deleted by Bosch as soon as the retention period is over. Excluded from the deletion are the personal data that Bosch requires to process outstanding tasks or to enforce our rights, as well as data that Bosch must keep in accordance with legal requirements.

Use of Cookies

1. Bosch uses cookies and active components (e.g. JavaScript) to monitor user preferences and to accordingly organise the websites optimally.
Cookies are small data saved on your computer when you visit our website. You can delete cookies from your devices at any time. This can, however, lead to your not being able to access individual functions. To delete cookies, you should check the help section of your browser.
2. The use of cookies as part of the registration process, as well as the further development of Bosch services, enables Bosch to recognise the user when, as a customer, they return to use the "Bosch eBike Connect" app or the portal www.ebike-connect.com after a previous session. Furthermore, Bosch can optimise their services according to users’ individual needs through cookies.
3. Bosch also uses cookies to measure the statistical frequency of visits to the various pages of the “Bosch eBike Connect” app and www.ebike-connect.com as well as the general navigation and, if necessary, to create pseudonymous profiles (see above). Each time you open www.ebike-connect.com, you are informed about the use of cookies. You can also set your browser in such a way that you exclude the acceptance of cookies for certain cases or generally and activate the automatic deletion of cookies when closing the browser.

Use of web analysis tools

Bosch uses various analysis tools to continuously improve our website and app. Not all tools are used on all platforms.
You can object to the use of your data for these purposes in various ways, depending on the tool.

1. Analysis tools in the app

1.1. Google Firebase
The app uses Google Firebase, a service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). The data collected in connection with the use of the aforementioned Firebase functions is aggregated and cannot be traced back by Bosch to an individual user.
More information about Google Firebase can be found here:
https://firebase.google.com/
You can find Google’s privacy policy here:
https://policies.google.com/privacy
The following functionalities of Google Firebase are used:
1.1.1. Cloud Messaging
Firebase’s cloud messaging service is used for communication between the app and the backend.
Push messages are sent from the back end to the app to control synchronisation between events in the app and the portal.
1.1.2. Crashlytics
Bosch uses the Crashlytics function to improve our app and to analyse errors. This allows us to analyse app crashes and provide targeted bugfixes.
1.1.3. Analytics
In order to continuously improve our app and adapt it to the needs of our users, we use Firebase Analytics.

2. Analysis tools on the website

2.1. Google Analytics
Bosch uses Google Analytics, a web analysis service of Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) on the web pages of the eBike Connect portal www.ebike-connect.com. Google Analytics uses so-called “cookies”, text files which are stored on your computer and which enable an analysis of your use of the website.
The information about your use of the website and/or the App generated by the cookie is generally transferred to a Google server in the USA and stored there. In case IP anonymity is activated on this website, your Google IP address will however be abbreviated in advance within the member countries of the European Union or other countries which are party to the Agreement on the European Economic Area. The complete IP address is transferred to a Google server in the USA and stored there only in exceptional cases. Google will use this information when ordered by this website's operator to do so in order to evaluate your use of the website, compile reports on the website activities and to provide further services associated with website and Internet use to the website operator.
The IP address notified by your browser as part of Google Analytics is not merged with other Google data. You can prevent storage of cookies by a corresponding setting of your browser; we however point out to the fact that you will not be able to use all functions of this website fully in this case, if you need to.
You can furthermore prevent the compilation of the data created by the cookie and related to the use of the website (incl. your IP address) to Google, as well as processing of this data by Google by downloading and installing the browser plugin available in the following link
[http://tools.google.com/dlpage/gaoptout?hl=de]
You will find other information about Google analysis services here:
https://www.google.com/policies/privacy/partners/

Social Sign In (login via social networks)

We offer you the possibility to sign into our Online Offers by so-called social sign ins such as Facebook Connect and Twitter.
To register, you are forwarded to the respective social network's page where you can sign on with your data. This means that your account with the respective net-work is linked to our service. In doing so, information from your public profile, your email address and the identification tags of your network friends, as well as, if applicable, further data is transmitted to us through the social network.
In turn, the social network used for the registration receives your login status, browser information and your IP address. The social network's provider or its server may be located outside the EU or the EEA (e.g. in the United States).
If you do not wish data transfer taking place between us and the social network services, log in via our own log in services instead of social log in services.

Use of Social Plugins as part of Social Media

1. Facebook
The “Bosch eBike Connect“-App and the portal www.ebike-connect.com uses Social Plugins (“Plugins”) of the social network facebook.com, which is operated by Facebook Inc., 1 Hacher Way, Menlo Park, CA, 94025, USA (“Facebook”). The Plugins are marked with a Facebook Logo or the addition “Facebook Social Plugin”.
If you call the Bosch eBike Connect App or the portal www.ebike-connect.com having such Plugins, these buttons are first disabled once. Only when you enable them, and thus declare that you consent to the transmission of data of the social network, are these buttons enables and establish the connection. If you are logged into the social network Facebook, it can assign the visit to your account in it. If you touch the respective button, the corresponding information is directly notified to Facebook and stored there.
Facebook gives statistical analysis data about the use of the portal www.ebike-connect.com and the App provided to us by Facebook, we can thus measure the effectiveness of our content (e.g., calls and clicks).
If you want to share activities on Facebook, the portal www.ebike-connect.com generates public a URL linked to your UserID with the following data for this activity:
- Times
- Distances
- Calories
- Heart frequency data
- Position data
- Altitude difference
- Speeds
- Pedalling rates
Independent of which setting you have chosen in Facebook, everyone using this URL can view your activity.
Purpose and scope of data extraction, further processing and use of data by Facebook and your relevant rights and setting options for protecting your private sphere, please take the data protection instructions from Facebook https://www.facebook.com/policy.php.
2. Strava
The portal www.ebike-connect.com uses Social Plugins (“Plugins”) of Strava, which is operated by Strava Inc., 500 3rd Street #110, San Francisco, CA 94107, USA.
If you wish to export an activity to Strava, choose “export to Strava” in options within your activity. The following data is then notified:
- Times
- Distances
- Calories
- Heart frequency data
- Position data
- Altitude difference
- Speeds
- Pedalling rates
If you export an activity for the first time, you come to a one-time authorisation dialogue in which you grant the permission to upload your data to Strava.
Purpose and scope of data extraction, revocation of the permission to upload your data, further processing and use of data by Strava and your relevant rights and setting options for protecting your private sphere, please take the data protection instructions from Strava. https://www.strava.com/legal/privacy

Using external links

Links to third party websites for vendors not associated with Bosch can be found at www.ebike-connect.com or in the “Bosch eBike Connect” app. After you click the link, Bosch is no longer responsible for the collection, saving, or processing of any data that is transmitted to a third party by clicking the link (e.g. IP address or the URL at which the link is located), since of course Bosch has no control over the conduct of third parties. For this reason, Bosch cannot accept any responsibility for the processing of this type of personal data by third parties.

YouTube

This online offering uses the YouTube video platform provided by YouTube, LLC, 901 Cherry Ave. San Bruno, CA 94066, USA (“YouTube”). YouTube is a platform that enables the playback of audio and video files.
If you call up a corresponding page of our offer, the embedded
YouTube player connects to YouTube to transfer and play the video or audio file. Data is also transferred to YouTube as the person responsible. We are not responsible for the processing of this data by YouTube.
For more information on the scope and purpose of the data collected, on YouTube’s further processing and use of the data, on your rights and the data protection options you can select, please see YouTube’s data protection notice.

Sharing personal data with third parties

1. As the user, you can always decide which personal data to share with third parties by issuing separate declarations stating the recipient. Stating the personal data that can be shared with third parties is done on a voluntary basis. In this event, Bosch will provide the voluntarily shared data via the portal on the provided spaces to the authorised users within the context of the respective service.
So for example, within the context of providing a service, we offer to share the data that we automatically collect through this service with other platforms (e.g., your fitness data collected through eBike Connect can be shared with general fitness platforms). By clicking this function and entering your login data details on this fitness platform, you are consenting to and instructing Bosch to automatically share the personal user data collected through your eBike Connect in the context of the relevant service with other platforms specified by you.
2. In the context of tracking, anonymised position data (from GPS) will be transmitted to Telenav GmbH so that maps can be expanded and improved.
3. With the exception of the above policy, personal user data can only be shared by us with third parties if and when (1) Bosch is legally obligated to do so, or (2) it becomes necessary in order to execute Bosch’s rights and requirements.
4. In the event that the user’s personal data is shared for reasons not specified here, the user will be asked for their consent on an individual basis: If the user does not consent, we will not share their personal data with third parties.

Deleting your personal data

1. Personal data will be deleted when it is no longer needed to fulfil the purpose of saving it, when consent is rescinded, or if saving of data is impermissible for other legal reasons.
2. Data that is required for the purposes of billing and accounting or that is subject to the duty to preserve records remain unaffected during the period for the legal duty to preserve records or beyond that, if this is required for executing Bosch’s rights and requirements.

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 dis-closure or unauthorized access. Our security measures are, pursuant to technological progress, constantly being improved.

User rights

Your user rights are individually described in this section. Among other rights, you have the right to information, to correction and a right of objection to direct marketing and to withdrawal your consent.

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.

2. Right to correction and deletion

You have the right to obtain the rectification of inaccurate personal data concerning yourself without undue delay from us. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
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).

3. Restriction of processing

You have the right to demand for – as far as statutory requirements are fulfilled – restriction of the processing of your data.

4. Objection to data processing

You have the right to object to data processing by us at any time. We will no longer process the personal data unless we demonstrate compliance with legal requirements to provide provable reasons for the further processing which are beyond your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

5. Objection to data processing based on the legal basis of “justified 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 a justified interest. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements which override your rights.

6. Withdrawal of consent

In case you consented to the processing of your data, you have the right to revoke this consent with immediate effect. The legality of data processing prior to your revocation remains unchanged.

7. Data portability

You are entitled 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.

8. 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.

Changes to this data protection statement

We reserve the right to change our security and data protection measures if this is required due to technical development. 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 change.

Contact

If you would like to contact us, you can reach us at the address given in the “Controller” section.
Use the following link to assert your rights and report data protection incidents:
https://www.bkms-system.net/bosch-datenschutz
For suggestions and complaints regarding the processing of your personal data, we recommend that you contact our data protection officer:
Data Protection Officer
Department for Information Security and Data Protection Bosch Group (C/ISP)
Postfach 30 02 20
70173 Stuttgart
GERMANY

or

E-mail

Status: November 2018