Data protection policy
Data protection policy of the Bosch Healthcare Solutions GmbH
Data protection Notice for Vivatmo Website and Vivatmo App
(Effective date: 19-Jun-2019)
Vivatmo App in a nutshell:
- You can use the Vivatmo App without user registration. While using the Vivatmo App, we do not collect any personal related information that allows us or third parties to identify you as a person (Privacy-by-Design).
- While using the Vivatmo App, we collect and transfer a) quality-related data about the connected Vivatmo me device as well as b) statistical information. This data is not related to you as a person (anonymized).
- We transfer measurement data and diary entries only with your explicit consent but only for statistical purposes. This option, however, is inactive (Privacy-by-Default). Only you can change this setting. The Vivatmo App can be used with these options remaining inactive.
Bosch Healthcare Solutions GmbH (hereinafter "Bosch“ or "We“ or "Us") welcomes 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.
1. Bosch respects your privacy
The protection of your privacy throughout the course of processing personal data as well as the security of all business data is an important concern 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.
Bosch is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows: Bosch Healthcare Solutions GmbH, Stuttgarter Str. 130, 71332 Waiblingen, e-Mail: email@example.com
3. Collection, processing and usage of personal data
While using the Vivatmo App, we collect and transfer a) quality-related data about the connected Vivatmo me device as well as b) statistical information. We do not know who used the device and which data has been entered into the app. This data is not related to you as a person (anonymized).
The following categories of data are processed:
a) Serial number of connected Vivatmo me device
b) Statistical information about your mobile phone (e.g. OS, language, time zone)
c) Statistical information, that has been entered by you (e.g. age, sex, smoker)
d) Your current GPS location, no history
Once you get in contact with us, we will additionally process:
e) Contact history (e.g. your requests, incl. contact details that you provided)
f) Extended communication data (e.g. postal address you provide for shipping issues) In case you give us your explicit consent, we additionally process:
g) Measurement data received from a Vivatmo me device
h) Diary entries entered in the app
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:
a) For Vivatmo website: Provision of these Online Offers, including contact form to contact us for the products and services offered by us. (Legal basis: Legitimate interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law)
b) For Vivatmo App and pollen forecast: Provision of these Online Offers, including contact form to contact us for the products and services offered by us for the purpose of the fulfillment of a contract. (Legal basis: Fulfillment of contractual obligations, legitimate interest on our part in market observation of our products as long as this occurs in accordance with data protection and competition law)
c) Resolving service disruptions as well as for security reasons. (Legal basis: Fulfillment of our legal obligations within the scope of data security, and justified interest in resolving service disruptions as well as in the protection of our offers)
d) Self-promotion and promotion by others as well as market research and reach analysis done within the scope statutorily permitted or based on consent. (Legal basis: Consent / justified interest on our part in direct marketing if in accordance with data protection and competition law)
e) Product or customer surveys performed via email and/or telephone subject to your prior express consent. (Legal basis: Consent)
You can use the Vivatmo App without user registration.
Each time you use the internet, your browser is transmitting certain information, which we store in so-called log files.
We save log files for a short period-of-time to determine service disruptions and for security reasons (e.g., to investigate attack attempts) 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). Also, see section web analysis.
In log files, in particular the following information is saved:
a) IP address (internet proto-col address) of the terminal device used to access the Online Offer;
b) Internet address of the website from which the Online Offer is accessed (so-called URL of origin or referrer URL);
c) Name of the service provider which was used to access the Online Offer;
d) Name of the files or information accessed;
e) Date and time as well as duration of recalling the data;
f) Amount of data transferred;
g) Operating system and information on the internet browser used, including add-ons installed (e.g., Flash Player);
h) http status code (e.g., “Re-quest successful” or “File requested not found”).
This Online Offer is not meant for children under 16 years of age.
Special data categories
The Vivatmo App can process special data (e.g. statements about your health) according to privacy laws but only if you provided the information by yourself, e.g. optional diary entry.
4. Data Transfer
Data transfer to other controllers
Principally, your personal data is forwarded to other controllers only if required for the fulfillment of a contractual obligation, or if we ourselves, or a third party, have a legitimate interest in the data transfer, or if you have given your consent. Particulars on the legal bases can be found in the Section Purposes of Processing and Legal Bases. Third parties may also be other companies of the Bosch group. When data is transferred to third parties based on a justified interest, this is explained in this data protection notice.
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 to the statutory provisions. Service providers may also be other Bosch group companies.
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 justified interest in storing the data (e.g. we might still have a justified 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).
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. due to the agreement based on so-called EU model clauses with the recipient). All third country recipients are listed in this data protection notice.
5. 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.
Cookies and tracking mechanisms that are technically not required
We only use such cookies and tracking mechanisms if you have given us your prior consent in each case. We distinguish between two sub-categories with regard to these cookies and tracking mechanisms:
These cookies facilitate operation and thus allow you to browse our online service more comfortably; e.g. your language settings may be included in these cookies.
Marketing cookies and tracking mechanisms - General
By using marketing cookies and tracking mechanisms we and our partners are able to show you offerings based on your interests, resulting from an analysis of your user behavior:
- Statistics: by using statistical tools, we measure e.g. the number of your page views.
- Conversion tracking: Our conversion tracking partners place a cookie on your computer ("conversion cookie") if you accessed our website via an advertisement of the respective partner. Normally these cookies are no longer valid after 30 days. If you visit certain pages of our website and the cookie has not yet expired, we and the relevant conversion partner can recognize that a certain user clicked on the advertisement and thereby was redirected to our website. The information obtained by means of the conversion cookie serves the purpose of compiling conversion statistics and recording the total number of users who clicked on the respective advertisement and were redirected to a website with a conversion tracking tag.
- Retargeting: These tools create user profiles by means of advertising cookies or third-party advertising cookies so called "web beacons" (invisible graphics that are also called pixels or tracking pixels), or by means of comparable technologies. These are used for interest-based advertising and to control the frequency with which the user looks at certain advertisements. The relevant provider is the controller responsible for the processing of data in connection with the tool. The providers of the tools might disclose information also to third parties for the purposes mentioned above. Please note the data protection notices of the relevant provider in this context.
Please note that using the tools might include transfer of your data to recipients outside of the EEA where there is no adequate level of data protection pursuant to the GDPR (e.g. the USA). For more details in this respect please refer to the following description of the individual marketing tools.
Name: Google Analytics
Provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Function: Analyses user behavior (page views, number of visitors and visits, downloads), UX testing
Management of cookies and tracking mechanisms
You can manage your cookie and tracking mechanism settings in the browser and/or our privacy settings. Note: The settings you have made refer only to the browser used in each case.
Deactivation of all cookies
If you wish to deactivate all cookies, please deactivate cookies in your browser settings. Please note that this may affect the functionality of the website.
Management of your settings with regard to cookies and tracking mechanisms not required technically
When visiting our websites, you will be asked in a cookie layer whether you consent to our using of any convenience cookies, marketing cookies or tracking mechanisms, respectively. In our privacy settings, you may withdraw the consent with effect for the future or grant your consent at a later point in time.
6. Usage of our mobile applications
In addition to our Online Offers, we offer mobile applications ("Apps"), which you can download to your mobile device. Beyond the data collected on websites, we collect additional personal data through our apps that specifically result from the usage of a mobile device. This is subject to your prior express consent.
7. Processing of your location data
Our offers also include so-called location based services without we could not provide the pollen forecast to you. To offer this app function, we collect the most recent GPS locations delivered by the mobile device and your IP address. We do not create a movement profile. You can deactivate this function in the respective app's settings or in the settings of the operating system of your mobile device or pause it temporarily. Please understand, that without your GPS location, we cannot offer the pollen service to you.
8. Processing of the advertising identifier / advertising ID
For advertising purposes, we use, given your consent, the so-called "advertising identifier" (IDFA) for iOS devices and the so-called advertising ID for Android devices. These are unique, but not personalized and not permanent identification numbers for a certain terminal device provided by iOS or Android. The data collected is not brought together with other device-related information. We use identification numbers to provide you with personalized advertisements and to analyze your usage. When you activate (for iOS devices) the option "no ad tracking" in the device settings under "Privacy" - "Advertisements" or (for Android devices) activate "deactivate interest-based advertisements" in the Google settings under "Advertisements", we can only perform the following measures: Measuring your interaction with banners by counting the number of displays of a banner without clicks ("frequency capping"), click rate, assessment of unique usage ("unique user") and security measures, fraud combating and troubleshooting. In the device settings, you are always able to delete your IDFA or advertising ID ("reset ad ID"); a new identification number is generated then which is not combined with data collected earlier. We advise you that you might be unable to use all functions of our app when you restrict the usage of the respective identification number.
9. App analysis
We do not use App analysis in Vivatmo App.
10. Data processing by App Store operators
We do not collect data, and it is beyond our responsibility, when data, such as username, email address and individual device identifier are transferred to an app store (e.g., Google Play by Google, App Store by Apple, Galaxy Apps Store by Samsung) when downloading the respective application. We are unable to influence this data collection and further processing by the App Store as controller.
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.
12. External links
Our Online Offers may contain links to third party internet pages – 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 supervision. 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 dis-closure or unauthorized access. Our security measures are, pursuant to technological progress, constantly being improved.
14. User rights
To enforce your rights, please use the details provided in the Contact section. Any statistical information is collected and processed without personal relation. We will check your user rights for every request due to limitations in personal relation. In doing so, please ensure that an unambiguous identification of your person related information 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 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). Please understand, that we can`t offer the Online Offers anymore to your, once you asked us to delete or restrict the processing of your personal data.
Restriction of 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 defense of legal claims.
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.
15. Right of complaint with supervisory authority
You have the right to lodge a complaint with a supervisory authority. You can appeal to the supervisory authority, which is responsible for your place of residence or your state of residency, or to the supervisory authority responsible for us. This is:
Dr. Stefan Brink, P.O.Box 10 29 32, 70025 Stuttgart or:
Königstraße 10a, 70173 Stuttgart
Phone: 07 11/61 55 41-0
Fax: 07 11/61 55 41-15
16. Changes to the Data Protection Notice
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 cur-rent version of our data protection notice, as this is subject to change.
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 Bosch Group (C/ISP)
PO 30 02 20 70442