Data Protection Notice
Robert Bosch (Pty) Ltd (hereinafter “RBSA” or “We” or “Us”) welcomes you to our internet pages, mobile applications, messaging services, and digital payment solutions (together also referred to as “Online Offers”). We thank you for your interest in our company and our products.
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 collected during your visit of our webpage confidentially and only in accordance with statutory regulations and solely in compliance with legal provisions.
Data protection and information security are included in our corporate policy.
RB is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows: Robert Bosch (Pty) Ltd, 96, 15th Road, Randjes Park, Midrand 1685, South Africa, +27(12)381-3478.
Communication data (e.g., name, telephone, e-mail, address, IP address) are processed.
- Principles
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 basis
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.
- In reply to user inquiries in the framework of a contact form
Legal basis: Predominantly, legitimate interest in direct marketing on our part and in the enhancement of our products and services, as long as this is carried out in compliance with data protection regulations and competition law regulations resp. contractual performance resp. consent.
- Resolving service disruptions as well as 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.
- 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 or predominantly, legitimate interest on our part in direct marketing if in accordance with data protection and competition law.
- Safeguarding and defending our rights
Legal basis: Legitimate interest on our part in the assertion and defence of our rights.
- Children
This service is not intended for children under 16 years of age.
- 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, has 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” (see no. 3.3).
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, installment payment, programming, data hosting, and hotline services. We have chosen 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.
- 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 except for 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).
- Data Processor
- Cooperation with ITUWEB
As Bosch we are working together with “ITUWEB” as the data processor to provide you with our digital services.
- Responsibilities of the Data processor
- Processor shall adopt adopt such measures to ensure a level of security appropriate to the sensitivity of the Data transferred to the Processor. These measures include the pseudonymization and encryption of personal data.
- Processor shall notify Controller in writing within 48 (forty-eight) hours, unless prohibited from doing so under Data Protection Laws, if it becomes aware or believes that any data processing instruction from Controller violates any Data Protection Law.
- Processor shall ensure it can restore the availability and access to Personal Data promptly in the event of a Security Incident.
- Processor shall ensure that any person who is authorized by Processor to process Personal Data (including its staff, agents and subcontractors) shall be under a contractual or statutory obligation of confidentiality.
- Processor shall in updating or modifying its Security Measures, ensure that such updates and modifications do not result in the degradation of the Processor’s Security Measures.
- Upon becoming aware of a Security Incident, Processor shall
- notify Controller without undue delay, and where feasible, in any event no later than 48 hours from becoming aware of the Security Incident.
- provide timely information relating to the Security Incident as it becomes known or as is reasonably requested by Controller; and
- promptly take reasonable steps to contain and investigate any Security Incident.
- Sub-processing
- Controller agrees that the Processor may engage Sub-processors to process Personal Data on Controller’s behalf
- Processor shall notify Controller of any engagement or disengagement of a Sub-processor.
- Processor shall:
- enter into a written agreement with each Sub-processor containing data protection obligations that provide at least the same level of protection for Controller’s Data as those in this Agreement; and
- remain responsible for the Sub-processor’s compliance with the obligations of this Agreement and for the acts or omissions of such Sub-processor that cause Processor to breach any of its obligations under this Agreement.
- International Transfers
ITUWEB may transfer and process Personal Data outside of South Africa, where as Processor, its Affiliates or its Sub-processors maintain data processing operations. ITUWEB shall at all times ensure that such transfers are made in compliance with the requirements of Data Protection Laws and the Processor shall ensure the Processor transfers data to jurisdictions that have adequate Data Protection Laws.
- External Links
Our webpage 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.
- 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.
- User rights
To enforce your rights, please use the details provided in the “Contact” section (see no. 13). 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.
- 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 those data to a third party.
- Right of objection
- 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:
The Information Regulator (South Africa)
33 Hoofd Street
Forum III, 3rd Floor Braampark
P.O Box 31533
Braamfontein, Johannesburg, 2017
Mr Marks Thibela
Chief Executive Officer
Tel No. +27 (0) 10 023 5200, Cell No. +27 (0) 82 746 4173
Complaints email: complaints.IR@justice.gov.za
General enquiries email: inforeg@justice.gov.za
- 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.
- Contact
If you wish to contact us, please find us at the address stated in the “Controller” section (see no. 2).
Data Protection Officer
Information Security and Privacy (C/ISP)
Robert Bosch South Africa Pty (Ltd)
Private Bag X118
Midrand
SOUTH AFRICA
or
E-mail to: DPO.southafrica@za.bosch.com