Privacy Protection Notice

1. Privacy protection note

The Bosch Digital Commerce GmbH (hereinafter „Azena” or "We“ or "Us") welcomes you to our internet pages (hereinafter "Online Offers"). We thank you for your interest in our company and our products.

In this privacy policy we describe how we process your personal data in connection with your use of the platform. This also includes the processing of personal data for the payment services that Azena provides for you in accordance with the Terms of Use.

2. Azena 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.

3. Controller

Azena 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 Digital Commerce GmbH
Ridlerstr. 57
80339 Munich
Germany
E-Mail: support@azena.com

4. Collection, processing and usage of personal data

4.1. Processed categories of data

The following categories of data are processed:

  • Registration- and contact data: name, telephone, e-mail, address, company
  • Technical data: User-ID, Password, IP-Address, browser data, Logs. resp. Activity data
  • Payment /Payout information: Bank account or credit card details, Identity verification and authentication data (e.g. ID documents)

4.2. 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 you have given your consent to the processing or use of personal data concerning this matter, e.g. by means of registration. Several legal bases can be applicable in parallel and allow the processing of personal data.

4.3. Processing purposes and legal basis

We as well as the service providers commissioned by us process your personal data for the following processing purposes:

  • Registration- and contact data
  1. Provision of services/Platform & Online Offers

Legal basis: Service contract and legitimate interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law.

  1. In reply to user inquiries in the framework of a contact form

Legal basis: Implementation of pre-contractual measures / service contract or overriding legitimate interest in marketing and in the improvement of our products and services, as long as this is in accordance with data protection and competition law requirements resp. consent.

  1. Newsletter: Sending an email

We process your personal data in order to provide you with newsletters, to personalize and to improve them.

Legal basis: prior consent

  1. Advertisements and/or market research (including customer surveys and feedbacks):

Legal basis: We have an overriding legitimate interest in marketing and in improving our products and services, as long as this is done in accordance with data protection and competition law requirements resp. consent, if required.

  1. Product or customer surveys performed via email and/or telephone

Legal basis: prior consent

  1. Pre-Sales, Sales and After-Sales

Legal basis: Overriding legitimate interest pursued by the controller or that of a third party. The legitimate interest for Azena lies in further developing and expanding business in the areas of safety and security as well as the software and IoT industry and in enabling other participants to participate in the IoT platform.

  • Technical data
  1. Optimization of our services and digital offers (incl. web and user tracking)

Legal basis: We have an overriding legitimate interest in marketing and in improving our services and online offerings, as long as this is done in accordance with data protection and competition laws.

  1. Resolving service disruptions as well as for security reasons

Legal basis: Fulfilment of our legal obligations in the area of data security and overriding legitimate interest in the elimination of disturbances and the security of our offers.

  1. Safeguarding and defending our rights

Legal basis: Overriding legitimate interest for safeguarding and defending our rights.

  • Payment / Payout information

In order to process payments / payouts, Azena must collect payment information from you that is necessary for the proper fulfilment of the contract with you. You cannot use the payment services without this data.

Legal basis: fulfilment of a contract

Categories of recipients: Payment service providers, Third Party Provider of Applications

  1. Identity verification and authentication data (e.g. ID documents)

Azena processes personal data to verify the identity required to comply with applicable laws. In some countries, payment service providers are required by law to collect identity information as part of their compliance with money laundering regulations in their capacity as regulated financial service providers. This includes (i) requesting the submission of government identification documents (e.g. driving license or passport) or providing date of birth, residential address and other data; (ii) taking measures to confirm the e-mail address, payment or withdrawal methods provided; or (iii) cross-checking information with third party databases. In these cases, the terms of use and privacy policy of the external payment service provider apply, to which the Customer should take note of separately.

Without this data, you cannot use the payment services.

Legal basis: fulfilment of a legal obligation

Categories of recipients: Payment service providers

  1. Data to identify and prevent fraud, abuse, security incidents, and other harmful activity

Legal basis: fulfilment of a legal obligation; Overriding legitimate interest on our part in fraud prevention and other harmful activities

Categories of recipients: Payment service providers

  1. Data on the conduct of safety investigations and risk assessments

Legal basis: fulfilment of a legal obligation; Overriding legitimate interest on our part in fraud prevention and other harmful activities

Categories of recipients: Payment service providers

  1. Data to be used for comparison with databases and other sources of information within the framework of the applicable legislation

Legal basis: fulfilment of a legal obligation, Overriding legitimate interest on our part in a comparison with anti-terrorism lists

Categories of recipients: Payment service providers

  1. Data on compliance with legal obligations

Legal basis: fulfilment of a legal obligation

Categories of recipients: Payment service providers

  1. Data for deposit of the payment method ("Re use")

It is possible to store payment data by placing a corresponding check mark. Azena receives masked financial information (e.g. masked credit card number) from the payment service provider.

Legal basis: Fulfilment of a contract or consent

4.4. Payment Provider Account

The financial use of the Application Store comprises the creation of an account ("Connected account") with the Payment Service Provider Stripe or Deutsche Bank. The account is mandatory to handle fund flows of the business transactions. To create an account with the Payment Service Provider a login to Azena’s Application Store is necessary. Access to the payment service section is available via the user symbols’ drop down menu. Customer needs to agree with Terms and Conditions of the Payment Service Provider to start the onboarding process of the account.

4.5. Children

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

4.6. Data transfer

4.6.1. 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 the implementation of pre-contractual measures, 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 and the recipients resp. the categories of recipients can be found in the Section - Purposes of Processing and legal basis. 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.

For payment processing we use

  • the external payment service provider Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland and Stripe Payments UK Ltd., 211 Old Street, The Warehouse, 7th Floor, London EC1V 9NR ("Stripe"). The disclosure of payment information is based on the legal basis Art. 6 para. 1 lit. b GDPR. The passing on of your data takes place exclusively for the purpose of the payment winding up and only to the extent that it is necessary for this. Stripe also collects some of this data itself as a controller if you create an account there. The privacy policy of Stripe applies in this respect, which must be noted separately.

Further information can be found in Stripe's privacy policy at https://stripe.com/gb/privacy.

  • the external payment service provider Deutsche Bank. The disclosure of payment information is based on the legal basis Art. 6 para. 1 lit. b GDPR. The passing on of your data takes place exclusively for the purpose of the payment winding up and only to the extent that it is necessary for this. Deutsche Bank also collects some of this data itself as a controller if you create an account there. The privacy policy of Deutsche Bank applies in this respect, which must be noted separately.

Further information can be found in Deutsche Bank’s privacy policy at https://www.db.com/legal-resources/privacy-notice?language_id=1

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.

If you are registered as an administrator for your company account, we will pass on your contact details to them in the event of further attempts by your company’s employees to register. The disclosure takes place on the basis of the legal basis article 6 section 1 lit. f GDPR.

4.6.2. Data processing under commission

We involve external service providers with tasks such as sales and marketing services, contract management, payment handling, programming, data hosting and hotline services. All service providers are obliged to maintain confidentiality and to comply with the statutory provisions. Service providers may also be other Bosch group companies.

4.7. 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 a decision of adequacy by the European Commission for the respective country or due to the agreement based on so-called EU model clauses 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 (No. 14).

4.8. Duration of storage; retention period

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).

5. Credit assessments

We have a legitimate interest in performing the credit assessments set forth in this section for the purpose to protect ourselves from bad debts or investments. We might commission companies performing mathematical and statistical analysis to assess the risk of payment default and deliver, within the scope of what is allowed under law, information on the probability of payment defaults. For the assessment, address data may be used, but not exclusively.

In case the result of a credit assessment does not satisfy our requirements, we reserve the right to ask for an assured payment method (e.g. credit card) or to refuse to enter into a contract.

A credit assessment is based on automated decision-making. If you disagree with the result, you may submit your point of view in writing to be reviewed by a responsible person. In addition, you are entitled to find out about the essential reasons supporting the decision of the respective service provider.

We have commissioned the following service providers with credit assessments:

Bisnode D&B Deutschland GmbH

Robert-Bosch-Straße 11

64293 Darmstadt

6. Cookie usage

6.1. General

Cookies are small text files that are saved on your computer when an Online Offer is accessed. In case you access this Online Offer another time, your browser sends the cookies' content back to the respective seller and, thus, allows the re-identification of the terminal device. Reading the cookies allows us to design our Online Offers optimally for you and makes it easier for you to use them.

6.2. Deactivation and deletion of cookies

When you visit our internet pages you will be asked in a cookie layer pop up whether you wish to allow the cookies which are being set on our page or you want to deactivate them in the settings.

In case you decide to block cookies, an opt out cookie is set in your browser. This cookie exclusively serves the purpose of assigning your objection. Deactivating cookies may disable individual functions of our internet pages.

Please note that an opt out cookie may, for technical reasons, only be set for the browser that was used to set it. In case you delete cookies or use a different browser or a different terminal device, you must opt out again.

The preference setting does not apply to cookies that are being set during your visits on third party internet pages by other providers.

Your browser allows you to delete all cookies at all times. To do so, please consult your browser's help functions. This might, however, lead to individual functions no longer being available.

In addition, you are able to manage and deactivate the use of third party cookies on the following web page:

http://www.youronlinechoices.com/uk/your-ad-choices

As we do not operate this website, we are not responsible and we are unable to influence content and availability

6.3. Overview of cookies used by us

In this section, please find an overview of cookies we use.

Absolutely necessary cookies

Certain cookies are necessary so we can securely render our Online Offers. This category includes, e.g.:

  1. Cookies that identify or authenticate our users;
  2. Cookies that temporarily save certain user input (e.g., content of a shopping cart or of an online form);
  3. Cookies that store certain user preferences (e.g., search or language settings);
  4. Cookies that store data to ensure a trouble-fee playback of video or audio content.

6.4. Analytical cookies

We use analytical cookies to record the usage behavior (e.g., ad banners clicked on, search queries put in) of our users and to evaluate it statistically.

7. Web analysis

We need statistical information about the usage of our Online Offers to design them to be more user-friendly, to perform range measurements and market research. For this purpose, we use the web analysis tools described in this section.

The usage profiles created by these tools using analysis cookies or by evaluating log files are not brought together with personal data. The tools either do not use user IP addresses at all or shorten them immediately after gathering them.

In the following, please find information on each tool seller and how you are able to object to the collection and processing of data by the tool.

Be advised that with regard to tools which use opt out cookies, the-opt out function is related to that individual device or browser. In case you use several terminal devices or browsers you must opt out on every device and with every browser used.

When using cookies and analysis tools, we might transfer personal data to recipients located outside the EEA into so-called third countries.

Beyond this, you can avoid the forming of usage profiles by generally deactivating cookie usage. Please refer to the section Deactivate and delete cookies.

7.1. Google Analytics

Google Analytics is provided by Google Inc., 1600 Amphitheatre Park-way, Mountain View, CA 94043, USA ("Google"). We use Google Analytics with the additional function offered by Google to anonymize IP addresses. While doing so, Google already shortens IPs within the EU in most cases but only does so for exceptional cases in the United States, and in both regions it only saves shortened IPs. You may object to the collection or processing of your data by using the following link to download and install a browser plugin: http://tools.google.com/dlpage/gaoptout?hl=en

7.2. HubSpot

Our Site employs HubSpot, which collects personal identifying information by using JavaScript and cookies to help us analyze how visitors use the Site. HubSpot’s products help us to identify Site visitors, analyze email campaigns, track Site contact forms and monitor Google AdWords click through. Anonymous visitor tracking information may be shared with other HubSpot customers.

For more information about HubSpot cookies, please visit: https://legal.hubspot.com/privacy-policy.

7.3. Google Adwords or Google Remarketing

We use the Google AdWords online advertising program and Google Remarketing technology to advertise online and make ads more relevant. We place Remarketing cookies which may be used by third parties (including Google) to show our ads on websites outside of our management. Our Remarketing Cookie and Remarketing Lists do not collect personal information. You can find more information about Google AdWords here:

https://ads.google.com/intl/de_de/home/how-it-works/

7.4. LinkedIn Insight Tag

We use LinkedIn advertising program to run advertisements on their platform. We place the LinkedIn cookie on the web browser of a visitor whenever they visit our website. This will allow us to monitor our ads and conversions on our website. You can find more information here:

https://www.linkedin.com/help/lms/answer/a427660/the-linkedin-insight-tag-frequently-asked-questions?lang=de

7.5. Google Maps

This page uses the map service Google Maps via an API. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

For the use of the functions of Google Maps it is necessary to store your IP address. This information is usually transmitted to a server of Google LLC in the USA and saved there. The provider of this page does not have any influence on this transmission of data. The use of Google Maps is in the interest of an appealing presentation of our online offers and an easy retrievability of the places listed by us on the website. This represents a predominant legitimate interest on our part within the meaning of article 6 section 1 lit. f GDPR.

Please see the privacy policy of Google for more information on the handling of user data: https://www.google.de/intl/de/policies/privacy/.

8. Usage of retargeting tools

For the purpose of optimizing our online marketing we use so-called retargeting technologies. This is to design a more interesting Online Offer for you, which is tailored to your needs. To do so, we use the tools listed below. The usage profiles compiled with the assistance of advertisement cookies or third party advertisement cookies, so-called web beacons (invisible graphics which are also called pixels or counting pixels) or comparable technologies that are not combined with personal data.

The tools are used by the providers to show our users in our Online Offers and in third party offers interest-based advertisements and to control the frequency in which users see certain advertisements. The provider of the respective tool is responsible for the data processing in connection with the tools. The tool providers eventually transfer information to third parties for abovementioned reasons.

When using retargeting tools, we might transfer personal data to recipients located outside the EEA into so-called third countries.

With each tool you can find information on the tool provider as well as information on how to object to the data collection by this tool.

Be advised that with regard to tools which use opt out cookies, the opt out function is related to that individual device or browser. In case you use several terminal devices or browsers you must opt out on every device and with every browser used.

Beyond this, you can avoid the forming of usage profiles by generally deactivating cookie usage; for this please refer to the section Deactivate and delete cookies.

Further information on interest-based advertising may be found on the consumer portal http://www.meine-cookies.org. The following link to the portal additionally enables you to view the activation status of certain tools provided by different providers and to object to the collection and processing of your data by these tools: http://www.meine-cookies.org/cookies_verwalten/praeferenzmanager-beta.html.

The option to object to certain tools especially issued by U.S. based providers can be found at the following link: http://www.networkadvertising.org/choices/

Facebook Pixel

We use Facebook pixels of Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA ("Facebook") in our online offering. The Facebook pixel enables us to display advertising tailored to your needs and to track whether you have been redirected to our online offering by clicking on our Facebook ad.

Further information about the processing of your personal data by Facebook, as well as the settings options for protecting your privacy on Facebook, can be found in the Facebook Data Policy: https://www.facebook.com/policy and https://www.facebook.com/business/help/651294705016616.

To permanently prevent the collection of usage data, please use one of the following links: http://www.aboutads.info/choices or http://www.youronlinechoices.eu. As a registered Facebook user, you can also set which types of ads are displayed to you within Facebook. To do this, please visit the following link: https://www.facebook.com/settings/?tab=ads.

Twitter Pixel

We use Twitter pixels of Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 U.S.A. ("Twitter") in our online offering. The Twitter pixel enables us to display advertising tailored to your needs and to track whether you have been forwarded to our online offering by clicking on our Facebook ad.

For more information about the processing of your personal data by Twitter, as well as the setting options for protecting your privacy on Twitter, please refer to the Twitter Data Policy: https://help.twitter.com/en/rules-and-policies/twitter-cookies.

To permanently prevent the collection of usage data, please use one of the following links: http://www.aboutads.info/choices or http://www.youronlinechoices.eu.

9. Newsletter

Within the scope of our Online Offers you are able to sign up for newsletters. To do so, we use the so-called double opt-in procedure 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 at a later date, 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 using the contact details provided in the Contact section.

10. Challenges and other marketing activities

You have the opportunity to participate in various Azena challenges and other marketing activities. To participate, you must fill out an online form. Unless otherwise stated in the specific privacy policy of the respective competition or of the equivalent marketing activity, we process the following personal data of you via the online form: First name, surname, e-mail address, company, country. The data processing is carried out exclusively for the purpose of pre-selection and the implementation of a challenge or other marketing activity. The legal basis for data processing in the event of your participation is Art. 6 para. 1 lit. b) GDPR (fulfilment of a contract).

The data of participants will be deleted after the end of the challenge or marketing activity.

11. 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 processing and using personal data possibly transmitted by clicking the link to the third party. We do not assume responsibility for the processing of such personal data by third parties.

12. 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.

13. 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, 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).

Restriction of processing

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

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 object this consent with immediate effect. The legality of data processing prior to your revocation remains unchanged. In addition, processing may continue to be permitted on the basis of another legal bases.

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. This does not apply if a transfer affects the rights and freedoms of another person.

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:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)

Promenade 27

91522 Ansbach

Telefon: +49 (0) 981 53 1300

Telefax: +49 (0) 981 53 98 1300

E-Mail: poststelle@lda.bayern.de

 

14. Changes to the Data Protection Notice

As far as the circumstances of the data processing change, we can adjust the privacy policy. Furthermore, 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.

15. Automated decision-making

We do not use automated decision-making for the establishment, execution and termination of business relationships according to Art. 22 GDPR. In case we use such procedures in particular, we will inform you about your corresponding rights subject to legal obligations.

16. Contact

If you wish to contact us, for example in connection with the processing of personal data or for the exercise of your user rights, please find us at the address stated in the "Controller" section.

If you want to unsubscribe from a newsletter, you can click on the corresponding unsubscribe link in the newsletter or tell us your request via the contact options mentioned in the “Controller” section.

To assert your data subject requests and notification of data protection incidents please use following link:

https://www.bkms-system.net/bosch-datenschutz

For suggestions and complaints regarding the processing of your personal data we recommend that you contact our group commissioner for data protection:

Data protection officer

Information Security and Privacy Bosch Group (C/ISP)
Postfach 30 02 20
70442 Stuttgart
GERMANY

or

send an email to: DPO@bosch.com

17. Effective Date

22.12.2021