eBike
Systems
Data
Protection
Notice
COBI.Bike
Robert
Bosch
GmbH
(hereinafter
"Bosch
eBike
Systems"
or
"we"
or
"us")
welcomes
you
to
our
COBI.Bike
platform
https://www.my.cobi.bike,
COBI.Bike
App
and
subdomains
of
the
services
(hereinafter
"online
offer").
Thank
you
for
your
interest
in
our
company
and
our
products.
The
protection
of
your
privacy
in
the
processing
of
personal
data
as
well
as
the
security
of
all
business
data
is
an
important
concern
for
us.
We
process
personal
data
collected
during
your
visit
to
our
online
offer
confidentially
and
only
in
accordance
with
legal
regulations.
Data
protection
and
information
security
are
anchored
in
our
corporate
policy.
1.
Data
Controller
The
Data
Controller
responsible
for
processing
your
data
is:
Robert
Bosch
GmbH
Robert-Bosch-Platz
1
70839
Gerlingen-Schillerhöhe
Germany
E-mail:
kontakt@bosch.de
Exceptions
are
explained
in
this
data
protection
notice.
1.1
Rights
of
the
Controller
To
exercise
your
rights,
please
use
the
following
link:
https://request.privacy-bosch.com/entity/RB/
To
report
data
protection
incidents,
use
the
following
link:
https://www.bkms-system.net/bosch-datenschutz
1.2
Questions
and
suggestions
regarding
data
protection
If
you
have
any
questions
or
suggestions
regarding
data
protection,
please
feel
free
to
contact
us.
You
can
reach
us
at:
E-mail:
kontakt@bosch.de
Tel.:
+49
711
400
40990
1.3
Contacting
the
data
protection
officer
If
you
have
any
complaints
or
suggestions
regarding
the
processing
of
your
personal
data,
we
recommend
that
you
contact
our
data
protection
officer:
eBike
Systems
Data
Protection
Officer
Department
for
Information
Security
and
Data
Protection
Bosch
Group
(C/ISP)
P.O.
Box
30
02
20
70442
Stuttgart,
Germany
Germany
or
E-mail
to:
DPO@bosch.com
2.
Collection,
processing
and
use
of
personal
data
2.1
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
only
when
there
is
either
a
statutory
legal
basis
for
doing
so.
2.2
Categories
of
data
processed
The
following
categories
of
data
are
processed:
–
user-related
data
(e.g.
name,
telephone,
e-mail,
address)
–
device-related
data
(e.g.
manufacturer
and
model
of
the
eBike,
serial
number)
–
service-related
data
(e.g.
GPS
data,
heart
rate)
–
Log
files
(e.g.
IP
address)
2.3
Processing
purposes
and
legal
bases
We
and
the
service
providers
commissioned
by
us
process
your
personal
data
for
the
following
purposes:
2.3.1
Provision
of
our
online
offer
Bei
der
Nutzung
unseres
Online-Angebots
werden
automatisch
bestimmte
Informationen
an
uns
übermittelt
und
in
sogenannten
Log-Dateien
gespeichert.
In
den
Log-Dateien
werden
insbesondere
die
folgenden
Informationen
verarbeitet:
–
IP
address
–
Name
of
the
retrieved
files
or
information
–
Date,
time
and
duration
of
the
retrieval
–
Amount
of
data
transferred
eBike
Systems
–
Referrer
URL
(last
visited
website
that
referred
to
our
website/app
via
link)
–
http
status
code
–
Device
type
(user
interface
string,
e.g.
iOS,
Android,
operating
system)
The
log
files
are
processed
for
the
purpose
of
providing
and
optimising
our
online
offer,
to
ensure
technical
operation
and
to
identify
and
eliminate
malfunctions
and
to
investigate
criminal
offences.
The
legal
basis
for
this
is
the
legitimate
interest.
The
legitimate
interest
of
Bosch
eBike
Systems
consists
of
the
purposes
just
mentioned.
The
data
is
deleted
after
30
days
if
it
is
no
longer
needed
for
the
purposes
described.
Log
files
whose
further
storage
is
necessary
for
evidentiary
purposes
are
excluded
from
deletion
until
the
final
investigation
of
the
relevant
incident
and,
in
individual
cases,
may
be
forwarded
to
investigating
authorities
within
the
framework
of
the
legal
regulations.
2.3.2
Registration
with
the
online
offer/previous
setup
of
a
central
SingleKey
ID
You
can
register
to
our
services
using
SingleKey
ID.
SingleKey
ID
was
devised
by
Robert
Bosch
GmbH
for
the
Bosch
Group
to
provide
users
with
a
comprehensive
login
option
on
Bosch
websites,
shops,
apps
and
services.
Robert
Bosch
GmbH,
Robert-Bosch-Platz
1,
70839
Gerlingen-Schillerhöhe,
Germany,
is
responsible
for
providing
SingleKey
ID.
Robert
Bosch
GmbH
processes
your
data
for
the
purposes
of
"Registration
and
login
with
SingleKey
ID"
and
"Overview
and
management
of
data
and
applications
with
SingleKey
ID".
For
more
information,
see:
https://singlekey-id.com/data-protection-notice/
.
After
a
one-time
registration,
you
can
use
SingleKey
ID
to
log
in.
To
do
this,
you
will
be
forwarded
to
a
login
screen
at
Robert
Bosch
GmbH.
You
can
terminate
your
SingleKey
ID
user
agreement
at
any
time
on
the
SingleKey
ID
website
by
deleting
your
SingleKey
ID:
https://singlekey-id.com/myprofile/
.
Please
note
that
by
deleting
your
SingleKey
ID
you
will
lose
access
to
all
Bosch
websites,
shops,
apps
and
services
that
you
used
to
log
in
to
with
your
SingleKey
ID.The
aforementioned
personal
data
are
processed
for
the
purpose
of
identification
and
contract
processing
(conclusion,
execution
and
termination
of
the
contract).
The
legal
basis
for
data
processing
is
the
Contract.
After
setting
up
the
user
account,
further
voluntary
information
(e.g.
gender,
date
of
birth,
height
and
weight,
resting
pulse
and
maximum
pulse)
can
be
provided
within
our
online
offer
in
the
user
account.
2.3.3
Use
of
the
services
Via
our
online
service,
information
about
your
eBike
is
prepared
and
visualized
for
you
individually
and
according
to
your
needs.
Among
other
things,
you
will
receive
an
overview
of
the
components
used
as
well
as
further
technical
information
about
your
eBike
including
the
current
eBike
settings.
eBike
Systems
To
use
our
services,
your
user
account
must
be
linked
to
an
eBike.
The
link
is
established
by
connecting
your
COBI
Hub
with
your
user
account.
To
establish
a
Bluetooth
connection
to
devices
with
the
Android
operating
systems,
Android
requires
access
to
your
position
data
(e.g.
GPS
data)
from
us.
For
this
purpose,
we
process
your
position
data
to
establish
a
Bluetooth
connection
with
an
Android
device.
When
linking
to
your
user
account,
the
following
information
of
the
hardware
and
software
component
of
your
eBike
("device-related
data")
is
processed,
among
others:
–
Manufacturer
of
the
eBike
–
Model
of
the
eBike
(incl.
bike
parameters)
–
Serial
number
–
Material
number
–
Date
of
manufacture
–
Version
number
of
hardware
and
software
–
Drive
unit
(motor)
–
Battery
status
–
eBike
settings
(e.g.
support
modes,
language,
time,
time
zone)
–
Statistics
(e.g.
total
mileage,
charging
cycles,
ABS
events
…)
–
Activity
data
(e.g.,
total
trip
time,
completed
and
upcoming
service
intervals).
Depending
on
your
selection,
personal
data
will
be
processed
accordingly
when
using
the
Services
("Service-related
data").
Service-related
data
is
processed
for
the
purpose
of
providing
the
functionalities.
The
legal
basis
for
the
processing
of
service-related
data
is
the
Contract,
unless
otherwise
stated
below.
2.3.3.1
Home
Screen
The
home
screen
gives
you
a
quick
overview
of
all
the
important
information
such
as
battery
status,
remaining
range,
distance
travelled
and
the
next
service
appointment.
Your
eBike
model
is
also
displayed
on
the
Home
Screen,
provided
that
the
relevant
eBike
manufacturer
supports
this
feature.
For
the
display
of
various
information
about
your
eBike
on
the
home
screen,
the
following
device-related
data,
for
example,
is
processed:
eBike
manufacturer,
eBike
model,
battery
status,
eBike
settings
(e.g.,
support
modes,
language,
time,
time
zone),
statistics
(e.g.,
total
mileage,
charging
cycles)
and
activity
data
(e.g.
total
trip
time,
completed
and
upcoming
service
intervals).
2.3.3.2
Route
planning,
navigation
and
activity
tracking
You
can
use
our
location-based
services
for
calculating
and
displaying
routes
and
for
route
guidance
in
the
online
offer
and
on
the
on-board
computer.
The
trip
duration
of
the
route,
if
available,
is
calculated
based
on
the
riding
behaviour
of
the
preceding
eBike
rides.
In
addition,
every
activity
with
your
eBike
is
recorded
and
visualised
in
the
app
(activity
tracking).
eBike
Systems
The
following
data
is
processed
when
you
use
the
services
("Service-related
data"):
–
Position
data
(e.g.
GPS
data)
–
Start
and
destination
address,
search
history
–
Routes
planned
and/or
completed
–
Activities
(e.g.
cadence,
speed,
total
trip
time)
As
part
of
activity
tracking,
you
have
the
option
to
start
activity
recording
in
the
background
without
having
to
open
the
app
first.
To
do
this,
you
must
set
the
location
access
in
the
background
to
"Always
allow".
You
can
change
the
location
sharing
in
the
background
at
any
time
in
the
settings.
Regarding
the
tracking
of
mobile
devices
(GSM
tracking),
we
refer
to
the
privacy
policy
of
your
mobile
provider
as
well
as
the
app
store
operators
for
devices
with
the
Android
and
iOS
operating
systems.
Please
note
that
most
mobile
devices
allow
you
to
enable
or
disable
the
use
of
location
services
in
the
device's
settings
menu.
If
you
use
our
online
offer,
please
note
that
if
you
disable
the
mobile
device
tracking
feature,
certain
services
may
not
be
available
due
to
the
nature
of
our
services.
2.3.3.3
Fitness
functionalities
If
you
want
to
measure
your
calorie
consumption
and
your
respective
training
effects
in
connection
with
your
eBike
activities
and
have
them
displayed
in
the
app
during
the
ride,
the
processing
of
further
information
is
required
to
provide
the
corresponding
functionalities.
This
includes,
among
others,
the
following
service-related
data:
–
Gender
–
Date
of
birth
–
Weight
–
Height
–
Heart
rate
In
the
app,
you
also
have
the
option
of
displaying
health
data
from
third-party
providers
(e.g.
pulse
watch,
chest
strap).
For
data
transmission,
the
different
devices
must
be
connected
to
each
other
via
Bluetooth.
The
legal
basis
for
the
training
effect
data
displayed
during
eBike
use
and
the
recorded
heart
rate
data
is
your
prior
consent.
2.3.3.4
Help
Center
To
help
you
quickly
find
answers
to
all
your
questions
about
your
eBike
with
the
smart
system,
the
Help
Centre
adapts
the
content
displayed
to
the
eBike
and
its
components
currently
connected
to
the
app.
For
this
purpose,
in
addition
to
your
name,
the
following
information
of
the
hardware
and
software
component
of
your
eBike
("device-related
data")
is
processed,
among
others:
material
number
of
the
Bosch
eBike
components,
eBike
settings
(e.g.
name,
language,
time,
time
zone)
and
device
type
(platform,
operating
system).
eBike
Systems
2.3.3.5
Weather
forecast
In
our
online
offer,
you
also
have
the
option
of
displaying
the
weather
forecast
for
the
current
location
of
your
eBike.
For
this
purpose,
we
process
your
current
and
location-related
position
data
(e.g.
GPS
data).
2.3.4
Product
improvement
and
development
We
need
your
information
to
continuously
improve
our
online
offer,
to
develop
new
products
and
services
and
for
market
research.
a)
Access
to
your
end
device
With
your
consent
(Art.
25
Para.
1
TTDSG),
information
is
stored
and
accessed
on
your
end
device.
This
information
is
user,
diagnostic
and
usage
data
resulting
from
the
use
of
Bosch
eBike
Systems
products
and
services
and
our
online
offer.
If
you
withdraw
your
consent,
access
to
your
end
device
will
stop.
For
information
on
how
we
further
process
user,
diagnostic
and
usage
data,
please
refer
to
the
section
"b)
Further
processing
of
information
for
product
improvement
and
development".
b)
Further
processing
of
information
for
product
improvement
and
development
We
process
user,
diagnostic
and
usage
data
resulting
from
the
use
of
Bosch
eBike
Systems
products
and
services
and
our
online
offer
or
which
we
have
received
from
you
as
described
under
a).
This
includes,
for
example,
analyses
of
user
groups
and
the
creation
of
performance
statistics
as
well
as
device
and
software-related
usage
information,
i.e.
how
you
use
our
online
offer
which
functions
you
access
and
to
what
extent,
when
you
delete
your
account
or
how
you
use
our
newsletter.
This
information
is
used
in
anonymized
form
for
evaluations
for
statistical
purposes.
The
legal
basis
for
this
is
our
legitimate
interest
in
optimizing
our
own
products
and
services,
developing
new
products
and
services
and
thus
maintaining
or
promoting
your
satisfaction.
Health
data
will
only
be
anonymized
with
your
prior
consent
and
processed
for
the
purposes
of
product
improvement
and
development.
2.3.5
Reviews
You
have
the
possibility
to
submit
reviews
and
provide
feedback
if
necessary.
This
process
is
voluntary.
If
you
are
dissatisfied,
we
will
take
the
liberty
of
forwarding
your
feedback
to
our
customer
service
department
and,
if
necessary,
contacting
you
to
resolve
your
concerns.
The
request
to
submit
a
review
is
intended
to
ensure
the
quality
of
our
online
offer
and
the
transparency
of
the
services
on
our
platform
for
other
users.
The
collection
and
processing
of
this
data
is
based
on
legitimate
interest.
The
legitimate
interest
of
Bosch
eBike
Systems
derives
from
an
interest
in
maintaining
or
promoting
your
satisfaction
and
optimising
our
own
products.
2.3.6
eBike
software
updates
(updates
over-the-air)
To
ensure
that
your
COBI
Hub
is
kept
up
to
date
and
continuously
enhanced
with
new
features,
our
online
offer
regularly
checks
in
the
background
whether
software
updates
are
available
for
your
board
computer.
You
also
have
the
option
of
manually
searching
for
eBike
Systems
software
updates
in
the
online
offer.
To
request
software
updates,
we
process
the
current
hardware
and
software
versions
of
your
COBI
Hub
and
the
serial
numbers.
This
processing
is
carried
out
based
on
the
contract.
We
will
inform
you
in
our
online
offer
as
soon
as
a
new
update
is
available
for
your
board
computer
and
you
decide
if
and
when
you
want
to
download
and
install
the
software
update.
2.3.7
Contacting
customer
service
If
you
contact
our
customer
service,
e.g.
for
questions,
complaints,
suggestions
or
to
verify
your
identity
for
eBikes
that
are
already
registered,
the
following
personal
data
will
be
processed
to
handle
your
request:
–
user-related
data
(e.g.
name,
telephone,
e-mail,
SingleKey
ID,
identity
document)
–
Time
of
the
phone
call/date
of
sending
the
email
–
Requests
–
Attachments
(e.g.
photos,
documents)
–
Device-related
data
(e.g.
eBike
components,
serial
number,
software
version,
device
information,
app
version).
Should
you
contact
us
outside
of
a
specific
contractual
relationship
or
registration,
the
legal
basis
for
data
processing
is
our
legitimate
interest
in
providing
you
with
the
best
possible
service.
In
the
case
of
a
contractual
relationship
or
registration,
the
legal
basis
is
the
requirement
to
fulfil
the
contract.
If
you
contact
us
by
phone,
we
may
ask
you
during
the
call
if
we
may
record
the
following
conversation
for
service
optimisation
purposes.
The
recording
is
voluntary.
We
will
only
record
the
conversation
if
you
give
your
consent
to
do
so.
The
legal
basis
is
your
consent.
2.3.8
Handling
of
a
service
case
at
the
bicycle
retailer
or
service
partner/connecting
an
eBike
to
a
DiagnosticTool
If
you
have
a
concern
regarding
your
eBike,
simply
contact
your
bicycle
retailer
or
service
partner.
In
order
to
process
your
request,
it
is
first
necessary
to
identify
the
technical
error.
For
this
purpose,
the
bicycle
retailer
connects
your
eBike
to
a
DiagnosticTool.
When
your
eBike
is
connected
to
the
DiagnosticTool,
the
following
information
about
your
eBike
is
sent
to
Bosch
eBike
Systems
for
processing
("device-related
data"):
Information
about
the
manufacturer,
the
production
date
and
the
model
of
the
eBike,
bike
ID,
information
about
the
eBike
components
(article
number,
serial
number,
hardware
and
software
versions,
configuration
data,
statistical
data),
as
well
as
activity
data
of
the
eBike
(e.g.
total
trip
time,
completed
and
upcoming
service
intervals)".
The
device-related
data
may
be
processed
for
the
following
purposes:
Processing
your
request,
handling
a
service
case,
configuring
the
eBike,
performing
updates,
resetting
a
detected
tampering,
enabling
the
eBike
components,
setting
the
system
time
and
for
product
improvement.
eBike
Systems
The
legal
basis
for
the
processing
is
the
Contract
or
the
legitimate
interest.
The
legitimate
interest
of
Bosch
eBike
Systems
derives
from
an
interest
in
processing
your
request,
processing
service
cases,
maintaining
or
promoting
your
satisfaction
and
optimising
our
own
products.
2.3.9
Safeguarding
and
defending
our
rights.
We
may
process
your
personal
data
to
protect
and
defend
our
rights.
Legal
basis:
Our
legitimate
interest
in
the
protection
and
defense
of
our
rights
2.4.
Children
This
online
offer
is
not
intended
for
children
under
the
age
of
16.
3.
Transfer
of
data
to
service
providers
and
third
parties
3.1
Transfer
of
personal
data
In
our
online
offer,
we
provide
you
with
various
features
from
external
providers
(for
detailed
information,
see
3.4)
in
order
to
offer
you
a
user-friendly
and
intuitive
navigation
with
regard
to
the
use
of
our
services
as
well
as
other
additional
functions.
In
this
context,
your
personal
data
will
only
be
transferred
to
other
responsible
parties
(our
"Partners")
if
this
is
necessary
for
the
provision
of
the
functionalities
selected
by
you
and
for
the
processing
of
your
enquiry
when
you
contact
our
customer
service
and/or
your
consent
has
been
granted.
You
can
revoke
your
consent
for
functionalities
at
any
time
directly
in
the
online
offer.
Please
also
note
the
privacy
policy
of
the
respective
providers.
We
also
use
external
service
providers
of
IT
and
marketing
services,
call
centres
and
programming
to
provide
you
with
our
services.
Other
companies
in
the
Bosch
Group
may
also
be
service
providers.
We
have
carefully
selected
these
service
providers
and
monitor
them
regularly,
in
particular
the
careful
handling
and
security
of
the
data
stored
with
them.
All
service
providers
are
obliged
to
maintain
confidentiality
and
to
comply
with
the
statutory
data
protection
provisions.
In
addition,
your
data
may
be
transferred
to
public
authorities
if
we
are
obliged
to
do
so
by
law
or
by
an
enforceable
official
or
court
order.
If
the
transfer
of
data
takes
place
on
the
basis
of
a
legitimate
interest,
you
will
be
expressly
informed
of
this
in
this
privacy
policy
description.
3.2
Transfer
to
partners
outside
the
EEA/Switzerland
eBike
Systems
If
your
personal
data
is
transferred
to
partners
who
are
based
outside
the
EEA/Switzerland
in
so-called
third
countries,
you
will
be
informed
of
this
in
each
case.
We
ensure
that
prior
to
the
transfer
either
an
adequate
level
of
data
protection
exists
with
the
partner
(e.g.
based
on
an
adequacy
decision
of
the
EU
Commission
for
the
respective
country
or
the
agreement
of
so-called
EU
standard
contractual
clauses
of
the
European
Union
[with
adaptations
to
the
Swiss
Data
Protection
Act]
with
the
partner)
or
your
consent
to
the
transfer
has
been
obtained.
Please
also
note
the
corresponding
privacy
policies
of
the
partners.
You
have
the
right
to
receive
an
overview
of
the
recipients
in
third
countries
and
a
copy
of
the
specifically
agreed
provisions
to
ensure
an
adequate
level
of
data
protection.
For
this,
please
use
the
information
in
the
contact
area.
3.3
External
services
3.3.1
Apple
Health
and
Apple
Watch
You
can
transfer
your
activity
and
fitness
data
from
our
online
offer
to
the
Apple
Health
application
from
Apple
Inc.
1
Infinite
Loop,
Cupertino,
CA
95014,
USA.
In
the
process,
Apple
Health
receives
the
following
data,
among
others:
Start
and
end
time
of
a
completed
activity,
distance,
duration,
speed
and
calories.
The
data
is
made
available
to
you
in
Apple
Health.
In
addition,
you
have
the
option
of
displaying
your
heart
rate
during
an
activity
using
the
"Apple
Watch".
The
various
devices
must
be
connected
to
one
another
for
data
transmission.
You
can
terminate
this
connection
between
the
accounts
at
any
time.
It
is
possible
that
Apple
Health
may
process
this
information
at
locations
outside
the
EU
or
the
EEA/Switzerland
(e.g.
in
the
US).
The
legal
basis
for
the
processing
of
data
to
provide
the
service
is
the
Contract.
The
legal
basis
for
the
transfer
of
data
to
Apple
Health
is
your
consent
.
For
more
information
about
Apple
Health's
processing
of
your
personal
data
and
your
rights
as
a
data
subject
and
privacy
settings
options,
please
refer
to
Apple
Health's
privacy
policy
at
https://www.apple.com/legal/privacy/
.
3.3.2
Google
Fit
and
Google
Health
Connect
You
can
synchronize
your
activity
data
and
fitness
data
from
our
online
offer
into
the
"Google
Fit"
/
„Google
Health
Connect“
application
of
Google
Ireland
Limited,
Gordon
House,
Barrow
Street,
Dublin
4,
Ireland.
In
the
process,
Google
Fit
/
Google
Health
Connect
receives
the
following
data,
among
others:
start
and
end
time
of
a
completed
activity,
duration,
distance
traveled,
speed,
calories.
It
makes
these
available
to
you
in
Google
Fit
/
Google
Health
Connect.
You
have
the
option
to
break
this
connection
between
the
accounts
at
any
time.
It
is
not
excluded
that
Google
Fit
/
Google
Health
Connect
processes
this
information
at
locations
outside
the
EU
or
the
EEA/Switzerland
(e.g.
in
the
USA).
The
legal
basis
for
processing
the
data
to
provide
the
service
is
the
contract.
The
legal
basis
for
the
transfer
of
data
to
Google
Fit
/
Google
Health
Connect
is
your
consent.
For
more
information
about
the
processing
of
your
personal
data
at
Google
Fit
/
Google
Health
Connect
and
your
rights
as
a
data
subject,
as
well
as
setting
options
for
protecting
your
privacy,
please
refer
to
the
privacy
notices
of
Google
https://safety.google/
.
eBike
Systems
3.3.3
Telenav
In
order
to
be
able
to
offer
you
the
navigation
and
route
calculation
function
with
additional
functionalities
such
as
topographical
range
measurement
or
use
in
offline
mode,
we
use
the
map
material
"p.b.
Scout"
from
Telenav
GmbH,
Fasanenstr.
81,
10623
Berlin,
Germany
("Telenav").
Here,
in
addition
to
the
IP
address,
your
location
as
well
as
search
and
route
data,
including
your
current
location,
the
address
of
your
destination,
the
start
time
of
your
journey
and
the
route
calculated
for
you,
are
stored
and
transmitted
to
Telenav,
unless
the
offline
function
is
used.
During
an
active
navigation
session,
data
about
your
current
location,
data
from
sensors
on
your
eBike,
GPS
direction
of
movement,
and
speeds
may
also
be
collected
and
processed
to
provide
you
with
route
information.
Telenav
is
responsible
for
the
processing
of
your
personal
data
under
data
protection
law.
It
is
not
excluded
that
Telenav
processes
this
information
at
locations
outside
the
EU
or
the
EEA/Switzerland
(e.g.
in
the
USA).
The
legal
basis
for
processing
the
data
to
provide
the
Service
is
the
Contract.
Telenav's
privacy
notice
can
be
found
at
the
following
link:
https://www.telenav.com/legal/policies-privacy-policy
.
3.3.4
Strava
Our
website
gives
you
the
option
of
exporting
certain
activity
data,
such
as
times,
distances
travelled,
calories
burned,
as
well
as
heart
rate
and
position
data,
elevation,
speeds
or
cadence,
to
the
Strava
external
portal
so
you
can
share
this
information
there.
For
this
purpose,
we
use
the
social
plugin
from
Strava
Inc,
500
3rd
Street,
110,
San
Francisco,
CA
94107,
USA.
It
is
possible
that
Strava
may
process
this
information
at
locations
outside
the
EU
or
the
EEA/Switzerland
(e.g.
in
the
US).
The
legal
basis
for
the
processing
of
data
to
provide
the
service
is
the
Contract.
The
legal
basis
for
the
transfer
of
data
to
Strava
is
your
consent.
For
information
about
the
processing
of
your
personal
data
and
your
rights
as
a
data
subject,
please
refer
to
Strava's
privacy
policy
at
https://www.strava.com/legal/privacy
.
3.3.5
Komoot
We
offer
Komoot's
Profile
Connect
function,
which
is
operated
by
komoot
GmbH,
Friedrich-Wilhelm-Boelcke-Straße
2,
14473
Potsdam,
Germany.
When
you
activate
the
Komoot
"Profile
Connect
function"
in
the
authorisation
dialogue,
the
routes
you
plan
on
Komoot
are
synchronised
with
your
Bosch
profile,
and
your
Bosch
activities
are
synchronised
with
your
Komoot
account.
This
involves
an
exchange
of
data
between
us
and
Komoot,
whereby
we
receive
the
route
information
planned
on
Komoot
and
make
it
available
to
you
via
the
"My
Routes"
function,
and
Komoot
receives
the
recorded
activity
data
(including
trip
times,
distances,
speeds,
and
position
and
elevation
data)
from
us
–
if
available.
You
can
end
this
connection
between
the
accounts
at
any
time.
It
is
possible
that
Komoot
may
process
this
information
at
locations
outside
the
EU
or
the
EEA/Switzerland
(e.g.
in
the
US).
The
legal
basis
for
the
processing
of
data
to
provide
the
service
is
the
Contract.
The
legal
basis
for
the
transfer
of
data
to
Komoot
is
your
consent.
For
more
information
about
how
Komoot
processes
your
personal
data
and
your
rights
as
a
data
subject,
as
well
as
settings
options
to
protect
your
privacy,
please
refer
to
Komoot's
privacy
policy
at
https://www.komoot.de/privacy
.
4.
App
analysis
eBike
Systems
We
need
statistical
information
about
the
use
of
our
online
offer
in
order
to
make
it
more
user-friendly,
to
measure
reach
and
to
conduct
market
research.
For
this
purpose,
we
use
the
app
analysis
tool
described
in
this
section.
The
tool
provider
only
processes
data
as
a
processor
in
accordance
with
our
guidelines
and
not
for
its
own
purposes.
Below
you
will
find
information
on
the
individual
tool
providers.
Google
Firebase
In
our
online
offer,
we
use
Google
Firebase,
a
service
of
Google
Inc.
1600
Amphitheatre
Parkway,
Mountain
View,
CA
94043,
USA,
("Firebase")
to
develop
and
enhance
mobile
applications.
In
doing
so,
Google
processes
data
on
our
behalf.
We
use
several
features
from
Firebase
in
our
app.
(a)
Firebase
Analytics
We
use
Firebase
Analytics
to
continuously
improve
our
app
and
develop
new
products
and
services.
It
analyses
user
interaction,
i.e.
how
you
use
the
app,
which
functions
of
the
app
you
access,
how
often
you
open
the
app
or
when
the
app
is
uninstalled.
This
information
helps
us
to
further
develop
our
platform
and
app
and
to
adapt
them
to
the
needs
of
our
users.
The
data
is
only
processed
in
pseudonymised
form
and
used
for
evaluations
for
statistical
purposes
and
transmitted
to
Google.
On
our
behalf,
Google
evaluates
this
usage
analysis
(e.g.
in
comparison
to
other
apps)
and
provides
results
and
further
services
based
on
this.
The
advertising
ID
of
your
device
is
used
for
evaluation
by
Google
Inc.
You
have
the
option
of
restricting
access
to
the
device
ID
of
your
mobile
device
in
the
device
settings.
The
legal
basis
for
this
processing
is
the
legitimate
interest.
The
legitimate
interest
of
Bosch
eBike
Systems
is
to
optimise
its
own
products
and
thus
to
maintain
or
promote
your
satisfaction.
(b)
Crashlytics
In
addition,
we
use
the
Firebase
function
"Crashlytics"
to
stabilise
and
improve
our
apps.
In
the
process,
data
is
collected
about
the
end
device
you
use
and
the
use
of
our
apps
(device
ID
and
the
time
stamp,
when
the
respective
app
was
started
and
when
a
malfunction
occurred),
which
enables
us
to
diagnose
and
rectify
malfunctions.
When
using
Firebase
Crashlytics,
your
data
is
processed
by
us
in
pseudonymised
form
–
without
a
user
ID.
Google
assures
in
its
Firebase
privacy
policy
that
this
data
is
not
merged
with
other
data
and
thus
no
conclusions
can
be
drawn
about
your
person.
The
legal
basis
for
this
processing
is
the
legitimate
interest.
The
legitimate
interest
of
Bosch
eBike
Systems
is
to
optimise
its
own
products
and
services,
to
develop
new
products
and
services
and
thus
to
maintain
or
increase
your
satisfaction.
(c)
Firebase
Cloud
Messaging
In
addition,
we
use
the
"Firebase
Cloud
Messaging"
service
to
send
you
technically-related
push
notifications
or
in-app
messages
to
your
device.
In
the
process,
your
device
is
assigned
a
pseudonymised
device
token
ID,
a
unique
connection
number
generated
from
the
device
ID,
which
we
use
to
address
the
push
messages
or
in-app
messages
to
you.
Google
acts
here
as
a
service
provider
on
our
behalf.
The
legal
basis
for
this
processing
is
the
Contract.
eBike
Systems
As
a
result
of
the
settings
we
make,
personal
data
(device
ID)
is
processed
and
stored
to
the
extent
possible
in
the
member
states
of
the
European
Union
or
in
other
countries
that
are
party
to
the
Agreement
on
the
European
Economic
Area
and
Switzerland.
Google
assures
that
personal
data
are
processed
within
the
EU
or
the
EEA
and
Switzerland.
5.
Use
of
cookies
Cookies
and
tracking
mechanisms
may
be
used
in
the
context
of
our
online
offer.
Cookies
are
small
text
files
that
can
be
stored
on
your
device
when
you
visit
our
online
offer.
Tracking
is
possible
using
various
technologies.
In
particular,
we
process
information
using
pixel
technology
and/or
log
file
analysis.
5.1
Categories
We
distinguish
between
cookies
that
are
absolutely
necessary
for
the
technical
functions
of
the
online
offer,
and
such
cookies
and
tracking
mechanisms
that
are
not
absolutely
necessary
for
the
technical
function
of
the
online
offer.
In
principle,
the
use
of
the
online
offer
is
also
possible
without
cookies
that
do
not
serve
technical
purposes.
5.1.1
Technically
essential
cookies
By
technically
essential
cookies
we
mean
cookies
without
which
the
technical
provision
of
the
online
offer
cannot
be
guaranteed.
These
include,
for
example,
cookies
that
store
data
to
ensure
smooth
playback
of
video
or
audio
material.
Such
cookies
are
deleted
when
you
leave
the
website.
5.1.2
Cookies
and
tracking
mechanisms
that
are
not
technically
necessary
We
only
use
cookies
and
tracking
mechanisms
if
you
have
given
us
your
prior
consent
in
each
case.
The
cookie
that
saves
the
current
status
of
your
privacy
settings
(selection
cookie)
is
an
exception.
This
cookie
is
set
on
the
basis
of
legitimate
interest.
For
these
cookies
and
tracking
mechanisms,
we
distinguish
between
two
subcategories:
●
Comfort
Cookies
These
cookies
facilitate
the
operation
and
thus
enable
you
to
surf
our
online
offer
more
comfortably;
e.g.
your
language
settings
may
be
included
in
these
cookies.
Comfort
cookies
are
not
currently
used
on
the
website.
●
Marketing
cookies
Through
the
use
of
marketing
cookies,
we
and
our
partners
are
able
to
show
you
offers
based
on
your
interests,
which
result
from
an
analysis
of
your
user
behaviour.
●
Analysis
mechanisms
We
use
analysis
mechanisms
to
compile
anonymous
statistics
on
the
use
of
our
services,
such
as
the
number
of
page
views.
With
the
help
of
such
evaluations,
we
can
improve
our
online
offer
or
develop
new
products
and
services.
We
use
the
following
tools:
Name:
Google
Tag
Manager
Provider:
Google
Ireland
Limited,
Gordon
House,
Barrow
Street,
Dublin
4,
Ireland
eBike
Systems
Function:
Management
of
website
tags
via
an
interface,
integration
of
program
code
on
our
websites.
Name:
Google
Analytics
Provider:
Google
Ireland
Limited,
Gordon
House,
Barrow
Street,
Dublin
4,
Ireland
Function:
Analysis
of
user
behaviour
(page
views,
number
of
visitors
and
visits,
downloads),
creation
of
pseudonymous
user
profiles
based
on
cross-device
information
of
logged-in
Google
users
(cross-device
tracking),
enrichment
of
pseudonymous
user
data
with
target
group-specific
information
provided
by
Google,
retargeting,
UX
testing,
conversion
tracking
and
retargeting
in
conjunction
with
Google
Ads.
The
legal
basis
for
this
processing
of
this
data
your
consent.
5.2
Management
of
cookies
and
tracking
mechanisms
You
can
manage
your
cookie
and
tracking
mechanism
settings
in
the
browser
and/or
in
our
privacy
settings.
Note:
The
settings
you
choose
only
relate
to
the
browser
you
use.
●
Disabling
all
cookies
If
you
want
to
disable
all
cookies,
please
disable
cookies
in
your
browser
settings.
Please
note
that
this
may
affect
the
functionality
of
the
website.
●
Managing
your
settings
regarding
cookies
and
tracking
mechanisms
that
are
not
technically
necessary
When
you
visit
our
websites,
you
will
be
asked
in
a
cookie
layer
whether
you
agree
to
our
use
of
comfort
cookies,
marketing
cookies
or
tracking
mechanisms.
In
our
privacy
settings,
you
can
revoke
the
consent
with
future
effect
or
give
us
your
consent
at
a
later
date.
6.
Duration
of
storage;
retention
periods
We
always
store
your
data
for
as
long
as
is
necessary
for
the
provision
of
our
online
offer
and
the
associated
services
or
as
long
as
we
have
a
legally
recognised
legitimate
interest
in
continued
storage.
In
all
other
cases,
we
delete
your
personal
data,
with
the
exception
of
data
that
we
must
retain
in
order
to
fulfil
legal
obligations,
e.g.
we
are
required
by
tax
and
commercial
law
to
retain
documents
such
as
contracts
and
invoices
for
a
certain
period
of
time.
Otherwise,
you
can
delete
all
your
data
directly
from
the
app
at
any
time.
7.
Security
We
use
all
necessary
technical
and
organisational
measures
to
ensure
an
adequate
level
of
protection
and
to
protect
your
data
under
our
management,
in
particular
against
the
risks
of
accidental
or
unlawful
destruction,
manipulation,
loss,
alteration
or
unauthorised
disclosure
or
access.
Our
security
measures
are
constantly
being
improved
in
line
with
technological
developments.
eBike
Systems
8.
Your
rights
according
to
Art.
12
ff.
GDPR
and/or
according
to
the
Swiss
Federal
Data
Protection
Act
To
assert
your
rights,
please
use
the
information
in
the
section
"Responsible
parties
and
contact"
(see
point
1).
In
doing
so,
please
ensure
that
we
can
clearly
identify
you.
Please
address
your
claims
listed
below
to
https://request.privacy-bosch.com/entity/RB/
.
8.1
Right
to
information
and
disclosure
You
have
the
right
to
receive
information
from
us
about
the
processing
of
your
data.
Taking
into
account
the
transparency
requirements,
we
have
designed
our
web
offer
and
our
app
in
such
a
way
that
you
can
access
the
most
important
information
about
yourself
in
a
well-structured
and
detailed
manner
directly
via
our
platform
and
app
electronically
and
in
an
independent
manner
at
any
time.
Of
course,
you
also
have
the
option
of
contacting
us
directly
using
the
contact
addresses
above,
especially
if
you
would
like
information
about
the
storage
of
personal
data
in
the
context
of
customer
service
or
about
a
specific
processing
operation.
8.2
Right
to
correction
and
deletion
You
can
demand
from
us
the
correction
of
incorrect
data
and
-
provided
the
legal
requirements
are
met
–
the
completion
or
deletion
of
your
data.
In
addition,
you
have
the
option
to
correct,
amend
or
delete
your
data
directly
on
our
platform
or
in
the
app.
If
data
is
not
allowed
to
be
deleted
due
to
legal
requirements,
processing
is
restricted
until
deletion
(see
below).
8.3
Restriction
of
processing
You
can
demand
from
us
–
provided
the
legal
requirements
are
fulfilled
–
that
the
processing
of
your
data
is
restricted.
8.4
Data
transferability
You
also
have
the
right
to
receive
data
that
you
have
made
available
to
us
in
a
structured,
standard
and
machine-readable
format
or
–
if
technically
feasible
–
to
demand
that
the
data
be
transferred
to
a
third
party.
For
this
purpose,
we
have
provided
you
with
appropriate
export
functionalities
and
various
formats
on
our
platform.
8.5
Right
of
withdrawal
and
right
of
objection
8.5.1
Individual
right
of
objection
If
we
process
data
on
the
basis
of
a
legitimate
interest
(Art.
6
Para.
1
letter
f,
GDPR),
as
set
out
in
this
privacy
policy,
you
have
the
right
to
object
to
this
processing
at
any
time.
To
do
so,
please
contact
the
addresses
described
above
(see
section
1).
We
will
then
stop
processing
your
data
unless
other
legal
grounds
legitimise
this
processing
or
there
is
an
overriding
legitimate
interest
of
Robert
Bosch
GmbH
in
processing
your
data
(e.g.
if
the
further
processing
serves
the
assertion,
exercise
or
defence
of
legal
claims).
The
legality
of
the
processing
of
your
data
up
to
the
time
of
the
objection
remains
unaffected
by
this.
It
may
also
be
the
case
that
certain
services
can
no
longer
be
made
available
to
you.
eBike
Systems
8.5.2
Right
to
revoke
consent
If
you
have
given
us
consent
to
process
your
data,
you
can
revoke
this
consent
at
any
time
with
effect
for
the
future.
This
also
applies
to
the
revocation
of
declarations
of
consent
made
to
us
before
the
GDPR
came
into
force,
i.e.
before
25
May
2018.
To
do
so,
please
contact
the
addresses
described
above
(point
1).
In
our
portal,
you
can
deactivate
granted
consents
for
certain
processing
operations
yourself.
The
legality
of
the
processing
of
your
data
until
revocation
remains
unaffected
by
this.
Please
note
that
in
the
event
of
revocation
of
consent,
certain
services
cannot
be
provided
for
technical
reasons,
as
they
necessarily
require
the
processing
of
personal
data.
This
does
not
apply
to
objections
relating
to
the
receipt
of
electronic
advertising.
We
automatically
delete
the
data
when
the
purpose
of
the
processing
has
ceased
to
exist
or
you
have
revoked
your
consent
and
there
is
no
other
legal
basis
for
the
data
processing.
If
the
latter
applies,
we
delete
the
data
after
the
other
legal
basis
no
longer
applies.
8.6
Right
of
appeal
to
the
supervisory
authority
You
have
the
right
to
file
a
complaint
with
a
data
protection
supervisory
authority.
For
this
purpose,
you
can
contact
the
data
protection
supervisory
authority
responsible
for
your
place
of
residence
or
your
federal
state
or
the
data
protection
supervisory
authority
responsible
for
us.
The
data
protection
supervisory
authority
responsible
for
us
is
the
State
Commissioner
for
Data
Protection
and
Freedom
of
Information
Baden-Württemberg.
9.
Changes
to
this
privacy
policy
We
reserve
the
right
to
change
our
security
and
data
protection
measures
as
far
as
it
becomes
necessary
due
to
technical
developments.
In
these
cases,
we
will
also
adapt
our
privacy
policy
accordingly.
Please
therefore
note
the
current
version
of
our
privacy
policy.
Date:
22.05.2025