DATA PROTECTION NOTICE
grow platform GmbH (hereinafter “grow” 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. GROW RESPECTS YOUR PRIVACY
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 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.
grow platform GmbH is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows:
grow platform GmbH
Dr. Karsten Rönner, Holger Hoffmann, Georg Stellmann
3. COLLECTION, PROCESSING AND USAGE OF PERSONAL DATA
3.1 Processed categories of data
The following categories of data are processed:
- Communication data (e.g. name, telephone, e-mail, address, IP address)
- Contractual master data (e.g. contractual relationships, contractual or pro-duct interest)
- Client history
- Contract accounting and payment data
- Planning and regulation data
- Transaction data
- Provision of information (from third parties, e.g. credit reference agencies or from public directories)
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.
3.3 Processing purposes and legal basis
We as well as the service providers commissioned by us; process your personal data for the following processing purposes:
- 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). (Legal basis: Fulfillment of contractual obligations. The following conditions apply: General Terms and Conditions).
- Online store with credit assessment: Provision of these Online Offers and fulfillment of contractual obligations under our contractual terms including invoicing and prior credit assessment. Invoicing may include the sale of claims.(Legal basis: Fulfillment of contractual obligation respectively our legitimate interest in an efficient claims management and in avoiding claim defaults as regards the sale of claims and the credit assessment.
- Resolving service disruptions as well as for security reasons: (Legal basis: Fulfillment of our legal obligations within the scope of data security and legitimate interest in resolving service disruptions as well as in the protection of our offers).
- Advertisements and/or market research (including web analysis, no customer surveys): 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 / 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 for safeguarding and defending our rights).
If you wish to use or get access to benefits requiring to enter into the fulfillment of a contract, we request your registration. With your registration we collect personal data necessary for entering into the fulfillment of the contract (e.g. first name, last name, email address, if applicable, details on the preferred payment method or on the account holder ) as well as further data on voluntary basis, if applicable. Mandatory information is marked with an *.
3.5 Log files
Each time you use the internet, your browser is transmitting certain information which we store in so-called log files.
We store log files to determine service disruptions and for security reasons (e.g., to investigate attack attempts) for a period of at least 4 weeks and a maximum of 1 year 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) see module “Advertisements and/or market research (including web analysis, no customer surveys)”.
In log files, the following information is saved:
- IP address (internet protocol address) of the terminal device used to access the Online Offer;
- Internet address of the website from which the Online Offer is accessed (so-called URL of origin or referrer URL);
- Name of the service provider which was used to access the Online Offer;
- Name of the files or information accessed;
- Date and time as well as duration of recalling the data;
- Amount of data transferred;
- Operating system and information on the internet browser used, including add-ons installed (e.g., Flash Player);
- http status code (e.g., “Request successful” or “File requested not found”).
This Online Offer is not meant for children under 16 years of age.
3.7 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 basis and the recipients or categories of recipients can be found in the Section - Processing purposes and legal basis.
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.
3.8 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 with the statutory provisions. Service providers may also be other Bosch group companies.
3.9 Payment service providers
We involve external payment service providers.
We use the following company as a payment service provider:
Bosch Service Solutions Magdeburg GmbH
Telephone: +49 391 59081988
3.10 Claims management
We reserve the right to have claims collected by external service providers.
Additionally, we have a legitimate interest in selling claims to third parties and in transferring data necessary for the collection of the claim to the respective buyer of the claim. During claim collection, claim buyers act in their own name and are themselves responsible for processing the data. In this respect, the data protection notices of the respective claim buyer apply.
We sell claims to the following company:
Bosch Service Solutions Magdeburg GmbH
Telephone: +49 391 59081988
3.11 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 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.
3.12 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 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).
3.13 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:
SCHUFA Holding AG
65201 Wiesbaden, Germany
infoscore Consumer Data GmbH
76532 Baden-Baden, Germany
4. 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.
4.2 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.
4.3 Cookies and tracking mechanisms that are technically not required
We distinguish between two sub-categories with regard to these cookies and tracking mechanisms:
4.4 Comfort cookies
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.
4.5 Marketing cookies and tracking mechanisms
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. This can also be done across multiple devices. 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 Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Function: Analysis of user behavior (page retrievals, 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
Name: Google Tag Manager
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Function: Administration of website tags via a user interface, integration of program codes on our websites
Provider: HubSpot Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141, USA
4.6 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.
4.7 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.
4.8 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 Comfort 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.
5. SOCIAL PLUGINS
In our Online Offers we use so-called social plugins from various social networks. They are individually described in this section.
When using plugins, your internet browser creates a direct connection to the respective social networks’ server. Hereby the respective provider receives the information that your internet browser accessed from the respective site of our Online Offers - even if you do not have a user account with this provider or are currently not logged into your account. Log files (including the IP address) are, in this case, directly transmitted from your internet browser to a server of the respective provider and might be stored there. The provider or its server may be located outside the EU or the EEA (e.g. in the United States).
The plugins are standalone extensions by social network providers. For this reason, we are unable to influence the scope of data collected and stored by them.
Purpose and scope of the collection, the continued processing and usage of data by the social network as well as your respective rights and setting options to protect your privacy can be found by consulting the respective social network's data protection notices.
In case you do not wish social network providers to receive and, if applicable, store or use data, you should not use the respective plugins.
5.1 LinkedIn plugins
LinkedIn is operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA ("LinkedIn").
Find an overview over plugins of LinkedIn and their appearance here:
Find information on data protection at LinkedIn here:
Our Online Offers use the YouTube video platform which is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland („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.
6. EXTERNAL LINKS
Our Online Offers 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.
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.
8. 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.
8.1 Right to information and access
You have the right to obtain confirmation from us about whether or not your personal data is being processed, and, if this is the case, access to your personal data.
8.2 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).
8.3 Restriction of processing
As far as statutory requirements are fulfilled you have the right to demand for restriction of the processing of your data.
8.4 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.
8.5 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.
8.6 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.
8.7 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.
8.8 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:
State Commissioner for Data Protection and Freedom of Information
70173 Stuttgart, GERMANY
P.O. Box 10 29 32
70025 Stuttgart, GERMANY
Phone: +49 (711)/615541-0
Fax: +49 (711)/615541-15
9. CHANGES TO 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.
If you wish to contact us, please find us at the address stated in the "Controller" section.
To assert your rights please use the following link:
To notify data protection incidents please use the following link:
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 (C/ISP)
Robert Bosch GmbH
P.O. Box 30 02 20
70442 Stuttgart, GERMANY
Effective date: 2022.04.08