This privacy notice provides information on the processing of personal data within the scope of the telematics service RSP Connect in addition to the General Privacy Notice of RSP GmbH ("RSP"). You will find detailed information regarding your data protection rights under the GDPR in the General Privacy Notice. The purpose of the RSP Connect Privacy Notice is to make you aware of any activities relating to data processing on RSP Connect.

I. What is RSP Connect?

(1) RSP GmbH equips the vehicles at the factory with a combined mobile radio module (SIM card with LTE modem) and telemetry module (GPS receiver, CAN bus-supported function control and machine data collection) also referred to as CU. The internet connectivity enables the centralised evaluation and accessibility of machine and location data collected in the vehicle, the function control as well as remote diagnosis and remote maintenance of the superstructures, if requested by the end customer.

(2) These functions (geolocation of the end customer's vehicles, evaluations of machine data, the de-/activation of vehicle functions) are provided to the end customer for vehicle and fleet management via a web portal (together "RSP Connect") by RSP GmbH. For this purpose, the individual vehicles send the required telemetry data to RSP GmbH.

II. Which data will be processed?

(1) When end customers and their end users use RSP Connect, RSP processes the following data in the process:

• Vehicle information: e.g. vehicle identification number (VIN), vehicle model
• Machine data of the RSP superstructures: e.g. speeds, pressures, functions and their duration of use, signal strengths of the radio module
• User profile data of the web portal: e.g. name and e-mail address of the connected user
• Location information: GPS data extracted to determine the location of the vehicle of registered end users - even if the end user's vehicle has been stolen
• Route information: e.g. driving speed, average speed, distance travelled, and driving and parking time of the registered end-user's vehicle;  Control data: e.g. activated or deactivated functions of RSP bodies, error codes
• pseudonymous location information: GPS data extracted to determine the region of use of RSP vehicles once RSP bodies are in use.
• Survey data: e.g. when end customers of the RSP leave feedback. This can be done anonymously.

III. What purposes the processing serve and on what legal basis?

(1) In order to be able to use the web portal, the end customer must initially agree to the end user contract for RSP Connect in the web portal. The legal basis for the processing of personal data by RSP GmbH that may be necessary for the contractual provision of the vehicle and fleet management services is Art. 6 Para. 1 lit. b GDPR.

(2) RSP also uses this data for research, development and analysis purposes within the scope of the legitimate interest (Art. 6 para. 1 lit. f GDPR) in order to improve RSP products and customer services as well as to develop new machine functions, where possible, pseudonymised or anonymised for statistical evaluations. In addition, the OEM processes the machine data to fulfil the product monitoring and traffic safety obligation. Location data is processed by RSP for statistical evaluations of regions of use, for planning and expansion of the service partner network, but also in order to be able to support the end customer in any investigations in the event of theft or loss during transfers.

(3) RSP and the end customer process machine data in order to be able to derive machine-specific service intervals which, for example, trigger invitations to service inspections by authorised specialist workshops (individual customer service) or make claims for rectification of defects objectively verifiable.

(4) The RSP may process this data to comply with a legal obligation, to cooperate with police investigations and to protect the rights of the RSP to the extent necessary to respond to legal claims (including disclosure of information in connection with legal proceedings) and to cooperate with police investigations involving RSP vehicles.

(5) RSP may give end customers the opportunity to leave feedback in the web portal. Clicking on the Feedback link opens a form on the website of our order processor Google Ireland Ltd.

IV. Who is the data controller and to whom can I assert my rights?

(1) End customers registered in the Web Portal process the machine, location and control data provided for their own purposes as the data controller within the meaning of Article 4 No. 7 of the Data Protection Regulation. In particular with regard to other users of their vehicles, the data processed in the web portal can be considered personal data, insofar as, for example, the spatial and factual scope of application of the GDPR is opened up. RSP GmbH, as the operator of the web portal for RSP Connect, processes the types of data listed in section 2 (1) for the end customer as its order processor. Both parties have entered into a corresponding agreement in accordance with Art. 28 GDPR.

(2) With regard to the data processed by RSP in accordance with section 3 (2), both parties are deemed to be jointly responsible. Both parties have entered into a corresponding agreement in accordance with Art. 26 GDPR in which they have also regulated the obligations with regard to the exercise of the rights of data subjects. The point of contact for data subjects is the end customer. However, data subjects can assert their rights under Chapter III of the GDPR against both RSP and the end customer (as a rule, the end customer is the employer).

(3) How can you contact RSP?

RSP GMBH
Zum Silberstollen 10
07318 Saalfeld/Saale
Germany
Phone +49 36 71 57 21 0
Fax +49 36 71 57 21 21
E-mail: info@rsp-germany.com

(3) If you have any questions about this data protection information, please do not hesitate to contact RSP's data protection officer. You can reach our company data protection officer at the above contact details for the attention of the data protection officer or by e-mail at datenschutz@rsp-germany.com.

(4) Further information on data protection at RSP GmbH and the rights of affected persons arising from the GDPR is available at www.rsp-germany.com/datenschutz.

V. Which recipients receive data?

1) Other recipients of this data, in addition to the two parties, are the service provider contractually bound by RSP (hoster of the web portal, software manufacturer).

2) With the use of the feedback link in the web portal, data processing takes place on cloud-based servers of our cloud provider Google Ireland Ltd. In doing so, we use so-called standard contractual clauses on data protection, which have been approved by the European Commission. These standard contractual clauses are intended to guarantee an adequate level of data protection, in particular legally binding and enforceable rights, to individuals affected by processing in insecure third countries. For more information, including to request a copy of the documents used to protect your data, please contact us.

VI. How long do we retain personal data?

1) RSP processes any personal data for as long as the aforementioned purposes require. This means that RSP will store your personal data until the customer requests RSP to delete his account or an end customer stops individual data processing or RSP has made the data anonymous.

(2) In the event of a legal claim, longer retention periods may apply. In such cases, the relevant data will be retained as required by law or for the duration of the claim.

(3) RSP will process anonymised data for, among other things, the purpose of developing new vehicles and for research and analysis purposes for longer periods of time, also in order to improve RSP Connect.

VII. Updating of this data protection noticE

(1) This privacy notice may be updated. We will update the date above accordingly and recommend that you check this document regularly for changes.