ADDITIONAL RSP TELEMATICS DATA PROTECTION DECLARATION

 

This additional Data Protection Declaration (“Data protection declaration“) about RSP TELEMATICS supplements the General Data protection declaration of the RSP GmbH (“RSP“). Detailed information with regard to the data protection rights granted to you from the GDPR can be found in the General Data Protection Declaration. The purpose of this additional Data Protection Declaration is to call your attention to any activities regarding the data processing of RSP TELEMATICS.

 

1. What is RSP TELEMATICS

The RSP company equips the vehicles at the factory with an LTE radio module (SIM card with LTE modem) and a telemetry module (GPS receiver, CAN-BUS based function control and vehicle operating data acquisition). Internet connectivity allows centralised evaluation of operating and location data collected in the vehicle, function control as well as remote diagnosis and remote maintenance of the superstructures, provided that the customer requests this.

These functions (geolocation of the vehicles of the customer, evaluation of operating data, deactivation / activation of vehicle functions) for the vehicle and fleet management are provided to the customer via the Webportal (collectively called “RSP TELEMATICS”) by the RSP company. To do so, the individual vehicles send the required telemetry data to the RSP.

 

2. What data is processed?

When customers and their users are using RSP TELEMATICS, we collect and process the following data:

  • Vehicle information: e.g. Vehicle identification number, the vehicle model; 
  • Operating data of the RSP superstructures: e.g. speeds, pressures, functions and their service life, signal strength of the radio module;
  • User profile data of the Webportal; e.g. name and email address of the connected user;
  • Location information: GPS data, which were extracted to determine the location of the vehicle of registered customers - also if the vehicle of the customer has been stolen;
  • Path information; e.g. driving speed, average speed, distance travelled as well as travel and parking duration of the vehicle of registered customers;
  • Control data: e.g. activated and deactivated functions of the RSP superstructures, error codes;
  • pseudonymous location data: GPS data which were extracted to determine the use region of RSP vehicles once RSP superstructures are used.

 

3. What purposes serves the processing of what legal basis?

To be able to use the Webportal, the customer must initially agree to the terms of use in the Webportal. The legal basis for the possibly required processing of personal data by the RSP to provide vehicle and fleet management services is Art. 6 Para 1, lit. b GDPR.

Additionally, the RSP uses this data for research and analysis purposes within the framework of legitimate interest (Art. 6 Para 1, lit. f GDPR), to improve RSP products and services and to develop new vehicle functions, but also to protect against unjustified correction of fault claims. During the process, the use for development, research and analysis purposes takes place in a pseudonymised or anonymised way for statistical evaluations in aggregated form.

The RSP can process this data to the required extent to comply with a legal obligation to protect the rights of the RSP and to cooperate in case of police investigations in order to react to legal rights (including disclosure of information in connection with legal proceedings) and to cooperate in case of police investigations concerning RSP vehicles. 

 

4. Who is the person responsible?

Customers registered in the Webportal process the provided operating, location and control data for own purposes as the legal data protection officer in the sense of Art. 4 No. 7 GDPR. Particularly in view of other users of the vehicles, the data processed in the Webportal can be considered as person-related provided that the spatial and material scope of the GDPR is opened.

Both parties, the RSP company as operator of the Webportal for RSP TELEMATICS and the customer, then process the above mentioned types of data as collectively responsible ones and have made an agreement on that according to Art. 26 GDPR.

 

5. How you can contact the RSP?

You can contact the RSP at any time:

RSP GmbH
Zum Silberstollen 10
D-07318 Saalfeld/Saale

Phone: +49 36 71 57 21 0
Fax: +49 36 71 57 21 21
E-Mail: info@rsp-germany.com

If you have any questions about this data protection statement, contact the data protection officers. You can reach our operational business data protection officer under the above-mentioned contact data: to the attention of the data protection officer as well as by email under datenschutz@rsp-germany.com 

 

6. What recipients get data?

Further recipient of this data, apart from both parties, are service providers entrusted by RSP with the processing (hosts of the Webportal, software developers).

 

7. How can you assert your rights?

Persons concerned by the data processing can assert their rights towards both responsible parties within the framework of the GDPR. Further information about the data protection with the RSP and the rights of persons concerned arising form the GDPR are available on www.rsp-germany.com/datenschutz

 

8. Duration of storage

The RSP retains your personal data as long as required in order to comply with the purposes stated hereunder. That means that the RSP retains you personal data as long as the customer prompts the RSP to deactivate their account or a user stops individual data processing. Longer retention periods might be valid to the extent required by law or in case of a legal claim. In such cases, the relevant data is retained as specified by law or for the duration of the claim. Among other things, RSP will retain anonymised data for longer periods for the purpose of developing new vehicles as well as for research and analysis purposes, also to improve RSP TELEMATICS.

 

9. Updating of this data protection declaration

This data protection declaration can be regularly updated. We will update the date above and recommend to check it regularly for changes.

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