11
March
2026
1
/
6
R
S
P
G
m
b
H
&
C
o
.
K
G
P
r
i
v
a
c
y
P
o
l
i
c
y
f
o
r
t
h
e
R
S
P
C
o
n
n
e
c
t
S
e
r
v
i
c
e
RSP
CONNECT
PRIVACY
NOTICE
This
privacy
notice
provides
information
on
the
processing
of
personal
data
in
connection
with
the
RSP
Connect
telematics
service,
supplementing
the
general
privacy
notice
of
RSP
GmbH
&
Co.
KG
(“RSP”)
available
at
and
.
Detailed
information
regarding
your
data
protection
rights
under
the
GDPR
can
be
found
in
the
general
privacy
notice.
The
purpose
of
the
RSP
Connect
Privacy
Notice
is
to
inform
you
about
all
activities
relating
to
data
proces-
sing
at
RSP
Connect.
I.
What
is
RSP
Connect?
(1)
RSP
GmbH
&
Co.
KG
equips
vehicles
at
the
factory
with
a
combined
mobile
communications
module
(SIM
card
with
4G
modem)
and
telemetry
module
(GPS
receiver,
CAN
bus-based
function
control
and
machine
data
acquisition),
also
referred
to
as
the
CU.
Internet
connectivity
enables
the
centralised
analysis
and
provision
of
machine
and
location
data
collected
in
the
vehicle,
as
well
as
the
control
of
functions
and
remote
diagnosis
and
maintenance
of
the
superstructures,
provided
the
customer
re-
quests
these
services.
(2)
These
functions
(geolocation
of
the
end
customer’s
vehicles,
analysis
of
machine
data,
and
the
activa-
tion/deactivation
of
vehicle
functions)
are
provided
to
the
end
customer
for
vehicle
and
fleet
manage-
ment
via
a
web
portal
and
a
mobile
app
(together
‘RSP
Connect’
)
by
RSP
GmbH
&
Co.
KG.
To
this
end,
the
individual
vehicles
transmit
the
necessary
telemetry
data
to
RSO.
II.
What
data
is
processed?
(1)
When
end
customers
and
their
end
users
use
RSP
Connect,
RSP
processes
the
following
data:
•
Vehicle
information:
e.g.
Vehicle
Identification
Number
(VIN),
the
vehicle
model;
•
Machine
data
from
RSP
superstructures:
e.g.
speeds,
pressures,
functions
and
their
operating
times,
signal
strengths
of
the
radio
module;
•
User
profile
data
from
the
web
portal:
e.g.
name
and
email
address
of
the
connected
user;
•
Location
information
:
minute-by-minute
GPS
coordinates
of
the
vehicle,
which
were
extracted
to
determine
the
location
of
the
vehicle
of
registered
end
customers
–
even
if
the
end
customer’s
vehicle
has
been
stolen;
•
Journey
information:
e.g.
driving
speed,
average
speed,
distance
travelled,
and
the
duration
of
journeys
and
parking
periods
for
the
vehicle
of
registered
end
customers;
•
Control
data:
e.g.
activated
or
deactivated
functions
of
the
RSP
superstructures,
error
codes;
•
Pseudonymous
location
information:
GPS
data
extracted
to
determine
the
region
of
use
of
RSP
vehicles
as
soon
as
RSP
systems
are
in
use;
•
Contract
data:
e.g.
subscription
status,
company
name
and
address,
as
well
as
the
name
and
contact
details
of
the
contact
person
(main
user);
•
Usage
and
user
data:
e.g.
username
and
password,
assigned
roles
and
rights
in
the
web
portal,
user
activities
including
timestamps
and
accessed
resources
or
events,
access
status
/
HTTP
sta-
tus
code;
•
Device
data:
e.g.
IP
addresses,
session
ID,
start
and
end
of
session,
browser
version,
app
version
information,
IDs,
network
status
information
and
internet
service
provider,
device
type/manufac-
turer/model,
OS
name/version,
app
name/version,
library/SDK
version,
screen/UI
parameters,
URL/path/title,
referrer
URL;
•
Survey
data:
e.g.
when
end
customers
provide
feedback
to
the
RSP.
This
may
be
done
anony-
mously.
III.
For
what
purposes
is
the
data
processed
and
on
what
legal
basis?
(1)
Provision
of
the
RSP
Connect
service
via
the
web
portal
or
the
app.