Data protection policy
Data protection policy of Robert Bosch LLC
Bosch Privacy Policy – Highlights
Robert Bosch LLC (hereinafter “Bosch“, “we“, “us“) has set out below some important highlights of the Privacy Policy for our Bosch Partner Portal (“Partner Portal”). The Partner Portal consists of services accessible for original equipment manufacturers (“OEM”) and bike shops, repair shops, etc (“IBD”). You can obtain more information about how we collect, use, disclose and safeguard your personal information by reviewing our full privacy policy below.
What personal information do we collect?
We collect various types of information about our users in connection with the services or products provided through the Partner Portal (collectively, the “Services”), including:
- Information we collect directly from you (i.e., when given by you);
- Information we collect indirectly from you (i.e., collected when you use the Partner Portal or Services); and
- Information we obtain from third-party sources.
We also may collect information in ways that we describe to you at the point of collection or otherwise with your consent.
Why do we collect personal information and how is it used?
1. Fulfilling or meeting the reason you provided the information.
2. Technical administration of Bosch and Bosch affiliate websites and/or services.
3. Maintaining the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
4. User/customer administration (like registration and creation of a user account/contact data) review and/or reports.
5. Administering, maintaining, personalizing and improving Bosch and Bosch affiliates’ products and services, including, without limitation, to authenticate users, process payments, provide requested services, provide optional additional services and to develop new features, products and/or services.
6. Providing customer service.
7. Responding to submitted inquiries and customer service requests and other questions and/or comments.
8. For the U.S., this data may be used for marketing and analytic purposes.
9. Compliance with legal and/or regulatory requirements.
10. Subject to your choice general service- and function-related user data.
Bosch will not collect or use personal information for materially different, unrelated or incompatible purposes without providing you notice (or obtaining your consent, where required by applicable laws in the relevant jurisdiction).
Is personal information shared or disclosed?
Bosch may share your information with:
- Bosch affiliated entities,
- service providers, vendors, consultants, suppliers, licensors, marketing, partners and other partners and entities performing work on Bosch’s behalf, as follows:
- relevant authorities in accordance with, and as Bosch deems required, necessary and/or appropriate by, or in connection with, applicable law, regulation, court order or legal process
What are the risks?
- We may transfer your personal information to countries other than the country where you reside, including to affiliates and service providers. Therefore, your information may be accessible to courts, law enforcement and national authorities in such other countries. You can obtain information about Bosch’s policies and practices with respect to foreign service providers, or ask questions about the collection, use, disclosure or storage of personal information by such service providers, by contacting our Privacy Policy Administrator as described in the Privacy Policy.
- Bosch security measures are being continuously improved in accordance with the state of technological developments, however, absolute protection is not possible. However, we cannot guarantee the security of information posted or transmitted using the Partner Portal .
What else should you know?
- Your personal information will be stored in Germany and accessible to service providers, employees that need to have access to fulfill the service.
- You may contact our Privacy Policy Administrator, as described in the Privacy Policy, with any questions about the collection of your personal information.
- In some circumstances, you also may have a right to access, update, and correct inaccuracies in your personal data (e.g., pursuant to local law).
- Any additional choices you may have are described in the full Privacy Policy below.
Notice to Canadian Users: Please note that by using the Partner Portal /or voluntarily providing your personal information to us, as applicable, you are consenting to the collection, use and disclosure of your personal information as described in our Privacy Policy and summarized above.
BOSCH PARTNER PORTAL PRIVACY POLICY
I. Introduction.
Robert Bosch GmbH (“Bosch”, “we”, “us” or “our”) is pleased to have you (“you” or “your”) use our Bosch Partner Portal (“Partner Portal”) and welcomes your interest in the services or products provided through the Bosch Partner Portal (collectively, the “Services”). This Privacy Policy (this “Notice”) applies to all users of the Partner Portal and the Services, anywhere in the United States, Canada, and their respective territories and possessions. Terms capitalized but not defined in this Notice are as defined in the Terms of Use for the Partner Portal (the “Terms”).
The protection of your privacy is an important concern to which we pay special attention. We process Personal Information collected during your visit to the Partner Portal and use of Services in compliance with this Notice and all applicable laws and regulations. Data protection and information security are part of Bosch corporate policy.
Notice to Canadian Users: Please note that by using the Partner Portal and/or voluntarily providing your Personal Information to us, as applicable, you are consenting to the collection, use and disclosure of your Personal Information as described in this Notice. If you do not consent to the processing of your Personal Information in accordance with this Notice, please do not access or continue to use the Partner Portal or otherwise provide any Personal Information to us.
II. Scope
This Notice covers our treatment of (1) personally identifiable information, as defined by numerous statutes in the United States ( “PII Laws”), (2) personal information, as defined by the California Consumer Privacy Act (“CCPA”), and (3) personal information, as defined by Canada’s Personal Information Protection and Electronic Documents Act and any applicable substantially similar provincial legislation (“Canadian Privacy laws”) (collectively, “Personal Information”) which we gather when you are accessing, viewing, completing, or using the Partner Portal or our Services.
III. Collection of Personal Information
The Partner Portal has collected the following Personal Information from users of the Bosch Partner Portal within the last twelve (12) months:
| Category and Sources of Information | Examples | How we use it | How we share it |
| Identifiers We collect this information from our users. We also generate identifiers internally. | first name, last name, SingleKey ID, email address, account name, message IDs. hardware ID, computer name, OEM dongle ID., client ID, OEM-Name, OEM-Identifier | To enable use of our sites, services, and products and to understand how our Users interact with our sites, and to improve our offerings. We need this information for identification purposes and to provide our sites, services, and products and also to communicate and respond to and manage your requests. | We share this data with our service providers and those whom you instruct us to send this information. |
| Personal Information under Cal. Civ. Code § 1798.80(e) We collect this information from our users. | first name, last name, SingleKey ID, message ID, hardware ID, OEM dongle ID, client ID, OEM name, OEM identifier, language, email address, account name, contact details, password, IP address, company name, company’s address, company’s country, company phone number, role at approval time, timestamp, timezone. Some Personal Information included in this category may overlap with other categories. | To enable use of our sites, services, and products, to communicate with you, to understand how our users interact with our sites, and to improve our offerings. In detail: Theming Service Through our Theming Service in the Partner Portal, OEM’s are able to create, manage and edit their brand assets for the mobile App of Bosch eBike Systems of their users. Through a simple interface they can publish a theme to all of their users. The following data is processed when using the service ("service-related data"): Color in hexadecimal code, a logo, an imagine or a video of the brand, OEM name and an OEM brand identifier. Dashboard Service Through the Dashboard Service you will have access to insights and analytics about the eBike users and the behavior of the users. The Dashboard will empower you to better understand your customers and their bike usage and enable data-driven decision making. The results are displayed in an aggregated and anonymized way in graphs and figures. Provision of the Diagnostic Tool When using the Diagnostic Tool in connection with Bosch eBike systems, we process your personal data if it is transmittednecessary to us, for example, for the operation of the Diagnostic Tool, fullfillment of contractual obligations, license management or creation and processing of a service case or a warranty case. For each remote access by the OEM user to the dealer's software, the full IP address (Internet Protocol address) of the end device from which the dealer's software is accessed, OEM dongle ID, and date and time are transmitted to us and logged by us. The logs are stored by us for the purpose of investigating malfunctions and for security reasons (e.g. to clarify attempted attacks, misuse) for a period of 1 year, after which they are deleted. Logs whose further storage is required for evidentiary purposes are exempt from deletion until the final clarification of the respective incident and may be passed on to investigating authorities in individual cases. Feedback You have the option to provide feedback via e-mail. This process is voluntary. Support If you have a concern about the Partner Portal, you can contact us via email. Competitions/ customer satisfaction surveys/ Feed If competitions and/or customer satisfaction surveys are conducted, your participation is always voluntary. Details of whether and, if applicable, which personal data are collected, stored and processed for which purposes in a specific case can be found in the respective descriptions of the competitions/surveys. In addition, individual and useful communication about the Partner Portal features with its digital services is continuously displayed via a so-called "feed" within the Partner Portal. The communication within the "feed" can, for example, contain information on how to use the online service and get to know the full scope of the functionality. Individual Newsletter You can subscribe to an individual newsletter as part of our online service. Individual newsletters contain information about offers and services of our online service, practical help and usage instructions for our online service as well as marketing and advertising messages about our products and services. In order to collect the individual information and use it for the content of the newsletter, we evaluate the use of the online service, e.g. your company and their location. If you want to withdraw the newsletter and stop the evaluation, you can terminate your subscription at any time by revoking your consent. The revocation can be done via the link printed in the newsletter or in the administrative settings of the respective online offer. Alternatively, you may contact us using the details in the "Contact" section. Usage of IBD services When you are an IBD and use the services only offered to IBDs, additionally the following data procession can occur:
We provide you with business relevant information.
We store training information (online training, participation) of the eBike dealers to check the authorization to receive a dongle or a license (Diagnostic Tool (BDP tool)).
For the provision of our Bike Dealer Self-Service, including Dealer Locator, we store information voluntarily provided by the dealer (to increase visibility/reachability for end customers, marketing for the dealer).
We contact you for reasons of product or customer surveys by e-mail and/or telephone, as well as market research activities.
We are conducting prize draws or discount campaigns in accordance with the respective prize draw or discount campaign conditions.
We provide our Dealer Locator Service via an interface (API) that uses maps from Google Maps for which Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland is responsible in relation to data protection. When you click “Start Google Maps” your IP address and the address/coordinates selected by you will be transmitted to Google. Google Maps is used here to provide any necessary location correction. This gives you the opportunity to adjust the location of your shop yourself so that it can be displayed accurately for the end customer during the dealer search. Please note that it is possible that data will be transferred by Google to the USA. More information on how user data is handled can be found in Google’s privacy policy: https://www.google.co.uk/intl/en/policies/privacy.
You can subscribe to a newsletter as part of our online service. Should you decide later that you no longer wish to receive newsletters, you can cancel your subscription at any time by revoking your consent. The revocation takes place via the link printed in the newsletter, or in the administration settings of the respective online offer. Alternatively, please contact us using the information in the “Contact Us” section. | We share this data with our service providers and with business partners, including those to whom you instruct us to send this information. |
| Activity Log Data We collect this information from our users and customers | Activity Log Data We collect this information from our users and customers Browsing history, e.g. – Name and category of requested files (functions calls) and information – date and time of calls; – http status information (e.g. "call successful" or "requested file not found”) – Component Identifiers To determine errors and for safety reasons. We share this data with our service providers and with business partners, including those to whom you instruct us to send this information. | To determine errors and for safety reasons. | We share this data with our service providers and with business partners, including those to whom you instruct us to send this information. |
Bosch will continue to collect the Personal Information described above. If any additional Personal Information is collected by Bosch, we will provide any required notice(s), and where applicable obtain any required consent(s), in accordance with applicable laws in the relevant jurisdiction.
IV. Sources of Personal Information.
Bosch collects Personal Information from the following categories of sources:
1) Directly from you.
For example, when given by you or collected from you thorough your access to and/or use of the Partner Portal/or the Services, in context of [registering an account, subscribing to or purchasing our Services or when you contact customer support or otherwise interact or communicate with Bosch, its agents, representatives, suppliers, vendors or consultants through the Partner Portal. This information may include, without limitation, your [first and last name, contact details, phone number and e-mail address and any other information you choose to provide us.For example, when given by you or collected from you thorough your access to and/or use of the Partner Portal/or the Services, in context of [registering an account, subscribing to or purchasing our Services or when you contact customer support or otherwise interact or communicate with Bosch, its agents, representatives, suppliers, vendors or consultants through the Partner Portal. This information may include, without limitation, your first and last name, contact details, phone number, SingleKey ID, e-mail address, password, company name, company’s address, company’s country, company phone number, your role at approval time and any other information you choose to provide us.
2) Indirectly from you.
For example, from observing your use of the Partner Portal and/or the Services, or services related thereto. The following data may be collected automatically: pages viewed, files downloaded (downloads), individual links clicked, search words or search phrases (site search), duration of visit, browser used, device data (e.g., unique device identifier, MAC address, IP address, serial number, hardware model, hardware identifier network information and operating system and version, hardware ID, computer name, OEM dongle ID), and other relevant details and/or information. If the visit is a result of online advertising such as banners, video ads, search engine advertising, etc., Bosch or its agents, representatives, suppliers, vendors or consultants may record which banner, adword, etc. motivated or assisted with the visit to Partner Portal.
V. Use of Personal Information and purpose specification
Bosch may use your Personal Information for the purpose of:
1) Fulfilling or meeting the reason you provided the information. For example, if you share your name and contact information to ask a question about our Services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a Service, we will use that information to facilitate delivery. We may also save your information to facilitate new product orders. When services that are subject to a charge are booked, payment processing data are collected and processed exclusively and directly by the app store operators for devices with the Android and iOS operating systems.
2) Technical administration of Bosch and Bosch affiliate websites, mobile applications and/or services.
3) Maintaining the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
4) Customer, vendor, licensor and/or supplier administration, review and/or reports.
5) Administering, maintaining, personalizing and improving Bosch and Bosch affiliates’ mobile applications, products and services, including, without limitation, to authenticate users, process payments, provide requested services, provide optional additional services and to develop new features, products and/or services.
6) User/customer administration (like registration and creation of a user account/contact data), review and/or reports. Users have to register in order to use our services. You can only register for our online offer by first setting up a central SingleKey ID. The central SingleKey ID was developed by Bosch.IO GmbH for the Bosch Group of Companies in order to enable shared users to use the services of different companies in the Group using uniform login data and to increase data security. As the party responsible for SingleKey ID, Bosch.IO GmbH (“BIO”) exercises joint responsibility, together with third parties responsible for the application(s) you use, for the processing of your data in accordance with the provisions of the General Data Protection Regulation and national data protection laws. In accordance with Art. 26 of the GDPR (Joint controllers), we have agreed in writing to exercise joint responsibility for data processing. In particular, we have determined and agreed upon the responsibilities and liabilities of the parties involved. For detailed information on individual processing operations, please refer to the data protection notice of Bosch.IO GmbH and the information sheet on data processing available at https://singlekey-id.com/data-protection-notice/. If you wish to register with BIO for a central SingleKey ID, the General Terms of Use for the registration and use of a central SingleKey ID and BIO's Privacy Notice apply. After successful registration, you can also use the login data used for the central SingleKey ID to register for this online service. For this purpose we provide you with a BIO login mask for the central SingleKey ID. BIO will then confirm your authorization and provide us with your E-Mail-Address and SingleKey ID. Regarding other data transfers within the Bosch Group associated with the central SingleKey ID, we refer to the BIO data protection information. You can terminate your user agreement for the central SingleKey ID at any time by deleting. Please click on the following link: https://singlekey-id.com/myprofile/ . In addition, we collect further user-related data from you when you register for our online offer, i.e. Name and Password. This personal data is processed for the purpose of identification and contract management (conclusion, implementation and termination of the contract) as well as to communicate and respond to and manage your requests. You can choose to submit reviews on our platform. Reviews are submitted on a voluntary basis. To submit a review, you must log in to your account and provide a review text. Your review will be sent to our customer service along with your name. If we actively solicit a review by e-mail, you must explicitly confirm this service during the registration process. Reviews are solicited to provide quality assurance for our platform and the transparency of the services on our Application for other users. You can unsubscribe from this service at any time. Please use the link provided in the relevant mail or change the settings in your account.
7) Responding to submitted inquiries and customer service requests and other questions and/or comments.
8) For the U.S., this data may be used for marketing and analytic purposes.
9) Compliance with legal and/or regulatory requirements.
10) Evaluating or conducting a merger, sale of assets, consolidation or restructuring, financing or acquisition of all or a portion of any Bosch business, asset or opportunity by, with or into another business, entity or company.
Bosch will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated or incompatible purposes without providing you notice (or obtaining your consent, where required by applicable laws in the relevant jurisdiction).
VI. Sharing and Disclosure of Personal Information.
Bosch may use, store, compile, manipulate, share and disclose your Personal Information with third parties for the purposes stated above. Your Personal Information is shared with the following third parties:
1) Bosch affiliated entities, including Bosch’s parent company in Germany, Robert Bosch GmbH, to leverage shared services and improve our Services;
2) Bosch third party service providers, vendors, consultants, suppliers, licensors, marketing partners and other partners and entities performing work on Bosch’s behalf, such as hosting vendors, advertising service providers, data analytics companies, marketing service companies, list managers and delivery companies;
3) Our newsletters are sent using an e-mail marketing software of the provider Optimizely GmbH, Wallstraße 16, 10179 Berlin (“Optimizely”). The e-mail addresses of the recipients of our newsletters, as well as their other data described in this notice, are located on Optimizely's servers in data centres in Germany and are subject to the data protection laws applicable there. Optimizely uses this information to send and evaluate the newsletter on our behalf. Furthermore, Optimizely can use this data to optimize or improve its own services, e.g. to technically optimize the sending and the presentation of the newsletters. However, Optimizely does not use the data of the recipients of our newsletters to write to them itself or to pass them on to third parties. The security concept for Optimizely's email marketing cloud Optimizely Campaign is certified according to ISO 27001. For more information, please visithttps://www.optimizely.com/de/privacy/.
4) Relevant authorities in accordance with, and as Bosch deems required, necessary and/or appropriate by, or in connection with, applicable law, regulation, court order or legal process.
By accessing and/or using the Bosch Partner Portal or the Services, you consent to the above uses and sharing of your Personal Information in accordance with this Notice.
VII. Disclosure or Sale of Personal Information – Past 12 Months
1) Disclosure of Personal Information.
In the preceding twelve (12) months, Bosch has not disclosed Personal Information for a business purpose.
2) Sales of Personal Information.
In the preceding twelve (12) months, Bosch has not sold Personal Information for a business purpose. We do not sell your Personal Information for a business purpose to third parties.
VIII. Use of the third-party analytics tools.
Bosch may use web analytics tools, such as the Google Analytics web analytics tool, to provide us with an analysis of your use of the Partner Portal, overall use of and traffic on the Partner Portal and other related services. Google Analytics uses cookies that enable an analysis of your use of the Partner Portal. The information generated by the cookie about your use of the Partner Portal (such as when you visited the Partner Portal, the referrer URL, details on the configuration of your operating system, your browser and your access provider) are generally transmitted to, and stored on, a server located in the European Economic Area. You are able to opt out of Google Analytics by downloading and utilizing the Google Analytics Opt-out Browser Add-on, which you can obtain at https://tools.google.com/dlpage/gaoptout?hl=en. Or, in our privacy settings, you can revoke consents already given with future effect or give us your consent at a later date.
We use Google Tag Manager, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, (Google Tag Manager) in our Partner Portal to Administration of website tags via a user interface and integration of program codes on our websites.
IX. International Data Transfer
Bosch may transfer your Personal Information to Bosch’s parent company in Germany, Robert Bosch GmbH, and/or to any other Bosch affiliates throughout the world, when processing, storing, analyzing and otherwise using data. Bosch may also transfer your data to a third party outside the country of origin. Accordingly, your Personal Information may be accessible to courts, law enforcement and national authorities in countries other than the country in which you reside. You can obtain information about Bosch’s policies and practices with respect to foreign service providers (including affiliates), or ask questions about the collection, use, disclosure or storage of personal information by such service providers, by contacting our Privacy Policy Administrator as described below.
X. Children’s Privacy
Bosch does not knowingly collect or use any personal Information from online visitors under the age of 16. Bosch does not knowingly allow visitors under the age of 16 to participate in any promotions or contests made available on Bosch Application from time to time.
XI. California “Shine the Light” Privacy Rights
California’s “Shine The Light” law permits those Bosch customers who are residents of California to annually request a list of their Personal Information (if any) that Bosch disclosed to third parties for direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties. At this time, Bosch currently does not share any Personal Information with third parties for direct marketing purposes.
XII. Use of links to affiliated sites
The Partner Portal may contain links to other Bosch sites (“Affiliated Sites”). The Partner Portal provides these links only as a convenience. Your use of these Affiliated Sites and any related services are outside the scope of this Notice and is governed by the Notices and any other terms referred to or located on such Affiliated Sites.
XIII. Use of external links
The Partner Portal may contain links to third-party websites or services operated by providers that are not associated with Bosch. After you click the link, Bosch no longer has any influence over the collection, storage, use or processing of any Personal Information transmitted by clicking the link (such as the IP address or URL of the page that contains the link), as the behavior of third parties is, by nature, beyond Bosch control. Therefore, Bosch is not responsible for the collection, storage, use, disclosure or other processing of Personal Information by such third parties. For further clarity, this Privacy Policy does not apply to any such third party websites or services; please refer to the privacy statements or policies for such third party websites or services for information about how they collect, use, disclose and protect personal information.
XIV. Security
Bosch takes commercially reasonable efforts to ensure that your data collected by Bosch through this Bosch Application is protected against tampering, loss, destruction, access by unauthorized persons or unauthorized disclosure. Bosch security measures are being continuously improved in accordance with the state of technological developments, however, absolute protection is not possible.
When you register with Bosch, you are required to create a username and password. You must not share this access information with anyone else as you are personally responsible for any information transmitted while logged in with your username and password. We disclaim any and all liability for any information transmitted due to an unauthorized log in.
XV. Use 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.
1. Categories
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.
1.1 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.
1.2 Technically not necessary mechanisms
We only use cookies and tracking, if you have given us your prior consent in each case. With the exception of the cookie that saves the current status of your privacy settings (selection cookie). This cookie is set based on legitimate interest.
We distinguish between two sub-categories with regard to these cookies and tracking mechanisms:
1.2.1 Marketing cookies
General
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.
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:
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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) -
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
1.3 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.
1.3.1 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.
1.3.2 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 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.
XVI. International Users
This is a U.S. website and service targeted to users in the U.S. and Canada, and the Bosch Partner Portal and Bosch Services are subject to U.S. and Canadian laws, as applicable, including, without limitation, those governing the privacy and security of your information. If you use Bosch Services, you are transferring your information to Bosch in the United States. By using the Bosch Services or providing your information to Bosch through the Services you consent to the transfer of your Personal Information to the United States, and Bosch handling of your information in accordance with applicable U.S. requirements and this Notice. Accordingly, your Personal Information may be accessible to courts, law enforcement and national authorities in the United States. You can obtain information about Bosch’s policies and practices with respect to service providers (including affiliates) outside the country where you reside, or ask questions about the collection, use, disclosure or storage of personal information by such service providers, by contacting our Privacy Policy Administrator as described below.
XVII. Rights of California “consumers” relating to Personal Information collected by Bosch
Individuals which fall within the definition of a “consumer” under the California Consumer Privacy Protection Act. You have the following rights relating to your Personal Information collected by Bosch.
1) Right to access specific information and data portability rights
You have the right to request that Bosch discloses certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see below, How to Exercise Your Rights), we will disclose to you:
a. The categories of Personal Information we collected about you.
b. The categories of sources for the Personal Information we collected about you.
c. Our business or commercial purpose for collecting or selling that Personal Information.
d. The categories of third parties with whom we share that Personal Information.
e. The specific pieces of Personal Information we collected about you.
2) Deletion Request Rights
You have the right to request that Bosch delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
a. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
i. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
ii. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
iii. Debug products to identify and repair errors that impair existing intended functionality.
iv. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
v. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
vi. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
vii. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
viii. Comply with a legal obligation.
ix. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
XVIII. Your Rights – Canadians
Individuals located in Canada have certain rights pursuant to Canadian Privacy Laws. Subject to certain exceptions and limitations, and depending upon the jurisdiction where you reside, such rights may include:
a. The right to withdraw your consent to the collection, use or disclosure of your Personal Information.
b. The right to be informed of the existence, use, and disclosure of your Personal Information, and to be provided with an account of the use that has been made or is being made of this information as well as the third parties to which it has been disclosed (including a list of organizations to which your information may have disclosed).
c. The right to challenge the accuracy and completeness of your Personal Information, and have it amended, updated or rectified as appropriate.
d. The right to acquire information about Bosch’s policies and practices with respect to Personal Information, including: a description of the type of personal information held by Bosch and a general account of its use; a copy of any brochures or other information that explain our policies, standards, or codes; and information about what Personal Information is shared with or accessible to our affiliates.
e. The right to challenge Bosch’s compliance with the applicable Canadian Privacy Laws.
XIX. How to exercise your rights
To exercise your rights, please submit a verifiable consumer request or access request, as applicable, to us by either:
Calling us at +1 248 876 1000.
To assert your rights please use the following link:
https://request.privacy-bosch.com/entity/RB/
To notify data protection incidents please use the following link:
https://www.bkms-system.net/bosch-datenschutz
Only you (or in case of a California resident, an authorized agent authorized by you to act on your behalf – see Section XXII, Authorized Agent below for more information) may make a verifiable consumer request or access request, as applicable related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. Your verifiable consumer request or access request, as applicable, must:
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Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
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Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request or access request does not require you to create an account with us, but if you already have an account with us, you may be required to make your request through that account.
We will only use Personal Information provided in a verifiable consumer request or access request, as applicable, to verify the requestor’s identity or authority to make the request.
XX. Response timing and Format
We endeavor to respond to a verifiable consumer request or access request, as applicable, within forty five (45) days of its receipt, or sooner where required by applicable law (including Canadian Privacy Laws). If we require more time (up 90 days), where permitted by applicable law, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide in response to a verifiable consumer request will only cover the 12-month period preceding the verifiable consumer request's receipt, unless otherwise required by applicable law. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, where applicable, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request or access request, as applicable, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
XXI. Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the "right to opt-out"). Furthermore, where required by applicable law in the relevant jurisdiction, we will obtain your consent prior to selling your Personal Information. We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you may submit a request to us via this email link.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by submitting a request to us via this email link.
You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.
XXII. Authorized Agent
As a California resident you may also exercise your request to know or request to delete through an authorized agent. When you submit your request through an authorized agent we require that you:
1. Provide us a copy of your written permission for the authorized agent to submit the applicable request; and
2. Verify your own identity directly with us.
The foregoing does not apply when you have provided your authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465; provided, that we may require a copy of such power of attorney before fulfilling any request.
XXIII. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
XXIV. Filing a Complaint
Regulatory authorities that oversee the privacy laws and regulations, including the Office of the Privacy Commissioner of Canada, advise individuals to file an objection or challenge with the relevant company before lodging a formal complaint with a regulatory authority. If you are dissatisfied with Bosch’s response to an objection or challenge filed under Article XX above, or you if wish to file a complaint with a regulatory authority first, you may do so as follows:
Under PIPEDA: You may file a complaint with the Office of the Privacy Commissioner of Canada. Depending upon the province where you live, you may also (or instead) have the right to file a complaint with the applicable provincial privacy commissioner/regulator.
Under PII Laws: You may file a complaint with the relevant state’s Attorney General’s office.
Under the CCPA: You may file a complaint with the California Attorney General’s Office. For additional information regarding consumer complaints against a business/company under the CCPA and to initiate the complaint process, please click on the link.
XXV. Changes of the Privacy Policy
Due to the constantly changing nature of Bosch business, Bosch reserves the right to change, update, revise and/or modify this Notice at any time at Bosch’s sole discretion, and Bosch will post any new or revised Notice here. Any such change, update, revision and/or modification will be effective immediately upon posting on this website, unless we are required to provide direct notice or obtain your consent pursuant to applicable laws. Use of information that Bosch gathers now will be subject to the Notice in effect at the time of use. By using or navigating around the Bosch Application or utilizing any of the Services, you acknowledge that you have read and understood and agree to be bound by this Notice and the applicable Terms of Use. If you do not agree to be so bound, do not remain on the Bosch Application. You are responsible for checking the Bosch Application frequently to keep apprised of recent changes.
The effective date of this Notice is April 19, 2023
Last modified: April 19, 2023
XXVI. Contact
To obtain more information or to submit suggestions or complaints regarding the processing of your Personal Information, you can contact the Bosch Privacy Policy Administrator.
If incorrect information has been stored despite Bosch efforts to maintain correct and up-to-date data, Bosch will correct this upon your written request, sent to:
Email: privacy.policy@us.bosch.com
Postal Address:
Robert Bosch LLC
Privacy Policy Administrator
38000 Hills Tech Drive
Farmington Hills, MI 48331
You may also contact as follows:
Phone: +1 248 876 1000