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Bosch Security and Safety Systems I UK

Data Protection Notice

Data protection policy of Robert Bosch Ltd.

We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us in the event you have a complaint.

This policy applies to:
(i) all those who visit our website; and
(ii) business customers (including e.g. distributors, installers, systems integrators, consultants and end-users);
(iii) consumers (including e.g. homeowners)

to that extent relevant to those individuals and except where the policy indicates otherwise.
Our 'Group' refers to the constituent companies of Robert Bosch GmbH.

1. Introduction
Robert Bosch Limited and its Security and Safety Systems division (hereinafter "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.

2. Robert Bosch Limited respects your privacy

The protection of your privacy throughout the course of processing personal data as well as the security of all business data is an important concern to us. We process personal data confidentially and only in accordance with statutory regulations.

Data protection and information security are included in our corporate policy.

3. Controller

Robert Bosch Limited is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.

Our contact details are as follows:

Name and address
Robert Bosch Ltd
PO Box 98
Broadwater Park
North Orbital Road
Denham, Uxbridge
UB9 5HJ

Members of the UK Board of Management
Mr. Vonjy Rajakoba
Mr. Jonathan Burton
Mr. Arun Srinivasan

Your contact at Bosch
E-Mail: contact@uk.bosch.com
Phone: 0344 892 0115

Corporate Headquarters
Phone: 0344 892 0115

Company register
Robert Bosch Limited incorporated in Scotland under company number SC13418.
Registered Office: Registered Office c/o Bosch Rexroth, Viewfield Industrial Estate, Glenrothes, KY6 2RD

Value-added tax identification number
196404153

4. Collection, processing and usage of personal data

4.1. Processed categories of data

The following categories of data are processed:

  • Communication data (e.g. name, telephone, e-mail, address, IP address, company)
  • Contractual master data (e.g. contractual relationships, contractual or product interest)
  • Client history
  • Contract accounting and payment data
  • Geolocation

4.2. Principles

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 you have given your consent to the processing or use of personal data concerning this matter, e.g. by means of registration.

4.3. Processing purposes and legal bases

We; as well as the service providers commissioned by us; process your personal data for the following processing purposes:

4.3.1 Provision of these Online Offers including contact form to contact us for the products and services offered by us for the purpose of the fulfillment of a contract.

(Legal basis: Justified interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law; as well as the fulfillment of contractual obligations).

4.3.2 Provision of these Online Offers and fulfillment of contractual obligation’s under our contractual terms including invoicing and prior credit assessment. Invoicing may include the sale of claims.

(Legal bases: Fulfillment of contractual obligation respectively our justified interest in an efficient claims management and in avoiding claim defaults as regards the sale of claims and the credit assessment.

4.3.3 Resolving service disruptions as well as for security reasons.

(Legal bases: Fulfillment of our legal obligations within the scope of data security and justified interest in resolving disruptions/disturbances and in the security of our offers).

4.3.4 Self-promotion and promotion by others, as well as market research and reach analysis within the scope statutorily permitted or based on consent.

(Legal bases: Consent / justified interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law).

4.3.5 Sending an email or SMS/MMS newsletter with the recipient’s consent.

(Legal basis: Consent).

4.3.6 Creating a customer profile and sending an email newsletter or mailing based on the recipient’s behavior with the recipient’s consent.

(Legal basis: Consent).

4.3.7 Safeguarding and defending our rights.

(Legal basis: Legitimate interest on our part for safeguarding and defending our rights).

4.3.8 Geolocation: In this process, IP addresses are shortened to the last octet before being used in any analysis of user behavior. Your IP address is also only used in its shortened form when establishing an approximate geolocation. Here, the country of origin is determined and this data is then stored.

(Legal basis: legitimate interests, as long as they are in accordance with the standards determined by data protection laws and competition regulations)

4.4. Registration

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 *.

4.5. Log files

Each time you use the internet, your browser is transmitting certain information which we store in so-called log files.

We save log files for 7 days to determine service disruption and for security reasons (e.g., to investigate attack at-tempts) and delete them after-wards. 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 ad-dress). Also see module web analysis.

In log files, in particular the following information is saved:

  • IP address (internet proto-col address) of the terminal device which is being 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 in-formation 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”).

4.6. Children

This Online Offer is not meant for children under 18 years of age.

4.7. Data transfer

4.7.1. 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/has 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 4.3 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.

Within the company such entities may have access to personal data, to fulfill our contractual and legal obligations. Also service provider and auxiliary person are granted with personal data for such purposes, providing that they preserving confidentiality and integrity. These are companies in the area of IT services, logistics, printing services, telecommunication, debt collection, consulting services as well as distribution and marketing.

With regard to data transfer to such recipients outside of our company it has to be outlined that personal data is only transferred in accordance with the applicable data privacy law. Considering these requirements, recipients of personal data may be:

  • Public entities and institutions (for example tax authorities, law enforcements authorities or courts) provided a legal or official obligation is given,
  • Credit and financial service institutions or similar institutions, which are recipients of personal data within our business relationships
  • Credit agencies to determine credit- and default risks
  • Other companies of the Bosch group for risk management
  • Creditor or insolvency administrator, which have requests within enforcement measures

4.7.2. 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 to the statutory provisions. Service providers may also be other Bosch group companies.

4.7.3. Payment service providers

We involve external payment service providers.

Depending on the type of payment method you choose during the ordering process, we transfer data used for the processing of payments (e.g., bank account or credit card data) to the financial institution charged with the payment or to payment service providers commissioned by us. Sometimes, payment service providers also collect and process such data as controllers. In this case (payment service providers are data controllers), the data protection notice or privacy policy of the respective payment service provider applies.

4.7.4. 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 names and are themselves responsible for processing the data. In this respect, the data protection notices of the respective claim buyer apply.

4.8. Transfer to recipients outside the EEA

We might transfer personal data to recipients located outside the UK or 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 (e.g. due to an adequacy regulation by the UK government for the respective country or due to the agreement based on so-called EU model clauses with the recipient, international data transfer agreement, or the international data transfer addendun tothe Europen Commission's standard contractual clauses for international data transfers(Addendum) as appropriate) 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-to provisions securing an appropriate level of data protection. For this purpose, please use the statements made in the Contact section 10.

4.9 Data processing under commission

We involve external service providers with several 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 processors are obliged to maintain confidentiality and to comply to the statutory provisions. Processors may also be other Bosch group companies.

4.10. Duration of storage; retention periods

Principally, we store your data for as long as it is necessary to render our Online Offers and the services connected to them, or for as long as we have a justified interest in storing the data (e.g., we might still have a justified interest in postal mail marketing upon fulfillment of a contract). In all other cases, we delete your personal data with the exception of data we must store to fulfill legal obligations (e.g., we are obliged due to retention periods under the tax and commercial codes to have documents such as contracts and invoices available for a certain period of time).

4.11 Data processing under commission

We involve external service providers with several 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 processors are obliged to maintain confidentiality and to comply to the statutory provisions. Processors may also be other Bosch group companies.

5. 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.

5.1. 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.

5.1.1 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.

5.1.2 Cookies and tracking mechanisms that are technically not required

We only use such cookies and tracking mechanisms 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:

5.2 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. Comfort cookies are currently not used.

5.3 Marketing cookies and tracking mechanisms:

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.

- 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.

- Customer profiling:

We merge reading and usage behavior to create a customer profile, in order to send relevant information or contact users about our products, services and solutions by e-mail or telephone. The reading and usage behavior is evaluated by setting a pixel and tracking links in mailings, which transmit information to Bosch like information regarding opened e-mails, links that you have clicked and e-mails that are undelivered or returned. The relevant provider is offering Bosch the feature within the email provider tool. Bosch is responsible for the processing of data.

We use the following tools:

5.3.1 Facebook-Pixel

Name: Facebook-Pixel
Provider: Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland
We are jointly responsible with Facebook for processing your personal data as part of the processing of your personal data on our online offering via Facebook Pixel. We have entered into a joint responsibility agreement with Facebook in order to determine our respective responsibilities for fulfilling obligations under the GDPR with regard to joint processing. The essential content of the agreement can be accessed at any time via the following link: https://www.facebook.com/legal/controller_addendum This regulates in particular which security measures Facebook must observe https://www.facebook.com/legal/terms/data_security_terms) and how data subject rights can be asserted against Facebook.

Function: Facebook processes your personal data based on your consent via the Facebook Pixel to create campaign reports, track conversions, click events, and target advertising outside of our websites (retargeting) using HTTP headers (including IP address, device and browser properties, URL, referrer URL and your person), pixel-specific data (including pixel ID and Facebook cookie), click behaviour, optional values (for example, conversions, page type), form field names (such as "email", "address", "quantity" for the purchase of a product or service). We do not receive any personal data about you from Facebook, only anonymized campaign reports about the website target group and ad performance. You can opt-out of receiving interest-based ads from Facebook by changing your advertising preferences on Facebook's website.

5.3.2 Optimizely-Pixel and Tracking links

Provider: Optimizely GmbH, Wallstraße 59, 10179 Berlin, Germany
We are using the email service provider tool from Optimizely GmbH. Bosch is responsible for the processing of data.

Function: Optimizely GmbH processes your personal data based on your consent using pixels and tracking links to create customer profiles based on reading and usage behavior. You can revoke your consent at any time, see Contact.

Alternatively, you can opt out of the use of cookies by third parties by visiting Digital Advertising Alliance's opt-out page at http://optout.aboutads.info/?c=2&lang=EN or page http://www.youronlinechoices.com. You will find more information at: https://www.facebook.com/policy

5.3.3 LinkedIn

Name: LinkedIn Insight Tag
Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.

Function: LinkedIn processes your personal data based on your consent via the pixel "LinkedIn Insight Tag" for the creation of campaign reports, tracking of conversions, click events as well as targeted advertising outside our websites (retargeting) based on URL, referrer URL, shortened or hashed IP address (for cross-device retargeting), devices and browser properties (user agent) and time stamp. We do not receive any personal data from you from LinkedIn, only anonymized campaign reports on website audience and ad performance. LinkedIn storage period: pseudonymization after 7 days, final deletion after 180 days. For more information, please visit: https://www.linkedin.com/legal/privacy-policy

5.3.4 Google Ads

Name: Google Ads Remarketing Tag
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

Function: Google processes your personal data on the basis of your consent through “Google Ads Remarketing Tag” Pixel for the generation of campaign reports, conversion tracking, click events and targeted advertising outside our website (retargeting) on the basis of URL, referrer URL or inclusion on remarketing lists defined through us, for example. Using the above information, it is also possible for you to be associated with your Google account and included in remarketing lists. We do not receive any personal data concerning you from Google, but rather receive anonymised campaign reports about the target audience and ad performance. You can stop getting interest-based ads from Google by changing your advertising preferences on the Google website at https://www.google.com/settings/ads/onweb#display_optout. Alternatively, you can deactivate the use of third-party cookies by visiting the Network Advertising Initiative opt-out page at http://www.networkadvertising.org/managing/opt_out.asp or managing the use of device identification in the device settings. You can find instructions at https://support.google.com/ads/ans-wer/1660762#mob and more information at https://policies.google.com/privacy

5.3.5 Twitter Advertising

Name: Twitter Advertising (Retargeting or Conversion Tracking)
Provider: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

Function: Twitter Ads allows advertisers to collect data from users who visit their website. Cookies and code are used to connect the website to another third-party platform such as Twitter. A non-reversible and non-personal hash value is generated from your usage data and transmitted to Twitter for analysis and marketing purposes. In addition, a so-called “Twitter pixel” can be used to track the actions of users after they have seen or clicked on a Twitter ad.

User behaviour, such as websites visited, content accessed, time of visit, etc., as well as device-related data, such as applications and operating systems used, are recorded. With “cross-device personalization”, Twitter also tries to link all devices of a user. Since the data is stored and processed by Twitter, a connection to the respective user profile on twitter.com is also possible. In the course of processing, the data may be transmitted to a Twitter Inc. server in the USA. Twitter Inc. is certified under the EU-US Privacy Shield and thus ensures an adequate level of protection of your data in accordance with European data protection law. You can download the certificate here: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active

Anonymized data will be deleted within 6 months. Data that can possibly identify a specific user on Twitter will be deleted within 90 days. Further information on the duration of the storage can be obtained from the provider or at https://legal.twitter.com/ads-terms/international.html.

You can object to Twitter’s data collection by adjusting the settings in your Twitter account or at https://twitter.com/personalization. If you would like to opt out of interest-based advertising from certain third-party advertisers, you can do so at https://optout.aboutads.info and https://optout.networkadvertising.org.

For more information about the purpose and scope of the data collection and the further processing and use of the data, as well as the privacy settings, please refer to Twitter’s privacy policy:https://twitter.com/privacy.

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.

5.4. Overview of the marketing tools and cookies we use

You will find an overview of the marketing tools and cookies we use in this section.

5.4.1 Cookie name: bosch-privacy-settings-v2
Storage period: This cookie will be stored for a maximum of 12 months or until you revoke your consent to the use of cookies.

Function: Remembers your consent to the use of cookies for this website.

5.4.2 Tool 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.

5.4.3 Tool name: Google Optimize
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

Function: Cookie can analyze how users have behaved on a cross-site basis, UX testing.

5.4.4 Tool 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.

5.4.5 Tool name: Google Ads
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

Function: Placement of advertisements, remarketing, conversion tracking. Further information is available at: (https://adssettings.google.com/authenticated). Google processes your personal data on the basis of your consent via the "Google Ads Remarketing Tag" pixel for the creation of campaign reports, tracking of conversions, click events as well as targeted advertising outside our websites (retargeting) by means of e.g. URL, referrer URL, membership of re-marketing lists defined by us. The aforementioned information can also be used to link you to your Google account and to include you in remarketing lists. We do not receive any personal data about you from Google, only anonymised campaign reports about the target group and ad performance.

5.4.6 Tool name: New Relic
Provider: New Relic Inc. 188 Spear Street, Suite 1000, San Francisco, CA 94105, USA

Function: Measurement of website availability and downtime

5.5 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.

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.

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 technically not required 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.

6. Rights of Data Subjects

To enforce your rights, please use the details provided in the Contact Section 10. In doing so, please ensure that an unambiguous identification of your person is possible.

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..

Right to correction and deletion

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 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).

Restriction of processing

You have the right to demand for – as far as statutory requirements are fulfilled – restriction of the processing of your data.

Data portability

You are entitled to receive data that you have provided to us in a structured, commonly used and machine-readable format or – if technically feasible – to demand that we transfer those data to a third party.

Objection to direct marketing

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, un-less we demonstrate compelling legitimate grounds according to legal requirements which override your rights.

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 a justified in-terest. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements which override your rights.

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.

7. Automated decision-making

We do not use automated decision-making for the establishment, execution and termination of business relationships according to Art. 22 GDPR. In case we use such procedures in particular, we will inform you about your corresponding rights subject to legal obligations.

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:

Address:
First Contact Team
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

or

Phone: +44 (0)303 123 1113
Email: casework@ico.org.uk

9. Changes to the Data Protection Notice

We reserve the right to change our security and data protection measures if this is required due to technical development. 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 change.

10. Contact

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:
https://request.privacy-bosch.com/

To notify data protection incidents please use the following link:
https://www.bkms-system.net/bosch-dataprotection

For suggestions and complaints regarding the processing of your personal data we recommend that you contact our data protection officer:

Officer for Data Protection
Information security and data protection Bosch Group
Postfach 30 02 20
70442 Stuttgart
GERMANY
Or
Mail to: DPO@bosch.com

11. Information to be provided to data subjects in accordance with Art. 13 GDPR – JOINT CONTROLLERS

As the party responsible for SingleKey ID, Bosch.IO GmbH 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 Data Protection Policy.

12. Effective date:

09.06.2023

Last update:

12.03.2024