Data protection policy of Bosch Smart Home online shop

1. Bosch respects your privacy

The Robert Bosch Smart Home GmbH (hereinafter „Robert Bosch Smart Home GmbH“ or "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.
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 that was gathered during your visit of our Online Offers confidentially and only in accordance with statutory regulations. Data protection and information security are included in our corporate policy.

2. Controller

The Robert Bosch Smart Home GmbH is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows:
Robert Bosch Smart Home GmbH
Schockenriedstr. 17
70565 Stuttgart-Vaihingen,
Service@bosch-smarthome.com

3. Collection, processing and usage of personal data

3.1 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 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. Several legal bases can be applicable in parallel and allow the processing of personal data.

3.2 Processing purposes and legal bases
We; as well as the service providers commissioned by us process your personal data for the following processing purposes:

Website
Provision of these Online Offers (Legal basis: Justified interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law).

Online store
Provision of these Online Offers and fulfillment of a contractual obligations under our contractual terms including invoicing. Invoicing may include the sale of claims.
(Legal bases: Fulfillment of contractual obligation, respectively our justified interest in an efficient claims management as regards the sale of claims).

Chat Board function
Answering user requests within the scope of a Chat Board.
(Legal bases: Fulfillment of contractual obligations or the implementation of pre-contractual measures taken in response to the data subject's request or justified interest in the processing of your request, consent).

Advertisements and/or market research (including web analysis, no customer surveys
Self-promotion and promotion by others as well as market research and reach analysis within the scope statutorily permitted.
(Legal bases: Justified interest on our part in marketing as long as this occurs in accordance with data protection and competition law, consent, if necessary).

Resolving service disruptions as well as for security reasons
Legal bases: Fulfillment of contractual obligations or fulfillment of our legal obligations within the scope of data security, and justified interest in resolving service disruptions as well as in ensuring the protection of our offers.

Product or customer surveys performed via email and/or telephone subject to your prior express consent
Legal basis: Consent.

Raffles
Conducting of raffles in accordance with respective terms and conditions for raffles.
(Legal basis: Fulfillment of contractual obligations).

Discount campaigns
Conducting of discount campaigns in accordance with respective terms and conditions for discount campaigns.
(Legal basis: Fulfillment of contractual obligations).

Newsletter
Sending an email or SMS/MMS newsletter with the recipient’s consent
(Legal basis: Consent).

Safeguarding and defending our rights
Legal basis: Justified interest on our part for safeguarding and defending our rights.

3.3 Registration
If you wish to use/access benefits that require the formation of a contract, we request that you register. Within the scope of the registration we collect personal data necessary for the formation and the fulfillment of the contract (e.g., first name, last name, date of birth, email address, if applicable, details on the preferred payment method or on the account holder) as well as, if applicable, additional data on a voluntary basis. Mandatory statements are marked with a *.

3.4 Log files
Each time you use the internet, your browser is transmitting certain information which we store in so-called log files when you visit our website.
We save log files for a short period of time to determine service disruptions and for security reasons (e.g., to investigate attack attempts) and delete them afterwards. 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. Also see module web analysis.

3.5 Chat Board
Within the scope of this Online Offer, we give you the opportunity to learn about the products and services offered by us by means of a chat. When using the chat, the chat conversation is recorded. After the chat, it will be deleted soon thereafter unless the chat is part of a support or service request. In the latter case, the chat’s content is assigned to your customer account and will be saved for the purpose of fulfilling the contractual obligations or the implementation of pre-contractual measures.

3.6 Data transfer

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 the implementation of pre-contractual measures, or if we ourselves, or a third party, have a legitimate interest in the data transfer, or if you have given your consent. Particulars on the legal bases can be found in the Section - Purposes of Processing and Legal Bases. Third parties may also be other companies of the Bosch group. When data is transferred to third parties based on a justified interest, this is explained in this data protection notice.
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.

Use of service providers
We involve external service providers with tasks such as sales and marketing services, contract management, payment handling, programming, data hosting and hotline services. All service providers are obliged to maintain confidentiality and to comply to the statutory provisions. Service providers may also be other Bosch group companies.

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.
Adyen (You will be forwarded to the website from Adyen)

Parcel announcements
For the announcement of your parcels, we transfer your email address and phone number to:
DHL Paket GmbH, Sträßchensweg 10, Postcode/City 53113 Bonn, Germany] or to [United Parcel Service Deutschland S.à r.l. & Co. OHG, Görlitzer Straße, Postcode/City 41460 Neuss, Germany.
These companies process data as data controllers.
Data transfer to recipients outside the EEA
We might transfer personal data to recipients located outside the EEA into so-called third countries.

3.7 Duration of storage; retention periods
Principally, we store your data for as long as it is necessary to render our Online Offers and connected services 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 after fulfillment of our contractual obligations). In all other cases we delete your personal data with the exception of data we are obliged to store for the fulfillment of legal obligations (e.g. due to retention periods under the tax and commercial codes we are obliged to have documents such as contracts and invoices available for a certain period of time).

4. Raffles and discount campaigns

In case you participate in one of our raffles, we use your data to inform you about any prize won. We can use that data for the purpose of advertising our products as far as you have consented. Information on raffles can be found in the respective terms of participation.
In case you participate in one of our discount campaigns (as for cash-back campaign), we use your data to inform you about any prize won. This may require you to provide us with information and evidence (e.g. copy of a voucher with required information) to purchase one of our products. Information on the individual discount campaigns can be found in the respective terms of participation.

5. Cookie usage

5.1 General
Cookies are small text files that are saved on your computer when an Online Offer is accessed. In case you access this Online Offer another time, your browser sends the cookies' content back to the respective seller and, thus, allows the re-identification of the terminal device. Reading the cookies allows us to design our Online Offers optimally for you and makes it easier for you to use them.

5.2 Deactivation and deletion of cookies
When you visit our internet pages you will be asked in a cookie layer pop up whether you wish to allow the cookies which are being set on our page or you want to deactivate them in the settings.
In case you decide to block cookies, an opt out cookie is set in your browser. This cookie exclusively serves the purpose of assigning your objection. Deactivating cookies may disable individual functions of our internet pages.
Please note that an opt out cookie may, for technical reasons, only be set for the browser that was used to set it. In case you delete cookies or use a different browser or a different terminal device, you must opt out again.
The preference setting does not apply to cookies that are being set during your visits on third party internet pages by other providers.
Your browser allows you to delete all cookies at all times. To do so, please consult your browser's help functions. This might, however, lead to individual functions no longer being available.
In addition, you are able to manage and deactivate the use of third party cookies on the following web page:
http://www.youronlinechoices.com/uk/your-ad-choices.
As we do not operate this website, we are not responsible and we are unable to influence content and availability.

5.3 Overview of cookies used by us
In this section, please find an overview of cookies we use.
Absolutely necessary cookies
Certain cookies are necessary so we can securely render our Online Offers. This category includes, e.g.:

  • Cookies that identify or authenticate our users;
  • Cookies that temporarily save certain user input (e.g., content of a shopping cart or of an online form);
  • Cookies that store certain user preferences (e.g., search or language set-tings);
  • Cookies that store data to ensure a trouble-fee playback of video or audio content.


Analytical cookies
We use analytical cookies to record the usage behavior (e.g., ad banners clicked on, search queries put in) of our users and to evaluate it statistically.

Advertisement cookies
We also use cookies for advertisement purposes. The usage behavior profiles created with the assistance of such cookies (e.g., ad banners clicked, visited sub-pages, search queries entered) are used by us to show you advertisements or offers that are tailored to your interests ("interest based advertisement").

Third party advertisement cookies
We also allow other companies to assess data of our users through advertisement cookies. This allows us and third parties to show the users of our Online Offers interest based advertisements which are based on an analysis of your usage behavior (e.g., ad banners clicked on, visited subpages, search queries put in) in total, thus, not restricted to our Online Offers.

Conversion cookies
Our conversion tracking partners set a cookie on your computer ("conversion cookie") in case you entered our website through an advertisement of the respective partner. These cookies generally lose their validity after 30 days. In case you visit certain pages we host and the cookie has not yet expired, we and the respective conversion tracking partner can see that a particular user clicked the ad and was forwarded to our page. Information gathered through the conversion cookie is used to create conversion statistics and to determine the total number of users who clicked the respective ad and were referred to a page furnished with a conversion tracking tag.

Tracking cookies in connection with social plugins
Some pages of our Online Offers integrate contents and services from other providers (e.g., Facebook, Twitter) who may in turn use cookies and active components. We are unable to influence the processing of personal data done by these providers. Find more details on social plugins in the Social Plugins section.

6. Web analysis

We need statistical information about the usage of our Online Offers to design them to be more user-friendly, to perform range measurements and market research. For this purpose, we use the web analysis tools described in this section.
The usage profiles created by these tools using analysis cookies or by evaluating log files are not brought together with personal data. The tools either do not use user IP addresses at all or shorten them immediately after gathering them.
In the following please find information on each tool seller and how you are able to object to the collection and processing of data by the tool.
Be advised that with regard to tools which use opt out cookies, the opt out function is related to that individual device or browser. In case you use several terminal devices or browsers you must opt out on every device and with every browser used.
When using cookies and analysis tools, we might transfer personal data to recipients located outside the EEA into so-called third countries.
Beyond this, you can avoid the forming of usage profiles by generally deactivating cookie usage. Please refer to the section Deactivate and delete cookies.

WebTrends
WebTrends is provided by WebTrends Inc., 851 SW 6th Ave., Suite 1600, Portland, Oregon 97206, USA.
You may object to the collection or processing of your data by using the opt out possibility by clicking the following link: https://ondemand.webtrends.com/support/optout.asp.

Optimizely
Optimizely is provided by Optimizely GmbH, Spichernstrasse 6, 50672 Cologne, Germany.
You may object to the collection or processing of your data by using the opt out possibility by clicking the following link: https://www.optimizely.com/de/opt_out/.

Google Analytics
Google Analytics Google Analytics is provided by Google Inc., 1600 Amphitheatre Park-way, Mountain View, CA 94043, USA ("Google"). We use Google Analytics with the additional function offered by Google to anonymize IP addresses. While doing so, Google already short-ens IPs within the EU in most cases but only does so for exceptional cases in the United States, and in both regions it only saves shortened IPs. You may object to the collection or processing of your data by using the following link to download and install a browser plugin: http://tools.google.com/dlpage/gaoptout?hl=en
You can object to the collection and/or evaluation of your data using this tool by clicking directly on the following link.
Click here to be excluded from the Google Analytics measurement.
We use the Google Tag Manger for advertising purposes. You can object to the collection and/or evaluation of your data by clicking directly on the following link.
Click here to opt out of the Google Tag Manager

Tealium iQ Tag Management
Tealium iQ Tag Management is provided by Tealium, 11095 Torreyana Road, San Diego, CA 92121, USA.
You may object to the collection or processing of your data by using the offered Do Not Track (DNT) option on the website https://tealium.com/gb/privacy/.

7. Usage of retargeting tools

For the purpose of optimizing our online marketing we use so-called retargeting technologies. This is to design a more interesting Online Offer for you, which is tailored to your needs. To do so, we use the tools listed below. The usage profiles compiled with the assistance of advertisement cookies or third party advertisement cookies, so-called web beacons (invisible graphics which are also called pixels or counting pixels) or comparable technologies that are not combined with personal data.
The tools are used by the providers to show our users in our Online Offers and in third party offers interest-based advertisements and to control the frequency in which users see certain advertisements. The provider of the respective tool is responsible for the data processing in connection with the tools. The tool providers eventually transfer information to third parties for abovementioned reasons.
When using retargeting tools, we might transfer personal data to recipients located outside the EEA into so-called third countries.
With each tool you can find information on the tool provider as well as information on how to object to the data collection by this tool.
Be advised that with regard to tools which use opt out cookies, the opt out function is related to that individual device or browser. In case you use several terminal devices or browsers you must opt out on every device and with every browser used.
Beyond this, you can avoid the forming of usage profiles by generally deactivating cookie usage; for this please refer to the section Deactivate and delete cookies.
Further information on interest-based advertising may be found on the consumer portal http://www.meine-cookies.org. The following link to the portal additionally enables you to view the activation status of certain tools provided by different providers and to object to the collection and processing of your data by these tools: http://www.meine-cookies.org/cookies_verwalten/praeferenzmanager-beta.html.
The option to object to certain tools especially issued by U.S. based providers can be found at the following link: http://www.networkadvertising.org/choices/.
Specifically, we use the following tools:

7.1 Double-click
Double-click is offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Find further information on this tool here.
You may object to the collection and processing of your data by this tool by following Google's user references.
7.2 Facebook Pixel
Provider of Facebook Pixel is Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA.
Further information on this tool may be found here.
You may object to the collection or processing of your data by this tool by deactivating the interest-based online advertisements under the following link. https://www.facebook.com/settings/?tab=ads#_=_

7.3 Visual Website Optimizer Provider of Visual Website Optimizer is Wingify, KLJ Tower, Netaji Subash Place, Pitampura, New Delhi, Delhi 110034, India. Further information on this tool may be found here.
You may object to the collection or processing of your data by this tool by following the given instructions on the website.

8. Usage of our mobile applications

In addition to our Online Offers, we offer mobile applications ("Apps"), which you can download to your mobile device. Beyond the data collected on websites, we collect additional personal data through our apps that specifically result from the usage of a mobile device. This is subject to your prior express consent.

9. Social Plugins

In our Online Offers we use so-called social plugins from various social networks; these are individually described in this section.
When using plugins, your internet browser creates a direct connection to the respective social networks’ server. This way, the respective provider receives information that your internet browser has accessed from the respective site of our Online Offers, even if you do not have a user account with this provider or are currently not logged into this account. Log files (including the IP address) are, in this case, directly transmitted from your internet browser to a server of the respective provider and might be stored there. The provider or its server may be located outside the EU or the EEA (e.g., in the United States).
The plugins are standalone extensions by social network providers. For this reason, we are unable to influence the scope of data collected and stored by them.
Purpose and scope of the collection, the continued processing and usage of data by the social network as well as your respective rights and setting options to protect your privacy can be found by consulting the respective social network's data protection notices.
In case you do not wish social network providers to receive and, if applicable, store or use data, you should not use the respective plugins.
By using the so-called two click solution (provided by Heise Medien GmbH & Co. KG) we protect your visit to our web pages from being logged and processed by social network providers by default. When using a page of our internet presence which contains such plugins, these are initially deactivated. Only when you click on the respective button, the plugins are activated.

Transfer to recipients outside the EEA
We might transfer personal data to recipients located outside the EEA into so-called third countries.
Facebook plugins
Facebook is operated under www.facebook.com by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, and under www.facebook.de by Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland ("Facebook"). Find an overview over Facebook's plugins and their appearance here: http://developers.facebook.com/plugins; find information on data protection at Facebook here: http://www.facebook.com/policy.php.

Google+ plugins
Google+ is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Find an overview over Google's plugins and their appearance here: https://developers.google.com/+/plugins; find information on data protection at Google+ here: http://www.google.com/intl/de/+/policy/+1button.html.

Twitter plugins
Twitter is operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA ("Twitter"). Find an overview over Twitter's plugins and their appearance here: https://twitter.com/about/resources/buttons; find information on data protection at Twitter here: https://twitter.com/privacy.

10. YouTube

Our Online Offers use the YouTube video platform which is operated by YouTube, LLC, 901 Cherry Ave. San Bruno, CA 94066, USA („YouTube”). YouTube is a platform which allows the playback of audio and video files.
When you access a respective site of our Online Offers that contains an embedded YouTube player, this creates a connection to YouTube so that the video or audio file can be transmitted and played back. In doing so, data is transferred to YouTube as a data processor. We are not responsible for the processing of such data by YouTube.
Additional information on the scope and purpose of collected data, on further processing and usage of data by YouTube, on your rights and the privacy options available to be chosen by you, can be found in YouTube's data protection notice.

11. Newsletter

Within the scope of our Online Offers you are able to sign up for newsletters. To do so, we use the so-called double opt-in procedure which means that we will only send you a newsletter via email, mobile messenger (such as, e.g., WhatsApp), SMS or push notification after you have explicitly confirmed the activation of the newsletter service to us by clicking on the link in a notification. In case you wish to no longer receive newsletters at a later date, you can terminate the subscription at any time by withdrawing your consent. You can withdraw your consent to email newsletters by clicking on the link which is sent in the respective newsletter mail, or in the administrative settings of the online offer. Alternatively, please contact us using the contact details provided in the Contact section.

12. External Links

Our Online Offers may contain links to third party internet pages – by providers who are not related to us. Upon clicking on the link, we have no influence on processing and using personal data possibly transmitted by clicking the link to the third party. We do not assume responsibility for the processing of such personal data by third parties.

13. Security

Our employees and the companies providing services on our behalf, are obliged to confidentiality and to compliance with the applicable data protection laws. We take all necessary technical and organizational measures to ensure an appropriate level of security and to protect your data that are administrated by us especially from the risks of unintended or unlawful destruction, manipulation, loss, change or unauthorized disclosure or unauthorized access.

14. User rights

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

14.1 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.

14.2 Right to correction and deletion
You have the right to obtain the rectification of inaccurate personal data concerning yourself without undue delay from us. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
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).

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

14.4 Objection to data processing
You have the right to object to data processing by us at any time. We will no longer process the personal data unless we demonstrate compliance with legal requirements to provide provable reasons for the further processing which are beyond your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

14.5 Objection to direct marketing
Additionally, you may object to the processing of your personal data for direct marketing purposes at any time. Please take into account that, due to organizational reasons, there might be an overlap between your objection and the usage of your data within the scope of a campaign which is already running.

14.6 Withdrawal of consent
In case you consented to the processing of your data, you have the right to object this consent with immediate effect. The legality of data processing prior to your revocation remains unchanged. In addition, processing may continue to be permitted on the basis of another legal bases.

14.7 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. This does not apply if a transfer affects the rights and freedoms of another person.

14.8 Right of 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 or to the supervisory authority responsible for us. This is:
State Commissioner for Data Protection and Freedom of Information Baden-Württemberg

15. Changes to the Data Protection Notice

As far as the circumstances of the data processing change, we can adjust the privacy policy. Furthermore, 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.

16. Contact

If you wish to contact us, for example in connection with the processing of personal data or for the exercise of your user rights, please find us at the address stated in the "Controller" section.
If you want to unsubscribe from a newsletter, you can click on the corresponding unsubscribe link in the newsletter or tell us your request via the contact options mentioned in the “Controller” section.
To assert your data subject requests and notification of data protection incidents please use following link:
https://www.bkms-system.net/bosch-datenschutz

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

Mr.
Matthias Goebel
Group Commissioner for Data Protection
Information Security and Privacy Bosch Group (C/ISP)
Robert Bosch GmbH
Kronenstrasse 20
70173 Stuttgart

or
mailto: Abteilungsbriefkasten.cisp@de.bosch.com.

17. Effective Date

22.05.2018

Bosch Smart Home App Privacy Statement

1. Bosch respects your privacy

The Robert Bosch Smart Home GmbH (hereinafter „Robert Bosch Smart Home GmbH“ or "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. 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 that was gathered during your visit of our Online Offers confidentially and only in accordance with statutory regulations. Data protection and information security are included in our corporate policy.

2. Controller

The Robert Bosch Smart Home GmbH is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows:

Robert Bosch Smart Home GmbH
Schockenriedstr. 17
70565 Stuttgart-Vaihingen
Service@bosch-smarthome.com

3. Collection, processing and usage of personal data

3.1 Principles

The Bosch Smart Home App and connected devices (e.g. Smart Home Controller) with their functionalities serve to offer you more comfort in your home. For the execution of the contract, i.e. for the provision of related services (e.g. app functionalities, control of the Smart Home Controller), it is unavoidable that we collect data that can be related to you or another natural person. Personal data is all information that refers to an identified or identifiable natural person, such as names, addresses, telephone numbers, e-mail addresses, contract, booking and billing data that are an expression of a person's identity. Some of the data we process is not personal data. With regard to this information, we have neither an interest in identifying a natural person, nor do we have the necessary knowledge or the legally permissible means to establish a personal reference. We may use such non-personal data to improve our products, for example. We only collect, process and use personal data if we have a legal basis for this or if you have given us your consent in this regard, e.g. as part of a registration. Several legal bases can coexist and allow the processing of personal data.

Processed data includes:

Contract information (e.g. when purchasing from the online shop)
This personal data that is necessary to establish, execute and terminate the contractual relationship with you. This includes in particular name and registration information.

Usage-related and technical information
This is information that is not personal or for which we are unable to establish any personal reference. These are required to enable the operation and use of the Bosch Smart Home System (in particular Smart Home Controller and Smart Home App). In concrete terms, these are:

  • Characteristics for identification as user (SHC identification, IP address)
  • Information on the beginning, end and scope of use of the Smart Home System
  • Device IDs
  • Device ID for event notification
  • Settings of the app regarding the use of offered services
  • Technical information to synchronize and provide current time and updates of your system via our servers
  • System data e.g. connected devices and accessories, serial numbers, Smart Home Controller specifications, software versions of the individual components
  • System status data, e.g. sensor readings, system time, timer program points, error messages
  • History data of the Smart Home System
  • Type of terminal used, e.g. smartphone or tablet PC, manufacturer, OS version of the terminal, device ID
  • Application usage data e.g. frequency of use, registered crashes, application errors
  • Smart Home system data.

Integration of additional Smart Home products into your Bosch Smart Home System
If you integrate additional Bosch Smart Home products (e.g.'360° indoor camera','Eyes outdoor camera','Twinguard','Home Connect') into your Bosch Smart Home System, it is usually necessary that you register with the product and/or service provider and accept the additional terms and conditions. It may also be necessary to allow connection to the Bosch Smart Home System in the additional product so that data can be exchanged. Please note that the data exchanged may be personal information.

3.2 Processing purposes and legal bases

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

Provision of these service (app and online storage)
Legal basis: Fulfillment of contractual obligations

Customer administration
Legal basis: Fulfillment of a contractual obligations

Resolving service disruptions as well as for security reasons
Legal bases: Fulfillment of contractual obligations or fulfillment of our legal obligations within the scope of data security, and justified interest in resolving service disruptions as well as in ensuring the protection of our offers.

Customer surveys
Product or customer surveys performed via email and/or phone in case you have expressly consented to this
Legal basis: Consent

Safeguarding and defending our rights
Legal basis: Justified interest on our part for safeguarding and defending our rights

Your request to the Robert Bosch Smart Home GmbH
Legal basis: Fulfillment of contractual obligations or implementation of pre-contractual measures; justified interest on our part on the consideration and clarification of request directed by our customers.

Contact based on your call to the customer hotline of the Robert Bosch Smart Home GmbH Provided that the transmission of personal data and technical data is voluntary, encrypted.
Legal basis: Justified interest on our part on the elimination of faults and the safety of our offers

3.3 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 a short period of time to determine service disruptions and for security reasons (e.g., to investigate attack attempts).

3.4 Data transfer

Data transfer to other controllers
Your personal data is principally forwarded to other controllers only when required for the fulfillment of a contract, in the case where we or the third party have a legitimate interest in the transfer, or when your consent has been given. Particulars on the legal bases can be found in the Section - Processing purposes and legal bases. Third parties may also be other companies of the Bosch group. When data is transferred to third parties based on a justified interest, this is explained in this data protection notice. 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.

Use of service providers
We involve external service providers with tasks such as sales and marketing services, contract management, payment handling, programming, data hosting and hotline services. All service providers are obliged to maintain confidentiality and to comply to the statutory provisions. Service providers may also be other Bosch group companies.

3.5 Integration of components provided by other providers

Use of Amazon Alexa
You have the option of controlling your Smart Home products via Amazon Alexa voice commands. To do so, you have to connect your Smart Home products to Amazon Alexa. If you control your Smart Home product via Alexa, you may have to transmit personal data via Amazon to your Smart Home product and vice-versa. If you give voice commands to Amazon Alexa in order to control Smart Home products or retrieve information from your Smart Home product, voice data are transmitted to Amazon and used by Amazon to perform the service. These data may be personal data. By connecting your Amazon Alexa and Bosch accounts and by activating skills, you make it plain that the Smart Home product installed on your system is to be controlled via Amazon Alexa and that information is to be output via Amazon Alexa and you instruct us to exchange data with Amazon Alexa in this context. You and Amazon are responsible for the data processing that is entailed. The data processing performed by Amazon is subject to Amazon's usage and privacy protection terms. Bosch has no influence on them. Please refer to Amazon's usage and privacy protection terms with regard to Alexa for more information on data processing by Amazon.

Use of Google Home
You have the option of controlling your Smart Home products via voice commands by Google products. To do so, you have to connect your Smart Home products to Google. If you control your Smart Home product via Google, you may have to transmit personal data via Google to your Smart Home product and vice-versa. If you give voice commands to Google in order to control Smart Home products or retrieve information from your Smart Home product, voice data are transmitted to Google and used by Google to perform the service. These data may be personal data. By connecting your Google Home and Bosch accounts and by activating skills, you make it plain that the Smart Home product installed on your system is to be controlled via Google and that information is to be output via Google and you instruct us to exchange data with Google in this context. You and Google are responsible for the data processing that is entailed. The data processing performed by Google is subject to Google’s usage and privacy protection terms. Bosch has no influence on them. Please refer to Google’s usage and privacy protection terms with regard to Google Home products for more information on data processing by Google.

3.6 Duration of storage; retention periods

Principally, we store your data for as long as it is necessary to render our Online Offers and connected services or for as long as we have a justified interest in storing the data. In all other cases we delete your personal data with the exception of data we are obliged to store for the fulfillment of legal obligations or are entitled to pursue our legal claims.

4. Security

Our employees and the companies providing services on our behalf, are obliged to confidentiality and to compliance with the applicable data protection laws. We take all necessary technical and organizational measures to ensure an appropriate level of security and to protect your data that are administrated by us especially from the risks of unintended or unlawful destruction, manipulation, loss, change or unauthorized disclosure or unauthorized access.

5. User rights

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

5.1 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.

5.2 Right to correction and deletion:
You have the right to obtain the rectification of inaccurate personal data concerning yourself without undue delay from us. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement. 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).

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

5.4 Objection to data processing:
You have the right to object to data processing by us at any time. We will no longer process the personal data unless we demonstrate compliance with legal requirements to provide provable reasons for the further processing which are beyond your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

5.5 Objection to data processing based on the legal basis of „justified interest “:
In addition, you have the right to object to the processing of your personal data any time, insofar as this is based on the legal basis of justified interest. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements for the processing, which override your rights.

5.6 Withdrawal of consent:
In case you consented to the processing of your data, you have the right to object this consent with immediate effect. The legality of data processing prior to your revocation remains unchanged. In addition, processing may continue to be permitted on the basis of another legal bases.

5.7 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. This does not apply if a transfer affects the rights and freedoms of another person.

5.8 Right of 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 or to the supervisory authority responsible for us. This is:

State Commissioner for Data Protection and Freedom of Information Baden-Württemberg
Address: Königstrasse 10a, 70173 Stuttgart
Postal address: P.O. Box 10 29 32, 70025 Stuttgart
Phone: 0711/615541-0
Fax: 0711/615541-15
Email: poststelle@lfdi.bwl.de

6. Changes to the Data Protection Notice

As far as the circumstances of the data processing change, we can adjust the privacy policy. Furthermore, 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.

7. Contact

If you wish to contact us, for example in connection with the processing of personal data or for the exercise of your user rights, please find us at the address stated in the "Controller" section.

If you want to unsubscribe from a newsletter, you can click on the corresponding unsubscribe link in the newsletter or tell us your request via the contact options mentioned in the “Controller” section.

To assert your rights, as well as for suggestions and complaints regarding the processing of your personal data, we recommend that you contact our group commissioner for data protection:

Mr.
Matthias Goebel
Group Commissioner for Data Protection
Information Security and Privacy Bosch Group (C/ISP)
Robert Bosch GmbH
Kronenstrasse 20
70173 Stuttgart

or
Abteilungsbriefkasten.cisp@de.bosch.com

8. Effective date

11.05.2018

Bosch Smart Camera solution privacy policy

1. Bosch respects your privacy

Robert Bosch Smart Home GmbH (we) appreciate your interest in our company and your use of our products, apps and services.

The Robert Bosch Smart Home GmbH (hereinafter „Robert Bosch Smart Home GmbH“ or "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.
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 that was gathered during your visit of our Online Offers confidentially and only in accordance with statutory regulations. Data protection and information security are included in our corporate policy.

2. Controller

The Robert Bosch Smart Home GmbH is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows:
Robert Bosch Smart Home GmbH
Schockenriedstr. 17
70565 Stuttgart-Vaihingen,
Service@bosch-smarthome.com

3. Collection, processing and usage of personal data

3.1 Principles

The Bosch Smart Camera App, the video cameras connected to it and the online storage accessible via the app, serve with their functionalities to make your home safer. For the execution of the contract, i.e. for the provision of related services (e.g. functionalities of the app, storage of image data in the online storage), it is necessary that we collect data that can be related to you or another natural person.
Personal data is all information that refers to an identified or identifiable natural person, such as names, addresses, telephone numbers, e-mail addresses, contract, booking and billing data that are an expression of a person's identity. Some of the data we process is not personal data. With regard to this information, we have neither an interest in identifying a natural person, nor do we have the necessary knowledge or the legally permissible means to establish a personal reference. For example we may use such non-personal data to improve our products.
We only collect, process and use personal data if we have a legal basis for this or if you have given us your consent in this regard, e.g. as part of a registration. Several legal bases can be applicable in parallel and allow the processing of personal data.
Processed data includes:
Contract details
This is personal data that is required to establish, execute and terminate the contractual relationship with you. This includes in particular name and registration information.

Usage-related and technical information
This is information that can be personal. These are required to enable the operation and use of the Bosch Smart Camera App and the storage of data in the online memory. In concrete terms, these are:

  • Characteristics for identification as user (user ID, identification, IP address)
  • Information on the beginning, end, and scope of use of the Bosch Smart Camera App
  • Device IDs
  • Location information
  • Contact data (e.g. for event notification)
  • Settings of the app regarding our offered services
  • Technical information for the adjustment and the provision of current time and updates of your system by our servers
  • System data e.g. connected cameras and accessories, serial number, software versions of the individual components
  • Circumstances of image generation (e.g. light conditions, date, time)
  • System status data, e.g. system time, error messages
  • Event history of the video system
  • Type of terminal used, e.g. smartphone or tablet PC, manufacturer, OS version of the terminal device
  • Application usage data e.g. frequency of use, registered crashes, application errors

Content data
This is data that relates to natural persons and that you generate with the Bosch Smart Camera App and the connected cameras. Only with this data is a sensible operation of the security solution possible from your point of view. Content data includes:


Registration via the central Bosch-ID
You may register for our online offers exclusively using the central Bosch-ID. The centralised Bosch-ID was devised by Robert Bosch GmbH for the Bosch Group in order to allow for the joint users to benefit from offers of different group companies using centralised application data and increase data safety.
Robert Bosch GmbH, Robert-Bosch-Platz 1 70839 Gerlingen-Schillerhöhe, Germany is responsible for the provision of this single sign-on service.
If you want to apply for a centralised Bosch-ID, the General Terms of Use for the Registration and Use of a centralised Bosch-ID and the Data Protection Notice of the Robert Bosch GmbH shall apply.
After successful registration you may utilise the registration data used for the centralised Bosch ID also for registering for this online offer. To this end, we shall provide an Robert Bosch GmbH registration template for the centralised Bosch-ID. The Robert Bosch GmbH then shall confirm your authorisation and provide us with the master data required for using our offers (e.g. surname, first name, date of birth, company name, email address, telephone numbers, mail address). Your password shall not be communicated to us.
Concerning further data transfers within the Bosch Group associated with the centralised Bosch-ID, please refer to the Data Protection Notice.

3.2 Processing purposes and legal bases
We; as well as the service providers commissioned by us; process your personal data for the following processing purposes:

Provision of these Online Offers and fulfillment of contractual obligations under our contractual terms
Legal basis: Fulfillment of contractual obligations.

Resolving service disruptions as well as for security reasons.
Legal bases: Fulfillment of contractual obligations or fulfillment of our legal obligations within the scope of data security, and justified interest in resolving service disruptions as well as in ensuring the protection of our offers.

Safeguarding and vindication of our rights
Legal basis: Justified interest on our part for the safeguarding and vindication of our rights.

Other purposes
Ensuring that the app and associated devices (e.g. cameras) are up-to-date and secure (e.g. by providing updates).

3.3 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 to determine service disruptions and for security reasons (e.g., to investigate attack attempts).

3.4 Data transfer

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 the implementation of pre-contractual measures, or if we ourselves, or a third party, have a legitimate interest in the data transfer, or if you have given your consent. Particulars on the legal bases can be found in the Section - Purposes of Processing and Legal Bases. Third parties may also be other companies of the Bosch group. When data is transferred to third parties based on a justified interest, this is explained in this data protection notice.
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.

Use of service providers
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 ensure that they carefully handle 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. When involving external service providers, we might transfer personal data to recipients located outside the EEA into so-called third countries.

3.5 Integration of components provided by other providers

Use of Amazon Alexa

You have the option of controlling your Smart Home products via Amazon Alexa voice commands. To do so, you have to connect your Smart Home products to Amazon Alexa. If you control your Smart Home product via Alexa, you may have to transmit personal data via Amazon to your Smart Home product and vice-versa. If you give voice commands to Amazon Alexa in order to control Smart Home products or retrieve information from your Smart Home product, voice data are transmitted to Amazon and used by Amazon to perform the service. These data may be personal data. By connecting your Amazon Alexa and Bosch accounts and by activating skills, you make it plain that the Smart Home product installed on your system is to be controlled via Amazon Alexa and that information is to be output via Amazon Alexa and you instruct us to exchange data with Amazon Alexa in this context. You and Amazon are responsible for the data processing that is entailed. The data processing performed by Amazon is subject to Amazon's usage and privacy protection terms. Bosch has no influence on them. Please refer to Amazon's usage and privacy protection terms with regard to Alexa for more information on data processing by Amazon.

3.6 Duration of storage; retention periods
Principally, we store your data for as long as it is necessary to render our Online Offers and connected services or for as long as we have a justified interest in storing the data. In all other cases we delete your personal data with the exception of data we are obliged to store for the fulfillment of legal obligations (e.g. due to retention periods under the tax and commercial codes we are obliged to have documents such as contracts and invoices available for a certain period of time).
In certain cases, we will offer you the option to arrange for the deletion of data yourself. For instance, if you use the delete function in the Bosch Smart Camera app, the images recorded in the data storage facilities in the video camera, Bosch Smart Camera App and online data storage will be deleted. Personal data and configuration information will also be deleted and will no longer exist.

4. Security

Our employees and the companies providing services on our behalf, are obliged to confidentiality and to compliance with the applicable data protection laws.
We take all necessary technical and organizational measures to ensure an appropriate level of security and to protect your data that are administrated by us especially from the risks of unintended or unlawful destruction, manipulation, loss, change or unauthorized disclosure or unauthorized access.

5. User rights

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

5.1 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.

5.2 Right to correction and deletion:
You have the right to obtain the rectification of inaccurate personal data concerning yourself without undue delay from us. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
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).

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

5.4 Objection to data processing:
You have the right to object to data processing by us at any time. We will no longer process the personal data unless we demonstrate compliance with legal requirements to provide provable reasons for the further processing which are beyond your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

5.5 Objection to data processing based on the legal basis of "justified interest":
In addition, you have the right to object to the processing of your personal data any time, insofar as this is based on the legal basis of justified interest. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements for the processing, which override your rights.

5.6 Withdrawal of consent:
In case you consented to the processing of your data, you have the right to object this consent with immediate effect. The legality of data processing prior to your revocation remains unchanged. In addition, processing may continue to be permitted on the basis of another legal bases.

5.7 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.

This does not apply if a transfer affects the rights and freedoms of another person.
5.8 Right of 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 or to the supervisory authority responsible for us. This is:
State Commissioner for Data Protection and Freedom of Information Baden-Württemberg
Address: Königstrasse 10a
70173 Stuttgart
Postal address:
P.O. Box 10 29 32
70025 Stuttgart
Phone: 0711/615541-0
Fax: 0711/615541-15
Email: poststelle@lfdi.bwl.de

6. User responsibility

You are responsible for ensuring use of the Bosch Smart Camera solution in compliance with the law. In this context, you are obliged to comply with the statutory provisions which are applicable to you or the place of use, particularly those relating to data protection.
Applicable statutory provisions may, in particular, restrict the purposes of use, installation locations, selection of image details and storage period of the video sequences. If required, inform persons, employees or third parties who live in the monitored premises or who are present there for a significant period of time of the use and specific circumstances of the Bosch Smart Camera solution as is appropriate.

7. Changes to the Data Protection Notice

As far as the circumstances of the data processing change, we can adjust the privacy policy. Furthermore, 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.

8. Contact

If you wish to contact us, for example in connection with the processing of personal data or for the exercise of your user rights, please find us at the address stated in the "Controller" section.
If you want to unsubscribe from a newsletter, you can click on the corresponding unsubscribe link in the newsletter or tell us your request via the contact options mentioned in the “Controller” section.
To assert your rights, as well as for suggestions and complaints regarding the processing of your personal data, we recommend that you contact our group commissioner for data protection:
Mr.
Matthias Goebel
Group Commissioner for Data Protection
Information Security and Privacy Bosch Group (C/ISP)
Robert Bosch GmbH
Kronenstrasse 20
70173 Stuttgart
or
mail-to: Abteilungsbriefkasten.cisp@de.bosch.com.

9. Effective date

09.05.2018

Bosch Twinguard App privacy policy

1. Bosch respects your privacy

The Robert Bosch Smart Home GmbH (hereinafter „Robert Bosch Smart Home GmbH“ or "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.
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 that was gathered during your visit of our Online Offers confidentially and only in accordance with statutory regulations. Data protection and information security are included in our corporate policy.

2. Controller

The Robert Bosch Smart Home GmbH is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows:

Robert Bosch Smart Home GmbH
Schockenriedstr. 17
70565 Stuttgart-Vaihingen
Service@bosch-smarthome.com

3. Collection, processing and usage of personal data

3.1 Principles

The Bosch Twinguard App, the smoke alarms connected to it and the online storage accessible via the app, serve with their functionalities to make your home safer. For the execution of the contract, i.e. for the provision of services in this context (e.g. functionalities of the app, storage of reporting information in the online storage), it is necessary that we use data that may be related to you or another natural person. Personal data is all information that refers to an identified or identifiable natural person, such as names, addresses, telephone numbers, e-mail addresses, contract, booking and billing data that are an expression of a person's identity. Some of the data we process is not personal data. With regard to this information, we have neither an interest in identifying a natural person, nor do we have the necessary knowledge or the legally permissible means to establish a personal reference. For example we may use such non-personal data to improve our products. We only collect, process and use personal data if we have a legal basis for this or if you have given us your consent in this regard, e.g. as part of a registration. Several legal bases can be applicable and allow the processing of personal data.
Processed data includes:

  • Characteristics for identification as user (user ID, identification, IP address, identifier, e.g. token for push messages, telephone number)
  • Contact data (first name, last name, e-mail address, e.g. for notifications)
  • Measured values (temperature, relative humidity, volatile organic compounds -VOC, ambient brightness), time of alarms/test alarms
  • Device IDs, the connected smoke alarms, the gateway and mobile phones (EUI64, Device Token mobile phones)
  • App or smoke alarm settings (e.g. pre-alarm, heartbeat, sensitivity settings)
  • Technical information for the adjustment and provision of current time and updates of the system
  • System data e.g. connected smoke alarms, software versions, system status information, error messages
  • System log data


Registration via the central Bosch-ID
You may register for our online offers exclusively using the central Bosch-ID. The centralised Bosch-ID was devised by Robert Bosch GmbH for the Bosch Group in order to allow for the joint users to benefit from offers of different group companies using centralised application data and increase data safety.
Robert Bosch GmbH, Robert-Bosch-Platz 1 70839 Gerlingen-Schillerhöhe, Germany is responsible for the provision of this single sign-on service.
If you want to apply for a centralised Bosch-ID, the General Terms of Use for the Registration and Use of a centralised Bosch-ID and the Data Protection Notice of Robert Bosch GmbH shall apply.
After successful registration you may utilise the registration data used for the centralised Bosch ID also for registering for this online offer. To this end, we shall provide a Robert Bosch GmbH registration template for the centralised Bosch-ID. The Robert Bosch GmbH then shall confirm your authorisation and provide us with the master data required for using our offers (e.g. surname, first name, date of birth, company name, email address, telephone numbers, mail address). Your password shall not be communicated to us.
Concerning further data transfers within the Bosch Group associated with the centralised Bosch-ID, please refer to the Data Protection Notice.
3.2 Processing purposes and legal bases

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

Provision of these services (app and online storage)
Legal basis: Fulfillment of contractual obligations.

Customer administration
Legal basis: Fulfillment of a contract.

Resolving service disruptions as well as for security reasons
Legal bases: Fulfillment of contractual obligations or fulfillment of our legal obligations within the scope of data security, and justified interest in resolving service disruptions as well as in ensuring the protection of our offers.

Customer survey – via email and/or telephone
Product or customer surveys performed via email and/or telephone subject to your prior express consent (Legal basis: Consent).

Safeguarding and defending our rights
Legal basis: Justified interest on our part for safeguarding and defending our rights.

Your request to the Robert Bosch Smart Home GmbH
Legal basis: Justified interest on our part on the consideration and clarification of request directed by our customers.

Contact based on your call to the customer hotline of the Robert Bosch Smart Home GmbH
Provided that the transmission of I) personal data and II) technical data is voluntary, encrypted. (Legal basis: Justified interest on our part on the elimination of faults and the safety of our offers)

3.3 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 to determine service disruptions and for security reasons (e.g., to investigate attack attempts).
3.4 Data transfer

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 a legitimate interest in the data transfer, or if you have given your consent. Particulars on the legal bases can be found in the Section - Processing purposes and legal bases. Third parties may also be other companies of the Bosch group. When data is transferred to third parties based on a justified interest, this is explained in this data protection notice.
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.

Use of service providers
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 ensure that they carefully handle 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. When involving external service providers, we might transfer personal data to recipients located outside the EEA into so-called third countries.

3.5 Integration of components provided by other providers

Use of Amazon Alexa
You have the option of controlling your Smart Home products via Amazon Alexa voice commands. To do so, you have to connect your Smart Home products to Amazon Alexa. If you control your Smart Home product via Alexa, you may have to transmit personal data via Amazon to your Smart Home product and vice-versa.
If you give voice commands to Amazon Alexa in order to control Smart Home products or retrieve information from your Smart Home product, voice data are transmitted to Amazon and used by Amazon to perform the service. These data may be personal data. By connecting your Amazon Alexa and Bosch accounts and by activating skills, you make it plain that the Smart Home product installed on your system is to be controlled via Amazon Alexa and that information is to be output via Amazon Alexa and you instruct us to exchange data with Amazon Alexa in this context. You and Amazon are responsible for the data processing that is entailed. The data processing performed by Amazon is subject to Amazon's usage and privacy protection terms. Bosch has no influence on them. Please refer to Amazon's usage and privacy protection terms with regard to Alexa for more information on data processing by Amazon.

3.6 Duration of storage; retention periods

Principally, we store your data for as long as it is necessary to render our Online Offers and connected services or for as long as we have a justified interest in storing the data. In all other cases we delete your personal data with the exception of data we are obliged to store for the fulfillment of legal obligations (e.g. due to retention periods under the tax and commercial codes we are obliged to have documents such as contracts and invoices available for a certain period of time).
In certain cases, we will offer you the option to arrange for the deletion of data yourself. For instance, by removing the gateway via the Bosch Twinguard App data stored in the backend are deleted. Personal data and configuration information will also be deleted and will no longer exist.

4. Security

Our employees and the companies providing services on our behalf, are obliged to confidentiality and to compliance with the applicable data protection laws.
We take all necessary technical and organizational measures to ensure an appropriate level of security and to protect your data that are administrated by us especially from the risks of unintended or unlawful destruction, manipulation, loss, change or unauthorized disclosure or unauthorized access.

5. User rights

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

5.1 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.

5.2 Right to correction and deletion:
You have the right to obtain the rectification of inaccurate personal data concerning yourself without undue delay from us. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
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).

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

5.4 Objection to data processing:
You have the right to object to data processing by us at any time. We will no longer process the personal data unless we demonstrate compliance with legal requirements to provide provable reasons for the further processing which are beyond your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

5.5 Objection to data processing based on the legal basis of "justified interest":
In addition, you have the right to object to the processing of your personal data any time, insofar as this is based on the legal basis of justified interest. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements for the processing, which override your rights.
5.6 Withdrawal of consent:
In case you consented to the processing of your data, you have the right to object this consent with immediate effect. The legality of data processing prior to your revocation remains unchanged. In addition, processing may continue to be permitted on the basis of another legal bases.

5.7 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. This does not apply if a transfer affects the rights and freedoms of another person.

5.8 Right of 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 or to the supervisory authority responsible for us. This is:

State Commissioner for Data Protection and Freedom of Information Baden-Württemberg
Address: Königstrasse 10a, 70173 Stuttgart
Postal address: P.O. Box 10 29 32, 70025 Stuttgart
Phone: 0711/615541-0
Fax: 0711/615541-15
Email: poststelle@lfdi.bwl.de

6. User responsibility (Your responsibility for lawful use)

You are responsible for the lawful use of the Bosch smoke alarm. In this context, you are obliged to comply with the statutory provisions which are applicable to you or the place of use, particularly those relating to data protection.

Applicable statutory provisions may in particular include prescribing or restricting designated use or installation locations. Insofar as it is necessary, please notify residents or persons, employees or third parties present in areas under surveillance of the use of Bosch products and the specific circumstances.

7. Changes to the Data Protection Notice

As far as the circumstances of the data processing change, we can adjust the privacy policy. Furthermore, 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.

8. Contact

If you wish to contact us, for example in connection with the processing of personal data or for the exercise of your user rights, please find us at the address stated in the "Controller" section.
If you want to unsubscribe from a newsletter, you can click on the corresponding unsubscribe link in the newsletter or tell us your request via the contact options mentioned in the “Controller” section.
To assert your rights, as well as for suggestions and complaints regarding the processing of your personal data, we recommend that you contact our group commissioner for data protection:

Mr.
Matthias Goebel
Group Commissioner for Data Protection
Information Security and Privacy Bosch Group (C/ISP)
Robert Bosch GmbH
Kronenstrasse 20
70173 Stuttgart
or
mail-to: Abteilungsbriefkasten.cisp@de.bosch.com.

9. Effective Date

16/05/2018