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

Germany

E-Mail: 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 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 Bosch.IO 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. Bosch.IO GmbH, Ullsteinstraße 128, 12109 Berlin, 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 Bosch.IO 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 Bosch.IO GmbH registration template for the centralised Bosch-ID. The Bosch.IO 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.

3.7 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 (https://www.adyen.com/)

3.8 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.

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

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: http://tools.google.com/dlpage/gaoptout?hl=de

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:

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#_=_

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 und 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.

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 information in the "Contact" section or our online tool under the following link: https://www.bkms-system.net/bosch-datenschutz. Please make sure that we can uniquely identify you.

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

Address: Königstrasse 10a, 70173 Stuttgart

Postal address: P.O. Box 10 29 32

Phone: 0711/615541-0

Fax: 0711/615541-15

E-Mail: poststelle@lfdi.bwl.de

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 exercise your rights and report data protection incidents, please use the following link: https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=18rbds19&c=-1&language=eng

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:

Group Commissioner for Data Protection

Information Security and Privacy Bosch Group (C/ISP)

Robert Bosch GmbH

Kronenstrasse 22

70173 Stuttgart

Germany

or

Email: Abteilungsbriefkasten.cisp@de.bosch.com

17. Effective Date

25-01-2021