Bosch U.S. Privacy Notice Disclosure – Highlights/Notice at Collection
This U.S. Disclosure supplements the information contained in Bosch's (“Bosch or “we”) Data Protection Notice and applies solely to all visitors, users, and others of the Logistics Operating System (also referred to as “Online Service”). We adopt this U.S. Disclosure to comply with the U.S. Data Protection Requirements and any terms defined in U.S. privacy frameworks have the same meaning when used in this U.S. Disclosure.
1. COLLECTION OF PERSONAL INFORMATION
The Logistics Operating System has collected the following personal information from users of the Logistics Operating System within the last twelve (12) months:
Category and Sources of Information | Examples | Business or Commercial Purpose | We disclose, share or sell this data? | Retention |
---|---|---|---|---|
IdentifiersWe collect this information from our users, customers, and business partners. We also generate identifiers internally. | Real name, postal address, Internet Protocol address, email address, or other similar identifiers. | Business- To enable use of our sites, services, and products, to communicate with you, and to understand how our users interact with our sites. Commercial- To improve our offerings. | We disclose this data with our service providers and with business partners, including those whom you instruct us to send this information with We do not share this data. We do not sell this data. | We only retain your data for (1) as long as it is necessary to render our offers and services to you, (2) as required to meet our legal obligations (e.g. due to retention periods under tax and commercial codes we are obligated to have documents such as contracts and invoices available for a certain period of time) and (3) for other purposes such as preventing harm, security and integrity. |
Personal InformationWe collect this information from our users, customers, and business partners | Real name, postal address, email address, telephone number, employment (company affiliation). Some personal information included in this category may overlap with other categories. | Business- To enable use of our sites, services, and products, to communicate with you, and to understand how our users interact with our sites. Commercial- To improve our offerings. | We disclose this data with our service providers and with business partners, including those whom you instruct us to send this information to. We do not share this data. We do not sell this data. | We only retain your data for (1)as long as it is necessary to render our offers and services to you, (2) as required to meet our legal obligations (e.g. due to retention periods under tax and commercial codes we are obligated to have documents such as contracts and invoices available for a certain period of time) and (3) for other purposes such as preventing harm, security and integrity. |
Internet or other similar network activityWe collect this information from our users and customers | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. Additionally, we may use technology to monitor how you interact with our Online Service. This may include, without limitation which links you click on, information that you type into our online forms, and about your device or browser. Further, we utilize session replay technology to monitor and record mouse clicks and movements, keystrokes, and pages and content viewed by you. Please discontinue use of the Online Service if you do not consent to our collection of such information. | Business- To enable use of our sites, services, and products, to communicate with you, and to understand how our users interact with our sites. Commercial- To Improve our offerings. | We disclose this data with our service providers and with business partners, including those whom you instruct us to send this information to. We do not share this data. We do not sell this data. | We only retain your data for (1) as long as it is necessary to render our offers and services to you, (2) as required to meet our legal obligations (e.g. due to retention periods under tax and commercial codes we are obligated to have documents such as contracts and invoices available for a certain period of time) and (3) for other purposes such as preventing harm, security and integrity. |
Professional or employmentrelated informationWe collect this information from our users, customers, and business partners | Employer affilitation | Business- To enable use of our sites, services, and products, to communicate with you, and to understand how our users interact with our sites. Commercial- To improve our offerings. | We disclose this data with our service providers and with business partners, including those whom you instruct us to send this information to. We do not share this data. We do not sell this data. | We only retain your data for (1)as long as it is necessary to render our offers and services to you, (2) as required to meet our legal obligations (e.g. due to retention periods under tax and commercial codes we are obligated to have documents such as contracts and invoices available for a certain period of time) and (3) for other purposes such as preventing harm, security and integrity. |
Bosch will continue to collect the personal information described above. If any additional personal information is collected by Bosch, we will provide any required notice(s), and where applicable obtain any required consent(s), in accordance with applicable laws in the relevant jurisdiction.
Bosch will not collect additional categories of sensitive personal information or use sensitive personal information for additional purposes that are “incompatible with the disclosed purpose” stated in this section for collection without providing you notice.
2. Sources of Personal Information
Bosch collects personal information from the following categories of sources:
- Directly from you. For example, when given by you or collected from you through your access to and/or use of the Logistics Operating System, in context of registering an account, subscribing to or purchasing our services, requesting marketing materials or when you contact customer support or otherwise interact or communicate with Bosch, its agents, representatives, suppliers, vendors or consultants through the Logistics Operating System. This information may include, without limitation, your first and last name, address, phone number, email address, type of interest, business affiliation and position, language preference and any other information you choose to provide us.
- Indirectly from you. For example, from observing your use of the Logistics Operating System and/or the Services, or services related thereto. The following data may be collected automatically: the website from which you visit Bosch (referrer), pages viewed, files downloaded (downloads), individual links clicked, search words or search phrases (site search), duration of visit, browser used, device data (e.g., unique device identifier, MAC address, IP address, serial number, hardware model, network information and operating system and version), and other relevant details and/or information. If the visit is a result of online advertising such as banners, video ads, search engine advertising, etc., Bosch or its agents, representatives, suppliers, vendors, or consultants may record which banner, adware, etc. motivated or assisted with the visit to the Logistics Operating System.
Bosch will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent, where required by applicable laws in the relevant jurisdiction.
3. Disclosure, Sale and Sharing of Personal Information – Past 12 Months
Bosch may use, store, compile, manipulate, share and disclose your personal information with third parties for the purposes stated above. Your personal information is disclosed with the following:
- Bosch affiliated entities, including Bosch’s parent company in Germany, Robert Bosch GmbH, to leverage shared services and improve our services.
- Bosch service providers, vendors, consultants, suppliers, licensors, marketing, partners and other partners and entities performing work on Bosch’s behalf, such as hosting vendors, advertising service providers, data analytics companies, marketing service companies, list managers and delivery companies.
- Relevant authorities in accordance with, and as Bosch deems required, necessary and/or appropriate by, or in connection with, applicable law, regulation, court order or legal process.
By accessing and/or using the Logistics Operating System or the services, you consent to the above uses and disclosure of your personal information in accordance with this notice.
Sale or Sharing of Personal Information. In the preceding twelve (12) months, Bosch has not sold or shared personal information for a business or commercial purpose the following categories of personal information for the business and commercial purposes listed in Section III:
- Identifiers
- Personal Information
- Internet or other similar network activity
- Professional or employment-related information
4. Children’s Privacy
Bosch does not knowingly collect or use any personal information from online visitors under the age of 16. Bosch does not knowingly allow visitors under the age of 16 to participate in any promotions or contests that may be offered on the Logistics Operating System
5. California “Shine the Light” Privacy Rights
California’s “Shine The Light” law permits those Bosch customers who are residents of California to annually request a list of their personal information (if any) that Bosch disclosed to third parties for direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties. At this time, Bosch currently does not share any personal information with third parties for direct marketing purposes.
6. How We Respond to Do Not Track Signals
The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize and/or respond to all DNT signals.
7. Use of Links to Affiliated Sites
Our website may contain links to other Bosch sites. Our website provides these links only as a convenience. Your use of these Affiliated Sites and any related services are outside the scope of this Privacy Notice and is governed by the Privacy Notice and any other terms referred to or located on such Affiliated Sites.
8. Use of External Links
The Logistics Operating System may contain links to third-party websites or services operated by providers that are not associated with Bosch. After you click the link, Bosch no longer has any influence over the collection, storage, use or processing of any personal information transmitted by clicking the link (such as the IP address or URL of the page that contains the link), as the behavior of third parties is, by nature, beyond Bosch control. Therefore, Bosch is not responsible for the collection, storage, use, disclosure or other processing of personal information by such third parties. For further clarity, this Privacy Notice Disclosure does not apply to any such third-party websites or services; refer to the privacy statements or policies for such third-party websites or services for information about how they collect, use, disclose and protect personal information.
9. Security
Bosch takes commercially reasonable efforts to ensure that your data collected by Bosch through the Logistics Operating System is protected against tampering, loss, destruction, access by unauthorized persons or unauthorized disclosure. Bosch security measures are being continuously improved in accordance with the state of technological developments, however, absolute protection is not possible.
When you register with Bosch, you are required to create a username and password. You must not share this access information with anyone else as you are personally responsible for any information transmitted while logged in with your username and password. We disclaim any and all liability for any information transmitted due to an unauthorized log in.
10. Your Rights - US
State specific privacy laws within the United States provide data subjects certain rights regarding the personal information that businesses collect and how the collected personal information is used. If you would like to exercise data subject right available to you, see the “Exercise your Rights” section below. Our privacy team will examine your request and respond to you as quickly as possible
We may still use any aggregated and de-identified Personal Information that does not identify any individual and may also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our Agreements. We maintain and use all de-identified information in de-identified form. We do not attempt to reidentify it except to ensure our deidentification processes are in compliance with applicable law.
Dependent on the state of your residence, you may be provided the following rights:
California:
- Right to know what personal information is being collected
- Right to access your personal information.
- Right to correct inaccurate personal information.
- Right to delete personal information
- Right to know what personal information is sold or shared and to whom.
- Right to opt-out of sale or sharing of personal information for cross-context behavioral advertising
- Right to data portability
- Right to opt-out of processing for the purpose of profiling
- Right to limit the use and disclosure of sensitive personal data
- Right of no retaliation following opt-out or exercise of other rights
Virginia:
- Right to confirm if personal data is processed
- Right to access your personal information
- Right to correction inaccuracies in your personal data
- Right to delete your personal data
- Right to obtain a copy of your personal data
- Right to opt-out for the purpose of targeted advertising, sale of data, or profiling
- Right to non-discrimination
- Right to appeal
Colorado:
- Right to confirm if personal data is processed
- Right to access your personal information
- Right to correction
- Right to deletion
- Right to opt-out of sale, targeted advertising, and profiling
- Right to data portability
- Right to non-discrimination
- Right to appeal
Connecticut:
- Right to confirm if personal data is processed
- Right to access your personal information
- Right to correction
- Right to deletion
- Right to data portability
- Right to opt-out of sale, targeted advertising, and profiling
- Right to Non-Discrimination
- Right to appeal
Utah:
- Right to confirm if personal data is processed
- Right to access your personal information
- Right to deletion
- Right to data portability
- Right to opt-out of sale and targeted advertising
- Right to non-discrimination
- Right to data portability
11. How to Exercise Your Rights
To exercise your rights, submit a verifiable consumer request or access request, as applicable, to us by either:
Calling us at (888-43-BOSCH (888-432-6724)).
Sending an email to: privacy.policy@us.bosch.com
To assist Bosch in processing your request when exercising your rights, supply the following information:
- Full name
- Phone number
- Address
- Any information you can provide about your previous contact with Bosch (e.g. contact point / touchpoint with Bosch, screenshots, reference to a specific product/newsletter)
Only you (or in case of a California resident, an authorized agent authorized by you to act on your behalf – see Section Authorized Agent below for more information) may make a verifiable consumer request or access request, as applicable related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. Your verifiable consumer request or access request, as applicable, must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request or access request does not require you to create an account with us, but if you already have an account with us, you may be required to make your request through that account.
We will only use personal information provided in a verifiable consumer request or access request, as applicable, to verify the requestor’s identity or authority to make the request.
12. Response Timing and Format
We endeavor to respond to a verifiable consumer request or access request, as applicable, within forty-five (45) days of its receipt, or sooner where required by applicable law. If we require more time (up 90 days in total), where permitted by applicable law, we will inform you of the reason and extension period in writing. Opt-out request will be honored as soon as feasibly possible, but no later than 15 days from the date we receive the request.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide in response to a verifiable consumer request will only cover the 12-month period preceding the verifiable consumer request's receipt, unless otherwise required by applicable law. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, where applicable, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request or access request, as applicable, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
13. Personal Information Sales: Opt-Out and Opt-In Rights
Bosch does not sell your personal information to third parties for money. However, Bosch engages in online advertising practices (and certain analytics or similar activities) whereby we share personal information with other companies and service providers in compliance with the law in order to deliver more meaningful ads and other communications to consumers, and for other similar reasons provided in this Privacy Notice. These practices may be considered a “sale”, “sharing” or targeted advertising for cross-context behavioral advertising as defined in the CPRA, VCDPA, and other relevant U.S. state laws.
Based on your state of residence and if you are 16 years of age or older, you may have the right to direct us to not sell your personal information at any time (the "right to opt-out"). Furthermore, where required by applicable law in the relevant jurisdiction, we will obtain your consent prior to selling your personal information. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by submitting a request to us via this email link.
To exercise the right to opt-out, you may submit a request to us via this email link
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
To disable sharing through cookies set by third parties that may be considered “sales” or “sharing” under the CPRA, VCDPA, and other relevant U.S. state laws, please refer to the “Manage Cookies” link in the cookie banner of the [websites / application].
14. Authorized Agent
As a California resident you may also exercise your request to know or request to delete through an authorized agent. When you submit your request through an authorized agent we require that you:
- Provide us a copy of your written permission for the authorized agent to submit the applicable request; and
- Verify your own identity directly with us.
The foregoing does not apply when you have provided your authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465; provided, that we may require a copy of such power of attorney before fulfilling any request.
15. Non-Discrimination; Financial Incentives
We will not discriminate against you for exercising any of your rights. Unless permitted by applicable law, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by applicable law that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. When we offer financial incentives, we request identifiers and contact information, though we may also request additional personal information.
16. Filing a Complaint
Regulatory authorities that oversee the privacy laws and regulations, including the Office of the Privacy Commissioner of Canada, advise individuals to file an objection or challenge with the relevant company before lodging a formal complaint with a regulatory authority. If you are dissatisfied with Bosch’s response to an objection or challenge filed under Article XX above, or you if wish to file a complaint with a regulatory authority first, you may do so as follows:
Under PII Laws: You may file a complaint with the relevant state’s Attorney General’s office.
Under U.S. State Privacy Laws : You may file a complaint with the applicable state Attorneys General Office or regulatory agency.
17. Changes to Privacy Notice
Due to the constantly changing nature of Bosch business, Bosch reserves the right to change, update, revise and/or modify this Privacy Notice at any time at Bosch’s sole discretion, and Bosch will post any new or revised Privacy Notice here. Any such change, update, revision and/or modification will be effective immediately upon posting on this website, unless we are required to provide direct notice or obtain your consent pursuant to applicable laws. Use of information that Bosch gathers now will be subject to the Privacy Notice in effect at the time of use. By using or navigating around the Logistics Operating System or utilizing any of the Services, you acknowledge that you have read, understand and agree to be bound by this Privacy Notice Disclosure in and the applicable Terms of Use. If you do not agree to be so bound, do not remain on the Logistics Operating System. You are responsible for checking the Logistics Operating System frequently to keep apprised of recent changes.
The effective date of this Privacy Notice is 05/16/2023
Last reviewed: 05/16/2023
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