PRIVACY POLICY
BOSCH UK POWER TOOLS
We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us in the event you have a complaint.
WHO WE ARE
Robert Bosch Limited and our UK Power Tools group comprising the entities listed in Section 14 below, and trading as the brands known as Bosch ("we"/”us”/"Bosch"/"UK Power Tools group") collect, use and are responsible for, certain personal information about you ("personal data"). The entities listed at Section 14 are data controllers under the General Data Protection Regulation 2016/679 as incorporated into UK domestic law as a result of Brexit ("UK GDPR"), the Privacy and Electronic Communications Regulations 2003 (and any replacement UK legislation), and the UK's Data Protection Act 2018 (collectively referred to as "Data Protection Laws").
This privacy policy outlines how Bosch will use, store and share your personal data, and supplements any other fair processing or privacy notices provided to you. However, this privacy policy does not apply where Bosch has provided you with a separate privacy policy and such policy does not include a link to this privacy policy (for example where Bosch website or app includes a link to a separate privacy policy for that specific website or app only and does not include a link to this privacy policy).
Unless a separate privacy policy is provided by us and/or such privacy policy does not link to this policy, this policy applies to any personal data we may collect about you when you:
• contact us or when we contact you, including via social media;
• purchase goods or services from us;
• carry out product testing for us;
• provide services or goods to us (where, for example, you are a sole trader, partnership or where you are providing goods or services on behalf of your employer or contractor);
• visit any of our premises;
• participate in our training at your premises or ours or online;
• enter one of our online promotions such as competitions or prize draws; and
• attend a trade show, conference, exhibition, or other event at which we have a presence.
This policy will therefore apply to you where you are a consumer or business customer or contact to the extent relevant to you, except where the policy indicates otherwise.
The details of the applicable data controller, depending on which member of our UK Power Tools companies you are dealing with, are set out at the end of this policy.
Our 'Group' refers to the constituent companies of Robert Bosch GmbH.
1. BOSCH RESPECTS YOUR PRIVACY
The protection of your privacy in the processing of your personal data is an important concern which we pay special attention to during our business operations. We use ("process") your personal data when you provide your personal data to us or when it is collected during your visit in a confidential manner and solely in accordance with the law.
2. THE PERSONAL DATA WE COLLECT AND USE
Information which you give us
We may collect your personal data when you provide it to us by filling in forms, or by corresponding with us by phone, face-to-face, email or otherwise. This includes information that you provide when you send an enquiry, through social media, which could include Facebook, Twitter, Pinterest, Youtube and Instagram or to create an account with us. We may also collect your personal data when you contact our contact centre in order to obtain information about a product or service, to register your manufacturers guarantee or register an extended warranty for your product via telephone, order spare parts via telephone, request a repair or other service via telephone, test any of our products for us, enter any of our promotions or competitions (online or elsewhere). We may also collect information from you if you respond to surveys or market research.
The personal data which we collect about you may include your name, billing and delivery addresses, date of birth, gender, your email address, user name and password, contact telephone number, credit card details, occupation , industry sector, and details of any comments or feedback which you provide to us.
We may also collect and process records of any correspondence and communications with us and a record of transaction history and details of transactions conducted on together with details of the fulfilment of any order over telephone.
Where you participate in training as part of your own employment which we provide face to face at one of our sites, or at your place of work, or online, we may collect personal data either from you directly or from your employer. Some of your information e.g. results of any assessments which we undertake as part of the training, may also be shared with your employer.
Information we collect about you
We may collect:
• information about your visits to our premises, including your image in CCTV footage (see 'CCTV' below);
• information about your calls to our contact centre, including a recording of such call and information about your orders for goods and services (see further below);
• information about you obtained at an exhibition, conference or trade show, including such events hosted by third parties (such as Bosch dealers) and those managed by third parties on our behalf. Your image may be captured in a photograph or video footage taken at our stand or elsewhere within the event for promotional purposes. The images may be used for promotional purposes such as social media channels and internal Bosch networks.
• information about services and goods that you provide to us including, for example, in connection with accidents or incidents as part of the service delivery;
• information about your buying habits and patterns when you purchase goods from us;
• information provided to us about you from lead generation companies such as Barbour;
• information about you when you send us a message on social media, which may include Facebook, Instagram, Youtube, Twitter and Pinterest. We may receive your name, profile picture, attachments and any voice messages, together with your incoming message.
Information we receive from other sources
We may receive personal information about you from other sources such as stockists of our products, from consumers who register their products with us and from third parties who work with us in connection with our websites and services. Third-party service providers may, without limitation, be appointed to provide technical support, process your transactions (see further below) and maintain your accounts or to run promotions or marketing campaigns. We may have access to any personal information provided to such vendors, service providers and third party e-commerce services.
We may receive information about you from other sources including when we use third party providers, such as Adyen N.V, to assist with financial verification checks when you are seeking to open a credit account with us and/or from third party vendors if we use customer lists from such third parties and from other third parties who work with us in connection with our goods or services. We also receive information from third party registers of suppliers where it is a condition of our contract with your employer (for example, to ensure that our supplier has appropriate insurance) when you are involved in the provision of goods or services to us.
We may also receive personal information about you from other companies within our Group to the extent we have legal basis to receive such information under Data Protection Laws.
Our customer contact centre
This is managed by Bosch Service Solutions Limited , which records incoming and outgoing telephone calls for the purposes of training, monitoring and verifying your order. Please note that no calls in which you provide your payment details are recorded. Bosch Service Solutions Limited also conduct satisfaction surveys on our behalf.
CCTV
Please note that CCTV is used across our UK sites and that your image may be captured by CCTV when you visit us. Some of our vehicles also use dashboard CCTV devices and your image may be captured when you come into contact with one of our vehicles.
Our social media pages
We receive anonymised, aggregated data from social media providers (e.g. Facebook through its 'Insights' tool) about the kinds of individuals who visit our social media page. We have access to statistical analyses from social media providers which provides us with information on how our social media page is being used by individuals. This does not include your personal data, except where you message us directly. Please see Section 3 ("How do we use your personal information?") for further detail on this use of your information.
3. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use information held about you in the following ways:
o to carry out our obligations arising from any agreements entered into between you and us and to provide you with the information, products and services that you request from us including in setting up credit accounts. We, through our third party provider, Adyen N.V, use your financial or credit card information solely for the purposes of processing payments either made by you for our products and services, or due to you by agreement (e.g. refunds) and to discharge our legal and regulatory duties.
o in the case of call recordings, to train staff, monitor staff performance and verify your order, for our legitimate business interests;
o to notify you about changes to our goods and services;
o to provide customer support;
o to analyse your spending and buying habits when purchasing goods from us to improve our own goods and services;
o to manage the goods/services that you are delivering to Bosch, for example to sign you in when you visit our site;
o to send you (i) a welcome email to verify your account when you create an account with us and (ii) other emails for the purposes of providing services to you, including in relation to account management or system maintenance;
o to safeguard our staff and other customers / users in respect of unlawful, disruptive or objectionable behaviour on our premises;
o to enhance our customer experience generally (e.g. through call recording) to ensure you receive a personalised and continuously improving customer service;
o to improve our processes and procedures;
o as part of our efforts to keep our sites and vehicles safe and secure and to improve our processes (for example, through the use of CCTV, dashboard CCTV and any other relevant image recording, and through incident reporting);
o to comply with our legal and regulatory obligations and for the purposes of assisting with the prevention and detection of crime.
o to measure, understand or monitor the effectiveness of advertising, promotions, marketing material and content and any joint initiatives with our affiliates, suppliers, partners, subcontractors and other selected third parties;
o to deliver (whether directly or indirectly via third parties) effective and personalised marketing material and content, e.g. about goods or services that may be of interest to you and to notify you about the launch of new goods, competitions, offers or other relevant news articles that you might find interesting. Your information may be shared within our UK Power Tools group, or sometimes within our wider Group for direct marketing purposes where there is a legal basis (such as your consent) for this under Data Protection Laws;
o to work with trusted third parties, including media organisations, to enable these parties to create an audience profile to present general advertisements delivered through their own platforms (including television adverts), to those whom we wish to engage and/or those who are most likely to be interested in our products and services. We may provide your contact details (email address, post code and first line of your address) to our media partners for this purpose. Your details will only be used by the third parties to create an anonymised audience profile and your details will then be securely deleted by the third party provider once this profile has been created. The delivery of such adverts will be through the media or social media account that you have with those partners and therefore subject to the privacy policies of those organisations. You may be able to adjust your account settings with these third parties if you no longer wish to receive such advertising. You can contact us at the detail set out at Section 14 below if you do not wish your details to be shared with third parties in this way.
o to process your query and to offer you support, for example, when you send us a message or query about our products and services through our social media pages, which we will then answer. We will forward the personal data which you provide to us to the appropriate Power Tools or other Bosch entity responsible for the processing of your query. The responsible Bosch entity may be located within EEA or UK. The messages which you send us on social media are also processed by the social medial providers. By way of an example, messages you send us on Facebook are also processed by Facebook as a data controller. For further information on how the social media providers process personal data please refer to their own privacy policies. For further information how we process your personal data on Facebook fanpage please refer to the Bosch privacy policy of the relevant Facebook fan page.
o We may use the personal data we collect about you on an anonymised basis to create statistics and anonymised information which we then share with third parties including ad networks, search engines and analytics providers.
4. LOG FILES
Each time you use the internet, your browser is transmitting certain information which we store in so-called log files.
We store log files to determine service disruptions and for security reasons (e.g., to investigate attack attempts) for a period of 7 days 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.
In log files, the following information is saved:
5. USING YOUR PERSONAL INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS
Data Protection Laws require that we meet certain conditions before we are allowed to use your data in the manner described in this privacy policy. We take our responsibilities under Data Protection Laws extremely seriously, including meeting these conditions. To use your personal data, we will rely on the following conditions, depending on the activities we are carrying out:
• Compliance with legal obligations: As entities established under the laws of England and Wales, each of the companies in our UK Group is obliged to comply with UK laws and guidance provided by UK regulatory bodies. In particular, we will need to process your personal data to verify your identity, establish your age, verify your source of funds for anti-money laundering and fraud purposes, and to establish whether you have been barred from any stores which stock our products or from using our website due to objectionable behaviour. You will not be able to object to processing or ask for the deletion of your personal information insofar as it falls under this category.
• Necessary for the entry into / performance of a contract: When you enter into a transaction with us, a contract between you and us will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to purchase goods from us), we will need to collect and process your personal data. Failure to provide the requisite personal information on sign-up and financial information on entering into the transaction or objecting to this type of processing / exercising your deletion rights will unfortunately mean we cannot provide our goods / services to you.
• Consent: We may send you marketing messages by email, text message or telephone about us and our products and offers where you have not unsubscribed and where you have purchased products or other services from us. We may also send you information by post on the products and services which we provide which we believe may be of interest to you. We provide easy ways to stop our marketing, and you can opt out at any time.
If you are not a customer of ours but you have provided us with consent to use your details for marketing purposes, then we may also contact you about our products and services.
If you have confirmed that you would like to hear from us about other the products and services of other companies in our UK Group or wider Group then we will use your details to contact you with marketing information about such products and services.
If you have confirmed that you would like to hear directly from other members of our UK Group or wider Group about such party’s products and services then we will share your details with such third party so they can contact you about their products and services.
In each of the situations above, you have the right to withdraw your consent at any time and can object to processing of this nature. Where you consent to us sending you marketing information, we will treat this as lasting for 12 months unless we tell you otherwise at the time.
• Legitimate interests: To use your personal data for any other purpose described in this privacy policy, we will rely on a condition known as "legitimate interests". It is in our legitimate interests to collect your personal data as it provides us with the information that we need to provide our services to you more effectively. We, and our trusted third parties, may build a profile of you so that we can provide you with information on our products and services which is tailored to your preferences.
This requires us to carry out a balancing test of our interests in using your personal data (for example, in order to provide you with the information, products and services that you request from us), against the interests you have as a citizen and the rights you have under Data Protection Laws (for example, to not have your data sold to third party marketing companies without your knowledge, or not store your personal data in insecure or unstable countries or regions). The outcome of this balancing test will determine whether we can use your personal data in the ways described in this privacy policy. We will always act reasonably and give full and proper consideration to your interests in carrying out this balancing test.
We rely upon this legal basis also when we process your personal data in response to a question from you through social media e.g. through our Facebook fan page and also when we use aggregated, anonymised data from our fan page. This is to ensure that the information we provide on this page is relevant to the visitors of our page and that the page attracts visitors who are or may be interested in our products.
6. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
When your data is no longer required for the purposes listed above, we will delete it within the periods set out below:
Marketing consents will be refreshed/deleted after 12 months (60 months for Commercial & Industrial projects) or can be withdrawn at any time (see Section 7);
Marketing emails and other communications where possible will typically be deleted after 24 months, unless we are required for legal and regulatory purposes to retain such communications for a longer period;
Our Contact Centre retains call recordings for a maximum of six months or as required by law;
CCTV recordings are usually deleted after 30 days;
Any other information will be retained for up to 6 years from the data of our last positive interaction with you, for legal and regulatory purposes. This data is archived where we have had no interaction with you for a period of 12 months. Some information, however, may be kept for longer where there is a regulatory requirement to do so e.g. some information relating to health and safety may need to be retained by us for up to 40 years.
7. MARKETING
We want to keep you informed about all our products, promotions and news, and where you have indicated you are happy to receive marketing by email, SMS or phone we will keep in touch with the latest news. We may also send you relevant information on products and services which we think may be of interest to you - you can easily opt out of this at any time by contacting as indicated below.
If you are an existing customer, we will contact you by e-mail, SMS, post or phone with information about products and services similar to those which you have already purchased from us. We may also provide you with adverts (or offers) about our products and services through your media or social media account as explained above.
If you have not made a purchase from us, and where we permit other companies in the UK Power Tools Group or wider Group to use your data, we (or they) will contact you with marketing if you have consented to this.
We may also send updates and marketing from the other companies in our UK Power Tools Group and the wider Group about their products, promotions and news to you on their behalf where you have consented to this.
If you prefer not to continue to receive promotional or marketing information from us or from the other companies in our Group, please use the unsubscribe function in the information we send you or alternatively write to our Data Security Officer using the contact details in Section 16.
8. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We may share your information with:
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; e.g. service providers who operate elements of our website service and process personal data on our behalf. These may include businesses who provide technology services such as hosting for our servers and email distribution, and business partners who provide delivery fulfilment services. We may also share your personal data with our supply and delivery partners, including electronic document interchange partners for the purpose of processing and fulfilling your order and marketing agencies who assist us with promotions. Where such sharing occurs, this will be under contractual arrangements with us and carried out in accordance with the requirements of Data Protection Laws;
• members of our UK Power Tools Group and third party suppliers and service providers for the purposes listed above under Section 3 above, for example where we use a third party to provide services to enable us to deliver goods and/or services to you or where we share IT platforms or processes within our UK Power Tools Group;
• third party suppliers and service providers such as Adyen N.V to the extent they assist our UK Power Tools Group with its legal / regulatory obligations;
• credit reference companies for the purposes of carrying out credit checks;
Credit Safe Business Solutions Limited
Bryn House
Caerphilly Business Park
Caerphilly
CF83 3GG
Dun & Bradstreet Limited
Marlow International Parkway
Marlow
Bucks
SL7 1AJ
• selected third parties so that they can contact you with details of the services that they provide, where you have expressly opted-in/consented to the disclosure of your personal data for these purposes;
• with our regulators, law enforcement or fraud prevention agencies, as well as our advisors (including legal advisors and auditors), courts, any authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters;
We will disclose your personal information to third parties:
• in the event of a merger, acquisition or other similar event, to a prospective buyer or otherwise of our business or assets, in which case we will disclose your personal data to such prospective buyer or otherwise of such business or assets;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property or safety of members of our UK Power Tools Group, our customers, staff or others. This may include exchanging information with other companies and organisations for the purposes staff and customer safety, crime prevention, fraud protection and credit risk reduction;
• in assessing your request for goods or services, we may use your personal data for the purposes of the prevention and detection of fraud. One of the purposes for which we may disclose your address and postcode details is to check against the IMRG Security Alert or any other Fraud Prevention Scheme. At all times where we disclose your personal data it will remain secure.
9. WHERE WE STORE YOUR PERSONAL DATA
The personal data that we collect from you is stored on secure information technology systems located in the UK and/or European Economic Area ("EEA"), which are operated by us or on our behalf by third parties.
Some data processing in relation to web and email services and delivery of any products ordered by you is carried out on our behalf by a third party. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this privacy policy and Data Protection Laws.
To respond to any comments and or queries which you submit to us through this website, or through social media, we may need to share your personal information with our offices or service providers located outside the EEA and UK.
Where we need to make a transfer of your personal data outside of the EEA and UK, these transfers are subject to special rules under UK Data Protection Laws.
Except where the transfer of your personal data is to a country which has been assessed by the United Kingdom as providing an adequate level of protection for personal data, we ensure that additional appropriate mechanisms are in place to protect your personal data. Our standard practice is to use the data protection contract clauses that have been approved by the the United Kingdom and where appropriate the European Commission. To obtain a copy of those clauses, or for any further information about transfers of your personal data outside of the EEA and UK, including how we secure an appropriate level of protection for personal data so transferred, please contact our Data Protection Officer whose details are provided at Section 16.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our websites; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security.
10. PROTECTING YOUR PERSONAL INFORMATION
Our employees and the companies providing services on our behalf, are obliged to confidentiality and to compliance with the applicable Data Protection Paws.
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. Our security measures are, pursuant to technological progress, constantly being improved.
Service providers
We involve external service providers with tasks such as sales and marketing services, contract management, delivery of products, payment handling, programming, data hosting and hotline services. We have chosen those service providers carefully and monitor them on a regular basis, especially regarding their diligent handling of and protection of the data that they store.
All service providers are obliged to maintain confidentiality and to be fully aware of, trained in, and compliant with, Data Protection Laws. Service providers may also be other Bosch Group companies.
11. THIRD PARTY SERVICES
Bosch online forms or offers may contain links to third-party websites operated by providers that are not associated with us. After you click the link, we no longer have any influence over the collection, storage, or processing of any personal data transmitted by clicking the link (such as IP address or URL of the page that contains the link), as the behaviour of third parties is, by nature, beyond our control.
Please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
12. YOUR RIGHTS
You have a number of rights under Data Protection Laws in relation to the way we process your personal data, although these are not absolute and in some instances we may be unable to accept your request, in which case we will respond to you to explain why. These are set out below. You may contact us using the details on our website (or by contacting us directly – details below) to exercise any of these rights and we will respond to any request received from you within one month from the date of the request.
Right 1
A right to access personal data held by us about you.
Right 2
A right to require us to rectify any inaccurate personal data held by us about you.
Right 3
A right to require us to erase personal data held by us about you. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).
Right 4
In certain circumstances, a right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims.
Right 5
In certain circumstances, a right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. This right will only apply where the processing is based on consent or a contract (see above) and the processing is carried out by automated means. You also have the right to require us to transfer this personal data to another organisation, at your request.
Right 6
A right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims.
Right 7
A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.
Right 8
A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products).
13. UPDATING YOUR PERSONAL INFORMATION
If you believe your details are incorrect you can amend your details by contacting us at the address provided below.
14. DETAILS OF THE DATA CONTROLLER
For the purpose of the Data Protection Laws, the data controller is:
• where you are dealing with our main UK Power Tools business, and in particular, Power Tools sales (including garden power tools sales), Robert Bosch Limited (SC013418) with its registered office at c/o Bosch Rexroth, Viewfield Industrial Estate, Glenrothes KY6 2RD and trading office at Broadwater Park, North Orbital Road, Denham, Uxbridge, England UB9 5HJ. Contact details of Robert Bosch Limited are as follows: Robert Bosch Limited, P.O. Box 98, Uxbridge UB9 5HN or Email: DSO@uk.bosch.com or Telephone: +44(0)344 892 0115.
• in some cases where you are dealing with our Garden Power Tools business and it is expressly stated by us that the contracting entity is Bosch Lawn and Garden Limited, then the data controller is Bosch Lawn and Garden Limited (03073491) with its registered office at Suffolk Works, Stowmarket, Suffolk IP14 1EY. Contact details of Bosch Lawn and Garden Limited are as follows: Bosch Lawn and Garden, Sufflk Works, Stowmarket, Suffolk IP14 1EY or Email: DSO@uk.bosch.com or Telephone: +44(0)344 892 0115.
15. CHANGES TO OUR PRIVACY POLICY
We reserve the right to change our security and data protection measures. 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 changes.
This policy was last reviewed and updated in August 2021.
16. CONTACT
If you wish to contact us, please find us at the address stated in the "Details of Controller" Section 14.
To assert your rights please use the following link: https://request.privacy-bosch.com/entity/RBGB/?app=c23c367f-9431-476a-a6ad-cce8400c20cb.
To notify data protection incidents please use the 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 data protection officer:
Data Protection Officer
Information Security and Privacy (C/ISP)
Robert Bosch GmbH
P.O. Box 30 02 20
70442 Stuttgart
GERMANY
or
Please address any questions, comments and requests regarding our data processing practices to us in this way in the first instance.
Please remember to include your name, address and postcode along with any correspondence reference you may have.
If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office. Their address is:
First Contact Team
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
Phone: +44 (0)303 123 1113
Email: casework@ico.org.uk