Dremel Data Protection Notice

1.    Data Protection Notice

Bosch Power Tools B.V. (hereinafter “Dremel” 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.

2.    Dremel respects your privacy

The protection of your privacy throughout the course of processing personal data as well as the security of all business data are important concerns 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.

3.    Controller

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

Our contact details are as follows:
DREMEL Europe
Bosch Power Tools B.V.
Konijnenberg 60
4825 BD Breda
The Netherlands
Telephone number +31-(0)76-5795-000
Fax number +31-(0)76-5875-431
Online contact

Please note that in the course of registration "Bosch Power Tools" is "Joint Controller" with other companies of the Bosch Group according to Art. 26 GDPR . For more information on this and your rights in this regard, please refer to Section 4.4: "Registration".

4.    Collection, processing and usage of personal data

4.1    Processed categories of data

The following categories of data are processed:

•    Communication data (e.g. name, telephone, e-mail, address, IP address)
•    Planning and regulation data transaction

4.2    Principles

Personal data consists of all in-formation related to an identified or identifiable natural person, this includes, e.g. names, ad-dresses, phone numbers, email addresses, contractual master data, contract accounting and payment data, which is an expression of a person's identity.

We collect, process and use personal data (including IP ad-dresses) only when there is either a statutory legal basis to do so or if you have given your consent to the processing or use of personal data concerning this matter, e.g. by means of registration.

4.3    Processing purposes and legal basis

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

4.3.1    Provision of these Online Offers

(Legal basis: Fulfillment of contractual obligations. The following conditions apply: Link ).

4.3.2    Answering user requests within the scope of a contact form

(Legal basis: Fulfillment of contractual obligations or legitimate interest in the improvement of products / services).

4.3.3    Resolving service disruptions as well as for security reasons.

(Legal basis: Fulfillment of our legal obligations within the scope of data security and legitimate interest in resolving service disruptions as well as in the protection of our offers).

4.3.4    Safeguarding and defending our rights.

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

4.3.5    Self-promotion and promotion by others as well as market re-search and reach analysis done within the scope statutorily permitted or based on consent.

(Legal basis: Consent / legitimate interest on our part in direct marketing if in accordance with data protection and competition law).

4.3.6    Product or customer surveys performed via our website, email and/or tele-phone subject to your prior express consent.
(Legal basis: Consent).

4.3.7    Conducting raffles or discount campaigns in accordance with respective terms and conditions for raffles or discount campaigns.

(Legal basis: Fulfillment of contractual obligations).

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

4.4    Registration

In order to use extended functionalities, registration in our online offers is required. Below you will find more information about the registration and login process.

This is structured as follows:

4.4.1 Integrated Customer Profile Management - enables the integration of various registration options such as Bosch Single Key ID and Social Sign In.

4.4.2 Single Key ID - one of the sign-in options provided by Bosch IO.

4.4.1 iCPM, Joint Controllership, according to Art. 26 GDPR

Bosch "Integrated Customer Profile Management" (iCPM) connects different Bosch applications, with the aim that you as a business partner (user, customer) do not have to provide your data multiple times, thus offering you the best possible customer experience. In addition, iCPM offers the possibility to log in to Bosch applications via different login options.

Within the framework of iCPM,

Robert Bosch Power Tools GmbH

Max-Lang-Strasse 40-46, D-70771 Leinfelden-Echterdingen

hereinafter referred to as "Bosch PT

and

the parties listed in the "List of Parties" (hereinafter referred to as "Parties")

work

closely together. This also applies to the processing of your personal data. The Parties have jointly determined the order in which this data is to be processed in the individual process phases and are therefore to be regarded as joint controllers under data protection law pursuant to Art. 26 GDPR.

Here is a detailed overview of the joint and separate data processing activities and responsibilities of the parties:

What this means for you:

- The parties shall provide you, as data subjects, with the information required by Articles 13 and 14 GDPR in a precise, transparent, understandable and easily accessible form in clear and simple language, free of charge. Each party shall provide the other party with all necessary information from its sphere of activity.

- The parties shall inform each other without delay of the data subject rights asserted by you as a data subject. They shall provide each other with all information required to respond to your requests for information.

- You may assert your data subject rights directly against either party at any time.

4.4.2. Login with SingleKey ID, Joint Controllership

You can log in to our website with SingleKey ID.

SingleKey ID was developed by Bosch.IO GmbH for the Bosch Group to provide users with an overarching login option on Bosch websites, stores, apps and services. Bosch.IO GmbH, Ullsteinstrasse 128, 12109 Berlin, Germany, is responsible for providing SingleKey ID.

Bosch.IO GmbH processes your data for the purposes of "registration and login with SingleKey ID", as well as "overview and maintenance of master data and apps with SingleKey ID" under joint responsibility with us. For more information, please visit: https://singlekey-id.com/data-protection-notice/.

After one-time registration you can use SingleKey ID to log in. For this purpose you will be redirected to a login mask of Bosch.IO GmbH. After successful authentication, Bosch.IO GmbH will provide us with the required personal data (e.g. e-mail address, telephone number, first name, last name, language, country). Your password will not be transmitted to us.

You can terminate your SingleKey ID user contract at any time on the SingleKey ID website by deleting your SingleKey ID: https://singlekey-id.com/myprofile/. Please note that by deleting your SingleKey ID you will lose access to all Bosch websites, stores, apps and services where you have logged in with SingleKey ID.

4.5    Log files

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

We 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:

-    IP address (internet protocol address) of the terminal device used to access the Online Offer;
-    Internet address of the website from which the Online Offer is accessed (so-called URL of origin or referrer URL);
-    Name of the service provider which was used to access the Online Offer;
-    Name of the files or in-formation accessed;
-    Date and time as well as duration of recalling the data;
-    Amount of data transferred;
-    Operating system and information on the internet browser used, including add-ons installed (e.g., Flash Player);
-    http status code (e.g., “Request successful” or “File requested not found”).

4.6  REGISTRATION VIA MYDREMEL

To take advantage of an extra year of registration, you can register for MyDremel. MyDremel gives you access to an application where you can register your Dremel tools.

If you wish to apply for MyDremel, TERMS AND CONDITIONS the registration and privacy statement apply.

After successful registration, you will be able to take advantage of this offer. For this purpose, we provide a registration template for the MyDremel ID. Dremel will then confirm your authorisation and provide us with the master data required to use our offers (e.g. last name, first name, email address, telephone numbers, postal address). Your password will not be communicated to us.

See the data protection notice on further data transfers within the Bosch Group that is associated with the MyDremel app. You can cancel your MyDremel user agreement at any time by unregistering. To do this, click the following link: HTTPS://REQUEST.PRIVACY-BOSCH.COM/ENTITY/PTNB

4.7    Children

This Online Offer is not meant for children under 16 years of age.

4.8    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 basis and the recipients or categories of recipients can be found in the Section – Processing purposes and legal basis. 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 enforce-able administrative or judicial orders.

4.8.1    Service providers (general)

We involve external service providers with tasks such as programming and data hosting 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 com-ply with the statutory provisions. Service providers may also be other Bosch group companies.

4.9    Transfer to recipients outside the EEA

We might transfer personal data to recipients located outside the EEA into so-called third countries.
In such cases, prior to the transfer we ensure that either the data recipient provides an appropriate level of data protection (e.g. due to a decision of adequacy by the European Commission for the respective country or due to the agreement based on so-called EU model clauses with the recipient) or that you have consented to the transfer.

You are entitled to receive an overview of third country recipients and a copy of the specifically agreed-provisions securing an appropriate level of data protection. For this purpose, please use the statements made in the Contact section.

4.10    Duration of storage, retention periods

Principally, we store your data for as long as it is necessary to render our Online Offers and connected services or for as long as we have a legitimate interest in storing the data (e.g. we might still have a legitimate 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 in-voices available for a certain period of time).

5.    Raffles or discount campaigns

In case you participate in one of our raffles or discount campaigns, we use your data to inform you about any prize won and for the purpose of advertising our products to the extent allowed by law or as far as you have consented. Information on raffles or discount campaigns can be found in the respective terms of participation.

6.    Usage of Cookies

In the context of our online service, cookies and tracking mechanisms may be used.

Cookies are small text files that may be stored on your device when visiting our online service.

Tracking is possible using different technologies. In particular, we process information using pixel technology and/or during log file analysis.

6.1    Categories

We distinguish between cookies that are mandatorily required for the technical functions of the online service and such cookies and tracking mechanisms that are not mandatorily required for the technical function of the online service.

It is generally possible to use the online service without any cookies that serve non-technical purposes.

6.1.1    Technically required cookies

By technically required cookies we mean cookies without those the technical provision of the online service cannot be ensured. These include e.g. cookies that store data to ensure smooth reproduction of video or audio footage.

Such cookies will be deleted when you leave the website.

6.1.2    Cookies and tracking mechanisms that are technically not required

We only use cookies and tracking mechanisms if you have given us your prior consent in each case. With the exception of the cookie that saves the current status of your privacy settings (selection cookie). This cookie is set based on legitimate interest.

We distinguish between two sub-categories with regard to these cookies and tracking mechanisms:

6.2    Comfort cookies

These cookies facilitate operation and thus allow you to browse our online service more comfortably; e.g. your language settings may be included in these cookies.

6.3     Marketing cookies and tracking mechanisms

General

By using marketing cookies and tracking mechanisms we and our partners are able to show you offerings based on your interests, resulting from an analysis of your user behavior:

- Statistics:

By using statistical tools, we measure e.g. the number of your page views.

- Conversion tracking:

Our conversion tracking partners place a cookie on your computer ("conversion cookie") if you accessed our website via an advertisement of the respective partner. Normally these cookies are no longer valid after 30 days. If you visit certain pages of our website and the cookie has not yet expired, we and the relevant conversion partner can recognize that a certain user clicked on the advertisement and thereby was redirected to our website. This can also be done across multiple devices. The information obtained by means of the conversion cookie serves the purpose of compiling conversion statistics and recording the total number of users who clicked on the respective advertisement and were redirected to a website with a con-version tracking tag.

- Retargeting:

These tools create user profiles by means of advertising cookies or third-party advertising cookies so called "web beacons" (invisible graphics that are also called pixels or tracking pixels), or by means of comparable technologies. These are used for interest-based advertising and to control the frequency with which the user looks at certain advertisements. The relevant provider is the controller responsible for the processing of data in connection with the tool. The providers of the tools might disclose information also to third parties for the purposes mentioned above. Please note the data protection notices of the relevant provider in this context.
Please note that using the tools might include transfer of your data to recipients outside of the EEA where there is no adequate level of data protection pursuant to the GDPR (e.g. the USA). For more details in this respect please refer to the following description of the individual marketing tools.

6.3.1 Name: Optimizely

Vendor: Optimizely Inc.; 631 Howard Street, Suite 100; San Francisco, CA 94105

Function: Cookie can track user behavior across website and provide UX-Testing and Personalization experiences

6.3.2    Google Analytics

Name: Google Analytics

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Function: Analysis of user behavior (page retrievals, number of visitors and visits, downloads), creation of pseudonymous user profiles based on cross-device information of logged-in Google users (cross-device tracking), enrichment of pseudonymous user da-ta with target group-specific information provided by Google, retargeting, UX testing, conversion tracking and retargeting in conjunction with Google Ads

6.3.3. Tealium iQ Tag Management

Name: Tealium iQ Tag Management

Provider: Tealium Inc, 9605 Scranton Road, Suite 600, San Diego CA 92121 USA.

Function: Tealium iQ Tag Manager is used to manage website tags via an interface, as well as to integrate program codes on our websites. The tag manager itself does not store any of your personal data.

6.3.4. Tealium AudienceStream Customer Data Platform

Name: Tealium AudienceStream CDP

Provider: Tealium Inc, 9605 Scranton Road, Suite 600, San Diego CA 92121 USA.

Function: Tealium Audience Stream records your user behavior (movement profile, purchasing behavior) on our digital offers in a pseudonymized way and also includes data that is already

stored in the general customer database. This is used to improve your browsing experience, analyze website traffic, support campaign planning and analysis and to display personalized advertising on advertising networks. Tealium Audience Stream also enables us to create target groups, which we use for customer matching for

6.3.5    Hotjar

Name: Hotjar

Provider: Hotjar Ltd.,Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 3155, Malta.

Function: Cookies can track how users browse across multiple pages; creation of heatmaps, session recording, surveys/polls.

6.3.6 Google AdSense

Name: Google AdSense

Provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. ("Google").

Function:  Google Adsense can help us by ad placement, remarketing, conversion tracking

6.3.7 Google Floodlight Tag

Name: Google Floodlight Tag

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Function: Google processes your personal data on the basis of your consent via the Google Floodlight Tag in order to measure the effectiveness of our advertising campaigns, to limit the frequency with which you are shown a particular ad and to only display ads that are relevant to you and your interests. Google uses a cookie ID to record which ads are displayed in which browser and can thus prevent them from being displayed more than once. In addition, Google can use cookie IDs to record so-called conversions that are related to ad requests. The cookies do not contain any personal information such as e-mail addresses, names or addresses.

Due to the marketing tools used, your browser automatically establishes a direct connection with Google's server. Through the integration of the floodlight tag, Google receives the information that you have called up the relevant part of our website or clicked on an advertisement from us.

In addition, the Floodlight Tags used allow us to understand whether you perform certain actions on our website after calling up one of our display/video ads on another platform or clicking on it (conversion tracking). Google uses this cookie to understand the content you have interacted with on our websites in order to later send you targeted advertising. If you generally want to reject cookies, you can set up your browser so that it always informs you when a cookie is to be set. In this way, you can decide for each individual cookie whether you allow the cookie or not. Downloading and installing this browser plug-in at https://support.google.com/ads/answer/7395996, will also disable all "personalized advertising cookies".

For more information, please visit: https://policies.google.com/privacy

6.4    Management of cookies and tracking mechanisms

You can manage your cookie and tracking mechanism set-tings in the browser and/or our privacy settings.

Note: The settings you have made refer only to the browser used in each case.

6.4.1    Deactivation of all cookies

If you wish to deactivate all cookies, please deactivate cookies in your browser settings. Please note that this may affect the functionality of the website.

6.4.2    Management of your settings with regard to cookies and tracking mechanisms not required technically

When visiting our websites, you will be asked in a cookie layer whether you consent to our using of any Comfort cookies, marketing cookies or tracking mechanisms, respectively.

In our privacy settings, you may withdraw the consent with effect for the future or grant your consent at a later point in time.

 7.  Meta-Pixel

Name: Meta-Pixel (formerly "Facebook Pixel")

Provider: Meta Platforms Ireland Limited, Harbour, D2, 4 Grand Canal Quay, Square, Dublin, Ireland, ("Meta").

We are jointly responsible with "Meta" for processing operations of your personal data in the context of processing on our online offer via Meta-Pixel.

In order to determine the respective responsibilities for fulfilling the obligations under the GDPR with respect to joint processing, we have entered into a Joint Controller Agreement with Facebook. You can access the main contents of the agreement at  link at any time: https://www.facebook.com/legal/controller_addendum. In particular, it regulates which security measures "Meta" must observe (https://www.facebook.com/legal/terms/data_security_terms) and how data subject rights can be asserted against "Meta".

Function: "Meta" processes your personal data on the basis of your consent via the Meta-Pixel to create campaign reports, track conversions, click events as well as targeted advertising outside our websites (retargeting) using HTTP headers (including IP address, device and browser properties, URL, referrer URL, your person), pixel-specific data (including pixel ID and facebook cookie), click behavior, optional values (for example, conversions, page type), form field names (such as "email", "address", "quantity" for the purchase of a product or service).

We do not receive any personal data from you from "Meta", only anonymized campaign reports about website audience and ad performance.

You may opt-out of receiving interest-based ads from “Meta” by changing your advertising preferences directly on facebook or Instagram. Alternatively, you can opt-out of third-party cookie use by visiting the Digital Advertising Alliance opt-out page at http://optout.aboutads.info/?c=2&lang=EN or the http://www.youronli-nechoices.com page.

8. Social Sign In (login via social networks)

We offer you the possibility to sign into our Online Offers by so-called social sign ins such as Facebook Connect and Twitter.

To register, you are forwarded to the respective social network's page where you can sign on with your data. This means that your account with the respective network is linked to our service. In doing so, information from your public profile, your email address and the identification tags of your network friends, as well as, if applicable, further data is transmitted to us through the social network.

In turn, the social network used for the registration receives your login status, browser information and your IP address. The social network's provider or its server may be located outside the EU or the EEA (e.g. in the United States).

If you do not wish data transfer taking place between us and the social network services, log in via our own log in services instead of social log in services.

9. 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.

10. Qualtrics

On our websites, we may use the services of Qualtrics LLC, 333 W. River Park Drive, Provo UT 84604, USA to conduct customer, product, and satisfaction surveys. The goal is to continuously develop and improve our products and services. If you participate in such satisfaction survey, only so-called "lod data" (date and time stamp / information about your browser and your browser settings / information about your terminal device / usage data) will be processed. Participation in a satisfaction survey is voluntary. The legal basis for the data processing is your consent, Art. 6 para. 1 lit. a) GDPR. You can revoke your consent at any time with effect for the future.

As part of the Qualtrics services also Cookies are used, in particular to maintain the current satisfaction survey during your browsing session and to prevent multiple participations. For more information about Qualtrics LLC and how Qualtrics processes personal data, please visit https://www.qualtrics.com/privacy-statement/.

11.  Newsletter with opt-in; Right of withdrawal

Within the scope of our Online Offers you can sign up for news-letters. We provide the so-called double opt-in option 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, you can terminate the subscription at any time by withdrawing your con-sent. 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 via the contact details provided in the Contact section.

12.    External links

Our Online Offers may contain links to internet pages of third parties, in particular providers who are not related to us. Upon clicking on the link, we have no influence on the collecting, processing and use of personal da-ta possibly transmitted by clicking on the link to the third party (such as the IP address or the URL of the site on which the link is located) as the conduct of third parties is naturally beyond our control. We do not assume responsibility for the processing of 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. Our security measures are, pursuant to technological progress, constantly being improved.

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.

Right to information and access

You have the right to obtain confirmation from us about whether or not your personal data is being processed, and, if this is the case, access to your personal data.

Right to correction and deletion

You have the right to obtain the rectification of inaccurate personal data.  As far as statutory requirements are fulfilled, you have the right to obtain the completion or deletion of your data.  

This does not apply to data which is necessary for billing or accounting purposes or which is subject to a statutory retention period. If access to such data is not required, however, its processing is restricted (see the following).

Restriction of processing

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

Data portability

As far as statutory requirements are fulfilled you may request to receive data that you have provided to us in a structured, commonly used and machine-readable format or – if technically feasible –that we transfer those data to a third party.

Withdrawal of consent

In case you consented to the processing of your data, you have the right to revoke this con-sent at any time with effect for the future. The lawfulness of data processing prior to your withdrawal remains unchanged.

15.    Right to lodge complaint with supervisory authority

You have the right to lodge a complaint with a supervisory authority. You can appeal to the supervisory authority which is responsible for your place of residence or your state of residency or to the supervisory authority responsible for us. This is:

State Commissioner for Data Protection and Freedom of Information
Address:
Autoriteit Persoonsgegevens
Postbus 93374
NL 2509 AJ Den Haag/The Hague
Telefone: + 31-70-88 88 500
Telefax: + 31-70-88 88 501
E-Mail: info@autoriteitpersoonsgegevens.nl

16.    Changes to the Data Protection Notice

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.

17. Contact

If you wish to contact us, please find us at the address stated in the "Controller" section.

To assert your rights please use the following link: https://request.privacy-bosch.com/entity/PTNB.

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:

(C/ISP) Data Protection Officer
Bosch-Group
P.O. Box 30 02 20
70442 Stuttgart
GERMANY

or

mailto:DPO@bosch.com.

Effective date: 21.05.2024