NEVONEX Privacy Policy for CCPA and Canada


1. NEVONEX Privacy Policy – Highlights

NEVONEX, belonging to Robert Bosch GmbH, Business Unit CVO, has set out below some important highlights of the Privacy Policy for our NEVONEX services. You can obtain more information about how we collect, use, disclose and safeguard your personal information by reviewing our full Privacy Policy below.


2. What personal information do we collect?

We collect various types of information about our users in connection with the services or products provided through the NEVONEX services (collectively, the “Services”), including:

  • Information we collect directly from you (i.e., when given by you);
  • Information we collect indirectly from you (i.e., collected when you use the NEVONEX Services); and
  • Information we obtain from third-party sources.

We also may collect information in ways that we describe to you at the point of collection or otherwise with your consent.


3. Why do we collect personal information and how is it used?

  • Fulfilling or meeting the reason you provided the information.
  • Technical administration of Bosch and Bosch affiliate websites, mobile applications and/or services.
  • Maintaining the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
  • Customer, vendor, licensor and/or supplier administration, review and/or reports.
  • Administering, maintaining, personalizing and improving Bosch and Bosch affiliates’ mobile applications, products and services, including, without limitation, to authenticate users, provide requested services, provide optional additional services and to develop new features, products and/or services.
  • Providing customer service.
  • Responding to submitted inquiries and customer service requests and other questions and/or comments.
  • Compliance with legal and/or regulatory requirements.

Bosch will not collect or use personal information for materially different, unrelated or incompatible purposes without providing you notice (or obtaining your consent, where required by applicable laws in the relevant jurisdiction).


4. Is personal information shared or disclosed?


Bosch may share your information with:

  • Bosch affiliated entities,
  • service providers, vendors, consultants, suppliers, licensors, marketing, partners and other partners and entities performing work on Bosch’s behalf, as follows:
  • 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;

5. What are the risks?

  • We may transfer your personal information to countries other than the country where you reside, including to affiliates and service providers. Therefore, your information may be accessible to courts, law enforcement and national authorities in other countries. You can obtain information about Bosch’s policies and practices with respect to foreign service providers, or ask questions about the collection, use, disclosure or storage of personal information by such service providers, by contacting our Privacy Policy Administrator as described in the Privacy Policy.
  • Bosch security measures are being continuously improved in accordance with the state of technological developments, however, absolute protection is not possible. We cannot guarantee the security of information posted or transmitted using the NEVONEX Services.

6. What else should you know?

  • Your personal information will be stored in Germany and accessible to system administrators for the NEVONEX service providers, consultants, suppliers, licensors, partners and other partners and entities performing work on our behalf.
  • You may contact our Privacy Policy Administrator, as described in the Privacy Policy, with any questions about the collection of your personal information.
  • In some circumstances, you also may have a right to access, update, and correct inaccuracies in your personal data (e.g., pursuant to local law).
  • Any additional choices you may have are described in the full Privacy Policy below.

Notice to Canadian Users: Please note that by using the NEVONEX Services and/or voluntarily providing your personal information to us, as applicable, you are consenting to the collection, use and disclosure of your personal information as described in our Privacy Policy and summarized above.



I. Bosch NEVONEX Services PRIVACY POLICY


Introduction


Robert Bosch GmbH, Business unit CVO (“Bosch”, “ we”, “us” or “our”) is pleased to have you (“you” or “your”) [visit our websites (“Bosch Website”)/use our application (“Application”)] and welcomes your interest in the services or products provided through the NEVONEX Services (collectively, the “Services”). This Privacy Policy (this “Notice”) applies to all users of the NEVONEX Services and the Services, anywhere in the United States, Canada, and their respective territories and possessions. Terms capitalized but not defined in this Privacy Policy are as defined in the “Terms”.


The protection of your privacy is an important concern to which we pay special attention. We process Personal Information collected during your visit to the NEVONEX Services and use of Services in compliance with this Privacy Policy and all applicable laws and regulations. Data protection and information security are part of Bosch corporate policy.


Notice to Canadian Users: Please note that by using the Website/Application and/or voluntarily providing your Personal Information to us, as applicable, you are consenting to the collection, use and disclosure of your Personal Information as described in this Notice. If you do not consent to the processing of your Personal Information in accordance with this Notice, please do not access or continue to use the Bosch Website/Application or otherwise provide any Personal Information to us.


II. Scope


This Notice covers our treatment of (1) personally identifiable information, as defined by numerous statutes in the United States ( “ PII Laws”), (2) personal information, as defined by the California Consumer Privacy Act (“CCPA”), and (3) personal information, as defined by Canada’s Personal Information Protection and Electronic Documents Act and any applicable substantially similar provincial legislation (“Canadian Privacy laws”) (collectively, “Personal Information”) which we gather when you are accessing, viewing, completing, or using this NEVONEX Services or our Services.


III. Collection of Personal Information


The NEVONEX Services has collected the following Personal Information from users within the last twelve (12) months


Category and Sources of InformationExamplesHow we use itHow we share it

Identifiers

We collect this information from our users, customers, and business partners. We also generate identifiers internally.

real name, alias, postal address, unique personal identifier, online

identifier, Internet Protocol address, email address, account name.

To enable use of our sites, services, and products, to communicate with you, to understand how our

Users interact with our sites, and to improve our offerings

We share this data with our service providers and with business partners, including those whom you instruct us to send this information

Personal Information under Cal. Civ. Code § 1798.80(e)

We collect this information from our users, customers, and business partners

name, address, telephone number. Some Personal Information included in this category may overlap with other categories.

To enable use of our sites, services, and products, to communicate with you, to understand how our users interact with our sites, and to improve our offerings

We share this data with our service providers and with business partners, including those to whom you instruct us to send this information

Commercial information

We collect this information from our customers, and generate it internally during transactions with our customers

Products or services purchased, obtained, or

considered, or other purchasing or consuming histories or tendencies.

To transact with you if you use our services or products, and to enable transactions you’ve requested

We share this data with our service providers and with business partners, including those to whom you instruct us to send this information

Internet or other similar network activity

We collect this information from our users and customers

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

To enable use of our sites, services, and products, to communicate with you, to understand how our users interact with our sites, and to improve our offerings

We share this data with our service providers and with business partners, including those to whom you instruct us to send this information

Geolocation data

We collect this information from our users and customers

Physical location or movements of the installed hardware (CPU)

To enable use of our sites, services, and products, to understand how our users interact with our sites, and to improve our offerings

We share this data with our service providers

Protected classifications

We collect this information from our users, customers, and business partners

Gender e.g. Mr., Mrs., Ms.

To understand how our users interact with our sites, and to conduct research into product trends and markets

We do not share this information


III.2.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.


IV. Sources of Personal Information


Bosch collects Personal Information from the following categories of sources:


0 Directly from you. For example, when given by you or collected from you through your access to and/or use of the NEVONEX Services and/or the Services, in context of registering an account, subscribing to or purchasing our Services, posting materials or when you contact customer support or otherwise interact or communicate with Bosch, its agents, representatives, suppliers, vendors or consultants through the NEVONEX Services. This information may include, without limitation, your first and last name, address, phone number, e-mail address, log in data, logging data, GPS data of the installed CPU and any other information you choose to provide us.


1 Indirectly from you. For example, from observing your use of the NEVONEX Services 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 NEVONEX Services.


2 From our business partners. For example notifying us who has purchased the NEVONEX services so we will be able to grant you access to the purchased service(s).


V. Use of Personal Information and Purpose Specification.


Bosch may use your Personal Information for the purpose of:

  1. Fulfilling or meeting the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our Services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a Service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  2. Technical administration of Bosch and Bosch affiliate websites, mobile applications and/or services.
  3. Maintaining the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
  4. Customer, vendor, licensor and/or supplier administration, review and/or reports.
  5. Administering, maintaining, personalizing and improving the NEVONEX services, products and services, including, without limitation, to authenticate users, provide requested services, provide optional additional services and to develop new features, products and/or services.
  6. Providing customer service.
  7. Responding to submitted inquiries and customer service requests and other questions and/or comments.
  8. Compliance with legal and/or regulatory requirements.
  9. Evaluating or conducting a merger, sale of assets, consolidation or restructuring, financing or acquisition of all or a portion of any Bosch business, asset or opportunity by, with or into another business, entity or company.

NEVONEX 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).


VI. Sharing and Disclosure of Personal Information.


Bosch may use, store, compile, manipulate, share and disclose your Personal Information with third parties for the purposes stated above. Your Personal Information is shared with the following third parties:


  1. Bosch affiliated entities, including Bosch’s parent company in Germany, Robert Bosch GmbH, to leverage shared services and improve our Services;
  2. Bosch third party service providers, vendors, consultants, suppliers, licensors, partners and other partners and entities performing work on Bosch’s behalf, such as hosting vendors, advertising service providers, data analytics companies, list managers and delivery companies.
  3. 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 NEVONEX Services, you consent to the above uses and sharing of your Personal Information in accordance with this policy.


Disclosure or Sale of Personal Information – Past 12 Months

  1. [Identifiers]
  2. [Commercial information.]
  3. [Geolocation data of the installed CCU.]
  4. [Sensory data of the installed CCU.]

We disclose your Personal Information for a business purpose to the following categories of third parties:

  • Service providers.

VII. Sale of Personal Information – Past 12 Months


Disclosure of Personal Information. In the preceding twelve (12) months, Bosch Information for a business has disclosed the following categories of Personal Information for a business purpose:


NEVONEX Services does not "sell" personal information of California consumers as defined by the CCPA.


VIII. International Data Transfer


Bosch may transfer your Personal Information to Bosch’s parent company in Germany, Robert Bosch GmbH, and/or to any other Bosch affiliates throughout the world, including, without limitation, Robert Bosch GmbH, Business unit CVO, when processing, storing, analyzing and otherwise using data. Bosch may also transfer your data to a third party outside the country of origin. Accordingly, your Personal Information may be accessible to courts, law enforcement and national authorities in countries other than the country in which you reside. You can obtain information about Bosch’s policies and practices with respect to foreign service providers (including affiliates), or ask questions about the collection, use, disclosure or storage of personal information by such service providers, by contacting our Privacy Policy Administrator as described below.


IX. 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 made available on NEVONEX Services from time to time.


X. 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.


XI. Use of links to affiliated sites


The NEVONEX Services may contain links to other Bosch sites (“Affiliated Sites”). The NEVONEX Services provides these links only as a convenience. Your use of these Affiliated Sites and any related services are outside the scope of this Privacy Policy, and is governed by the Privacy Policy and any other terms referred to or located on such Affiliated Sites.


XII. Use of external links / Features


The NEVONEX Services 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, NEVONEX is not responsible for the collection, storage, use, disclosure orother processing of Personal Information by such third parties.For further clarity, this Privacy Policy does not apply to any such third party websites or services; please 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.


XIII. Security


Bosch takes commercially reasonable efforts to ensure that your data collected by Bosch through this NEVONEX Services 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.


XIV. Use of cookies


Bosch cookies.

Bosch uses cookies and active components (e.g., JavaScript) to track visitors’ preferences and customize the design of the NEVONEX Services.


Cookies are small text files stored on your computer or device when you visit a Website/Application. If you wish, you can delete the cookies at any time from your web browser. However, this can result in some functions no longer being available. For information on deleting the cookies, please consult your browser‘s help function.


Bosch makes it possible to control the use of cookies. To do so, click the “Privacy settings” link in the footer. This link gives you additional information about the cookies used. In addition, you can configure which cookies you want to use there.


There will be only technically necessary cookies being set.


XV. Rights of California “consumers” relating to Personal Information collected by NEVONEX Services.


Individuals who fall within the definition of a “consumer” under the California Consumer Privacy Protection Act have the following rights relating to their Personal Information collected by NEVONEX Services.


  1. Right to access specific information and data portability rights. You have the right to request that Bosch discloses certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see below, How to Exercise Your Rights), we will disclose to you:
    1. The categories of Personal Information we collected about you.
    2. The categories of sources for the Personal Information we collected about you.
    3. Our business or commercial purpose for collecting or selling that Personal Information.
    4. The categories of third parties with whom we share that Personal Information.
    5. The specific pieces of Personal Information we collected about you.
    6. If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
      1. For “sales”, the Personal Information categories that each category of recipient purchased; and
      2. for disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
  2. Deletion Request Rights. You have the right to request that Bosch delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
    1. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
      1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
      2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
      3. Debug products to identify and repair errors that impair existing intended functionality.
      4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
      5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
      6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
      7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
      8. Comply with a legal obligation.
      9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

XVI. Your Rights – Canadians


Individuals located in Canada have certain rights pursuant to Canadian Privacy Laws. Subject to certain exceptions and limitations, and depending upon the jurisdiction where you reside, such rights may include:

  1. The right to withdraw your consent to the collection, use or disclosure of your Personal Information.
  2. The right to be informed of the existence, use, and disclosure of your Personal Information, and to be provided with an account of the use that has been made or is being made of this information as well as the third parties to which it has been disclosed (including a list of organizations to which your information may have disclosed).
  3. The right to challenge the accuracy and completeness of your Personal Information, and have it amended, updated or rectified as appropriate.
  4. The right to acquire information about Bosch’s policies and practices with respect to Personal Information, including: a description of the type of personal information held by Bosch and a general account of its use; a copy of any brochures or other information that explain our policies, standards, or codes; and information about what Personal Information is shared with or accessible to our affiliates.
  5. The right to challenge Bosch’s compliance with the applicable Canadian Privacy Laws.

XVII. How to exercise your rights


To exercise your rights, please submit a verifiable consumer request or access request, as applicable, to us by either:


Calling us at (888-43-BOSCH (888-432-6724)).


Sending us an Email to: DPO@bosch.com


Only you (or in case of a California resident, an authorized agent authorized by you to act on your behalf – see Section XX, 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.


XVIII. 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 (including Canadian Privacy Laws). 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.


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.


XIX. Sale of Personal Information – Past 12 Months


Sales of Personal Information.

In the preceding twelve (12) months, NEVONEX Services has not sold Personal Information for a business purpose. We do not sell your Personal Information for a business purpose to third parties.


XX. 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.


XXI. Non-Discrimination


We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.


XXII. 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 PIPEDA:You may file a complaint with the Office of the Privacy Commissioner of Canada. Depending upon the province where you live, you may also (or instead) have the right to file a complaint with the applicable provincial privacy commissioner/regulator.


Under PII Laws:You may file a complaint with the relevant state’s Attorney General’s office.


Under the CCPA:You may file a complaint with the California Attorney General’s Office. For additional information regarding consumer complaints against a business/company under the CCPA and to initiate the complaint process, please click on the link.


XXIII. Changes to Privacy Policy


Due to the constantly changing nature of Bosch business, NEVONEX reserves the right to change, update, revise and/or modify this Privacy Policy at any time at NEVONEX’s sole discretion, and NEVONEX will post any new or revised Privacy Policy 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 Policy in effect at the time of use. By using or navigating around the NEVONEX Services or utilizing any of the Services, you acknowledge that you have read and understood and agree to be bound by this Privacy Policy in and the applicable Terms of Use. If you do not agree to be so bound, do not remain on the NEVONEX Services. You are responsible for checking the NEVONEX Services frequently to keep apprised of recent changes.

________________________________________________________________________

The effective date of this Privacy Policy is: 2020.11.09


XXIV. Contact


To obtain more information or to submit suggestions or complaints regarding the processing of your Personal Information, you can contact the Bosch Privacy Policy Administrator.


If incorrect information has been stored despite Bosch efforts to maintain correct and up-to-date data, Bosch will correct this upon your written request, sent to:


Email: kontakt@bosch.de


Postal Address:


Robert Bosch GmbH (Business Unit CVO)
Robert-Bosch-Platz 1
70839 Gerlingen-Schillerhöhe



© Copyright 2020 Robert Bosch GmbH. All rights reserved.