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CCPA and Canadian Privacy Disclosure

 

CCPA and Canadian Privacy Disclosure of Bosch Sicherheitssysteme GmbH for our website “https://community.boschsecurity.com”

 

This CCPA and Canadian Privacy Disclosure (“Disclosure”) supplements the information contained in Bosch's Building Technologies “Knowledge Base” website (“Knowledge Base”) and applies solely to all visitors, users, and others of the “https://community.boschsecurity.com” who reside in the State of California (“you”) and Canada. We adopt this CCPA and Canadian Privacy Disclosure to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and applicable Canadian law and any terms defined in the CCPA and applicable Canadian law have the same meaning when used in this Disclosure.

 

I.       Collection of Personal Information

 

The Knowledge Base has collected the following Personal Information from users within the last twelve (12) months.

Category and Sources of Information	Examples	How we use it	How we share it
Identifiers     We collect this information from our users, customers, and business partners. We also generate identifiers internally.	Real name, alias, Internet Protocol address, email address	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. 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
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.	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

 

II.       Sources of Personal Information

The Knowledge Base collects Personal Information from the following categories of sources:

1.                Directly from you.

For example, when given by you or collected from you through your access to and/or use of the Knowledge Base and/or the Services, in context of registering on the website or subscribing to articles or article categories or rating an article or when you contact customer support or otherwise interact or communicate with the Knowledge Base, its agents, representatives, suppliers, vendors or consultants through the Knowledge Base. This information may include, without limitation, your first and last name, alias, e-mail address and any other information you choose to provide us.

2.                Indirectly from you.

For example, from observing your use of the Knowledge Base website and/or the Services, or services related thereto. The following data may be collected automatically: the website from which you visit the Knowledge Base (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., the Knowledge Base or its agents, representatives, suppliers, vendors or consultants may record which banner, adware, etc. motivated or assisted with the visit to Knowledge Base website.

 

III. Disclosure or Sale of Personal Information – Past 12 Months

 

1. Disclosure of Personal Information.

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

      a. Identifiers.

      b. California Customer Records Personal Information categories.

2. Sales of Personal Information.

In the preceding twelve (12) months, Bosch has not sold Personal Information for a business purpose.

 

IV. Consumer Rights

 

IV.1. Rights of California “consumers” relating to Personal Information collected by Bosch

 

Individuals which 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 Bosch.

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 article IV.2 – How to Exercise Your Rights), we will disclose to you:

a. The categories of Personal Information we collected about you.

b. The categories of sources for the Personal Information we collected about you.

c. Our business or commercial purpose for collecting or selling that Personal Information.

d. The categories of third parties with whom we share that Personal Information.

e. The specific pieces of Personal Information we collected about you.

f. If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:

i. For “sales”, the Personal Information categories that each category of recipient purchased; and

ii. For disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

2. Deletion Request Rights.

Method 1: Delete your Knowledge Base account by proceeding with the following link. You will be asked to supply your registered email address and password. This will not delete your Bosch-ID account.

Method 2: Delete your Bosch-ID account by proceeding the following link. You will be asked to supply your registered email address and password.

Method 3: Alternatively, 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.

a.   We may deny your deletion request if retaining the information is necessary for us or our service  provider(s) to:

i. 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.

ii. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

iii. Debug products to identify and repair errors that impair existing intended functionality.

vi. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

v. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

vi. 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.

vii. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

viii. Comply with a legal obligation.

ix. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

IV.2. 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:

a. The right to withdraw your consent to the collection, use or disclosure of your Personal Information.

b. 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).

c. The right to challenge the accuracy and completeness of your Personal Information, and have it amended, updated or rectified as appropriate.

d. 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.

e. The right to challenge Bosch’s compliance with the applicable Canadian Privacy Laws.

 

IV.3. 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)). Submitting a request here.

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

 

IV.4. 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.

 

IV.5. Personal Information Sales: CCPA Opt-Out and Opt-In Rights

 

The Knowledge Base does not “sell” personal information of California consumers as contemplated by the CCPA.

 

IV.6. 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:

1. Provide us a copy of your written permission for the authorized agent to submit the applicable request; and

2. 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.

 

IV.7. 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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

 

IV.8. 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 IV.2 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.

 

Effective date: Nov.03, 2020