Privacy Notice - Robert BOSCH Limited (United Kingdom)
This policy applies to:
(i) all those who visit our website;
(ii) business customers (including e.g. Independent Workshops/ Repairers, Wholesalers, Bosch Car Service and Bosch Diesel Centre/Service workshops ); and
(iii) consumers (including e.g. Vehicle Owners)
to that extent relevant to those individuals and except where the policy indicates otherwise.
Our 'Group' refers to the constituent companies of Robert Bosch GmbH.
1. WHO WE ARE
2. BOSCH RESPECTS YOUR PRIVACY
3. THE PERSONAL DATA WE COLLECT AND USE
If you are a consumer
We may collect your personal data when you provide it to us through our website, if you write to us or telephone our offices or if you provide your details to us through a third party (including through a Bosch Car Service or Bosch Diesel Centre/ Service workshop.) Your information may be provided to us in the following ways:
- if you contact us to register to receive our newsletter and/or to register to our loyalty programmes.
- If you contact our customer services team or other team at Robert Bosch Limited to enquire about our products and services or to provide feedback to us on our products and services.
If you are a business customer
We may collect your personal data when you provide it to us through our website or ‘Bosch Wiper Blade App or when you purchase products or make enquiries about our products and services, enter a competition, register to receive our newsletters or join our loyalty programmes. We may collect this information directly through the website or app or if you provide your details over the telephone, or by post.
We may collect your company name, contact name, billing address, delivery address details, your email address, date of birth, gender, contact telephone number, type of workshop and details of any comments or feedback which you or a third party provides to us.
We will also require your credit card details. We will use this information to supply you with the products and services, such as training, to recover debt and to help us prevent fraud.
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 our site or through our app is kept by us together with details of the fulfilment of any order.
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 sites and services. We may also obtain your personal data through third parties such as the [e.g. Distributor] or if you or your employer or educational provider submits your details in connection with one of our training courses. Third-party service providers may, without limitation, be appointed to provide technical support, process your transactions 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 monitor, record, store and use any telephone, email or other communication you provide in order to: check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.
What other information do we collect?
As you move around our site, subject to appropriate consents being obtained, we will collect information about your visit, such as which pages you visit, how often you visit and what links you click on.
This will include technical information such as Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, operating system and platform and information about your visit such as: the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
We may also receive information about you if you use any of the other websites we operate or the other services we provide. In this case, we will have informed you when we collected that personal data that it may be shared internally and combined with personal data collected on this site for the purposes set out in this policy, including helping us to build a profile of you to get to know you better, and so that we can personalise and enhance your customer experience with us.
4. HOW DO WE USE YOUR PERSONAL INFORMATION?
We will use this information:
- 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;
- to carry out appropriate and necessary investigations and discharge our legal and regulatory obligations and duties, including to comply with anti-fraud and anti-money laundering requirements;
- to send you a welcome email to verify your account when you register with the site and other emails for the purposes of providing any services, products, competitions or promotions to you, including in relation to account management or system maintenance;
- to provide you with marketing information about other services or products we offer that are similar to those that you have already purchased, or services or products you have consented to receiving on the site or; to notify you about changes to our services and/or products;
- build a profile of you, your preferences and your habits in order to personalise and enhance your customer experience; to provide customer support; and/or
- to ensure that content from the site is presented in the most effective manner for you and for your computer.
Please note we will not use any financial or credit card information for any purpose other than to discharge our legal / regulatory duties and to process payments paid by you for our products and services or due to you by agreement (e.g. refunds).
Information we collect about you.
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to carry out appropriate and necessary investigations and discharge our legal and regulatory obligations and duties, including to comply with anti-fraud and anti-money laundering requirements, and (where applicable) to safeguard our staff and other customers / users in respect of unlawful, disruptive or objectionable behaviour on our premises or on our website;
- to improve our website to ensure that content is presented in the most effective manner for you and for your computer;
- to enhance our website experience to ensure you receive a personalised and continuously improving customer service;
- to allow you to participate in interactive features of our website, when you choose to do so;
- as part of our efforts to keep our website safe and secure;
- to deliver (whether directly or indirectly via third parties) effective and personalised marketing material and content of Robert Bosch Limited and where you have consented, other companies within our Group and to assist us in the improvement and optimisation of advertising, marketing material and content, our services and the sites;
- 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;
- build a profile of you, your preferences and your habits;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you where permitted; and/or
- to make suggestions and recommendations to you and other users of our site or services about goods or services that may interest you or them.
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
5. USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS
- Compliance with legal obligations: As an entity established under the laws of England and Wales, Robert Bosch Limited 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 site 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 the Bosch 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 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 24 months unless we tell you otherwise at the time.
6. HOW LONG WE KEEP YOUR INFORMATION FOR
Marketing consents will be refreshed or deleted after 24 months;
Marketing emails and other communications where possible will typically be deleted after 24 months.
Any other information will typically be deleted within 7 years from the data of our last positive interaction with you. This data is archived where customers are inactive for a period of 12 months. In some circumstances, some of your data will be deleted in much shorter timescales, where possible (e.g. copies of marketing emails and other communications). We keep your personal information for 7 years, to enable us to retain the information we may require for legal and regulatory purposes.
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.
If you have not made a purchase from us, and where we permit other companies in the Bosch 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 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 details below.
We will only share your personal information with other members of our Group for marketing purposes where you have expressly opted-in/consented to the disclosure of your personal data for these purposes.
We will only disclose your information to
- 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 site 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 disclose your personal data to our supply and delivery partners for the purpose of processing and fulfilling your order. Where such disclosures are made, this will be under contractual arrangements with us and carried out in accordance with the requirements of data protection law.
- members of our Group and third party suppliers and service providers for the purposes listed under How do we use your personal information? above;
- third party suppliers and service providers to the extent they assist our Group with its legal / regulatory obligations e.g. providers of services in respect of anti-money laundering, fraud, verification etc.;
- 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;
- analytics and search engine providers that assist us in the improvement and optimisation of our site and other selected third parties; and
- your employer, educational institution (e.g. school, college or university), email or internet provider, parents (if you are under the age of 18) or law enforcement agencies, or other appropriate third parties, where we consider your behaviour to be unlawful, offensive, inappropriate or objectionable in one of our training facilities;
We will disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- in the event of any insolvency situation (e.g. the administration or liquidation) of Robert Bosch Limited or any of its Group;
- if Robert Bosch Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- to protect the rights, property or safety of us, our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation, other third parties, your employer, educational institution, email or internet provider, your parents (if you are under the age of 18) and law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction; and
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements or in order to enforce or apply any provisions of our terms and conditions or the terms of any other agreement, or otherwise for the prevention or detection of fraud or crime.
- 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
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 site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
10. PROTECTING YOUR INFORMATION
We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you via our site. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
11. THIRD PARTY SERVICES
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
|NUMBER||DESCRIPTION OF RIGHT|
|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 INFORMATION
This policy was last reviewed and updated: May 2018
- Data Security Officer, UK and Ireland
Robert Bosch UK Holdings Limited.
North Orbital Road
Denham UB9 5HJ
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