Bosch Learn RefineMySite Privacy Notice – Highlights

Robert Bosch Tool Corporation, located at 1800 W Central Rd., Mount Prospect, IL 60056, has set out below some important highlights of the Privacy Notice for our website . You can obtain more information about how we collect, use, disclose and safeguard your personal information by reviewing our full Privacy Notice below.

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 website Learn RefinemySite (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 website Learn RefinemySite or Services). We also may collect information in ways that we describe to you at the point of collection or otherwise with your consent.

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.
• •    Administering, maintaining, personalizing and improving Bosch and Bosch affiliates’ mobile websites, products and services, including, without limitation, to authenticate users, process payments, 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.
• •    For the U.S., this data may be used for marketing and analytic purposes.
• •    Compliance with legal and/or regulatory requirements.
• •    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.

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).

Is personal information shared or disclosed?

Bosch may share your information with:

•    Bosch affiliated entities, Robert Bosch GmbH, Robert Bosch Tool Corporation

• •    Service providers, vendors, consultants, partners and other partners and entities performing work on Bosch’s behalf
• •    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

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 such 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 Notice Administrator as described in the Privacy Notice.  
• •    Bosch security measures are being continuously improved in accordance with the state of technological developments, however, absolute protection is not possible.  However, we cannot guarantee the security of information posted or transmitted using the website Learn RefinemySite.
  What else should you know?
• •    .
• •    You may contact our Privacy Notice Administrator, as described in the Privacy Notice, 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).
  
  Notice to Canadian Users: Please note that by using the website Learn RefinemySite 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 Notice and summarized above.

Bosch Learn RefinemySite Privacy Notice

1. I.    Introduction.

Robert Bosch Tool Corporation (“Bosch”, “we”, “us” or “our”) is pleased to have you (“you” or “your) use our website Learn RefinemySite (“Website”) and welcomes your interest in the services provided through the website Learn RefinemySite (collectively, the “Services”). This Privacy Notice (this “Notice”) applies to all users of the website Learn RefinemySite and the Services, anywhere in the United States, Canada, and their respective territories and possessions. Terms capitalized but not defined in this Notice are as defined in the Learn RefinemySite Terms and Conditions (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 website Learn RefinemySite and use of Services in compliance with this Notice 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 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 website Learn RefinemySite or otherwise provide any personal information to us.

1. 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 (PIPEDA) and any applicable substantially similar Canadian provincial legislation (“Canadian Privacy laws”)  (collectively, “Personal Information”) which we gather when you are accessing, viewing, completing, or using this website Learn RefinemySite or our Services.

III.    Collection of Personal Information

The website Learn RefinemySite has collected the following personal information from users of the website Learn RefinemySite within the last twelve (12) months:

Learn RefinemySite 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.

1. IV.    Sources of Personal Information.

Learn RefinemySite  collects personal information from the following categories of sources:

Directly from you. For example, when given by you or collected from you thorough your access to and/or use of the website Learn RefinemySite and/or the Services, in context of registering an account, subscribing to or purchasing our Services, set-up profile, or when you contact customer support or otherwise interact or communicate with Learn RefinemySite, its agents, representatives, suppliers, vendors or consultants through the website Learn RefinemySite. This information may include, without limitation, your first and last name, address, e-mail address, password.

Indirectly from you.  For example, from observing your use of the website Learn RefinemySite and/or the Services, or services related thereto.  The following data may be collected automatically: IP address and other relevant details and/or information.

1. V.    Use of personal information and purpose specification.

Learn RefinemySite may use your personal information for the purpose of:

• •    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.
• •    Technical administration of Bosch and Bosch affiliate websites, mobile websites 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 websites, products and services, including, without limitation, to authenticate users, process payments, 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.
• •    For the U.S., this data may be used for marketing and analytic purposes.
• •    Compliance with legal and/or regulatory requirements.
• •    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.

Learn RefinemySite  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).

1. VI.    Sharing and Disclosure of Personal Information.

Learn RefinemySite 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:

• •    Bosch affiliated entities, including Bosch’s parent company in Germany, Robert Bosch GmbH, to leverage shared services and improve our Services;
• •    Bosch third party service providers, vendors, consultants, suppliers, licensors, marketing, partners and other partners and entities performing work on Bosch’s behalf, such as hosting vendors, advertising service providers, data analytics companies, marketing service companies, list managers and delivery companies. We also may share your information, including your payment information, as appropriate to process your payments for the Services or complete a transaction.;
• •    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 website Learn RefinemySite or the Services, you consent to the above uses and sharing of your personal information in accordance with this Notice.

VII.    Disclosure or Sale of personal information – Past 12 Months

In the preceding twelve (12) months, Learn RefinemySite has disclosed the following categories of personal information for a business purpose:

1. i.    Identifiers
2. ii.    California Customer Records personal information categories.

iii.    Protected classification characteristics under California or federal law.

1. iv.    Internet or other similar network activity.
2. v.    Geolocation data.

We disclose your personal information for a business purpose to the following categories of third parties:

• •    Contracted Service providers
• •    Consultants
• •    Partner

Sales of Personal Information. The use of certain kinds of third-party cookies, such as advertising or social media cookies, on the website Learn RefinemySite could be considered a "sale" of your personal information for purposes of the CCPA. During the last 12 months, we used third party advertising and social media cookies on the website Learn RefinemySite, which allowed the publisher of such third-party cookies to obtain the following categories of personal information:

VIII.    International Data Transfer.

Learn RefinemySite 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, 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 Notice Administrator as described below.

1. IX.    Children’s Privacy.

Learn RefinemySite 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 the website Learn RefinemySite from time to time.

1. 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.

1. XI.    Security

Learn RefinemySite takes commercially reasonable efforts to ensure that your data collected by Bosch through this website Learn RefinemySite 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 enter your e-mail address (User ID) and create a 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 e-mail address (User ID) and password. We disclaim any and all liability for any information transmitted due to an unauthorized log in.

XII.    International Users.

This is a US website and service targeted to users in the U.S. and Canada, and the website Learn RefinemySite and Bosch Services are subject to U.S. and Canadian laws, as applicable, including, without limitation, those governing the privacy and security of your information. If you use Bosch Services, you are transferring your information to Bosch in Germany. By using the Bosch Services or providing your information to Bosch through the Services you consent to the transfer of your personal information to Germany, and Bosch handling of your information in accordance with applicable U.S. requirements and this Notice. Accordingly, your personal information may be accessible to courts, law enforcement and national authorities in Germany. You can obtain information about Bosch’s policies and practices with respect to service providers (including affiliates) outside the country where you reside, or ask questions about the collection, use, disclosure or storage of personal information by such service providers, by contacting our Privacy Notice Administrator as described below.

XIII.    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 (CCPA) have the following rights relating to their personal information collected by Bosch.

• •    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. a.    The categories of personal information we collected about you.
2. b.    The categories of sources for the personal information we collected about you.
3. c.    Our business or commercial purpose for collecting or selling that Personal Information.
4. d.    The categories of third parties with whom we share that Personal Information.
5. e.    The specific pieces of personal information we collected about you.
6. f.    If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
7. i.    For “sales”, the personal information categories that each category of recipient purchased; and
8. ii.    for disclosures for a business purpose, identifying the personal information categories that each category

of recipient obtained.

• •    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.

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

1. 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.
2. 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.

1. iv.    Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
2. v.    Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
3. 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.

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

XIV.    Your Rights – Canadians

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

1. a.    The right to withdraw your consent to the collection, use or disclosure of your Personal Information.
2. 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).
3. c.    The right to challenge the accuracy and completeness of your Personal Information, and have it amended, updated or rectified as appropriate.
4. 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.
5. e.    The right to challenge Bosch’s compliance with the applicable Canadian Privacy Laws.    
6. XV.    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 [1-800-428-6318].

Emailing us at OptOut.PTNA@us.bosch.com

Visiting  https://learnrefinemysite.tovuti.io/contact-page

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

XVI.    Response timing and Format

Learn RefinemySite 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), 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 usable 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.

XVII.    Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). Furthermore, where required by applicable law in the relevant jurisdiction, we will obtain your consent prior to selling your Personal Information. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you may submit a request to us by emailing us at OptOut.PTNA@us.bosch.com: As noted above, certain kinds of third party cookies, such as ad network or analytics cookies, on the Bosch website could be considered a "sale" of your personal information for purposes of the CCPA. In order to opt out of the “sale” of your information via such cookies, turn off the Analytics, Advertising, and Social Media cookies in our cookie settings manager available here.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by changing your cookie preferences on Bosch Tools website.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

XVIII.    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. 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.

XIX.    Non-Discrimination

Learn RefinemySite 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.

1. XX.    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 XVI 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.

XXI.    Changes to Notice

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

XXII.    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: privacy.policy@us.bosch.com

Postal Address:
Robert Bosch LLC
Privacy Policy Administrator
38000 Hills Tech Drive Farmington Hills,
MI 48331

or

Email: DPO@bosch.com.
You may also contact as follows:

Phone: 1-800-428-6318

Website:  https://learnrefinemysite.tovuti.io/contact-page

• · Tovuti is on AWS and configured for High Availability with multiple auto-fail overs in place.The backup process connects to each client's database and stores it in our EFS shared file system. All data is encrypted at rest and in transit. Data is stored in our Encrypted EFS for 30 days.   
• · Bosch owns your data (as reflected in our Software As A Service Agreement [SAASA], which can be exported by Bosch via Excel spreadsheet or CSV, or PDF.