Robert Bosch (South East Asia) Pte. Ltd. and its subsidiaries and related companies in ASEAN (‘Robert Bosch Singapore’, ‘we’, ‘us’ ‘our’, etc.) take the protection of your personal data very seriously. Consequently, data protection and information security are an integral part of our corporate policy for ASEAN.
‘Personal data’ means all the information that relates to an identified or identifiable natural person (that is, an individual) – for example, your name, telephone number, email address and street / mailing address.
In this Privacy Policy, we set out information about how we process personal data if and when we collect personal data about you in connection with providing you with our products and/or services or otherwise do business with you and when you use our online service. (Our website may include links to third party websites. They are not covered by this Privacy Policy. Please check the third party website for information about how they may process personal data.)
This Privacy Policy does not include how we process personal data in connection with recruitment, human resources management and ex-employees. If you would like information about how we process personal data for these categories of individuals, please email asean.dpo@sg.bosch.com and we will be happy to send you a copy of it.
We have written this Privacy Policy in a way that is straightforward and easy for you to understand. You are welcome to read it from end-to-end. Otherwise, you may like to click on a link below to take you directly to the parts of it that are most relevant to you.
For general information about how we process personal data, how we keep it secure, when we dispose of personal data and when we transfer it overseas click here (general information), here (security), here (disposal) and here (overseas transfer).
To find information relevant to your relationship with us, click on:
To find information about your rights, click on:
3.1. Standard of data protection laws
Some countries in ASEAN do not yet have data protection laws. If you live in such a country we generally aim to protect your personal data as if there were data protection laws that apply to you.
The data protection laws in some countries in ASEAN are different from the data protection laws in other countries in ASEAN. We generally aim to protect your personal data as if the strictest standard of data protection law applies to you.
3.2. General principles that we apply when we process personal data
We collect personal data about you only for specific and legitimate purposes. We notify you about those purposes and we process such personal data only in ways that are compatible with the specific and legitimate purposes that we tell you about. We process personal data about you lawfully and fairly.
We only collect personal data about you that is adequate and not excessive in relation to the purpose(s) for which we process it. We take care to make sure such personal data is accurate and relevant and, where necessary for the purposes for which we process it, we keep it up-to-date.
We retain personal data about you only for so long as we need to do so for legal and business purposes. For so long as we retain such personal data we make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
3.3. Lawful bases of processing
We want to treat all of the individuals with whom we interact equally, but sometimes we cannot do so because of the way we must apply the laws.
In Singapore, the data protection law requires us to obtain your consent before we collect, use, disclose and store (collectively, ‘Process’) personal data about you, except where there is an exception to the requirement for consent. For example, we do not need consent to process personal data to respond to an emergency that threatens someone’s life, health or safety.
Elsewhere in ASEAN, the data protection laws lay out the lawful bases on which we may process personal data about you. Broadly, these are:
4.1. How we collect personal data about or relating to our customers
We generally collect personal data directly from you. We will ask you for it (including contact information) when you interact with us, including when we are responding to your enquiries about our products or services. Sometimes we collect it from a third party, but only after checking that the third party has the right to provide the personal data to us – for example, where they do so at your request to enable us to provide information to you or to provide you with our products and/or services.
4.2. The types of personal data that we collect
The personal data we collect about or relating to you depends on the circumstances in which we interact with you. We only collect personal data for purposes that are directly related to our business activities and when it is necessary for such purposes. We set out more specific information below, but generally:
4.3. Why we collect personal data and how we use it
Product offering, sales and support
In connection with our product offerings, sales and support we collect personal data that is about you or relates to you when:
and we use that personal data only for the purpose for which we collected it
Warranty registration and technical support
In connection with warranty registration and technical support we collect and use personal data that is about you or relates to you when you register a product with us for warranty purposes and if you contact us for technical support and (in each case) we use that personal data only for the purpose for which we collected it
Processing purposes and legal basis
We as well as the service providers commissioned by us; process your personal data for the following processing purposes:
(Legal basis: Contract fulfilment, including contact form to contact us with enquiries about the products and services we offer for the purpose of contract fulfilment)
(Legal basis: Fulfillment of our legal obligations within the scope of data security and legitimate interest in resolving service disruptions as well as in the protection of our offers).
(Legal basis: Consent / legitimate interest on our part in direct marketing if in accordance with data protection and competition law).consent.
(Legal basis: Consent).
(Legal basis: Fulfillment of contractual obligations).
(Legal basis: Consent).
(Legal basis: Legal obligations and for the establishment, exercise, or defense of legal claims.).
Promotion
Insofar as "Promotion" functionalities are used, our data protection information for Promotion also applies.
Prize draws or discount campaigns
In case you participate in one of our prize draws or discount campaigns, we use your data to inform you about any prize won and for the purpose of advertising our products to the extent allowed by law or as far as you have consented. Information on prize draws or discount campaigns can be found in the respective terms of participation.
Log files
Each time you use the internet, your browser is transmitting certain information which we store in so-called log files.
We store log files to determine service disruptions and for security reasons (e.g., to investigate attack attempts) for a period of 7 days and delete them afterwards. Log files which need to be maintained for evidence purposes are excluded from deletion until the respective incident is resolved and may, on a case-by-case basis, be passed on to investigating authorities.
In log files, the following information is saved:
- IP address (internet protocol address) of the terminal device used to access the Online Offer;
- Internet address of the website from which the Online Offer is accessed (so-called URL of origin or referrer URL);
- Name of the files or information accessed;
- Date and time as well as duration of recalling the data;
- Amount of data transferred;
- http status code (e.g., “Request successful” or “File requested not found”).
Children
This Online Offer is not meant for children under 16 years of age.
4.4. When we disclose personal data
We do not sell personal data about or relating to you. We do, however, disclose it as follows:
5.1. How we collect personal data about or relating to our business partners
We generally collect personal data directly from you. We will ask you for it (including contact information and relationship information) when you interact with us, including when we are responding to your enquiries about our services and pricing or when we are working with you in the course of establishing a business relationship with you and/or your company and when we are providing our services to you and/or your company.
Sometimes we collect personal data about you from a third party, such as another individual working at your company – for example, when they add you to a project team.
Sometimes an entity providing services to us collects it from you on our behalf (for example, where you take an item (such as a motor vehicle) to a service workshop (whether or not it is a Bosch-branded workshop) and the service workshop interacts with us directly or indirectly in the course of providing its services to you. In any such case, we have arrangements in place so that the service provider is under a contractual obligation to ensure that your personal data is protected and not used by the service provider for any purpose other than providing the specific contracted service to you.
5.2. The types of personal data that we collect
If you are an individual who does business with us, including if you work for a company that does business with us, we or our service provider (for example, where a service provider operates a website on our behalf, such as an eCommerce portal) may collect the following types of personal data about or relating to you:
5.3. How we use personal data about or relating to you
We use personal data about or relating to you:
5.4. When we disclose personal data about or relating to you
We do not sell personal data about or relating to you. We do, however, disclose it as follows:
6.1. Using cookies and other tracking mechanisms
In the context of our online service, we may use cookies and other tracking mechanisms. Cookies are small text files that may be stored on your device when you visit our online service. Tracking is possible using different technologies. In particular, we process information using pixel technology and/or during log file analysis. We distinguish between:
6.2. Technically required cookies
‘Technically required cookies’ means those cookies that are necessary for ensuring the technical provision of the online service. They include, for example, cookies that store data to ensure smooth reproduction of video or audio footage. Technically required cookies will be deleted when you leave the website.
6.3. Cookies and tracking mechanisms that are not technically required
We only use cookies and tracking mechanisms that are not technically required if you have given us your prior consent in each case. With regard to these cookies and tracking mechanisms, we distinguish:
You can manage your cookie and tracking mechanism settings in the browser and/or our privacy settings. (Note: the settings you have made refer only to the browser used in each case.)
If you wish to deactivate all cookies, please deactivate cookies in your browser settings. Please note that this may affect the functionality of the website.
When visiting our websites, you will be asked in a cookie layer whether you consent to our using of convenience cookies, marketing cookies or tracking mechanisms, respectively.
In our privacy settings, you may withdraw the consent with effect for the future or grant your consent at a later point in time.
6.4. Processed categories of data
The following categories of data are processed:
• Communication data (e.g. name, telephone, e-mail, address, IP address)
• Contractual master data (e.g. contractual relationships, contractual or product interest)
• Client history
• Contract accounting and payment data
• Planning and regulation data
• Transaction data (e.g. tool runtime, working direction of the tool, service and tool status)
• Product details (e.g. product and serial-number)
• Product settings information, status and usage log
6.5. Registration
In order to use extended functionalities, registration in our online offers is required. Below you will find more information about the registration and login process.
This is structured as follows:
Bosch "Integrated Customer Profile Management" (iCPM) connects different Bosch applications, with the aim that you as a business partner (user, customer) do not have to provide your data multiple times, thus offering you the best possible customer experience. In addition, iCPM offers the possibility to log in to Bosch applications via different login options.
Within the framework of iCPM,
Robert Bosch Power Tools GmbH
Max-Lang-Strasse 40-46, D-70771 Leinfelden-Echterdingen
hereinafter referred to as "Bosch PT”
and
the parties listed in the "List of Parties " (hereinafter referred to as "Parties") work closely together. This also applies to the processing of your personal data. The Parties have jointly determined the order in which this data is to be processed in the individual process phases and are therefore to be regarded as joint controllers under data protection law pursuant to Art. 26 GDPR.
Here is a detailed overview of the joint and separate data processing activities and responsibilities of the parties:
|
Data processing:
|
Responsibility: |
|
Identity brokering with CIAM for B2C and external B2B user |
Bosch PT |
|
Identity brokering with BCD/Bosch ADFS for B2E (Bosch administrators) |
Bosch PT |
|
Provision of user attributes for connected applications - Access tokens |
The Parties |
|
Saving user attributes (synchronization) |
The Parties |
|
Providing user attributes for connected applications - User info endpoint |
The Parties |
|
Providing user attributes for connected applications - Notification service |
The Parties |
What this means for you:
- The parties shall provide you, as data subjects, with the information required by Articles 13 and 14 GDPR in a precise, transparent, understandable and easily accessible form in clear and simple language, free of charge. Each party shall provide the other party with all necessary information from its sphere of activity.
- The parties shall inform each other without delay of the data subject rights asserted by you as a data subject. They shall provide each other with all information required to respond to your requests for information.
- You may assert your data subject rights directly against either party at any time.
You can log in to our website with SingleKey ID.
SingleKey ID was developed by Robert Bosch GmbH for the Bosch Group to provide users with an overarching login option on Bosch websites, stores, apps and services. Robert Bosch GmbH, Ullsteinstrasse 128, 12109 Berlin, Germany, is responsible for providing SingleKey ID.
Robert Bosch GmbH processes your data for the purposes of "registration and login with SingleKey ID", as well as "overview and maintenance of master data and apps with SingleKey ID" under joint responsibility with us. For more information, please visit: https://singlekey-id.com/data-protection-notice/.
After one-time registration you can use SingleKey ID to log in. For this purpose you will be redirected to a login mask of Robert Bosch GmbH. After successful authentication, Robert Bosch GmbH will provide us with the required personal data (e.g. e-mail address, telephone number, first name, last name, language, country). Your password will not be transmitted to us.
You can terminate your SingleKey ID user contract at any time on the SingleKey ID website by deleting your SingleKey ID: https://singlekey-id.com/myprofile/.
Please note that by deleting your SingleKey ID you will lose access to all Bosch websites, stores, apps and services where you have logged in with SingleKey ID.
We also offer you the option of logging in to our online offering with so-called social sign-ins such as your Apple or Google account.
To register, you will be redirected to the page of the respective social network, where you can log in with your data there. This has the effect that your account of the respective provider is linked to our service. In the process, the information of your public profile there, your e-mail address and the identification tags are transmitted to us by the respective provider.
The provider may link information already held by it, such as IP address or browser information, with the use and duration of use of the service offered (e.g.. our login service). The provider of the social network or its server may be located outside the EU or the EEA (e.g. in the USA).
If you do not want any data transfer to take place between us and the social networks, do not log in via the social sign-in, but use our own login services instead.
7.1. Usage of our mobile applications
In addition to our Online Offers, we offer mobile applications ("Apps"), which you can download to your mobile device. We also collect personal data through our apps when you use a mobile device, if you consent.
Processing of the advertising identifier / advertising ID
For advertising purposes, we use, given your consent, the so-called "advertising identifier" (IDFA) for iOS devices and the so-called advertising ID for Android devices. These are not permanent identification numbers for a certain terminal device provided by iOS or Android. The data collected is not brought together with other device-related information. We use identification numbers to provide you with personalized advertisements and to analyze your usage.
When you activate (for iOS de-vices) the option "no ad tracking" in the device settings under "Privacy" - "Advertisements" or (for Android devices) activate "deactivate interest-based advertisements" in the Google set-tings under "Advertisements", we can only perform the following measures: Measuring your interaction with banners by counting the number of displays of a banner without clicks ("frequency capping"), click rate, assessment of unique usage ("unique user") and security measures, fraud combating and troubleshooting. In the device settings, you are always able to delete your IDFA or advertising ID ("reset ad ID"); a new identification number is generated then which is not combined with data collected earlier. We advise you that you might be unable to use all functions of our app when you restrict the usage of the respective identification number.
App analysis
Some of our apps include location based services, through which we provide you offers tailored to your specific location. Your movement is not tracked. You can de-activate this function in the app settings, or in your mobile device operating system.
In order to provide you with a more user friendly platform, and also to perform range measurements and market research, we may use app analysis tools on some of our apps.
In addition, we use the “Firebase Cloud Messaging” service to send you technically required
send push notifications or so-called in-app messages to your end device. In doing so device is assigned a pseudonymized device token ID, a unique connection number generated from the device unique connection number generated from the device ID, which we use to address the push messages or in-app messages to you. Google acts here as a service provider on our behalf. The Firebase Cloud Messaging is used to provide you with the expressly requested provide you with the telemedia service expressly requested (Section 25 (2) No. 2 TTDSG).
As a result of the settings we have made, personal data (device ID) will be as far as possible in the member states of the European Union or in other contracting states of the Agreement on the European Economic Area and Switzerland.
Google assures that personal data is processed within the EU or the EEA..
Google Analytics is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). We use Google Analytics with the additional function offered by Google to anonymize IP addresses. While doing so, Google already shortens IPs within the EU in most cases and only does so in the United States in exceptional cases, while always saving shortened IPs only.
Teamlium is provided by Tealium Inc., 11095 Torreyana Road San Diego, CA 92121, USA. We use Tealium for segmenting and profiling in real time; tag management.
On our website, we use the services of Qualtrics LLC, 333 W. River Park Drive, Provo UT 84604, USA to conduct customer, product, and satisfaction surveys. The goal is to continuously develop and improve our products and services. If you participate in a satisfaction survey, only so-called "lod data" (date and time stamp / information about your browser and your browser settings / information about your terminal device / usage data) will be processed. Participation in a satisfaction survey is voluntary. The legal basis for the data processing is your consent, Art. 6 para. 1 lit. a) GDPR. You can revoke your consent at any time with effect for the future.
As part of the Qualtrics services also Cookies are used, in particular to maintain the current satisfaction survey during your browsing session and to prevent multiple participations. For more information about Qualtrics LLC and how Qualtrics processes personal data, please visit https://www.qualtrics.com/privacy-statement/.
7.2. Data processing by App Store operators
We do not collect data, and it is beyond our responsibility, when data, such as username, email address and individual device identifier are transferred to an app store (e.g., Google Play by Google, App Store by Apple, Galaxy Apps Store by Samsung) when downloading the respective application. We are unable to influence this data collection and further processing by the App Store as controller.
8.1. Limiting the information you provide to us
If we ask you for personal data that you do not want to provide, please tell us and we will try to continue without it. However, it might not be possible for us to provide the product or service that you are seeking or lack of personal data may result in inconvenience to you when we are providing such product or service.
8.2. Withdrawing consent and opting out of receiving marketing messages
Where we have obtained your consent to process your personal data, you may withdraw your consent at any time. You can do this by notifying us in writing (which includes email) – click here for our contact details.
You can optout of commercial emails by clicking the ‘unsubscribe’ line at the bottom of any such email that we send to you. Please note that if you opt-out of commercial emails we may still need to contact you with important transactional information about you and/or your company’s account and/or about a product and/or service that you have purchased from us.
Newsletter with opt-in; Right of withdrawal
Within the scope of our Online Offers you can sign up for newsletters. We provide the so-called double opt-in option which means that we will only send you a newsletter via email, mobile messenger (such as, e.g. WhatsApp), SMS or push notification after you have explicitly confirmed the activation of the newsletter service to us by clicking on the link in a notification. In case you wish to no longer receive newsletters, you can terminate the subscription at any time by withdrawing your consent. You can withdraw your consent to email newsletters by clicking on the link which is sent in the respective newsletter mail, or in the administrative settings of the online offer. Alternatively, please contact us via the contact details provided in the Contact section.
8.3. Data accuracy
We take steps to ensure that the personal data we collect is accurate, up-to-date and complete. This includes updating it if and when you let us know that it has changed. Please let us know about any changes by notifying us in writing (which includes email) – click here for our contact details.
External links
Our Online Offers may contain links to internet pages of third parties, in particular providers who are not related to us. Upon clicking on the link, we have no influence on the collecting, processing and use of personal data possibly transmitted by clicking on the link to the third party (such as the IP address or the URL of the site on which the link is located) as the conduct of third parties is naturally beyond our control. We do not assume responsibility for the processing of personal data by third parties.
8.4. Access to personal data
You can request us to provide you with a copy of personal data about you or that refers to you that is in our possession or under our control. We will also give you information about the ways in which we have, or may have, used or disclosed it within the previous 12 months.
Please ask us in writing (which includes email) – click here for our contact details. We may request information from you that enables us to verify your identity before meeting your request. Subject to you verifying your identity, we will respond to your request as soon as reasonably possible. If we are unable to respond to your request within 30 days we will let you know within that period when we expect to be able to respond to your request.
We reserve the right to charge a fee for access to your personal data, which will be limited to the incremental costs incurred by us in meeting your request. We will notify you of the amount (or, if that cannot be determined, the estimated amount) of the fee before fulfilling your request.
8.5. Correction of personal data
You can request us to correct on error or omission in personal data about you or that refers to you that is in our possession or under our control.
Notify us about your correction request in writing (which includes email) – click here for our contact details. We may request information from you that enables us to verify your identity before meeting your request. Subject to you verifying your identity, we will respond to your request as soon as practicable. If we are unable to respond to your request within 30 days we will let you know within that period when we expect to be able to respond to your request. We may also send the corrected personal data to other organisations to which we have disclosed your personal data.
As a leading global supplier of technology and services we take the security of personal data about or referring to you seriously
We have appropriate security measures in place to prevent your personal data being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business ‘need to know’. They will process your personal data only on our instructions.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable supervisory authority of an actual or suspected personal data breach where we are required by contract or law to do so.
We will cease to retain documents that contain personal data about you or that refers to you as soon as it is reasonable to assume that the purpose for which we collected it is no longer being served by us retaining it and we no longer need it for a business or legal purpose. Alternatively, we may anonymise the personal data so that it can no longer be associated with you.
We may from time to time, depending on the circumstances under which you provided personal data to us, have a business need to transfer it (or a copy of it) out of the country in which you gave it to us and to one of our subsidiaries or related companies a different country. For example, if you gave it to us outside of Singapore we might need to transfer it to our regional headquarters in Singapore.
We have entered into contracts to ensure that personal data about or relating to you is treated by the receiving entity with the same degree of care as is required by this Privacy Policy. This includes us adopting uniform practices / standard operating procedures (SOPs) in all of our subsidiaries and related companies in ASEAN (and in the location of our global headquarters, in the European Economic Area).
If you have any complaint about the way in which we have processed personal data about you or that refers to you – that is, if you feel we have not complied with this Privacy Policy and/or with the applicable data protection / privacy law please let us know. You may do this in writing (which includes email) – click here for our contact details. Please include the following:
We will acknowledge receipt of your complain as soon as practicable. Then we will investigate it. We may need to obtain further information from you, speak to relevant staff members, review relevant documents and/or obtain legal or technical advice to do our investigation. Once we have completed our investigation, we will write to you to let you know the outcome of the investigation.
You can contact us to get further information in relation to this Privacy Policy, to provide comments or to make any complaint by contacting our data protection officer as follows:
By letter: Data Protection Officer, ASEAN Region
Robert Bosch (S.E.A.) Pte. Ltd.
11 Bishan Street 21
Singapore 573943
By email: asean.dpo@sg.bosch.com
By phone: +65 6258 5511
We reserve the right to change and update this Privacy Policy from time to time. We will notify changes by posting them on our website. The amended Privacy Policy will come into effect from the time that it is posted on our website.