TSP Mobile Application Privacy Notice

The TSP Mobile Application (any references to “Bosch” within this Privacy Notice to mean “Bosch Security Systems LLC”, “we”, “us” or “our”) is pleased to have you (“you” or “your”) use our mobile application (“TSP Mobile Application”) and welcomes your interest in the services or products provided through this website (collectively, the “Services”)

The protection of your privacy throughout the course of processing personal data as well as the security of all business data are important concerns to us. We process personal data that was gathered during your visit of our Online Offers confidentially and only in accordance with statutory regulations.
Data protection and information security are included in our corporate policy.

Bosch Security Systems LLC is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows:
Bosch Security Systems LLC
130 Perinton Parkway
Fairport, NY 14450

E-Mail: security.marketing@us.bosch.com
Tel.: +1 800-289-0096

The following categories of data are processed:

• Personal Details (e.g. name, telephone, e-mail, address)
• Employment Details (e.g. dealer name, dealer number)
• Product Details (e.g. product type, serial number)
• IT Data Details (e.g. IP address, log files, time stamps)

Personal data consists of all information related to an identified or identifiable natural person, this includes, e.g. names, addresses, phone numbers, email addresses, contractual master data, which is an expression of a person's identity.
We collect, process and use personal data (including IP addresses) only when there is either a statutory legal basis to do so or if you have given your consent to the processing or use of personal data concerning this matter, e.g. by means of registration.

We as well as the service providers commissioned by us; process your personal data for the following processing purposes:

• Provision of this mobile application
  (Legal basis: User consent).
• Answering user requests within the scope of a chatbot
  (Legal basis: User consent).
• Resolving service disruptions as well as for security reasons.
  (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).
• Safeguarding and defending our rights.
  (Legal basis: Legitimate interest on our part for safeguarding and defending our rights).
• Training results and certifications to you and your employer
  (Legal basis: contractual)
• Self-promotion, promotion by others for direct marketing
  (Legal basis: consent)
• Product or customer surveys
  (Legal basis: consent)

Notice to Mexican Users: The legal basis for the processing will always be the consent or any of the exceptions foreseen in article 10 of the Federal Law on Protection of Personal Data Held by Private Parties. This note is applicable for any reference to legal basis hereinafter.
The only transfers of personal data to other controllers that could take place are the ones exempted of consent that are established in article 37 of the Federal Law on Protection of Personal Data Held by Private Parties.

If you wish to use or to get access to the TSP Mobile Application, a contract needs to be concluded between you and Bosch Security Systems LLC. With your registration we collect personal data necessary for entering into the fulfillment of the contract (e.g. first name, last name, email address, phone number, and any other information you may disclose with us) as well as further data on voluntary basis, if applicable. Mandatory information is marked with an *.

Within the scope of this mobile application, we give you the opportunity to learn about the products and services offered by us by means of a chat. When using the chat, the chat conversation is recorded. After the chat, it will be deleted soon thereafter unless the chat is part of a support or service request. In the latter case, the chat’s content is assigned to your customer account and will be saved for the purpose of fulfilling the contractual obligations.

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 short period of time 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.
Log files are also used for analysis purposes (without the IP address or without the complete IP address) see module “Advertisements and/or market research (including web analysis, no customer surveys)”.
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 service provider which was used to access the Online Offer;
• Name of the files or information accessed;
• Date and time as well as duration of recalling the data;
• Amount of data transferred;
• Operating system and information on the internet browser used, including add-ons installed (e.g., FlashPlayer);
• http status code (e.g., “Request successful” or “File requested not found”).

This Online Offer is not meant for children under 18 years of age.

We involve external service providers with tasks such as sales and marketing services and data hosting and training. We have chosen those service providers carefully and monitor them on a regular basis, especially regarding their diligent handling of and protection of the data that they store. All service providers are obliged to maintain confidentiality and to comply with the statutory provisions. Service providers may also be other Bosch group companies.

Principally, your personal data is forwarded to other controllers only if required for the fulfillment of a contractual obligation, or if we ourselves, or a third party, have a legitimate basis for the data transfer, if you have given your consent, such as marketing our products and/or services and sending training certificates to your employer. Particulars on the legal basis and the recipients or categories of recipients can be found in the Section – Processing purposes and legal basis.
Additionally, data may be transferred to other controllers when we are obliged to do so due to statutory regulations or enforceable administrative or judicial orders.

Principally, we store your data for as long as it is necessary to render our Mobile Application and connected services or for as long as we have a legal basis in storing the data (e.g. we might still have a legal basis in postal mail marketing after fulfillment of our contractual obligations). In all other cases we delete your personal data with the exception of data we are obliged to store for the fulfillment of legal obligations (e.g. due to retention periods under the tax and commercial codes we are obliged to have documents such as contracts and invoices available for a certain period of time).

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.

In the context of our online service, cookies and tracking mechanisms may be used.
Cookies are small text files that may be stored on your device when visiting our online service.
Tracking is possible using different technologies. In particular, we process information using pixel technology and/or during log file analysis.

Our Online Offers use the YouTube video platform which is operated by YouTube, LLC, 901 Cherry Ave. San Bruno, CA 94066, USA („YouTube”). YouTube is a platform which allows the playback of audio and video files.
When you access a respective site of our Online Offers that contains an embedded YouTube player, this creates a connection to YouTube so that the video or audio file can be transmitted and played back. In doing so, data is transferred to YouTube as a data controller. We are not responsible for the processing of such data by YouTube.
Additional information on the scope and purpose of collected data, on further processing and usage of data by YouTube, on your rights and the privacy options available to be chosen by you, can be found in YouTube's data protection notice.

Our Mobile Applications 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.

Our employees and the companies providing services on our behalf, are obliged to confidentiality and to compliance with the applicable data protection laws.
We take all necessary technical and organizational measures to ensure an appropriate level of security and to protect your data that are administrated by us especially from the risks of unintended or unlawful destruction, manipulation, loss, change or unauthorized disclosure or unauthorized access. Our security measures are, pursuant to technological progress, constantly being improved.

To enforce your rights, please use the details provided in the Contact section. In doing so, please ensure that an unambiguous identification of your person is possible.

You have the right to obtain confirmation from us about whether or not your personal data is being processed, and, if this is the case, access to your personal data.

You have the right to obtain the rectification of inaccurate personal data. As far as statutory requirements are fulfilled, you have the right to obtain the completion or deletion of your data.
This does not apply to data which is necessary for billing or accounting purposes or which is subject to a statutory retention period. If access to such data is not required, however, its processing is restricted (see the following).

As far as statutory requirements are fulfilled you have the right to demand for restriction of the processing of your data.

As far as statutory requirements are fulfilled you may request to receive data that you have provided to us in a structured, commonly used and machine-readable format or – if technically feasible –that we transfer those data to a third party

Additionally, you may object to the processing of your personal data for direct marketing purposes at any time. Please take into account that due to organizational reasons, there might be an overlap between your objection and the usage of your data within the scope of a campaign which is already running.

In addition, you have the right to object to the processing of your personal data at any time, insofar as this is based on “legitimate interest”. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements which override your rights.

In case you consented to the processing of your data, you have the right to revoke this consent at any time with effect for the future. The lawfulness of data processing prior to your withdrawal remains unchanged

North American Disclosure

This North American Disclosure supplements the information contained in the TSP Mobile Application (“Bosch” or “we”) Privacy Notice and covers our treatment of (1) personally identifiable information, as defined by numerous statutes in the United States and any applicable substantially similar state legislation (“PII Laws”) and (2) personal information, as defined by Canada’s Personal Information Protection and Electronic Documents Act and any applicable substantially similar provincial legislation (“Canadian Privacy laws”) (collectively, “Personal Information”) which we gather when you are accessing, viewing, completing, or using this TSP Mobile Application or our Services, and (3) Personal information as defined by the Mexican Federal Law on Protection of Personal Data in Possession of Private Individuals”, which we gather while you are accessing, viewing, completing, or using the Services.
Notice to Canadian Users Please note that by using the TSP Mobile Application and/or voluntarily providing your personal information to us, as applicable, you are consenting to the collection, use and disclosure of your personal information as described in this Notice. If you do not consent to the processing of your personal information in accordance with this Notice, please do not access or continue to use the TSP Mobile Application or otherwise provide any personal information to us. Notice to Mexican Users: Please note that by using TSP Mobile Application and/or voluntarily providing your personal information to us, as applicable, you are consenting to the collection, use and disclosure of your personal information as described in this Notice

The TSP Mobile Application has collected the following personal information from users of the TSP Mobile Application within the last twelve (12) months

Bosch will continue to collect the Personal Information described above. If any additional Personal Information is collected by Bosch, we will provide any required notice(s), and where applicable obtain any required consent(s), in accordance with applicable laws in the relevant jurisdiction.

Bosch collects Personal Information from the following categories of sources:

Directly from you
For example, when given by you or collected from you through your access to and/or use of the TSP Mobile Application and/or the Services, in context of registering an account, subscribing to or using our Services, or when you contact customer support or otherwise interact or communicate with Bosch, its agents, representatives, suppliers, vendors or consultants through the TSP Mobile Application. This information may include, without limitation, your name, address, phone number, e-mail address, company, customer product information, and any other information you choose to provide us

Indirectly from you
For example, from observing your use of the TSP Mobile Application and/or the Services, or services related thereto. The following data may be collected automatically: the website from which you visit Bosch (referrer), pages viewed, files downloaded (downloads), individual links clicked, search words or search phrases (site search), duration of visit, browser used, device data (e.g., unique device identifier, MAC address, IP address, serial number, hardware model, network information and operating system and version), and other relevant details and/or information. If the visit is a result of online advertising such as banners, video ads, search engine advertising, etc., Bosch or its agents, representatives, suppliers, vendors or consultants may record which banner, adware, etc. motivated or assisted with the visit to the TSP Mobile Application.

1. Disclosure of Personal Information. In the preceding twelve (12) months, Bosch has disclosed the following categories of Personal Information for a business purpose:
   1. Identifiers
   2. California Customer Records Personal Information categories.
   3. Commercial information
   4. Sensory daata
   5. Professional or employment-related information.
   We disclose your Personal Information for a business purpose to the following categories of third parties:
   • Service providers.
   
   
2. Sales of Personal Information. In the preceding twelve (12) months, Bosch has not sold Personal Information for a business any purpose.
   Sales of Personal Information The use of certain kinds of third-party cookies, such as advertising cookies, on the TSP Mobile Application could be considered a "sale" of your Personal Information for purposes of the CCPA. During the last 12 months, we used third party advertising cookies on the TSP Mobile Application, which allowed the publisher of such third-party cookies to obtain the following categories of Personal Information: Identifiers, California Customer Records Personal Information categories, Internet or other similar network activity, Inferences drawn from other Personal Information. For more information on how Bosch uses cookies on the TSP Mobile Application, see Section XVI (Use of Cookies) below.

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

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

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

To assert your rights, use the data provided in the Contact section when doing so, make sure that an unambiguous identification of you is possible. Such rights include:

1. Right to access and information: You have the right to obtain our confirmation as to whether or not your personal data is being processed and, if so, to access your personal data.
2. Right to rectification and cancellation (deletion): You have the right to obtain the rectification of inaccurate personal data. As long as the legal requirements are met, you have the right to obtain the completion or deletion of your data. This does not apply to data that is necessary for billing or accounting purposes or that is subject to a legal retention period.
3. Right of objection: You have the right to object to the processing of your personal data at any time, as long as it is regarding secondary purposes of processing.
4. Withdrawal of consent: In case you have given your consent to the processing of your data, you have the right to revoke this consent at any time with effect for the future. The legality of the data processing before its withdrawal remains unchanged.
5. Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with a supervisory authority. You can appeal to the supervisory authority:

National Institute of Transparency, Access to Information and Protection of Personal Data (INAI)
Av. Insurgentes Sur # 3211, Col. Insurgentes Cuicuilco,
Delegación Coyoacán, C.P. 04530, Ciudad de México,
Phone number: 800 835 4324
E-mail: atencion@inai.org.mx

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)).
Send an email to: privacy.policy@us.bosch.com
To assist Bosch in processing your request when exercising your rights, please supply the following information:

• Full name
• Phone number
• Address
• Any information you can provide about your previous contact with Bosch (e.g. contact point/touchpoint with Bosch, screenshots, reference to a specific product/newsletter)

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.

Notice to Mexican Users: : for the execution of your ARCO rights or any other right, you may get in contact with us, through the electronic address mail privacy.policy@us.bosch.com by sending your request in terms of the Law and the Regulation, which must include:

• First and last name of the data subject
• Address, e-mail address of data subject or another means to communicate the response to your request.
• Copy or digital copy of official identification to prove the identity.
• Legal representation (if applicable).
• Brief description of the personal data for which you seek to exercise your rights and specify what particular rights you wish to exercise.

Or, if you prefer (it is optional), by sending us the format for the exercise of ARCO rights that you will find on the web page www.bosch.com.mx, in the section Data privacy: “formato para ejercer sus derechos ARCO”.

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.

Notice to Mexican Users: The response time will be of 20 (twenty) business days based on the official calendar published in the Official Gazette of the Federation. The response to your request will be sent through the same means by which it was received, that is, via email. If you do not receive a response from us within the indicated period or if it is unsatisfactory, you have a period of 15 business days to go to the National Institute of Transparency, Access to Information and Protection of Personal Data and request that you initiate a rights protection procedure.

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 via this email link.

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 submitting a request to us via this email link.

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.

As a California resident you may also exercise your request to know or request to delete through an authorized agent. When you submit your request through an authorized agent we require that you:

• Provide us a copy of your written permission for the authorized agent to submit the applicable request; and
• Verify your own identity directly with us.

The foregoing does not apply when you have provided your authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465; provided, that we may require a copy of such power of attorney before fulfilling any request

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.

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 10.6 above, or you if wish to file a complaint with a regulatory authority first, you may do so as follows:

• Under the GDPR: You have the right to lodge a complaint with a supervisory authority. You can appeal to the supervisory authority which is responsible for your place of residence or your state of residency in the EU.
• 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.
• 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 US PII Laws: You may file a complaint with the relevant state’s Attorney General’s office.
  
• Under the Mexican Federal Law on Protection of Personal Data in Possession of Private Individuals: You may file a complaint before the National Institute of Transparency, Access to Information and Protection of Personal Data and request that you initiate a rights protection procedure

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 TSP Mobile Application 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 TSP Mobile Application. You are responsible for checking the TSP Mobile Application frequently to keep apprised of recent changes.

The effective date of this Notice is 09/15/2022
Last reviewed: 09/15/2022

To obtain more information or to submit suggestions or complaints regarding the processing of your personal information, you can contact the Bosch Privacy Notice 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:

European Union:
You can assert your rights under the GDPR by using the following link:
https://request.privacy-bosch.com/entity/RB.

Others:
Email: privacy.policy@us.bosch.com

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

You may also contact as follows:
privacy.policy@us.bosch.com
Phone: 888-43-BOSCH (888-432-6724).

© Copyright 2022 Bosch Security Systems LLC. All rights reserved.