CCPA PIPEDA Privacy Policy

This CCPA Disclosure supplements the information contained in the Bosch PSIRT’s website “psirt.bosch.com” data protection notice and applies solely to all visitors, users, and others of the Bosch Website “psirt.bosch.com” who reside in the State of California and in Canada (“you”). We adopt this Disclosure to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and Canadian privacy law including the Personal Information Protection and Electronic Documents Act [“PIPEDA”], and any terms defined in the CCPA and relevant Canadian law have the same meaning when used in this Disclosure.

I. Collection of Personal Information

The Bosch PSIRT Website “psirt.bosch.com” has collected the following Personal Information from users of the Bosch PSIRT Website “psirt.bosch.com” within the last twelve (12) months.

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

II. Sources of Personal Information

The Bosch PSIRT collects Personal Information from the following categories of sources:

0. Directly from you

For example, when given by you or collected from you through your access to and/or use of the Bosch PSIRT Website “psirt.bosch.com” and/or the Services, in context of sending inquiries via e-mail or otherwise interact or communicate with the Bosch PSIRT, its agents, representatives, suppliers, vendors or consultants through the Bosch PSIRT Website “psirt.bosch.com”. This information may include, without limitation, your first and last name, address, phone number, e-mail address and any other information you choose to provide us.

1. Indirectly from you

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

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

1. Disclosure of Personal Information.

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

• a) Identifiers

Information provided by security researchers added in our acknowledgements (Security advisories, Hall of Fame)

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

1) Right to access specific information and data portability rights.

You have the right to request that the Bosch PSIRT 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:

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

2) Deletion Request Rights.

You have the right to request that the Bosch PSIRT deleteS any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

• a. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
  • i. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • ii. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • iii. Debug products to identify and repair errors that impair existing intended functionality.
  • iv. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • v. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • vi. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • vii. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • viii. Comply with a legal obligation.
  • ix. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

IV.2. Your Rights — Canadians

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

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

IV.3. How to exercise your rights

To exercise your rights, please submit a verifiable consumer request or access request, as applicable, to us by either:

Calling us at (888-43-BOSCH (888-432-6724)).

Emailing us at privacy.policy@us.bosch.com

Only you (or in case of a California resident, an authorized agent authorized by you to act on your behalf — see Section IV.6, Authorized Agent below for more information) may make a verifiable consumer request or access request, as applicable related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. Your verifiable consumer request or access request, as applicable, must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request or access request does not require you to create an account with us, but if you already have an account with us, you may be required to make your request through that account.

We will only use Personal Information provided in a verifiable consumer request or access request, as applicable, to verify the requestor’s identity or authority to make the request.

IV.4. Response timing and format

We endeavor to respond to a verifiable consumer request or access request, as applicable, within forty five (45) days of its receipt, or sooner where required by applicable law (including Canadian Privacy Laws). If we require more time (up 90 days in total), where permitted by applicable law, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide in response to a verifiable consumer request will only cover the 12-month period preceding the verifiable consumer request's receipt, unless otherwise required by applicable law. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, where applicable, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request or access request, as applicable, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

IV.5. Personal Information Sales: 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 contact@us.bosch.com. As noted above, certain kinds of third party cookies, such as ad network or analytics cookies, on the Bosch PSIRT 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 Privacy settings.

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 PSIRT Website “psirt.bosch.com”.

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.

IV.6. Authorized Agent

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

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

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

IV.7. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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

IV.8. Filing a Complaint

Regulatory authorities that oversee the privacy laws and regulations, including the Office of the Privacy Commissioner of Canada, advise individuals to file an objection or challenge with the relevant company before lodging a formal complaint with a regulatory authority. If you are dissatisfied with Bosch PSIRT’s response to an objection or challenge filed under Article IV.3 above, or you if wish to file a complaint with a regulatory authority first, you may do so as follows:

• Under PIPEDA: You may file a complaint with the Office of the Privacy Commissioner of Canada. Depending upon the province where you live, you may also (or instead) have the right to file a complaint with the applicable provincial privacy commissioner/regulator.
• Under PII Laws: You may file a complaint with the relevant state’s Attorney General’s office.
• Under the CCPA: You may file a complaint with the California Attorney General’s Office. For additional information regarding consumer complaints against a business/company under the CCPA and to initiate the complaint process, please click on the link.

Effective date: 18.02.2021