Bosch Privacy Policy – Highlights

I. Introduction.

Robert Bosch LLC (“Bosch”, “we”, “us” or “our”) is pleased to have you (“you” or “your”) use our eBike Flow application (“Application”) and welcomes your interest in the services or products provided through the Bosch Application (collectively, the “Services”). This Privacy Policy (this “Notice”) applies to all users of the Bosch Application 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 Terms and Conditions of Use for the Application (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 Bosch Application 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 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 Bosch Website/Application or otherwise provide any Personal Information to us.

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 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 Bosch Application or our Services.

III. Collection of Personal Information

The Bosch Application has collected the following Personal Information from users of the Bosch 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.

IV. Sources of Personal Information

Bosch 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 Bosch Application and/or the Services, in context of [registering an account, subscribing to or purchasing our Services or when you contact customer support or otherwise interact or communicate with Bosch, its agents, representatives, suppliers, vendors or consultants through the Bosch Application. This information may include, without limitation, your [first and last name, contact details, phone number and e‑mail address and any other information you choose to provide us.

Indirectly from you. For example, from observing your use of the Bosch Application and/or the Services, or services related thereto. The following data may be collected automatically: 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, adword, etc. motivated or assisted with the visit to Bosch Application.

Other Source category: For example, when you connect to the service Apple Health of Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, USA (“Apple Health”) in the authorization dialog, your activity and fitness data from our Application are synchronized with yout Apple Health Account. Apple Health receives the following data, among others: start and end time of a completed activity, distance, duration, speed and calories. The data is made available to you in Apple Health. In addition, you have the option of displaying your heart rate during an activity with the help of the "Apple Watch". The different devices must be connected to each other for data transfer.

V. Use of Personal Information and purpose specification

Bosch may use your Personal Information for the purpose of:

1. Fulfilling or meeting the reason you provided the information. For example, if you share your name and contact information to 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 facilitate delivery. We may also save your information to facilitate new product orders. When services that are subject to a charge are booked, payment processing data are collected and processed exclusively and directly by the app store operators for devices with the Android and iOS operating systems.
2. Technical administration of Bosch and Bosch affiliate websites, mobile applications and/or services.
3. Maintaining the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
4. User/customer administration (like registration and creation of a user account/contact data), review and/or reports. Users have to register in order to use our services. The personal information you provide when registering and using our services includes your name, contact details, and your email address and password. We need this information for identification purposes and to provide our services and also to communicate and respond to and manage your requests. You can choose to submit reviews on our platform. Reviews are submitted on a voluntary basis. To submit a review, you must log in to your account and provide a review text. Your review will be sent to our customer service along with your name. If we actively solicit a review by e-mail, you must explicitly confirm this service during the registration process. Reviews are solicited to provide quality assurance for our platform and the transparency of the services on our Application for other users. You can unsubscribe from this service at any time. Please use the link provided in the relevant mail or change the settings in your account.
5. Administering, maintaining, personalizing and improving Bosch and Bosch affiliates’ mobile applications, products and services, including, without limitation, to authenticate users, provide requested services, provide optional additional services and to develop new features, products and/or services.
6. Provision of our Online Offer. When using our Online Offer, certain information is automatically transmitted to us and stored in so-called log files. The log files are processed for the purpose of providing and optimizing our Online Offer, to ensure technical operation, as well as to determine and eliminate malfunctions and to clarify criminal offences.The data will be deleted after 30 days if they are no longer required for the purposes described. Log files whose further storage is required for evidentiary purposes are excluded from deletion until final clarification of the respective incident and may be passed on to investigating authorities in individual cases within the scope of legally applicable provisions. In addition, we perform an eBike tuning detection to determine the intended use of Bosch eBike-Systems and, if applicable, to be able to check existing warranty and guarantee claims on the Bosch eBike system and other bicycle components.
7. Registration at Online Offer / Prior setup of a central SingleKey ID at Bosch.IO GmbH. To use our services, registration in our Online Offer is required. You can only register for our Online Offer by first setting up a central SingleKey ID. The central SingleKey ID was developed by Bosch.IO GmbH for the Bosch Group of Companies in order to enable shared users to use the services of different companies in the Group using uniform login data and to increase data security. Responsible for providing this registration service is Bosch.IO GmbH, Ullsteinstrasse 128, Germany ("BIO"). BIO as the responsible party for SingleKey ID and Bosch eBike Systems processes your data under joint responsibility in accordance with the rules of the General Data Protection Regulation and national data protection laws. We have assumed this joint responsibility with regard to data processing pursuant to Art. 26 GDPR (Joint Controllership) and, in particular, regulated and defined the responsibilities of the parties involved. For more detailed information on the individual data processing operations, please refer to BIO's data protection notice under point 13 ("Information on joint responsibility towards data subjects pursuant to Art. 26 (2) sentence 2 GDPR") https://singlekey-id.com/data-protection-notice/. If you wish to register with BIO for a central SingleKey ID, the General Terms of Use for the Registration and Use of a Central SingleKey ID and BIO's Privacy Notice apply. After successful registration, you can also use the login data used for the central SingleKey ID to register for this Online Offer. For this purpose we provide you with a BIO login mask for the central SingleKey ID. BIO will then confirm your authorization. Your password will not be transmitted to us. With regard to other data transfers within the Bosch Group associated with the central SingleKey ID, we refer to the BIO data protection information. You can terminate your user agreement for the central SingleKey ID at any time by logging out. Please click on the following link: https://myaccount.bosch.com/BeaPUssWeb/unregistration. Once the user account has been set up, additional further voluntary information (e.g. gender, date of birth, height and weight, resting pulse and maximum pulse) within our Online Offer within the user account.
   User accounts that are inactive for longer than 24 months are automatically deleted irretrievably. Inactivity occurs when user accounts are not used, e.g., by logging into the online offering or using services. Before deleting the inactive user account, we will send an information e-mail to the unused user accounts and give users the opportunity to object to the deletion. If the request remains unsuccessful, the unused user accounts are finally deleted.
8. Provision of services. Through our Online Offer, information about your eBike is prepared and visualised for you individually and according to your needs. You get among others an overview of used components, as well as further technical information about your eBike incl. current eBike settings. In order to use our service, it is necessary to link your user account with an eBike. The link is established by connecting via Bluetooth from the Bosch Remote Controller (BRC) to your user account. For the establishment of such a Bluetooth connection to devices with the Android operating systems, Android requires access by us to your position data (e.g. GPS data). For this purpose, we process your position data for the establishment of a Bluetooth connection to an Android device. In addition to the general service, you have the option of using other services that are free of charge and subject to a charge. These are described below and are subject to your selection. Depending on your selection, personal data will be processed accordingly when using the services ("service-related data"). Service-related data is processed for the purpose of providing the functionalities. When booking paid services (Flow+), payment processing data is collected and processed exclusively and directly by the operators of the App Store for devices with the operating systems Android and iOS.
9. Home screen. The home screen gives you a quick overview of all the important information such as battery status, remaining range, distance travelled and the next service appointment. Your eBike model is also displayed on the Home Screen, provided that the relevant eBike manufacturer supports this feature. For the display of various information about your eBike on the home screen, the device-related data mentioned above will be processed.
10. Route planning, navigation and activity tracking. You can use our location-based services to calculate and display routes and for destination guidance in the Online Offer and on the board computer. The trip duration of the route, if available, is calculated based on the riding behavior of the preceding eBike trips. In addition, when an activity is detected with your eBike, it is recorded and visualized in the app (activity tracking). We also record the frequency of use of Bosch eBikes on road and bicycle path networks and visualise the most frequently used path sections for you in maps in our navigation and activity tracking functions. The visualisation of popular route sections helps you find your way when riding. Furthermore, our online offer calculates the remaining range during navigation and displays it to you, i.e. you get an overview of how far you can get with the current engine support. Besides planning in our app, you can additionally upload GPX (GPS Exchange Format) routes to the Flow app and use them afterwards. As part of the activity tracking, you have the option to allow the activity recording to run in the background. To do this, you must set the location access in the background to "always allow". You can change the location sharing in the background at any time in the settings. Regarding the location of mobile devices (GSM location), we refer you to the data protection declarations of your mobile phone provider as well as to the operators of the App Store for devices with the operating systems Android and iOS. Please note that most mobile devices allow you to enable or disable the use of location services on your mobile device in the device's settings menu. If you use our Online Offer, please note that if you deactivate the mobile device tracking feature, certain services may not be available due to the nature of our services. In the context of activity tracking, you can delete individual recordings within the app. Deletion has no effect on route planning and navigation.
11. Dealer Locator. You can use the Dealer Locator to find eBike dealers close to you. In order to show you the nearest dealers, we process your location data (e.g. GPS data). Regarding the location of mobile devices (GSM positioning), we refer you to the privacy statements of your mobile provider and to the operators of the app stores for devices with the operating systems Android and iOS. Please note that most mobile devices allow you to activate or deactivate the use of location services on your mobile device in the settings menu of the device. To the extent that you use our Online Offer, please note that if you deactivate the mobile device location function, certain services may not be offered due to the nature of our services.
12. Flow+ Service: Making life more difficult for thieves. The ConnectModule allows you to locate your smart system eBike after is has been stolen, for example. This requires the eBike Lock and Alarm function to be activated. When eBike Lock is activated, motor support is deactivated. You can also use the Alarm function to display the location of your eBike. This data is required for the purpose of deactivating the motor and locating your eBike.
13. Help Center. To help you quickly find answers to all your questions about your eBike with the smart system, the Help Center adapts the displayed content to the eBike and its components currently connected to the app. For this purpose, in addition to your name, the information about the hardware and software component of your eBike is processed.
14. Digital service book. We process your data to provide you with a digital service history of your eBike with information about changes, updates and services relating to your bike and to enable eBike dealers to manage the entries in your digital service book.
15. Individual riding modes. You can modify the motor characteristics of your eBike's drive unit and store these along with the associated properties of the drive unit via our Online Offer and retrieve the relevant data at any time. Additional information on the respective drive unit (settings for the motor) is compiled and visualised here for you, enabling you to activate the motor characteristics you have used in the past, as well as at present, with the specific optimised motor characteristics.
16. Activation of an already registered eBike for a new user account. To make full use our services, your user account must be linked to an eBike. Each eBike can be assigned to just one user account at a time. If your eBike is already assigned to another user account (e.g. if you have purchased your eBike privately because the previous owner has forgotten to remove the eBike from his user account after selling it), you will receive an error message when you try to link the eBike to your user account. The current link between your eBike and another user account must first be reset so that you can link the eBike with your own user account. For this purpose, you must contact the user currently linked to your eBike in order to have the eBike removed from the currently linked user account. If you find you are unable to contact the user currently linked to the eBike, you can initiate further steps via an eBike dealer.
17. Product improvement and development. We use user, diagnostic and usage data resulting from the use of Bosch eBike Systems products and services as well as our Online Offer to continuously improve our Online Offer, to develop new products and services and for market research. This includes, for example, an analysis of user groups performance statistics as well as device and software-related usage information, i.e. how you our Online Offer, which features you access and to what extent, or when you delete your account or uninstall the app or how you use our newsletter. The data is only processed in anonymized form and used for statistical usage evaluations.
18. Assessments. You have the opportunity to submit reviews and optionally provide feedback. This process is voluntary. If you are dissatisfied, we reserve the right to forward your feedback to our customer service and, if necessary, to contact you to resolve your dissatisfaction. If you want us to actively ask you to submit a review by email, you must explicitly confirm this service in the registration process. The request to submit a rating serves the quality assurance of our Online Offer and the transparency of the services on our platform for other users.
19. Competitions/ customer satisfaction surveys/ Feed. If competitions and/or customer satisfaction surveys are conducted, your participation is always voluntary. Details of whether and, if applicable, which personal data are collected, stored and processed for which purposes in a specific case can be found in the respective descriptions of the competitions/surveys. The collection and processing of this data is based on contract. In addition, individual and useful information about the eBike and the digital services is continuously displayed in the app, so-called "feed". A feed can contain, for example, instructions on how to use the Online Offer and discover the ecosystem.
20. Customised newsletter/Customised in-app advertising. You can subscribe to an individual newsletter as part of our Online Offer. Individual newsletters contain information tailored to you about offers and services of our Online Offer and information about the eBike (e.g. news, updates and product or service information from Bosch eBike Systems, eBike manufacturers, eBike dealers or other partners), practical help and usage tips for our Online Offer as well as marketing and advertising messages. In order to collect the individual information and use it for the content of the newsletter, we evaluate user and diagnostic data as well as data resulting from the use of Bosch eBike Systems products and services and our Online Offer. If you wish to unsubscribe from the newsletter and discontinue the evaluation, you can terminate your subscription at any time by revoking your consent. The revocation can be made via the link provided in the newsletter or in the administrative settings of the respective Online Offer. Alternatively, you can also contact us using the details in the "Contact" section.
21. eBike software updates (over-the-air updates). To ensure that your eBike is kept up to date and is continuously enhanced with new features, our Online Offer regularly checks in the background whether software updates are available for your Bosch eBike components. You also have the option of manually searching for software updates in the Online Offer. We will inform you in our Online Offer as soon as a new update is available for your eBike and you decide if and when you want to download and install the software update. If you wish to download and install all future software updates without your any action on your part, you can consent to automated processing in the settings of our Online Offer.
22. Contacting customer service. If you contact our customer service, e.g. in case of questions, complaints, suggestions or to verify your identity for already registered eBikes your data will be processed to process your request. If you contact us using the contact form in our website, log files with device-related data can be attached to your request so that customer service can process your request as efficiently as possible. If you contact us by phone, we may ask you in the phone call if we may record the following conversation for service optimization. The recording is voluntary. We will then only record the conversation if you give your consent to do so.
23. Handling of a service case at the bicycle dealer or service partner/ Connection of an eBike to a diagnosis tool. If you have a concern about your eBike, you are welcome to contact your bicycle dealer or service partner. To be able to process your request, it is first necessary to identify the technical fault. For this purpose, the bicycle dealer connects your eBike to a diagnostic tool. When your eBike is connected to the diagnosis tool, the following information about your eBike is sent to Bosch eBike Systems for processing ("device-related data"): information about the manufacturer, the date of production and the model of the eBike, Bike-ID, information about the eBike components (article number, serial number, hardware and software versions, configuration data, statistical data), as well as activity data of the eBike (e.g. total riding time, service intervals performed and pending)". The device-related data can be processed for the following purposes: Processing your request, handling a service case, configuring the eBike, performing updates, Tamper detection and reset, unlocking the eBike components, setting the system time and for product improvement.

VI. Sharing and Disclosure of Personal Information

Bosch 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:

1. Bosch affiliated entities, including Bosch’s parent company in Germany, Robert Bosch GmbH, to leverage shared services and improve our Services;
2. 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.
3. 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 Bosch Application 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

1. Disclosure of Personal Information. In the preceding twelve (12) months, Bosch has not disclosed Personal Information for a business purpose.
2. [Sales of Personal Information. [In the preceding twelve (12) months, Bosch has not sold Personal Information for a business purpose.

VIII. Use of the third-party Application analytics tools

We use Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland ("Firebase") in our Application to develop and improve mobile apps. In doing so, Google processes data on our behalf. We use several features of Firebase in our app.

1. Firebase Analytics
   We use Firebase Analytics to continuously improve our app and for the development of new products and services. This involves an analysis of user interaction, i.e. how you use the app, which functions of the app you access, how often you open the app or when the app is uninstalled. This information helps us to further develop our app and adapt it to the needs of our users. The data is only processed in pseudonymized form and used for statistical usage evaluations and transferred to Google. On our behalf, Google evaluates this usage analysis (e.g., in comparison to other apps) and provides results and further services based on them. The advertising ID of your end device is used for the evaluation by Google Inc. You have the option to restrict access to the device ID of your mobile device in the device settings.
2. Crashlytics
   Furthermore, we use the Firebase Crashlytics function to stabilize and improve our apps. In doing so, data about the terminal device you use and the use of our apps is collected (device ID and the timestamp, when the respective app was started and when a malfunction occurred), which enables us to diagnose and solve malfunctions. When using Firebase Crashlytics, your data is processed by us in a pseudonymized form - without a user ID. Google assures in its Firebase privacy policy that this data is not merged with other data and therefore it is not possible to draw conclusions about your person.
3. Firebase Cloud Messaging
   Furthermore, we also use the Firebase Cloud Messaging service to send you technically-related push messages or so-called in-app messages to your end device. In the process, your end device is assigned a pseudonymized device token ID, a unique connection number generated from the device ID, by means of which we can address the push messages or in-app messages to you. Google acts here as our service provider on our behalf.
   Through the settings made by us, personal data (device ID) is processed and stored wherever possible within the member states of the European Union or in other contracting states to the Agreement on the European Economic Area and Switzerland. Google assures that personal data is processed within the EU and the EEA and Switzerland.
4. Firebase Performance Monitoring
   We use the Firebase Performance Monitoring service to detect performance problems of the app and to fix them. For this purpose, reports on the network behavior of the Flow App are created and analyzed in order to be able to improve the stability of the infrastructure. The following information, among others, is processed: Device type (e.g. iOS, Android), operating system, mobile carrier, radio/network information (e.g. WLAN, LTE), country, language, signal strength, battery level and charging status, app version and network URLs. When monitoring HTTP network requests, URLs without URL parameters are used to create aggregated and anonymous URL patterns that are eventually stored and displayed.
5. Firebase Remote Config
   With the help of Firebase Remote Config, changes can be made to app settings configurations on apps already installed in end devices without having to completely re-download and re-install them from the app store for each change. The legal basis for the processing is legitimate interest. The legitimate interest of Bosch eBike Systems is to optimize its own products and services, to develop new products and services and thus to maintain or promote your satisfaction.

IX. Usage of Cookies

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

1. Categories
   We distinguish between cookies that are mandatorily required for the technical functions of the Online Offer and such cookies and analysis mechanisms that are not mandatorily required for the technical function of the Online Offer. It is generally possible to use the Online Offer without any cookies that serve non-technical purposes.
   • a. Technically required cookies
     By technically required cookies we mean cookies without those the technical provision of the Online Offer cannot be ensured. These include e.g. cookies that store data to ensure smooth reproduction of video or audio footage. Such cookies will be deleted when you leave the website.
   • b. Cookies and analysis mechanisms that are technically not required
     We only use cookies and analysis mechanisms if you have given us your prior consent in each case. With the exception of the cookie that saves the current status of your privacy settings (selection cookie). This cookie is set based on legitimate interest.
     We distinguish between two sub-categories with regard to these cookies and analysis mechanisms:
     • i. Comfort cookies
       These cookies facilitate operation and thus allow you to browse our Online Offer more comfortably; e.g. your language settings may be included in these cookies. Comfort Cookies are currently not used on the website.
     • ii. Marketing cookies
       By using marketing cookies we and our partners are able to show you offerings based on your interests, resulting from an analysis of your user behavior:
       Statistics: By using statistical tools, we measure e.g. the number of your page views.
     • iii. Analysis mechanisms
       We use analysis mechanisms to compile anonymous statistics on the use of our services, such as the number of page views. With the help of such evaluations, we can improve our online offer or develop new products and services.

We use the following tools:

Name: Google Tag Manager

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

Function: Management of website tags via an interface, integration of program code on our websites.

Name: Google Analytics

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

Function: Analysis of user behaviour (page views, number of visitors and visits, downloads), creation of pseudonymous user profiles based on cross-device information of logged-in Google users (cross-device tracking), enrichment of pseudonymous user data with target group-specific information provided by Google, retargeting, UX testing, conversion tracking and retargeting in conjunction with Google Ads.

2) Management of cookies and analysis mechanisms

You can manage your cookie and analysis 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.

• a. Deactivation of all cookies
  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.
• b. Management of your settings with regard to cookies and analysis mechanisms not required technically
  When visiting our websites, you will be asked in a cookie layer whether you consent to our using of any Comfort cookies, marketing cookies or analysis 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.

X. External services

1. Apple Health and Apple Watch
   You can transfer your activity and fitness data from our Online Offer to the Apple Health application from Apple Inc. 1 Infinite Loop, Cupertino, CA 95014, USA. In the process, Apple Health receives the following data, among others: Start and end time of a completed activity, distance, duration, speed and calories. The data is made available to you in Apple Health. In addition, you have the option of displaying your heart rate during an activity using the "Apple Watch". The various devices must be connected to one another for data transmission.
   You have the option to disconnect this connection between the accounts at any time. It is not excluded that Apple Health processes this information at locations outside the EU or the EEA/Switzerland (e.g. in the USA). For more information about the processing of your personal data at Apple Health and your rights as a data subject, as well as setting options to protect your privacy, please refer to the privacy notices of Apple Health www.apple.com/de/legal/privacy/de-ww/.
2. Mapbox
   We use the map material of Mapbox Inc, 740 15th St NW, 5th Floor Washington, D.C. 20005, USA ("Mapbox") to be able to offer you the navigation and route calculation function with additional functionalities, such as topographic range measurement or use in offline mode. Mapbox is responsible under data protection law for the processing of your personal data. It is possible that Mapbox may process this information at locations outside the EU or the EEA/Switzerland (e.g. in the US). Further information about Mapbox's services can be found here: www.mapbox.com. The data protection information of Mapbox can be found under the following link: https://www.mapbox.com/legal/privacy/.
3. Strava
   Our website gives you the option of exporting certain activity data, such as times, distances travelled, calories burned, as well as heart rate and position data, elevation, speeds or cadence, to the Strava external portal so you can share this information there. For this purpose, we use the social plugin from Strava Inc, 500 3rd Street, 110, San Francisco, CA 94107, USA. It is possible that Strava may process this information at locations outside the EU or the EEA/Switzerland (e.g. in the US). For information about the processing of your personal data and your rights as a data subject, please refer to Strava's privacy policy at https://www.strava.com/legal/privacy.
4. Komoot
   We offer Komoot's Profile Connect function, which is operated by komoot GmbH, Friedrich-Wilhelm-Boelcke-Straße 2, 14473 Potsdam, Germany. When you activate the Komoot "Profile Connect function" in the authorisation dialogue, the routes you plan on Komoot are synchronised with your Bosch profile, and your Bosch activities are synchronised with your Komoot account. This involves an exchange of data between us and Komoot, whereby we receive the route information planned on Komoot and make it available to you via the "My Routes" function, and Komoot receives the recorded activity data (including trip times, distances, speeds, and position and elevation data) from us - if available. You can end this connection between the accounts at any time. It is possible that Komoot may process this information at locations outside the EU or the EEA/Switzerland (e.g. in the US). For more information about how Komoot processes your personal data and your rights as a data subject, as well as settings options to protect your privacy, please refer to Komoot's privacy policy https://www.komoot.de/privacy.
5. Explore – Outdooractive
   As a registered user, you can search for, view and save tour suggestions for selected regions on our website using the "Explore" function. This service is provided externally by our service partner Outdooractive GmbH & Co. KG with registered offices at Missener Straße 18, 87509 Immenstadt, Germany. When you use the Outdooractive tour search, the following data may be transferred from your device to Outdooractive: the name of the app, date and time of the server request, amount of data transferred, terminal device type/version, the user's operating system, the user's IP address and confirmation of successful retrieval. It is possible that Outdooractive may process this information at locations outside the EU or the EEA/Switzerland (e.g. in the US). For further information, please refer to Outdooractive's privacy policy https://www.outdooractive.com/de/datenschutz.html.
6. Trek's "Next Service Integration"
   We offer Trek's "Next Service Integration" function, which is operated by Trek Bicycle Corporation, 801 West Madison Street, Waterloo, WI 53594, United States. As a registered user, you can use this function to check upcoming workshop service intervals on our website. When you enable this feature in the authorisation dialogue, the technical bike information you have entered on Trek, as well as your Bosch activities, will be synchronised with your Trek account.
   This involves an exchange of data between us and Trek, however we have no access to the technical bicycle information stored by Trek (such as, for example, the name of the bicycle). bicycle model, bicycle model description) or activity data. This information is provided through the Next Service Integration function if Trek has made this recorded activity data available to us. It is possible that Trek may process this information at locations outside the EU or the EEA/Switzerland (e.g. in the US). For more information about how Trek processes your personal data and your rights as a data subject, as well as settings options to protect your privacy, please refer to Trek's privacy policy: www.trekbikes.com/de/de_DE/company/legal_policies/privacy_policy_terms_of_use/
7. YouTube
   Videos from the YouTube platform, for which Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland acts as data controller ("YouTube"), can be played in our portal. YouTube is a platform that enables the playback of audio and video files. If you wish to play a video, the embedded YouTube player connects to YouTube to transfer and play the video or audio file. Browser data is also transferred to YouTube as the responsible party. For more information on the scope and purpose of the data collected, on YouTube’s further processing and use of the data, on your rights and the data protection options you can select, please see YouTube’s privacy policy https://policies.google.com/privacy?hl=de&gl=de.

XI. Sharing with other providers via Cloud API

Bosch eBike Systems puts you in control of your data. With your express consent, we may share your device-related data (such as eBike manufacturer, total ride time, eBike statistics) and/or service-related data (such as activities, cadence, speed) with other providers ("third parties"). This requires that you first log in on the Bosch eBike Systems user interface (Flow app/website) with your central SingleKey ID and consent to the corresponding transfer of data. Once you have granted us such consent, we will allow the relevant third party access to your personal data generated by us on your behalf. You can cancel third party access to your data at any time. To do this, you need to revoke the corresponding permission for data transfer in the Flow app under "Settings">"Connected Services">"3rd Party Integration".

Responsibility for the data processing associated with the transfer lies with you or the third party. The data processing carried out by the Third Party is subject to the said Third Party's terms of use and privacy policy. Bosch eBike Systems has no influence over these. For more information on data processing, please refer to the third party's terms of use and privacy policy.

XII. Children’s Privacy

Bosch 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 Bosch Application from time to time.

XIII. 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.

XIV. Use of links to affiliated sites

The Bosch Application may contain links to other Bosch sites (“Affiliated Sites”). The Bosch Application provides these links only as a convenience. Your use of these Affiliated Sites and any related services are outside the scope of this Notice, and is governed by the Notices and any other terms referred to or located on such Affiliated Sites.

XV. Use of external links

The Bosch Application may contain links to third-party websites or services operated by providers that are not associated with Bosch. After you click the link, Bosch no longer has any influence over the collection, storage, use or processing of any Personal Information transmitted by clicking the link (such as the IP address or URL of the page that contains the link), as the behavior of third parties is, by nature, beyond Bosch control. Therefore, Bosch is not responsible for the collection, storage, use, disclosure or other processing of Personal Information by such third parties. For further clarity, this Privacy Policy does not apply to any such third party websites or services; please refer to the privacy statements or policies for such third party websites or services for information about how they collect, use, disclose and protect personal information.

XVI. Security

Bosch takes commercially reasonable efforts to ensure that your data collected by Bosch through this Bosch Application 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 create a username and 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 username and password. We disclaim any and all liability for any information transmitted due to an unauthorized log in.

XVII. International Users

This is a U.S. website and service targeted to users in the U.S. and Canada, and the Bosch Application 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 the United States. By using the Bosch Services or providing your information to Bosch through the Services you consent to the transfer of your Personal Information to the United States, 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 the United States. 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 Policy Administrator as described below.

XVIII. 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. You have the following rights relating to your 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:
   • i. The categories of Personal Information we collected about you.
   • ii. The categories of sources for the Personal Information we collected about you.
   • iii. Our business or commercial purpose for collecting or selling that Personal Information.
   • iv. The categories of third parties with whom we share that Personal Information.
   • v. The specific pieces of Personal Information we collected about you.
    
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.
   • i. 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.

XIX. 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:

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.

XX. 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 +1 248 876 1000.

To assert your rights please use the following link: 

https://request.privacy-bosch.com/entity/RB/ 

To notify data protection incidents please use the following link: 

https://www.bkms-system.net/bosch-datenschutz 

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

XXI. 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), 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.

XXII. 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.

XXIII. 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.

XXIIII. 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 XX 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, although please note that the CCPA is not effective as of the date of this Privacy Policy and that the rules governing the CCPA and the formal complaint mechanism have yet to be established.

XXV. 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 Bosch 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 Bosch Application. You are responsible for checking the Bosch Application frequently to keep apprised of recent changes.

________________________________________________________________________

The effective date of this Notice is 23 Nov. 2021

Last modified: 04 July 2023

XXVI. 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@remove.this.us.bosch.com

Postal Address:

Robert Bosch LLC

Privacy Policy Administrator

38000 Hills Tech Drive

Farmington Hills, MI 48331

You may also contact as follows:

Phone: +1 248 876 1000

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