PRIVACY STATEMENT

1. Data Protection Notice
BOSCH POWER TOOLS B.V. (hereinafter "DREMEL“ or "We“ or "Us") welcomes you to our internet pages and mobile applications (together also referred to as "Online Offers"). We thank you for your interest in our company and our products.

2. DREMEL respects your privacy
The protection of your privacy throughout the course of processing personal data as well as the security of all business data is an important concern 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.

3. Controller
DREMEL is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.

Our contact details are as follows:
DREMEL Europe
Bosch Power Tools B.V.
Konijnenberg 60
4825 BD Breda
The Netherlands
Telephone number +31-(0)76-5795-000
Fax number +31-(0)76-5875-431

4. Collection, processing and usage of personal data

4.1. Processed categories of data
The following categories of data are processed:

  • • Communication data (e.g. name, telephone, e-mail, address, IP address)

4.2. Principles
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, contract accounting and payment 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.

4.2.1. – Resolving service disruptions as well as for security reasons.
(Legal bases: Fulfillment of our legal obligations within the scope of data security, and justified interest in resolving service disruptions as well as in the protection of our offers).

4.2.2. – Self-promotion and promotion by others as well as market research and reach analysis done within the scope statutorily permitted or based on consent
(Legal bases: Consent / justified interest on our part in direct marketing if in accordance with data protection and competition law).

4.2.3. – Product or customer surveys performed via email and/or telephone subject to your prior express consent.
(Legal basis: Consent).

Note: In case we involve a market research institute for the purpose of surveys, it shall only act based on our instructions and follow our directives.

4.2.4. – Conducting raffles or discount campaigns in accordance with respective terms and conditions for raffles or discount campaigns.
(Legal basis: Fulfillment of contractual obligations).

4.2.5. – Sending an email or SMS/MMS newsletter subject to the recipient’s consent
(Legal basis: Consent).

4.2.6. – Safeguarding and defending our rights.
(Legal basis: Justified interest on our part for safeguarding and defending our rights).

4.3. Log files
Each time you use the internet, your browser is transmitting certain information which we store in so-called log files.

We save log files for a short period of time to determine service disruptions and for security reasons (e.g., to investigate attack attempts) 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). Also see module web analysis.

In log files, in particular 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., Flash Player);
  • http status code (e.g., “Request successful” or “File requested not found”).

4.4. Data transfer

4.4.1. Data transfer to other controllers
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 interest in the data transfer, or if you have given your consent. Particulars on the legal bases can be found in the Section - Purposes of Processing and Legal Bases. Third parties may also be other companies of the Bosch group. When data is transferred to third parties based on a justified interest, this is explained in this data protection notice.

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.

4.4.2. Service providers (general)
We involve external service providers with tasks such as sales and marketing services, contract management, payment handling, programming, data hosting and hotline services. 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 to the statutory provisions. Service providers may also be other Bosch group companies.

4.5. Transfer to recipients outside the EEA
We might transfer personal data to recipients located outside the EEA into so-called third countries.

In such cases, prior to the transfer we ensure that either the data recipient provides an appropriate level of data protection (e.g. due to a decision of adequacy by the European Commission for the respective country or due to the agreement based on so-called EU model clauses with the recipient) or that you have consented to the transfer.

You are entitled to receive an overview of third country recipients and a copy of the specifically agreed-to provisions securing an appropriate level of data protection. For this purpose, please use the statements made in the Contact section.

4.6. Duration of storage; retention periods
Principally, we store your data for as long as it is necessary to render our Online Offers and connected services or for as long as we have a justified interest in storing the data (e.g. we might still have a justified interest 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).

5. Raffles or discount campaigns
In case you participate in one of our raffles or discount campaigns, we use your data to inform you about any prize won and for the purpose of advertising our products to the extent allowed by law or as far as you have consented. Information on raffles or discount campaigns can be found in the respective terms of participation.

6. Cookie usage

6.1. General
Cookies are small text files that are saved on your computer when an Online Offer is accessed. In case you access this Online Offer another time, your browser sends the cookies' content back to the respective seller and, thus, allows the re-identification of the terminal device. Reading the cookies allows us to design our Online Offers optimally for you and makes it easier for you to use them.

6.2. Deactivation and deletion of cookies
When visiting our internet pages you will be asked in a cookie layer pop up whether you wish to allow the cookies which are set on our page or if you wish to deactivate them in the settings.

In case you decide to block cookies, an opt out cookie is set in your browser. This cookie exclusively serves the purpose of assigning your objection. Deactivating cookies may disable individual functions of our internet pages. Please note that an opt out cookie may, for technical reasons, only be set with the actual browser. In case you delete cookies or use a different browser or a different terminal device, you must opt out again.

The preference setting does not apply to cookies that are set during your visit on third party internet pages by other providers.

Your browser allows you to delete any cookies at all times. To do so, please consult your browser's help functions. This might, however, lead to individual functions no longer being available.

In addition, you could manage and deactivate the use of third party cookies on the following web page:
http://www.youronlinechoices.com/uk/your-ad-choices.

As we do not operate this website, we are not responsible and we are unable to influence the content and availability.

6.3. Overview of cookies used by us
In this section, please find an overview of the cookies we use.

6.3.1. Absolutely necessary cookies
Certain cookies are necessary to provide our Online Offers in a secure manner. This category includes, e.g.:

  • Cookies that identify or authenticate our users;
  • Cookies that temporarily save certain input of the user (e.g. content of a shopping cart or of an online form);
  • Cookies that store certain user preferences (e.g. search or language settings);
  • Cookies that store data to ensure a trouble-fee playback of video or audio content.

6.3.2. Analytical cookies
We use analytical cookies to record the usage behavior (e.g. ad banners clicked on, search queries put in) of our users and to evaluate it statistically.

6.3.3. Advertisement cookies
We also use cookies for advertisement purposes. The usage behavior profiles created with such cookies (e.g. ad banners clicked on, visited subpages, search queries entered) are used to show you advertisements or offers that are tailored to your interests ("interest based advertisement").

6.3.4. Third party advertisement cookies
We also allow other companies to assess data of our users through advertisement cookies. This allows us and third parties to show the users of our Online Offers interest based advertisements which are based on an analysis of their usage behavior in total (e.g. ad banners clicked on, visited subpages, search queries put in), thus, not restricted to our Online Offers.

6.3.5. Conversion cookies
Our conversion tracking partners set a cookie on your computer ("conversion cookie") in case you entered our website through an advertisement of the respective partner. These cookies generally lose their validity after 30 days. In case the cookie has not yet expired, we and the respective conversion tracking partner can see that a particular user clicked the ad and was forwarded to our page. Information gathered through the conversion cookie is used to create conversion statistics and to determine the total number of users who clicked the respective ad and were referred to a page provided with a conversion tracking tag.

6.3.6. Tracking cookies in connection with social plugins
Some pages of our Online Offers integrate contents and services from other providers (e.g. Facebook, Twitter) who may in turn use cookies and active components. We are unable to influence the processing of personal data done by these providers. Find more details on social plugins in the Social Plugins section.

6.4. WebTrends
WebTrends is provided by WebTrends Inc., 851 SW 6th Ave., Suite 1600, Portland, Oregon 97206, USA.

You may object to the collection or processing of your data by using the opt out possibility by clicking the following link: https://ondemand.webtrends.com/support/optout.asp.

6.5. Monetate
Monetate is provided by Monetate Inc., 100 Crosby Street #402, New York, NY 10012, USA.

You may object to the collection or processing of your data by using the opt out possibility by [amend individual solution].

6.6. Google Analytics
Google Analytics is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). We use Google Analytics with the additional function offered by Google to anonymize IP addresses. While doing so, Google already shortens IPs within the EU in most cases but only does so for exceptional cases in the United States, and in both regions it only saves shortened IPs.

You may object to the collection or processing of your data by using the following link to download and install a browser plugin: http://tools.google.com/dlpage/gaoptout?hl=en

7. Usage of retargeting tools
For the purpose of optimizing our online marketing we use so-called retargeting technologies. This is to design a more interesting Online Offer for you, which is tailored to your needs. To do so, we use the tools listed below.

The usage profiles compiled with help of advertisement cookies or third party advertisement cookies, so-called web beacons (invisible graphics which are also called pixels or counting pixels) or comparable technologies, are not brought together with personal data.

The tools are used by the providers to show our users in our Online Offers and in third party offers interest-based advertisements and to control the frequency in which users see certain advertisements. The provider of the respective tool is responsible for the data processing in connection with the tools. The tool providers eventually transfer information to third parties for abovementioned reasons.

The tools either do not process user IP addresses at all or shorten them immediately after collecting the data.

With each tool you can find information on the tool provider as well as information on how to object to the data collection by this tool.

Be advised that with regard to tools which use opt out cookies, the opt out function is related to that individual device or browser. In case you use several terminal devices or browsers you must opt out on every device and with every browser used.

Beyond this, you can avoid the forming of usage profiles by generally deactivating cookie usage. Please refer to the section Deactivate and delete cookies.

Further information on interest-based advertising may be found on the consumer portal http://www.meine-cookies.org. The following link to the portal additionally enables you to view the activation status of certain tools provided by different providers and to object to the collection and processing of your data by these tools: http://www.meine-cookies.org/cookies_verwalten/praeferenzmanager-beta.html.

The option to object to certain tools especially issued by U.S. based providers can be found at the following link: http://www.networkadvertising.org/choices/.

Specifically, we use the following tools:

7.1. Google AdSense
Google AdSense is offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Find further information on this tool here.

You may object to the collection and processing of your data by this tool by following Google's user references.

7.2. Double-click
Double-click is offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Find further information on this tool here.

You may object to the collection and processing of your data by this tool by following Google's user references.

8. Social Plugins
In our Online Offers we use so-called social plugins from various social networks. They are individually described in this section.

When using plugins, your internet browser creates a direct connection to the respective social networks’ server. This way, the respective provider receives the information that your internet browser accessed from the respective site of our Online Offers - even if you do not have a user account with this provider or are currently not logged into your account. Log files (including the IP address) are, in this case, directly transmitted from your internet browser to a server of the respective provider and might be stored there. The provider or its server may be located outside the EU or the EEA (e.g. in the United States).

The plugins are standalone extensions by social network providers. For this reason, we are unable to influence the scope of data collected and stored by them.

Purpose and scope of the collection, the continued processing and usage of data by the social network as well as your respective rights and setting options to protect your privacy can be found by consulting the respective social network's data protection notices.

In case you do not wish social network providers to receive and, if applicable, store or use data, you should not use the respective plugins.

8.1. By using the so-called two click solution (provided by Heise Medien GmbH & Co. KG) we protect your visit to our web pages from being logged and processed by social network providers by default. When using a page of our internet presence which contains such plugins, these are initially deactivated. Only when you click on the respective button, the plugins are activated.

8.2. Facebook plugins
Facebook is operated under www.facebook.com by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, and under www.facebook.de by Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland ("Facebook"). Find an overview over Facebook's plugins and their appearance here: http://developers.facebook.com/plugins; find information on data protection at Facebook here: http://www.facebook.com/policy.php.

8.3. Twitter plugins
Twitter is operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA ("Twitter"). Find an overview over Twitter's plugins and their appearance here: https://twitter.com/about/resources/buttons; find information on data protection at Twitter here: https://twitter.com/privacy.

8.4. Google+ plugins
Google+ is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Find an overview over Google's plugins and their appearance here: https://developers.google.com/+/plugins; find information on data protection at Google+ here: http://www.google.com/intl/de/+/policy/+1button.html.

8.5. Pinterest plugins
Pinterest is operated by Pinterest Inc., 808 Brennan St, San Francisco, CA 94103, USA ("Pinterest"). Find an overview over Pinterest's plugins and their appearance here: https://developers.pinterest.com/tools/widget-builder/; find information on data protection at Pinterest here: https://about.pinterest.com/de/privacy-policy.

8.6. Instagram plugins
Instagram is operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA ("Instagram"). Find an overview over Instagram's plugins and their appearance here: http://blog.instagram.com/post/36222022872/introducing-instagram-badges; find information on data protection at Instagram here: https://help.instagram.com/155833707900388/.

9. Social Sign In (login via social networks)
We offer you the possibility to sign into our Online Offers by so-called social sign ins such as Facebook Connect and Twitter.

To register, you are forwarded to the respective social network's page where you can sign on with your data. This means that your account with the respective network is linked to our service. In doing so, information from your public profile, your email address and the identification tags of your network friends, as well as, if applicable, further data is transmitted to us through the social network.

In turn, the social network used for the registration receives your login status, browser information and your IP address. The social network's provider or its server may be located outside the EU or the EEA (e.g. in the United States).

If you do not wish data transfer taking place between us and the social network services, log in via our own log in services instead of social log in services.

10. YouTube
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 processor. 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.

11. Newsletter

11.1. Newsletter with opt-in; Right of withdrawal
Within the scope of our Online Offers you can sign up for newsletters. We provide the so-called double opt-in option which means that we will only send you a newsletter via email, mobile messenger (such as, e.g. WhatsApp), SMS or push notification after you have explicitly confirmed the activation of the newsletter service to us by clicking on the link in a notification. In case you wish to no longer receive newsletters, you can terminate the subscription at any time by withdrawing your consent. You can withdraw your consent to email newsletters by clicking on the link which is sent in the respective newsletter mail, or in the administrative settings of the online offer. Alternatively, please contact us via the contact details provided in the Contact section.

12. External links
Our Online Offers may contain links to third party internet pages – by 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 supervision. We do not assume responsibility for the processing of personal data by third parties.

13. Security
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.

14. User rights
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.

Right to information and access:
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.

Right to correction and deletion:
You have the right to obtain the rectification of inaccurate personal data concerning yourself without undue delay from us. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

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).

Restriction of processing:
You have the right to demand for – as far as statutory requirements are fulfilled – restriction of the processing of your data.

Objection to data processing:
You have the right to object to data processing by us at any time. We will no longer process the personal data unless we demonstrate compliance with legal requirements to provide provable reasons for the further processing which are beyond your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Objection to direct marketing:
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.

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

Withdrawal of consent:
In case you consented to the processing of your data, you have the right to revoke this consent with immediate effect. The legality of data processing prior to your revocation remains unchanged.

14.1. Data portability:
You are entitled to receive data that you have provided to us in a structured, commonly used and machine-readable format or – if technically feasible – to demand that we transfer those data to a third party.

14.2. Right of complaint with supervisory authority:
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 or to the supervisory authority responsible for us. This is:

State Commissioner for Data Protection and Freedom of Information
Address:
Mr Aleid WOLFSEN, Chairman of Autoriteit Persoonsgegevens
Bezuidenhoutseweg 30
Postbus 93374
NL 2509 AJ Den Haag/The Hague
Telefon: + 31-70-88 88 500
Telefax: + 31-70-88 88 501
E-Mail: info@autoriteitpersoonsgegevens.nl

15. Changes to the Data Protection Notice
We reserve the right to change our security and data protection measures if this is required due to technical development. In such cases, we will amend our data protection notice accordingly. Please, therefore, notice the current version of our data protection notice, as this is subject to change.

16. Contact
If you wish to contact us, please find us at the address stated in the "Controller" section.

To assert your rights, for data protection breaches as well as for suggestions and complaints regarding the processing of your personal data we recommend that you contact our group commissioner for data protection:

Mr.
Matthias Goebel
Group Commissioner for Data Protection
Information Security and Privacy Bosch Group (C/ISP)
Robert Bosch GmbH
Kronenstrasse 20
70173 Stuttgart
GERMANY
or
Abteilungsbriefkasten.cisp@de.bosch.com .

17. Effective date: 2018.05.01