Privacy statement

Freud S.p.A. Società Unipersonale (referred to below as “Freud” 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.

1. Freud respects your privacy

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

2. Data Controller

The Controller responsible for processing your data is Freud S.p.A. Società Unipersonale Via Remigio Solari 7, 33050 Pavia di Udine (UD), telephone +39 0432 551411.

3. Collection, processing and usage of personal data

Personal data consists of all information related to an identified or identifiable natural person, this includes, e.g. names, addresses, phone numbers, email addresses 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. Purpose and legal basis

We as well as Robert Bosch Limited, Broadwater Park North Orbital Rd, UB9 5HJ Denham UK, commissioned by us, process your personal data for the following processing purposes:
• Provision of these Online Offers (Legal basis: Legitimate interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law).
• Safeguarding and defending our rights (legal basis: legitimate interest on our part for safeguarding and defending our rights).
• Responding to requests for information or to requests to be contacted made via dedicated forms, given that such information may be delivered by Freud directly or by local associates or local dealers, acting as autonomous Data Controllers (legal basis: fulfillment of a pre-contractual or contractual obligation).

4.1 Log files

Every time you use the Internet, your web browser automatically transfers certain information, which we store in “log files”.
We store the log files for seven days in order to identify defects and for security reasons (e.g. for information on hacking attempts), and then delete them. Log files that need to be stored for a longer period for evidence purposes are not deleted until the incident in question has been fully clarified and may be passed on to investigation authorities in individual cases.
The following information is stored in log files:
- IP address (Internet protocol address) of the device from which the online service is accessed;
- Internet address of the website from which the online service is accessed (referrer URL);
- Name of the service provider via which the online service is accessed;
- Name of the files or information retrieved;
- Date, time and duration of the visit;
- Data volume transferred;
- Operating system and information about the web browser used including any add-ons installed (e.g. for Flash Player);
- Http status code (e.g. “request successful” or “requested file not found”).

5. Children

This online service is not suitable for children under the age of 16.

6. Data transfer

6.1 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 basis and the recipients or categories of recipients can be found in the Section – Purpose and legal basis.
Additionally, data may be transferred to other controllers when we are obliged to do so due to statutory regulations or enforceable administrative or judicial orders.

6.2 Service providers

We involve external service providers with tasks such as sales and marketing services, contract management, 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 with the statutory provisions. Service providers may also be other Bosch group companies.

Provider: Microsoft Ireland Operations Ltd, South County Business Park, One Microsoft Place, Carmanhall and Leopardstown, Dublin, D18P521, Ireland
Function: Provision of Microsoft Azure infrastructure services, geolocation functionality to identify country location of website visitors.

6.3 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 legitimate interest in storing the data (e.g. we might still have a legitimate 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).

7. Usage of Cookies

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

7.1 Categories

We distinguish between cookies that are mandatorily required for the technical functions of the online service and such cookies and tracking mechanisms that are not mandatorily required for the technical function of the online service.
It is generally possible to use the online service without any cookies that serve non-technical purposes.

7.2 Technically required cookies

By technically required cookies we mean cookies without those the technical provision of the online service 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.

7.3 Cookies and tracking mechanisms that are technically not required

We only use cookies and tracking 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 tracking mechanisms:

Comfort cookies

These cookies facilitate operation and thus allow you to browse our online service more comfortably; e.g. your language settings may be included in these cookies.

Marketing cookies and tracking mechanisms

General

By using marketing cookies and tracking mechanisms 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.
- Conversion tracking:
Our conversion tracking partners place a cookie on your computer ("conversion cookie") if you accessed our website via an advertisement of the respective partner. Normally these cookies are no longer valid after 30 days. If you visit certain pages of our website and the cookie has not yet expired, we and the relevant conversion partner can recognize that a certain user clicked on the advertisement and thereby was redirected to our website. This can also be done across multiple devices. The information obtained by means of the conversion cookie serves the purpose of compiling conversion statistics and recording the total number of users who clicked on the respective advertisement and were redirected to a website with a conversion tracking tag.

Name: Google Analytics
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Function: Analysis of user behavior (page retrievals, 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.

Name: Tealium
Provider: Tealium Inc., 11095 Torreyana Road San Diego, CA 92121
Function: Administration of website tags via a user interface, integration of program codes on our websites.

7.6 Management of cookies and tracking mechanisms

You can manage your cookie and tracking mechanism settings in the browser and/or our privacy settings.
Note: The settings you have made refer only to the browser used in each case.

7.7 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.

7.8 Management of your settings with regard to cookies and tracking 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 tracking mechanisms, respectively.
In our privacy settings, you may withdraw the consent with effect for the future or grant your consent at a later point in time.

8. 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 controller. We are not responsible for the processing of such data by YouTube.
Additional information on the scope and purpose of collected data, on further processing and usage of data by YouTube, on your rights and the privacy options available to be chosen by you, can be found in YouTube's data protection notice.

9. External links

Our Online Offers may contain links to internet pages of third parties, in particular providers who are not related to us. Upon clicking on the link, we have no influence on the collecting, processing and use of personal data possibly transmitted by clicking on the link to the third party (such as the IP address or the URL of the site on which the link is located) as the conduct of third parties is naturally beyond our control. We do not assume responsibility for the processing of personal data by third parties.

10. 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.

11. 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.

11.1 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.

11.2 Right to correction and deletion

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

11.3 Restriction of processing

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

11.4 Data portability

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

11.5 Objection to data processing based on the legal basis of “legitimate 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 “legitimate interest”. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements which override your rights.

11.6 Withdrawal of consent

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

11.7 Right to lodge 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:
Garante per la Protezione dei Dati Personali
Piazza Venezia n. 11
I - 00187 Roma
Phone: + 39 06 696771 Telefax: + 39 06 69677.3785
Email: protocollo@gpdp.it
PEC: protocollo@pec.gpdp.it
Website: http://www.garanteprivacy.it

12. Changes to the Data Protection Notice

We reserve the right to change our security and data protection measures. 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 changes.
If you wish to contact us, please find us at the address stated in the "Controller" section.
To assert your rights please use the following link: https://request.privacy-bosch.com/entity/PTIP/.
To notify data protection incidents please use the following link:https://www.bkms-system.net/bosch-dataprotection.
For suggestions and complaints regarding the processing of your personal data we recommend that you contact our data protection officer:

Data Protection Officer
Information Security and Privacy (C/ISP)
Robert Bosch GmbH
P.O. Box 30 02 20
70442 Stuttgart
GERMANY
or
DPO@bosch.com

Effective date: 2024.09.26