Synced Home Appliance Account Privacy Policy Canada

BSH Home Appliances Ltd., 6696 Financial Drive, Unit 3, Mississauga, ON L5N 7J6 (hereinafter "Home Connect," “BSH,” or "we") is responsible for the collection, processing and/or use of your Personal Information associated with the Synced Home Appliance Account (hereinafter, the "Synced Home Appliance Account").

We collect, process and use your Personal Information, which is either entered by you or otherwise created and processed in the course of using the Synced Home Appliance Account, the associated household appliances or services offered by Home Connect in accordance with the applicable data privacy laws. The following information explains how we treat such data based on the Terms of Use or on another legal basis.

If you do not consent to the processing of your personal information in accordance with this Privacy Policy, please do not register for, access or continue to use the Synced Home Appliance Account or otherwise provide any personal information to us.

This Privacy Policy does not apply to any BSH product or service other than the Synced Home Appliance Account.

1. Types of Personal Information

In terms of the Synced Home Appliance Account, the use of touchpoints where the Synced Home Appliance Account is connected to, the associated household appliances or services and functions offered by Home Connect (hereinafter "Services"). Home Connect collects, processes and uses the following categories of Personal Information.

Home Connect collects, processes and uses the following categories of personal data for itself as well as on behalf of the BSH Group Companies you are interacting with (hereinafter “Home Connect Family“).

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual.

Personal Information that we may collect from you:

a. User master data and usage data

Below we describe how we may collect and use your Personal Information when setting up a user account (registration via SingleKey ID) as well as when setting up the Synced Home Appliance Account. This data is stored into your account and this account is personal and non-transferable.

• When registering with SingleKey ID:

– Access data, i.e. identification data that serves to control access to the SingleKey ID user account and consists of the user ID (e.g. email address or mobile phone number of the user). Responsible for providing this registration service is Robert Bosch GmbH, Robert-Bosch-Platz 1, 70839 Gerlingen-Schillerhöhe, GERMANY ("RBG").

• Additional details that you provide during the registration process including the setting up of the Synced Home Appliance Account (as long as they are not transmitted via SingleKey ID), such as:

– “User Master Data” as

 first and last name,

 salutation

 email address (which is used as the user ID),

– language setting,

– the country in which you operate your Synced Home Appliance Account,

– consent to and recognition of the terms of use,

– acknowledgement of the Privacy Policy,

– information within existing MyAccounts (e.g. your master data, existing orders or service assignments), if those are migrated by you to the Synced Home Appliance Account.

The details requested as part of the registration process may differ from country to country.

• Information which we collect, and store while your use of the Synced Home Appliance Account:

– additional “User Master Data” if and as provided via Home Connect Family touchpoints (e.g. delivery address, phone number),

– “Contractual Data” if and as provided via Home Connect Family touchpoints (e.g. purchase order(s), date of purchase, warranty extensions), as well as service history (e.g. service orders, service technician assignment) of your household appliances as well as related orders of the user (e.g. consumables).

b. Appliance master data

The data we collect and use if you directly buy an appliance via a Home Connect Family entity, register it or otherwise include your household appliance and the user account are as follows:

• brand of the household appliance (e.g. Bosch, Thermador, or Gaggenau),

• serial number and, if applicable, manufacture date of the appliance (so-called E number (full model) and FD (production) number – you can also find these details on the appliance label),

• additional programs (if you have purchased additional programs for your connected home appliance),

• home appliance specific services you have registered for or opted in for (e.g. proactive maintenance),

• data you provide during purchase/registration of your home appliance,

• pairing-status of a Home Connect enabled home appliance.

c. Touchpoint data

The data we collect and use in relation to your usage of Home Connect Family touchpoints are as follows:

• personal information and other content you provide via contact forms or within a service call,

• information about gift/cashback/warranty processes and similar product related information,

• customer satisfaction data, if you participate in a survey,

• website related information, e.g. information of your shopping cart (if you accepted the specific cookie on the relevant website), content you provided via website forms or similar interactions with our website(s),

• anonymised data provided by you via Home Connect Family touchpoints, for statistical use.

d. Permissions and permission related data

The data we collect and use in relation to your permissions given to us and/or a Home Connect Family entity are as follows, whereby your profile information will not be used for marketing purposes without your permission:

• data regarding a (separate) marketing permission given by you (e.g. identifier for the marketing permission, usually your e-mail address, timestamp and touchpoint of your given permission, scope of your permission);

• if you revoke your marketing permission given, we will store the data necessary to process and prove the execution of your revocation by the relevant Home Connect Family entity (e.g. identifier, timestamp and touchpoint of your revocation),

• Home Connect Family brand and communication preferences set in your preference center,

• aggregation of your Home Connect Family touchpoint interactions to better understand your interests (as part a given marketing permission given),

• data provided via such marketing tools, you opted-in to allow them sending data

• to the extent permitted by a separately collected, specific permission, we may also combine the information you provide with other data collected online or offline and use or share it for the marketing purposes described herein.

2. Purposes of use

We use the above-mentioned categories of data

• to provide the login-functionality via SingleKey ID,

• to provide Synced Home Appliance Account features itself as well as the services offered via the Synced Home Appliance Account and or Home Connect Family touchpoints (1.a.-c.),

• for contractual purposes, insofar you use your Synced Home Appliance Account for e.g. the purchase of products, service arrangements and similar contractual interactions (1.a. to c.),

• to improve the Synced Home Appliance Account's user friendliness and for specific or general troubleshooting of the Synced Home Appliance Account and the digital services offered through it (1.a. and c.),

• to improve our range of products and services (including those of Home Connect Family entities), especially with regard to the usage of the features of the Synced Home Appliance Account and your registered household appliance(s), if any (1.b. and c.),

• for marketing and market research purposes including in Synced Home Appliance Account/email messages (1.a. to d.) as far as a corresponding consent is given,

• for notification purposes in case of specific safety instructions and/or recall information in the context of product monitoring (1.a. and b.),

• for general Safety Action purposes your Name, contact details and appliance master data (including customer service transaction data) in a separate "Safety Action" database, e.g. to perform product recalls (1.a. and b.); and

• in anonymized form for statistics on the use of the Synced Home Appliance Account including connected home appliance(s) for use by Home Connect and its affiliates for internal purposes and in the context of general communications, including social media (1.b and c anonymized).

Regarding other data transfers within the Bosch Group associated with the central SingleKey ID, we refer to the RBG Privacy Policy at https://singlekey-id.com/en/data-protection-notice/.

3. General retention periods

We will retain your Personal Information only for as long as necessary to fulfil the purposes for which it was collected or to comply with our legal, regulatory, or other compliance obligations. Provided there are no statutory provisions to the contrary, the following general retention periods shall apply:

a. SingleKey ID: Deletion with deletion of the SingleKey ID user account.

b. User Master Data: Deletion of the User Master Data (including additional User Master Data you provided, if any) as soon as the Synced Home Appliance Account is deleted.

c. Contractual Data: in case of the deletion of the Synced Home Appliance Account or in case of an individual deletion of such data, contractual data will be deleted automatically, if no binding retention period will apply to such contractual data. If there is a binding retention period, as e.g. for tax reasons, the contractual data will be kept for such reasons, but not actively used otherwise and will also not be visible via the Synced Home Appliance Account (e.g. in case you did not ask for deletion of the whole account including all data).

d. Appliance Master Data: Removal of link to you as the user and the Synced Home Appliance Account upon removing the household appliance from the Synced Home Appliance Account.

e. Touchpoint Data: in case of the deletion of the Synced Home Appliance Account or in case of an individual deletion of such data, contractual data will automatically be deleted, if no binding retention period will apply to such contractual data. If there is a binding retention period, as e.g. for tax reasons, the contractual data will be kept for such reasons, but not actively used otherwise and will also not be visible via the Synced Home Appliance Account (e.g. in case you did not ask for deletion of the whole account including all data).

f. Permissions and permission related data: Storage until revocation of the relevant permission, for such data, connected to that permission covered by your revocation.

g. Name, contact details and Appliance master data (including customer service transaction data): Stored in personal form for a period of 30 years in a separate "Safety Action" database, held solely for these purposes, e.g., to conduct product recalls.

If you sell the home appliance, please note that you must reset your home appliance to its factory settings before deleting the SingleKey ID or the Synced Home Appliance Account. If you have allowed the use of a home appliance together with another Synced Home Appliance Account user who does not use their own account, the deletion of your account also triggers the deletion of the other user. If you have allowed the use of a home appliance together with another Synced Home Appliance Account user who uses their own account, please note that the deletion of your account does not trigger the deletion of the additional user at the same time. If you do not want the other user to be able to continue using the home appliance via the Synced Home Appliance Account, please also arrange for the deletion of the other user. If such deletion does not take place, the previously collected appliance master data and appliance usage data will remain available for the additional user.

4. Account management

You can manage your user accounts via the Synced Home Appliance Account and e.g. delete Synced Home Appliance Account data as follows:

• If you use SingleKey ID, the SingleKey ID account will be deleted via the SingleKey ID functions, whereby in addition to the SingleKey ID itself, individual linked applications can also be deleted. If the SingleKey ID is the only access mechanism to the Synced Home Appliance Account/to the central BSH user account, the deletion of the SingleKey ID may make access to the linked services impossible. Therefore, before deleting the SingleKey ID, please check if you still have linked applications/user accounts.

• You can delete your Synced Home Appliance Account via a deletion request via the SingleKey ID management page.

• You can delete your user account also directly within your Synced Home Appliance Account.

• You can delete your registered home appliances – choosing this will lead you to the MyProducts page where you can delete products without deleting the whole account.

• You can manage your personal information, edit your address, and customize your communication preferences via the Synced Home Appliance Account.

• You can opt-out from communication fully or in part via the Synced Home Appliance Account. Choosing this function will lead you to the communication preferences where you can manage your communication preferences.

Based on specific action you choose from the above, you will receive an e-mail communication to confirm your choice(s) and/or deletion request.

5. Transmission or disclosure of your data (e.g., to our service providers)

Information Disclosed to With Our Service Providers

We work together with our Home Connect Family entities as well as various external service providers to create and run the Synced Home Appliance Account and provide the respective services. We secure the data processing within the Home Connect Family entities by an intra group data protection agreement. To the extent that we have bound these external service providers to process data in line with strict instructions in their capacity as data processors on our behalf, any data processing activities undertaken by such providers do not require your consent.

The service providers we have commissioned to create and run the Synced Home Appliance Account are:

• Service providers for hosting services

• Service providers for programming services

• Service providers for hotline services (also if performed via a chat-function or similar communication channels) and other Synced Home Appliance Account services

We only transmit your data to other recipients where necessary to fulfil a contract with you or between you and the third party, where we or the recipient has a legitimate interest in the disclosure of your data, or where you have given your consent to that transmission. These recipients include service providers and other companies within our corporate group. Furthermore, data may be transmitted to other recipients in the event that we are obliged to do so due to legal provisions or enforceable administrative or court orders.

Other recipients of your data are especially such service providers whose offers and services (third-party services) can be used in connection with the Synced Home Appliance Account or where the Synced Home Appliance Account enables access to such services.

6. Data security

We deploy technical and organizational measures to protect your data, for example, from manipulation, loss and unauthorized third-party access. These measures include the use of encryption technologies, certificates, firewalls on the Home Connect servers and password protection in the Synced Home Appliance Account.

7. Scope of application

This Privacy Policy shall apply for the functions and services offered by Home Connect via the Synced Home Appliance Account. Insofar as additional functions or services are offered within the Synced Home Appliance Account by Home Connect or a BSH Group company, special information on data protection is provided, insofar as their use is subject to special data protection regulations or information.

However, this Privacy Policy shall not apply for third-party services, even if Home Connect facilitates the use of and/or access to such third-party services in the Synced Home Appliance Account (please see the terms of use with regard to third-party services). The use of such third-party services is governed by the prevailing data protection provisions put in place by the third-party service provider and, if applicable, additional data protection information on our part which outline the distinctive features of these third-party services and shall only be relevant in this regard.

If you are referred to another service provider, Home Connect shall make reasonable and appropriate efforts to elucidate such referral (e.g. by embedding the service provider's content within the Synced Home Appliance Account using inline frames) if such referral is not clear. If you click on a link in the Synced Home Appliance Account which calls up a Synced Home Appliance Account or website of another service provider, this is considered to be a clear referral.

8. Changes to the Privacy Policy

As the Synced Home Appliance Account and the services provided via the Synced Home Appliance Account continues to undergo development – among other things, through the implementation of new technologies or the introduction of new services – this Privacy Policy may need to be adjusted accordingly from time to time. Home Connect shall reserve the right to amend or supplement this information as required. Home Connect may update the Privacy Policy for the Synced Home Appliance Account from time to time.

9. Rights and contact information

If, despite our efforts to only store data which is correct and up-to-date, your personal details are stored incorrectly, we shall correct such information upon your request. In case you gave us your consent for the collection, processing and use of your personal data, you may withdraw such consent at any time with effect for the future. Consent may generally be withdrawn by termination of the Synced Home Appliance Account itself or individually through the contact information referred to in the Synced Home Appliance Account.

Your personal data will be deleted if you withdraw your consent to your data being stored, if your personal data is no longer needed to serve the purpose pursued by such storage or if such storage is inadmissible for other legal reasons. Please bear in mind that, for technical or organizational reasons, there may be an overlap between you withdrawing your consent and your data being used, e.g. in the case of a newsletter which has already been sent out. Data required for billing and accountancy purposes or which are subject to the legal duty to preserve records are not affected by this.

Should you have any questions on the topic of data protection or should you wish to exercise your rights to withdraw consent or your rights to information, rectification, deletion or suspension, please contact us using the contact information provided in the Synced Home Appliance Account.

Notice of Information We Collect

This serves as notice of the categories of Personal Information that we collect through the Synced Home Appliance Account and the specific commercial purposes for which the Personal Information was collected. Please see Section 2 for the specific commercial purposes for which Personal Information was collected, and Section 3 for the general retention periods of such collected Personal Information.

Please note that all of the categories of Personal Information we collect about you (as detailed below) come from the following categories of sources:

• You, including through your use of our services

• Automatically collected from you

• Our affiliate companies

• Third parties

In particular, we may have collected the following categories of Personal Information from users within the last twelve (12) months (please also refer to Section 1 for more details):

• Contact Information: such as your name, salutation, and email address;

• Appliance Information: information regarding your BSH appliance, such as brand of household appliance, serial number, manufacture date of appliance (if applicable), and other appliance-related services or programs (if applicable).

• Touchpoint data: information related to your usage of Home Connect Family touchpoints, including any personal information you provide to BSH via various means, such as service call, contact forms, surveys, website forms, and information about gift/cashback/warranty processes and similar product related information.

Categories of Personal Information that have been disclosed for a business purpose

In the past 12 months, we have disclosed the following categories of Personal Information for a business purpose to the third parties listed below:

Categories of Personal Information shared Categories of third parties that have received such information

• Contact Information: such as your name, salutation, and email address;

• Appliance Information: information regarding your BSH appliance, such as brand of household appliance, serial number, manufacture date of appliance (if applicable), and other appliance-related services or programs (if applicable).

• Touchpoint data: information related to your usage of Home Connect Family touchpoints, including any personal information you provide to BSH via various means, such as service call, contact forms, surveys, website forms, and information about gift/cashback/warranty processes and similar product related information. Our affiliates

• Contact Information: such as your name, salutation, and email address;

• Appliance Information: information regarding your BSH appliance, such as brand of household appliance, serial number, manufacture date of appliance (if applicable), and other appliance-related services or programs (if applicable).

• Touchpoint data: information related to your usage of Home Connect Family touchpoints, including any personal information you provide to BSH via various means, such as service call, contact forms, surveys, website forms, and information about gift/cashback/warranty processes and similar product related information. Service providers: We use various services providers that help provide you with the Services offered in the Synced Home Appliance Account as well as provide feedback on improving Synced Home Appliance Account. Such service providers can only use Personal Data to provide such services to us and for no other purpose.

• Contact Information: such as your name, salutation, and email address;

• Appliance Information: information regarding your BSH appliance, such as brand of household appliance, serial number, manufacture date of appliance (if applicable), and other appliance-related services or programs (if applicable).

• Touchpoint data: information related to your usage of Home Connect Family touchpoints, including any personal information you provide to BSH via various means, such as service call, contact forms, surveys, website forms, and information about gift/cashback/warranty processes and similar product related information. Public authorities and legal proceedings: BSH may disclose Personal Data about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the App; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

• Contact Information: such as your name, salutation, and email address;

• Appliance Information: information regarding your BSH appliance, such as brand of household appliance, serial number, manufacture date of appliance (if applicable), and other appliance-related services or programs (if applicable).

• Touchpoint data: information related to your usage of Home Connect Family touchpoints, including any personal information you provide to BSH via various means, such as service call, contact forms, surveys, website forms, and information about gift/cashback/warranty processes and similar product related information. Parties to a corporate transaction or proceeding: In the event of a corporate sale, merger, reorganization, bankruptcy, dissolution or similar event, Personal Data may be part of the transferred assets.

10. International Users

If you visit, register for or use the Synced Home Appliance Account, you may be transferring your personal information to BSH’s parent company in the U.S. and other related entities including its ultimate parent company in Germany. By visiting, registering for or using the Synced Home Appliance Account or providing your information to BSH, you consent to the transfer of your personal information to Germany, and our handling of your information in accordance with applicable German and U.S. requirements and this Privacy Policy. Accordingly, your personal information may be accessible to courts, law enforcement and national investigation authorities in the United States as well as in Germany.

If you are a Quebec resident, your personal information may be transferred outside of Quebec. We assess such transfers to ensure that your personal information is adequately safeguarded.

You can obtain information about BSH’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 Canada Privacy Officer as described below.

11. Your Rights – Canada

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

a) Right to withdraw consent: The right to withdraw your consent to the collection, use or disclosure of your personal information. However, doing so may preclude entitlement to particular services.

b) Right to be informed: 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).The right to acquire information about BSH’s policies and practices with respect to personal information, including: a description of the type of personal information held by BSH 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.

c) Right to request information on automated decisions: The right to request information when your personal information is being used to make a decision exclusively based on automated processing, without human intervention. This includes being informed of the personal information used to make the decision, the reasons behind the decision and the key factors and parameters that influenced it.

d) Right to Access: The right to request access to a copy of the personal information we retain about you.

e) Right to data portability: The right to request, to receive a computerized personal information collected directly from you in a structured, commonly used technological format or request that this information be provided to a third party authorized by law to receive it.

f) Right to request rectification: The right to challenge the accuracy and completeness of your personal information, and have it amended, updated or rectified as appropriate.

g) Right of de-indexation: The right to request that we stop sharing/disseminating your personal information or de-index any hyperlink attached to your name that provides access to your information by technological means, if the dissemination of the information contravenes the law or a court order.

h) Right to make a complaint: The right to challenge BSH’s compliance with the applicable Canadian Privacy Laws.

You may submit a verifiable consumer request to us for disclosure or deletion of Personal Information by contacting us at bsh-us-dataprotection@bshg.com or submitting a request at https://datarequest.bsh-group.us/en/form?c=us.

Alternatively, you may call us at our toll free number at (855) 769-1755.

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. 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.

We strive to respond to verifiable consumer access or rectification requests, as applicable, within thirty (30) days of its receipt, or sooner where required by applicable Canadian Privacy Laws. If we require more time, where permitted by applicable law, we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your verifiable consumer request or access request, 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.

If you have any questions, concerns or are unhappy with the outcome of your request to exercise one of your rights outlined above and wish to appeal our decision, you can contact our Canada Privacy Officer through the contact information listed below.

12. Children’s Privacy

We do not knowingly collect or use any personal information relating to the Synced Home Account Appliance from anyone under the age of sixteen. If we discover or are notified that we have collected such personal information from a person under 16, we will delete that information from our systems.

13. 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.

14. Contact Us

You may address any questions, concerns or requests around the use of your Personal Information by contacting our Canada Privacy Officer at to bsh-us-dataprotection@bshg.com or call our toll-free number at 855-769-1755.

Please include your name, address, and phone number or email in all communications and state clearly the nature of your request.

You may also direct a complaint concerning compliance with the Privacy Policy to our Canada Privacy Officer. The complaint must be in writing. Within a reasonable time of receipt of the complaint, an investigation into the complaint may be conducted depending on the nature of the complaint. The format of this investigation will also vary depending on the circumstances and the nature of the complaint.

After any investigation into the complaint, Home Connect may take appropriate measures necessary to rectify the source of the complaint if it is necessarily required.

Date of issue: December 2024