1. General

It is our policy to respect the privacy statement of our customers, and to comply with the regulations and requirements of Personal Data (Privacy Statement) Ordinance, Cap. 486 of the Laws of Hong Kong (the “Ordinance”) to process any personal data which you may supply to us.

By accessing and/or using our websites, including at BSH’s website: www.bsh-group.com , Siemens’ website: www.siemens-home.com.hk and Bosch’s website: www.bosch-home.com.hk (collectively “our Websites”) you as the user shall be deemed to have accepted and agreed to the terms of this Privacy Statement. You should discontinue access to and the use of the website in the event that you do not agree with any of the terms and conditions of this statement.

2. Personal Data

We hold your personal data, including names, addresses, email addresses telephone numbers, together with other personal data which may be necessary for the provision of our services or helps us personalize and continually improve our services.

All requested data will be collected on a voluntary, open and fair basis. Whilst you are entitled to refuse to provide any of the requested data, incomplete disclosure may prevent us from providing facilities and services to you.

Thus it is important that you inform us immediately of any inaccuracies of or changes to the personal data supplied.

In some instances, you may also be requested to provide on a voluntary basis, amongst others, the following personal data that may be used to further improve our products and services and/or better tailor the type of information presented to you: -

(1) age;

(2) gender;

(3) household income range;

(4) other related products and services subscribed to;

(5) education and profession.

3. Cookies, Analytics, Marketing and Tracking

(1) Analytics

Analytics refers to the process of collecting, processing, and analysing data to gain insights and make decisions. For us, it's like examining patterns and trends to better understand how our products and services are used by you. This insight allow us to make our products and services more user-friendly. It also enables us to identify areas for improvement and innovation in our products and services. Our websites integrate with analytics platforms (e.g., Adobe Analytics). These platforms provide JavaScript code that is added to the website. This code interacts with cookies or similar technologies to collect data when users interact with our website. As users navigate the website, the analytics code collects data from the cookies/pixels. This data we collect includes information on page views, clicks, time spent on pages, and other relevant metrics.

Analytics platforms aggregate the collected data, providing us with insights into user behaviour and website performance. This aggregated data is used for understanding audience demographics, popular content, and areas that may need improvement.

(2) Marketing and Tracking (including Re-Marketing)

We may collect and use your personal data to send you relevant marketing communications. These communications could include product updates, promotional offers, and newsletters. You can easily manage your communication preferences and opt out if desired.

We also carry out digital marketing activities including retargeting. Retargeting, also known as remarketing, means showing targeting ads to users who have previously interacted with Our website or digital content but did not complete a desired action, such as making a purchase.

When a user visits our website and takes specific actions (e.g., views a product, adds an item to the cart), a tracking pixel or cookie is placed on their device. This allows us to show targeted ads to these users as they browse other websites or social media platforms, encouraging them to return to our website.

Please see Section (6) for more information on the providers including information about the specific usage and additional information on provider-specific data protection aspects.

(3) Cookies and similar Technologies

When you visit our website cookies or a so-called pixel-code/web beacon as well as similar technologies can be used by us. These technologies will allow us to interact with your browsing device as follows:

• Cookies are small text files that are stored in a special memory area of your browser which enable us to identify you when you revisit our website.

• Web beacons are tiny graphic files that contain a unique identifier that allows us to recognize user activity such as how often you have visited our website.

• We may also use direct server side solutions and similar technologies to measure the usage of our websites as well as the reach of our advertisements.

• Cookies and similar technology may be used for a variety of reasons such as making the website work or show you personalized content and advertisement.

(4) Profiling (based on Permission)

We offer you the option to enable profiling, which allows us to personalize your experience and provide you with tailored content. We want to ensure transparency and give you control over how your personal data is used. Profiling involves the automated processing of your personal data to analyse and predict your characteristics, preferences, behaviour, or interests.

By enabling profiling, we can better understand your needs and deliver a more customized experience based on such information and to enhance your experience on our website. This includes personalizing recommendations, delivering targeted advertisements, and improving our services based on your preferences.

To create your profile, we may collect and analyse various types of data, such as your browsing history, search queries, location information, and demographic details. You can find a comprehensive list of the data categories we utilize if you agreed in profiling in Section XIV, located at the end of this document. Rest assured that we handle your data with utmost care and in accordance with applicable data protection laws.

Our profiling activities are based on your consent, which you can freely give or withdraw at any time. We also rely on our legitimate interests in providing you with a tailored and relevant experience. You have the right to control your data and profiling preferences. You can choose to enable or disable profiling through your account settings or privacy preferences. Additionally, you can exercise your data protection rights, including the right to access, rectify, or delete your personal data at any time.

We may share your data with trusted third parties for profiling purposes. However, we only do so with your explicit consent or when necessary to provide our services. We ensure that appropriate safeguards are in place to protect your data when shared with these parties.

Please see Section (6) for more information on the providers including information about the specific usage and additional information on provider-specific data protection aspects.

(5) Cookie Handling, Tools and their providers

You can find a comprehensive list of the marketing and analytics tools we utilize in Section (6), located at the end of this document. This section not only provides the names of the tools but also describes the type of data processing conducted by each respective tool or provider.

(6) List of the Third party providers and their use

• Facebook and Instagram including WhatsApp and Facebook messenger is provided by the following entities:

  • for countries in the European region: Meta Platforms Ireland Limited, Merrion Road Dublin 4 D04 X2K5, Ireland

• Meta is providing the following services:

  • as social media provider
  • providing chat functionality via WhatsApp and Facebook Messenger
  • Facebook Pixels and Custom Audiences, where For Facebook Pixels and Custom Audiences, Facebook processes your data under a joint responsibility with us, in accordance with the contract we concluded with Facebook on our joint responsibility. We do not have access to your individual tracking data processed by Facebook as Facebook provides us with aggregated data only. We may share this aggregated data with third parties, e.g. cooperation partner for marketing purposes.The essence of this contract is available here: https://www.facebook.com/legal/controller_addendum

• Adobe is providing several services which are used or can be used via our websites. These services are provided by Adobe Systems Software Ireland Ltd., 4-6 Riverwalk, Citywest Business Park, Dublin 24, Ireland ("Adobe”). You can find additional information about how Adobe Analytics cookies work and the opt-out option via the following link: http://www.adobe.com/privacy/opt-out.html We use the following services:

  • for web analytics we use Adobe Audience Manager und Adobe Tracking being part of the Adobe Marketing Cloud: The information relating to your use of our website is transferred to Adobe servers, analyzed and solely returned to us as cumulative data. This data allows us to identify trends in how the website is generally used. We do not conflate the resultant usage profiles with your name or any other details that could disclose your identity, such as your e-mail address. The usage data is stored by the service used for a maximum duration of 37 months from the date on which it was collected.
  • for A/B testing we use Adobe Test & Target: Adobe Test & Target works on the basis of A/B tests. This means that the person using our website is shown a different version of the website from the original (e.g. with altered design and content). Comparing both versions provides us with information about which version of our website is preferred by users. When Adobe Test & Target is used, the only information relating to you that is processed cannot be used to identify you. IP anonymisation is also activated, meaning that your IP address is shortened before Adobe Test & Target carries out any further processing. We do not conflate the usage profiles resulting from this with your name or any other details that could disclose your identity, such as your e-mail address. The usage data is stored by the service used for a maximum duration of 37 months from the date on which it was collected. You can also use the following link if you wish to prevent your usage data being collected: http://bsh.tt.omtrdc.net/optout

Google is providing several services which are used or can be used via our websites. These services are provided via several brands or tools, which we describe in more detail below. In general these services are provided by the following entities:

  • for countries of the European Union (EU), the European Economic Area (EEA) and Switzerland: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
  • for other countries including UK: Google LLC (formerly Google Inc.), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

You can find general information on how personal data is processed when Google tools are used via the following link https://policies.google.com/privacy. Opt-out: To permanently prevent the collection of usage data, Google offers a plugin for various Internet browsers: http://www.google.com/settings/ads/plugin. To disable only interest-based ads, you can block the use of third party cookies or cookies from the "www.googleadservices.com" domain or disable interest-based ads using this link at https://support.google.com/ads/answer/2662922?hl=en-GB

We are using the following Google tools in the following specific way:

  • YouTube for the presentation of videos on our websites. If you declined the use of cookies via the cookie banner, you may be ask to consent separately for consent before the display of such videos on our website. Only if you consented, any possible data transfer will start.
  • YouTube as social media provider, where we present videos on different YouTube Channels. Please see the privacy information stated above when using such channels.
  • Google reCAPTCHA: In order to protect your website interactions, such as logins or registrations, it performs risk assessments on website users, we use Google reCAPTCHA for these purposes. These assessments use cookies and collect personal information. However, Google may only set cookies and use personal information with users' prior consent, which can be given via the Cookie Layer.
  • Google Maps as service for location and mapping services, whereby only such data is used, you provide in using that service. A proximate location is used to show e.g. partners near your location or verify the postal code for service requests.
  • Google GA4 Technology is used by us (only if you gave your cookie consent), to implement server side tracking as similar technology to cookies. In using that tool, we do not send usage data or similar data to Google, but use the tool to send information of the website use to our servers. This data is processed by us and does not allow any individual identification of you or your device, you use the website/service from.
  • Google Tag Manager (GTM) is a tool used by us enabling us to manage and deploy marketing tags on websites without code modification. Tags include analytics and tracking codes, providing insights into website performance and user behaviour. While GTM itself doesn't set cookies, tags deployed through it may use cookies for tracking.
  • We use online marketing tools from Google on our own responsibility. The cookies used in this service generally lose their validity after 30 days and are not intended to identify you personally. Google merely provides us with statistical evaluations. Google processes your information in accordance with Google's data usage policy.
  • Opt-out: To permanently prevent the collection of usage data, Google offers a plugin for various Internet browsers: http://www.google.com/settings/ads/plugin. To disable interest-based ads, you can block the use of third party cookies or cookies from the "www.googleadservices.com" domain or disable interest-based ads using this link at https://adssettings.google.com/authenticated?hl=en_GB
  • Interest ads can also be deactivated via the link http://www.aboutads.info/choices if the provider has joined the self-regulatory campaign "About Ads".

• Google Ad Server We use online marketing tool (formerly DoubleClick) of Google. The usage data will be deleted after 540 days from the time of collection. For more information about DoubleClick, please visit https://support.google.com/admanager/answer/6022000?hl=en, We use online marketing tools from Google on our own responsibility. To this end, we have agreed with Google in a data protection agreement that our customers' data may only be processed on the basis of our instructions, may not be passed on to third parties and must be sufficiently technically protected.

4. Internet Protocol Address

We may use your internet protocol (IP) address to help diagnose problems with our server and to administer or Websites.

Your internet protocol address may be used to identify you and to gather broad demographic information on the website visitorship for our analysis and strategic planning.

Most browsers are initially set to accept cookies.

If you would prefer, you can set your browser to disable cookies or inform you when they are set. However, by disabling them, you may not be able to take full advantage of our Websites.

5. External Links

Our Websites may contain links to various other websites for whose content, management and privacy statement practices made, released and maintained independently by other parties we shall not be responsible in any manner howsoever.

6. Purpose

From time to time it is necessary for customers to supply us with data in connection with the opening or continuation of customer accounts and the provision of other related facilities and services.

The purposes for which data may be used are as follows:

(1) identifying you when you access and/or use our Websites;

(2) daily operation of our services;

(3) maintaining or updating your personal details to facilitate you in using our services;

(4) handling customer complaints and enquiries;

(5) enabling us to improve the scope and quality of our home appliance products under the brands “Siemens” and “Bosch”, etc. and the services related thereto, including without limitation, installation and maintenance;

(6) conducting customer, product and service surveys;

(7) marketing and promotion of our home appliance products under the brands “Siemens” and “Bosch”, etc. and the services related thereto;

(8) subject to the requirement of the Ordinance, direct marketing of products and services as described in Paragraph 7 below;

(9) enabling compliance with all applicable laws and regulations in Hong Kong and elsewhere;

(10) enabling us to discharge our obligations to you and/or regulators, and/or any other purposes to which you may from time to time agree.

7. Direct Marketing

We intend to use your data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. In this connection, please note that: -

(1) your name and contact details (including address, contact numbers and email address) held by us from time to time may be used by us in direct marketing;

(2) the following classes of services, products and subjects may be marketed: -

(a) home appliances under our brands, including “Siemens” and “Bosch” and related services (including installation and maintenance);

(b) reward, loyalty or privileges programs;

(3) the above services, products and subjects may be provided by us.

Should you desire not to wish us to use your personal data for use in direct marketing, you may exercise your opt-out right by writing to: BSH Home Appliances Limited at Unit 07, 23/F, CDW Building, 388 Castle Peak Road, Tsuen Wan, New Territories, Hong Kong stating your name, address and contact telephone numbers. We shall update our records and shall cease to use your personal data for the purposes of direct marketing. No charge shall be levied on such request.

8. Transfer of Personal Data

We may, to the extent necessary for achieving the above purposes or any of them, make such enquiries as we consider necessary to confirm the accuracy of your personal data and in particular, we may disclose, obtain, transfer (whether within or outside Hong Kong) your personal data to, from or with any and all of the following persons and entities: -

(1) any agents, contractors or third-party service providers who offer administrative, telecommunications, computer, transportation, installation, maintenance or other services to us in connection with the operation of our business;

(2) the media (related to the handling of customer complaints and enquiries in certain circumstances);

(3) any regulatory or governmental bodies.

9. Access and Correction of Personal Data

As a data subject, you have a right under the Ordinance to check whether BSH Home Appliances Limited holds personal data on you, to obtain a copy of that data and to correct any data relating to you which in inaccurate. Requests for access to data or correction of data should be in writing and made to: -

Addressee : BSH Home Appliances Limited

Address : Unit 07, 23/F, CDW Building, 388 Castle Peak Road, Tsuen Wan, New Territories, Hong Kong

Fee may be charged towards administrative expenses in complying with access requests.

10. Amendments

We may amend or update this Privacy Statement from time to time and all information will be governed by our most recent Privacy Statement, available on our Websites.

BSH Home Appliances Limited

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