Privacy statement

Freud S.p.A. Società Unipersonale (referred to below as "Freud" or "we") would like to thank you for using our websites and mobile applications and for your interest in our company and products.

1. Freud respects your privacy
We respect your privacy and we are committed to protecting it in accordance with applicable law.
This statement reflects the culture of our Group and demonstrates its desire to promote the collection and use of your fair, responsible and secure data.

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 and processing of personal data
Personal data is detailed information concerning the personal or material circumstances of an identified or identifiable individual, for example, names, postal addresses, phone numbers, e-mail addresses, photos or other information about an identified or identifiable person.
We collect, process and use personal data (including IP addresses) only if there is a legal basis for doing so, or if you have declared your consent to the aforementioned parameters, for example, as part of registration, a survey, or for the purposes of contract performance.

4. Purpose and legal basis
Your data is collected for the following purposes and on the following legal basis:
• Client management (legal basis: contract)
• Surveys, surveys on products and services (legal basis: consent / legitimate interest)
• Requests for information (legal basis: consent)
• Technical maintenance of sites (legal basis: legitimate interest)
• Advertising, marketing communication (legal basis: consent, legitimate interest)

5. Transmission of data
5.1 Transmission of data to other data controllers
We may communicate your personal data to other entities of the Bosch Group and / or other controllers in accordance with the purposes and legal basis on which the processing is based (e.g. legitimate interest, consent, contract).
In addition, we may communicate your personal data to other data controllers within the framework of a legal obligation or even in the event of administrative or judicial requisition.
In any event, you will be kept informed through our present Privacy Policy, in particular in Sections 4. Purposes and legal basis and 5. Data transmission.

5.2 Service providers
We may entrust certain missions to service providers such as sales, marketing, programming, data hosting and hotline services.
The choice of these service providers is made with the utmost care and we undertake to regularly monitor the way in which the data that we entrust to them and that are stored on their premises are processed and secured.

5.4 Transmission to recipients outside the European Economic Area (EEA)
We may also transmit your data to recipients outside the European Union, called third countries.
In this case, we make sure, before the transfer, that the third country has an appropriate level of data protection (eg on the basis of an adequacy decision validated by the European Commission or standard contractual clauses) or on the basis of your consent.
You can obtain the list of recipients located in third countries and a copy of the contractual provisions ensuring an appropriate level of data protection. Please refer to Section 2. Data controller.

6. Use of cookies
6.1 General
Cookies are small text files which are stored on your computer. These files are used to determine whether your terminal device has already communicated with our sites. By reading the cookie data we can design our websites to suit you and make them easier for you to use.

6.2 Freud cookies
Freud uses cookies and active components, such as JavaScript, to keep track of visitors’ preferences and optimize the design of the websites accordingly.

6.3 Third-party providers’ cookies
Content and services from other providers (e.g. YouTube, Facebook and Twitter), which may use cookies and active components, are integrated into some Freud websites.
Freud has no control over how these providers process personal data. We invite you to contact third party sites for more information on their Privacy and Cookie Policies.

6.4 Disabling and deleting cookies
Whenever you visit our websites, you are asked in a cookie-layer pop-up whether you want to allow the cookies used on our site or disable them in the settings, with the exception of cookies necessary for the proper functioning of the site.
If you decide not to allow cookies, an opt-out cookie is set in your browser. This cookie is used solely to record your objection.
However, if you disable cookies some functions of our websites may no longer be available to you.
Please be aware that for technical reasons an opt-out cookie can be used only for the browser by which it was set. If you delete the cookies or use a different browser or terminal device, you need to repeat the opt-out procedure.
On the other hand, the settings option does not cover the cookies set by other providers when you visit third-party websites. However, you can delete all cookies at any time via your browser.
Please refer to the help functions in your browser for information. However, if you do delete cookies, some functions may no longer be available to you.

7. Use of analysis tools
7.1 Freud measures website access using web analysis tools such as Google Analytics and Tealium.

7.2 When selecting analysis tools, we take care to ensure that they capture access data only in anonymised form so that no link can be established to a user. In particular, this is achieved by anonymising the IP address. Cookies are used for measuring purposes so that website usage can be analysed. In particular, this allows Freud to improve data quality. The information derived on usage of the websites is sent to the statistics server (wts.bosch.com) operated by Bosch Italia in Germany. Only authorised persons are granted access to this anonymised data.

7.3 If you do not want the analysis cookies in question to be used, please follow the instructions in section 6.4.

8. Advertising
We use your data for the purposes of marketing communication about our products and services, surveys for the purpose of improving our products and services on the basis of your consent.
You have the right to withdraw your consent at any time, your data will be deleted in accordance with the GDPR unless otherwise specified by law.

9. Use of external links
Freud websites may contain links to websites of third-party providers with which we have no association. After you have clicked the link, we have no further control over the collection, processing and use of any of the personal data (such as IP address or URL of the page containing the link) transmitted to the third party when the link is clicked, since the conduct of third parties is clearly beyond our control. Freud assumes no responsibility for the processing of such personal data by third parties.
We invite you to contact third party sites for more information on their Privacy and Cookie Policies.

10. Security
10.1 All of our employees and service providers are subject to an obligation of confidentiality and compliance with the applicable data protection legislation.

10.2 We take all the technical and organizational measures necessary to ensure the security and protection of your personal data and to prevent the risks of accidental or illegal destruction, manipulation, loss, modification, disclosure or unauthorized access, in accordance with the state of the art.

11. User rights
In accordance with the regulations in force relating to data protection, you have rights over your personal data. When exercise your rights, please ensure that we can clearly identify you.

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, deletion and update
You have the right to obtain from us the rectification of your inaccurate personal data, their updating as well as their erasure to the exclusion of data subject to legal prescription, in particular billing or accounting data.
In this case, processing will be restricted (see below).

11.3 Right to restriction
You have the right to obtain from us the restriction of processing in the cases which are exhaustively provided for by law.

11.4 Right to object to processing
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.
In the latter case, we will terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements which override your rights.

11.5 Right of withdrawal
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.
However, this withdrawal is likely to make you lose the right to browse our Site, in the event that the processing is based exclusively on the consent of the user.

11.6 Right to 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.

11.7 Right to give directions on the fate of his data
You have the right to define directives relating to the storage, erasure and communication of your personal data after your death.
You therefore have the right to organize the fate of your post-mortem data in compliance with article 85 of the Data Protection Act.

11.8 Right to lodge a complaint
You also have the right to lodge a complaint with the supervisory authority, the CNIL (Commission Nationale Informatique et Libertés), at the following postal address: CNIL, 3 place de Fontenoy TSA 80715, Paris (75334) or by email: https://www.cnil.fr/fr/agir

12. Updating
We may update our privacy policy in light of technical and technological progress.

13. Contact
If you would like to contact us, you can use the address given in Section 2 “Data Controller”.
Please use the following link to exercise your rights and report data protection incidents:

For suggestions and complaints with regard to how your personal data is processed, we recommend that you contact our Data Protection Officer:
Group Data Protection Officer
Bosch Group Information Security and Data Protection (C / ISP)

Robert Bosch GmbH
Postfach 30 02 20
70442 Stuttgart
mailto: DPO@bosch.com

14. Effective date of the Privacy Policy
This privacy policy has been in effect since February 28, 2020.