This Privacy Notice was last updated on August 10, 2021.
This Privacy Notice applies to the trial version of the Daily Care app, which will be used for Home User Testing (HUT) purposes.
The Daily Care app provides you with personalized services in the personal health domain (“Services”). Subject to your choices and your region, the app may process personal data from different Philips products that have capability to connect to the app (“Product”).
The purpose of this Privacy Notice is to help you understand our privacy practices when you use our Services, including what information and personal data we collect, why we collect it, and what we do with it, as well as your individual rights.
The controller of your personal data under this Privacy Notice is Philips Consumer Lifestyle B.V. with address at High Tech Campus 5, 5656 AE, Eindhoven, The Netherlands ("Philips", "our", "we" or "us").
What information and personal data do we collect and for which Purposes?
We receive or collect information and personal data, as described in detail below, when we provide our Services, including when you access, download, install the Product or the app, or use our Services. We associate your personal data with unique identifiers. We may use this personal data as specified below and in general to perform the Services based on your consent or as requested by you as a contractual necessity, to operate, provide, improve, customize, support, and market our Services based on our legitimate interest, or to comply with a legal obligation to which we may be subject. If you do not want us to collect and process your personal data, you may not be able to use the Services.
You may login to the app using a Philips account or by using your social media profile, including your Apple account. The personal data we collect may include your name, email address, country, language and password. We also process information on your app usage, including your session, login and authentication information, which we use to manage your account.
If you choose to log in via social media, the personal data we collect may include your basic public profile (e.g., profile photo, identifier, gender, profile URL, birthday, homepage, and location) and email for authentication purposes. In this case, your social media provider may collect information on the fact that you are using the app and logging in using your social media account. Please read your social media provider’s Privacy Notice (e.g., Facebook, Google, Apple) to learn about their privacy practices, including, what type of personal data they collect, and how they use, process and protect them.
We use your Account Data to create and manage your account and provide personalized Services. You can use your account to securely login to the app. If you create a Philips account to login to the app, we will send you a welcoming email to verify your username and password, to communicate with you in response to your inquiries, to send you strictly service-related announcements, or direct marketing communications in case you have provided consent. You may also use your Philips account to order a Philips product or service, participate in a promotion or game, participate in a social media activity related to a Philips promotion (for example clicking "like" or "share"), and participate in product testing or surveys.
Sensitive personal data
When using the app, you may provide us with sensitive information, such as details about your lifestyle and wellbeing. We may also collect personal data from the Products you decide to use in combination with the app. This section details the types of sensitive personal data collected based on the features you interact with and the nature of the Products you pair with the app. We will update this section as soon as we enable new Products and features.
- Male Grooming. Subject to your choices, we securely store your shaving and styling data in your account so that you can easily re-store it if you install the app on another device. We also use your data to provide you with a personalized shaving and styling experience via for example, customized coaching programs and other services. The data processed includes your: Shaving details, including your shaver’s information, such as model, serial number, session and usage data, and CleanPod fluid usage; as well as shaving frequency and duration; Skin and facial hair details, including skin or facial photos you upload to the app; your skin and hair profile, color and type; as well as your skin care routine and skin issues; Lifestyle and well-being details that you enter in the app, including routine, stress, sleep and environment; and your style preferences; app usage patterns and mobile device details; and your Answers to our personalization questions. Based on your settings, we may send you emails, push notifications, in-app content and in-app messages. We may also combine, pseudonymize, anonymize or aggregate your data for personalization purposes. If you use the Skin Analyst Sensor (for your iPhone), the iPhone records a detailed picture of your skin and sends it to the app. This photo is stored on your iPhone.
Other than provided above, we ask you not to send or disclose any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religious, philosophical or other beliefs, health, sex life or sexual orientation, biometrics or genetic characteristics, criminal background or trade union membership) to us, on or through the app, or by any other means.
Subject to your choices, you can help us improve the app and our connected products (as well as develop new personal health solutions for you!) based on the data we observe and collect when you use our services. We do so by:
- Assessing how you use the app and how the app performs on your mobile device, including when the app crashes to identify and fix issues
- Implementing and analyzing changes or features across different groups to understand interactions
- Evaluating how the app is accessed and used and directly link you to specific app sections
- Interacting with you to obtain your feedback, supporting you when required, and sending you service-related communications
- Inviting you to participate in surveys or research projects organized by the Philips group and recording your answers and responses
We may also use these insights to further personalize our services. Based on the data we observe when you use the app and your connected product, we will try to understand which usage patterns lead to certain interactions with the app, like reading a specific app article, buying a product, staying engaged with the app or developing conditions that are relevant to the product you are using. We will use these insights to create rules on what content to show to which users, and use this information to ultimately improve the algorithms used to provide personalized services. If you login to the app with your Philips account, we will use these insights to personalize your experience based on your app usage patterns.
We may combine your personal data, including account data, with data collected during your interactions and usage of the Philips digital channels such as social media, websites, emails, apps and connected products, including your IP addresses, Cookies, mobile device information, communications you click on or tap, location details, and websites you visit.
We may analyze your Combined Data to improve the content, functionality and usability of the app, Product(s) and Services, as well as to develop new products and services in the mother and childcare domain. We may aggregate your Combined Data, removing individual personal data, in order to create publications, presentations, reports or other (marketing) communications, which we can use for both internal and external purposes.
Ratings and reviews data
If you write a review or rate the app on the app stores, we may process such information to respond to your comments and questions, understand how you feel when using the app, get familiar with your general perception of the app and our brand, and use these insights to improve the app. We can only see your app store username, ratings, comments and any other detail you decide to share with us or make publicly available. Unless you require us to do so, we do not link this information to your account credentials or any other information we hold from you. When you require customer support, we may use your data to follow-up on your case and guide you through our customer support process in accordance with section Customer support data further below.
Customer support data
When you require customer support, we may ask you to provide us with information related to your use of our Services, including your interaction with Philips, and how to contact you so we can provide the required support. We operate and provide our Services, including providing customer support, and improving, fixing, and customizing our Services. We also use your information to respond to you when you contact us.
If you consent to receive promotional communications about Philips products, services, events and promotions that may be relevant to you based on your preferences and online behavior, we may send you marketing and promotional communications via email, phone and other digital channels, such as mobile apps and social media. To be able to tailor the communications to your preferences and behavior and provide you with a more relevant and personalized experience, we may analyze and combine your personal data. You revoke your consent and unsubscribe from such communications at any time.
Cookies and device information
The app may request your permission to access your mobile device’s storage capabilities, sensors or other features. We require access when strictly necessary to provide the Services as detailed below.
- Bluetooth and WIFI. The app requires WIFI connection to connect to the internet. The app also needs Bluetooth/WIFI to connect your Device(s) to the app. You can at any time block Bluetooth/WIFI connection through the settings of the mobile device.
- Location. To connect and use any Bluetooth device with your phone, Android 6.0+ requires location access to enable Bluetooth functions. The app does not use these permissions to determine your location, nor does Philips collect your location data. You can revoke location permissions at any time in the settings of your mobile device.
- Files. The app requires access to the mobile device's files to store the language configurations and other files that the app uses to operate (e.g., manuals, graphics, media files, or other large program assets). If you delete the app, the Files will be deleted from your mobile device.
- Photos and Media. If you add a picture to your profile, the app requires permission to access your mobile device's camera or photo gallery. Android operating systems may request permission for Videos, however, the app will only use the permission to allow you to upload your picture.
In some cases, your operating system may request permissions that your mobile device needs for technical reasons, but that are not controlled or used by Philips. We will not collect any data associated with such permissions unless required to provide our services in accordance with this notice.
You may block or revoke these permissions at any time under the settings of your operating system.
With whom do we share your Personal Data?
Your data may be shared with other Philips affiliates who are part of the Philips Group. Only people (within Philips) who have a need to know the information will have access to the information. Philips may disclose your personal data to third party service providers, business partners, or other third parties in accordance with this Privacy Notice and/or applicable law.
We work with third-party service providers to help us operate, provide, improve, understand, customize, support, and market our Services.
We may share your personal data with the following service providers:
- IT and cloud providers. These service providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the app or provide the Services.
Philips requires its service providers to provide an adequate level of protection to your personal data similar to the level that we provide. We require our service providers to process your personal data only in accordance with our instructions and only for the specific purposes mentioned above, to have access to the minimum amount of data they need to deliver a specific service, and to protect the security of your personal data.
Other third parties
Philips may also work with third parties who process your personal data for their own purposes. If Philips shares personal data with third parties that use your personal data for their own purposes, Philips will ensure to inform you and/or obtain your consent in accordance with applicable laws before sharing your personal data. In this case, please read their privacy notices carefully as they inform about their privacy practices, including, what type of personal data they collect, how they use, process and protect them.
Philips sometimes sells a business or a part of a business to another company. Such a transfer of ownership could include the transfer of your personal data directly related to that business, to the purchasing company. All of our rights and obligations under our Privacy Notice are freely assignable by Philips to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your personal data to any of our affiliates, successor entities, or new owner.
Your personal data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you acknowledge the transfer (if any) of information to countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal data.
If you are located in the EEA, your personal data may be transferred to our affiliates or service providers in non-EEA countries that are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en).
For transfers from the EEA to countries not considered adequate by the European Commission, such as the United States, we have put in place adequate measures, such as our Binding Corporate Rules for Customer, Supplier and Business Partner Data and/or standard contractual clauses adopted by the European Commission to protect your personal data. You may obtain a copy of these measures by following the link above or by contacting us here.
How long do we keep your data?
We will retain your personal data for as long as needed or permitted in light of the purpose(s) for which the data is collected. The criteria we use to determine our retention periods include: (i) the length of time you use the app and Services; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Your choices and rights
If you would like to submit a request to access, rectify, erase, restrict or object to the processing of personal data that you have previously provided to us, or if you would like to submit a request to receive an electronic copy of your personal data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us here.
In your request, please make clear what personal data you would like to access, rectify, erase, restrict or object to its processing. For your protection, we may only implement requests with respect to the personal data associated with your account, your email address or other account information, that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that:
- Where we rely on consent to collect and/or process your personal data, you may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before your withdrawal.
- When we process your personal data based on a legal obligation to which we are subject, including when you interact with us to exercise any of your rights, we consider the processing to be lawful in accordance with Article 6.1.(c) of Regulation (EU) 2016/679.
- Where we rely on performance of a contract to process your personal data for purposes of the Services, we may not be able to provide the Services if we do not receive your information.
- We will only process your data for Philips’ legitimate interests when we’ve concluded that the processing will not outweigh your privacy rights and interests.
- If you make use of (some of) your choices and rights, you may not be able to use, in whole or in part, our Services anymore.
We protect your personal data
We take seriously our duty to protect the data you entrust to Philips against accidental or unauthorized alteration, loss, misuse, disclosure or access. Philips uses a variety of security technologies, technical and organizational measures to help protect your data. For this purpose we implement, among others, access controls, use firewalls and secure protocols.
Special information for parents
While the Services are not directed to children, as defined under applicable law, it is Philips policy to comply with the law when it requires parent or guardian permission before collecting, using or disclosing personal data of children. We are committed to protecting the privacy needs of children and we strongly encourage parents and guardians to take an active role in their children’s online activities and interests.
If a parent or guardian becomes aware that his or her child has provided us with his or her personal data without their consent, please contact us here. If we become aware that a child has provided us with personal data, we will delete his/her data from our files.
Changes to this Privacy Notice
Our Services may change from time to time without prior notice to you. For this reason, we reserve the right to amend or update this Privacy Notice from time to time. When we update this Privacy Notice, we will also update the date at the top of this Privacy Notice.
We encourage you to review regularly the latest version of this Privacy Notice.
The new Privacy Notice will become effective immediately upon publication. If you do not agree to the revised notice, you should alter your preferences, or consider stop using our Services. By continuing to access or make use of our Services after those changes become effective, you acknowledge that you have been informed and agree to the Privacy Notice as amended.
If you have any question about this Privacy Notice or about the way in which Philips uses your personal data, you may contact Philips and/our Data Protection Officer here. Alternatively, you have the right to lodge a complaint with a supervisory authority competent for your country or region
Philips Consumer Lifestyle B.V.
High Tech Campus 5, 5656 AE,
Eindhoven, The Netherlands