This Privacy Notice was last updated on 17th June 2019.
Lumea IPL App provides services that help you set your treatment schedule and goals related to hair removal; to receive reminders to keep up with your treatments schedule; to get personalized usage tips based on the progress and to follow your progress and Lumea device usage; and other services (“Services”) to users around the world. This Privacy Notice is meant to help you understand our privacy practices when you use our Services, including what data we collect, why we collect it, and what we do with it, as well as your individual rights.
Lumea IPL App uses personal data collected or processed the Lumea IPL App mobile application (“App”).
This Privacy Notice applies to personal data collected or processed by the App, which is controlled by or under control of Koninklijke Philips N.V. or any of its affiliates or subsidiaries (”Philips”, “our”, “we” or “us”).
What Personal Data are collected and for which Purposes
We receive or collect personal data, as described in detail below, when we provide our Services, including when you access, download, install the App, or use our Services. We may use this personal data to perform the Services 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.
Sensitive Personal Data
Before we collect sensitive personal data, we will inform you and ask your explicit consent. This data includes hair color and skin tone. You may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before withdrawing your consent.
Sensitive Personal Data
We ask that you not send us and you not disclose any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the App or otherwise to us.
We collect your personal data when you create an account. You may login to the App using a MyPhilips account or by using your social media profile. The personal data we collect may include your username, profile photo, name, email address, gender, birthday/age, country, language, latest tweet, profile URL, social media profile, location and password.
The personal data collected is used to create and manage your account. You can use your account to securely login to the app. If you create a MyPhilips 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 communication in case you have opted-in. You may also use your MyPhilips 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.
We use Facebook Login. This enables you to sign into our App with your Facebook credentials. Philips will collect your Facebook credentials, your name, email address and picture associated with your Facebook account. Facebook also collects certain information when you use Facebook Login:
Configuration data: After a user has logged in, the SDK makes periodic background requests to manage the lifetime of the access token automatically.
Error information: The SDK captures error information, including during initialisation of the SDK, which may include a user ID of individuals who are logged in to Facebook.
Short-term data: The SDK measures some user activity for purposes of managing fraud and abuse. This data is only retained for a very short period for those not logged in to Facebook.
Other Provided Data
This data includes hair color and skin tone, notification settings, treatment history, goals, Lumea device usage, and responses to surveys.
The data collected is used to help you set your treatment schedule and goals; to receive reminders to keep up with your treatment schedule; but also to get personalized usage tips based on the progress and to follow your progress and Lumea device usage. We do this by sending you push notifications via App or email.
When you allow access to location data, we may collect the geographic location of your mobile device. You can at any time block geo-location collection through the settings of your App or mobile device.
When you make use of the ‘Find Philips near you’ functionality on the Support Page, you are requested to share your location data with Philips. If you use our location features, based on your location data, you will be directed towards a store near you, or to the consumer care contact details for your country.
If you pay for our Services, we may receive information and confirmations, such as payment receipts, including from app stores or other third parties processing your payment.
You may 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 you customer 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.
We may combine your personal data, including account data, other data provided by you, cookies, location data, data collected during your interactions and usage of the Philips digital channels such as social media, websites, emails, apps and connected products, IP address, cookies, device information, communications you click on or tap, location details, and websites you visit.
The combined data is analyzed and used to provide you with the Services such as to help you set your treatment schedule and goals; to receive reminders to keep up with your treatment schedule; to get personalized usage tips based on the progress and to follow your progress and Lumea device usage; and help us improve the content, functionality and usability of the App, Device and Services as well as to develop new products and services.
If you opt-in 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 may opt-out and unsubscribe from such communications at any time.
The App may request your permission to access your phone or sensors (e.g. camera, Wi-Fi, geo-location, or Bluetooth) or other data (e.g. photos, agenda, or contacts) on your mobile device.
We use such data only when it is needed to provide you the Services and only after you provided your explicit consent.
Sometimes the permission is a technical precondition of the operating systems of your mobile device. In such case, the App may ask your permission to access such sensors or data, however we will not collect such data, unless when it is required to provide you the App Service and only after you provided consent.
With whom are Personal Data shared?
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. 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.
If Philips shares personal data with a third party that uses your personal data for their own purposes, Philips will ensure to inform you and/or obtain your consent in accordance with applicable laws before we share your personal data.
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 consent to 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. For transfers from the EEA to countries not considered adequate by the European Commission, such as 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 firstname.lastname@example.org.
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 at email@example.com. We will respond to your request consistent with applicable law.
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 if you make use of (some of) your choices and rights, you may not be able to use, in whole or in part, of 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 at firstname.lastname@example.org. If we become aware that a child has provided us with personal data, we will delete his/her data from our files.
Local specific information: Your California Privacy Rights (US Only)
California Civil Code Section 1798.83 permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and like to make such a request, please visit our privacy website: philips.com/a-w/privacy/questions-and-feedback
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, please contact our Data Protection Officer at email@example.com. Alternatively, you have the right to lodge a complaint with a supervisory authority competent for your country or region.