Philips Privacy Statement: Customer Services Portal

Philips International B.V., High Tech Campus 52, 5656 AG Eindhoven, the Netherlands (“Philips”), wants you to be familiar with how we collect, use and disclose information. This Privacy Notice describes our practices in connection with information that we collect through the Customer Services Portal (CS-Portal) website operated by us from which you are accessing this Privacy Notice as well as through HTML-formatted email messages that we send to you that link to this Privacy Notice. (Last updated: 2018-11-06)

What Personal Data are collected? 

“Personal Data” are data that identify you as an individual or relate to an identifiable individual, including:

Title
First name
Last name*
Email address*
Phone number*
Phone extension
Mobile phone
Address (Street, State, Postal Code)
Country
User settings
Data collected when using CS-Portal ** (Date and time of login, IP Address, Browser used)

*This information must be provided in order to use the CS-Portal.

**This information is captured every time a user logs into the CS-Portal. 

How are Personal Data collected?

We and our service providers collect Personal Data in a variety of ways, including:

When we setup a CS-Portal user account (on your request).
When an account is setup for you by a ‘Portal Manager’ designated for your facility/organization. A ‘Portal Manager’ is a user who is able to create and manage other user accounts.
 Manually provided by the user on the user’s profile page.
Automatically during your interactions with CS-Portal

If you, in your role as a ‘Portal Manager’, disclose any Personal Data about other people to us or to our service providers in connection with the CS-Portal, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice. 

What is the purpose of the collection of Personal Data?

We and our service providers use Personal Data for our legitimate business purposes including:  

Providing the functionality of the CS-Portal and fulfilling your requests.

To provide the CS-Portal functionality to you, such as arranging access to your registered account, and providing you with related information.
To provide other portal users, associated with the same account, an easy means to contact you (as ‘Portal Manager’) for administrative activities.
To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you request questions, information on contracts or submit other inquiries via the portal.
To respond to the case(s) you created via the CS-Portal
To send administrative information to you, such as changes to our terms, conditions and policies.
To send system administrative information to you, such as account activation mails, password reset mails and/or other messages related to the CS-Portal of which we would like to make you aware (e.g. major upgrades and timing there off)

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

Aggregating and/or anonymizing Personal Data

If we aggregate and/or anonymize Personal Data, it will no longer be considered Personal Data. We can do so to generate other data for our use, which we may use and disclose for any purpose.

We will engage in this activity because we have a legitimate interest.

 Accomplishing our business purposes

For data analysis, for example, to improve the efficiency, functionality and/or user experience of the CS-Portal;
For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
For developing new products and services;
For enhancing, improving, or modifying our current products and services;
For identifying usage trends, for example, understanding which parts of the CS-Portal is of most interest to users;
For operating and expanding our business activities, for example, understanding which parts of the CS-Portal is of most interest to our users so we can focus our energies on meeting our users’ interests; and
To conduct scientific research related to the CS-Portal.

With whom are Personal Data shared?

We disclose your Personal Data:

To our affiliates for the purposes described in this Privacy Notice;
To our third party service providers who provide services such as website hosting, data analysis, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services

Other uses and disclosures

We also use and disclose your Personal Data as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

To comply with applicable law.

This can include laws outside your country of residence

To respond to requests from public and government authorities.

For example, when we respond to law enforcement requests and orders.

For other legal reasons.

To enforce our terms and conditions; and
To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

In connection with a sale or business transaction.

We have a legitimate interest in disclosing or transferring your Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How can you contact us?” section below. 

What are your rights?

If you would like to:

Ask questions about how we handle Personal Data;
Request to review, correct, update, suppress or restrict the use of your Personal Data;
Request that your Personal Data be removed from our database;
Withdraw your consent to our use of your Personal Data, without affecting the lawfulness that use prior to this withdrawal;
Object to our use of Personal Data for direct marketing purposes or for our legitimate business interests, or
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)

Please contact us at privacy@philips.com. We will respond to your request consistent with applicable law. 

Note: In the CS-Portal, users can update their personal information on the user profile page. 

In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Data. For your protection, we only implement requests with respect to the Personal Data associated with the particular email address 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 we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. 

If you are a resident of California, under 18 and a registered user of the CS-Portal, you can ask us to remove content or information that you have posted to the CS-Portal by writing to privacy@philips.com. 

How long will the Personal Data be kept?

We will retain your Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

(i) the length of time we have an ongoing relationship with you (for example, for as long as you have an account with us participate in the CS-Portal);

(ii) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); 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).

Use of the CS-Portal by minors

The CS-Portal is not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Data from individuals under 16. 

Jurisdiction and cross-border transfer

The CS-Portal is controlled and operated by us from The United States of America, India and the Netherlands and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the Netherlands. Your Personal Data can be stored and processed in any country where we have facilities or in which we engage service providers, and by using the CS-Portal you consent to the transfer of information to countries outside of your country of residence, including the United States of America, which can 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 (European Economic Area), your Personal Data can 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, 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 can obtain a copy of these measures by following the link above or contacting privacy@philips.com 

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 CS-Portal or otherwise to us. 

Updates to this Privacy Notice

We may change this Privacy Notice. The “LAST UPDATED” legend at the top of this Privacy Notice indicates when this Privacy Notice was last revised. Any changes will become effective when we post the revised Privacy Notice on the CS-Portal. Your use of the CS-Portal following these changes means that you accept the revised Privacy Notice. 

How can you contact us?

If you have any questions about this Privacy Notice or about the way Philips uses your Personal Data, please contact our Data Protection Officer via our contact form. Alternatively, you have the right to lodge a complaint with a supervisory authority competent for your country or region.