Philips Sonicare Privacy Notice

This Privacy Notice was last updated on [25]th July, 2019.

The Philips Sonicare (“App”) advises users around the world on how to improve their brushing and oral hygiene habits ("Services"). The App uses personal data collected or processed by the Philips Sonicare connected toothbrush ("Device") and/or the App.

The purpose of this Privacy Notice is 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. This Privacy Notice applies to personal data collected or processed by the Device and/or the App, which is controlled by or under control of Philips Oral Healthcare, LLC or any of its affiliates or subsidiaries ("Philips", "our", "we" or "us").

Please also read our Cookie Notice and Terms of Use, which describe the terms under which you use our Services.

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 and install the App.

Sensitive Personal Data

We collect the following oral care data:

Your Device’s brushing data, including your routine, session information, and sensor data such as mode, position, motion and pressure of the brush.
Your brushing goals and other oral care habits/activities (such as flossing and rinsing), your answers to our Personalization page in the Onboarding Questionnaire and the Focus Area (such as your plaque build-up, bleeding areas, gum recession, and potential cavities); and your brushing start location (i.e., the location in your mouth where you want to start brushing).

We collect this data to provide you with the Services, including providing feedback and real time guidance while you brush; give you a customised program to immediately address missed spots; track your brush head effectiveness and alert you when to replace your brush head; and send you mouthwash or tongue cleaning reminders. We also use your oral care data to develop new products and services for you.

Where you would like to receive In App recommendations for Philips products, we process your oral care data to recommend products for you and help you get better results.

Before collecting any sensitive data, we will inform you and ask your explicit consent in accordance with article 9.2.a. of Regulation (EU) 2016/679. 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.

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Account Data

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 name, email address, country, language and password. For China users, we collect the users’ phone numbers

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. 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) to learn about their privacy practices, including, what type of personal data they collect, and how they use, process and protect them.
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 communications 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.

Because we use your Account Data to provide the Services, we consider this processing to be necessary for the performance of a contract to which you are party and lawful under Article 6.1. (b) of Regulation (EU) 2016/679.

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Device Data

We may collect device-specific information when you install, access or use the Device, including your unique user Device number. The App also records (i) your Device’ time of use and battery level; and (ii) the type and lifespan of your brush head. We use this data to connect your Device with the App, track your brush head effectiveness and alert you when to replace your brush head.

Because your Device(s) Data are only processed for purposes of the Services, we consider this processing to be necessary for the performance of a contract to which you are party and lawful under Article 6.1.(b) of Regulation (EU) 2016/679.

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Cookies

In some countries, we use cookies, tags or similar technologies (“Cookies”) to operate, provide, improve, understand, and customize our Services. Cookies allow us to recognize your mobile device and collect your personal data including your unique user device number, the IP address of your mobile device, the type of mobile internet browser or operating system you use, session and usage data, or service-related performance information, which is information about your use of the App.

Before we use Cookies, we will ask your consent. For further information about the use of Cookies in this App, please read our Cookie Notices, which you can find under the privacy settings of the App.

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Transactional information

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.

Customer support

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.

We consider the processing of your Customer Support data to be necessary for the performance of a contract to which you are party and lawful under Article 6.1.(b) of Regulation (EU) 2016/679.

Combined Data

We may combine your personal data, including Account Data and Cookies, 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 use your Combined Data to improve the content, functionality and usability of the App, Device(s) and Services, as well as to develop new products and services. In this case, we consider the processing of your Combined Data to be based on a legitimate interest of Philips and lawful under Article 6.1. (f) of Regulation (EU) 2016/679. Before processing any Sensitive Data for the purposes mentioned in this section, we will inform you and ask your explicit consent in accordance with article 9.2.a. of Regulation (EU) 2016/679. 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.

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 behaviour, 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 analyse your Combined Data. Before sending any promotional communications to you, we will ask your consent.

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Permissions
When the App needs permission to access your mobile device’s sensors (e.g. camera, Wi-Fi, geo-location or Bluetooth) or other data (e.g. photos, agenda or contacts) for purposes of the Services, we will ask your consent.

Bluetooth. The App requires Bluetooth connection to connect the Device to the App. You can at any time block your Bluetooth connection through the settings of your mobile device.
Location. Android operating systems require coarse geo-graphic location to connect to your Device. iOS operating systems require geo-location to recognize when the App and the Device are nearby. However, Philips will not process such data in any manner. The data will remain stored in the App on your mobile device, where Philips will not have access to it. If you delete your profile and/or the App, the data will be deleted from your mobile device. You can at any time block geo-location collection through 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., graphics, media files, or other large program assets). If you delete the App, the data will be deleted from your mobile device.
Sometimes a 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 required to provide you the Services and only after you provided consent.

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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.

Service Providers

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.

Payment

We work with WorldPay, a service provider that handles and processes your financial data in relation to the payment features of this App, including app stores or other third parties processing your payment.

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.

At your request, we may share your personal data with the following third parties:

Delta Dental (USA only).
ONVZ (Netherlands only).
Amazon (If Amazon DRS is available in your country – see further details below).

These third parties may provide their own services to you. We may share your personal data with these third parties at your request and/or in accordance with applicable laws.

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)Data about your interactions and usage of the Philips digital channels such as social media, websites, emails, apps and connected product. This data may include: IP address, cookies, device information, communications you click on or tap, location details, websites you visit.

IT Providers

These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided.

Cloud Providers

These providers deliver data storage services. Philips is committed to store your personal data in your region, with cloud services in Europe, US, Latin-American, Tokyo or Sydney and China.

Grooming App service Providers

These providers deliver specific services for Grooming App such ascalculating heart-age, providing coaching (only for apps that use coaching).

Payment

These providers handle financial data in relation to in-app purchases.

IT Providers

These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided.

Cloud Providers

These providers deliver data storage services. Philips is committed to store your personal data in your region, with cloud services in Europe, US, Latin-American, Tokyo or Sydney and China.

Grooming App service Providers

These providers deliver specific services for Grooming App such ascalculating heart-age, providing coaching (only for apps that use coaching).

Payment

These providers handle financial data in relation to in-app purchases.

IT Providers

These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided.

Cloud Providers

These providers deliver data storage services. Philips is committed to store your personal data in your region, with cloud services in Europe, US, Latin-American, Tokyo or Sydney and China.

Grooming App service Providers

These providers deliver specific services for Grooming App such ascalculating heart-age, providing coaching (only for apps that use coaching).

Payment

These providers handle financial data in relation to in-app purchases.

IT Providers

These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided.

Cloud Providers

These providers deliver data storage services. Philips is committed to store your personal data in your region, with cloud services in Europe, US, Latin-American, Tokyo or Sydney and China.

Grooming App service Providers

These providers deliver specific services for Grooming App such ascalculating heart-age, providing coaching (only for apps that use coaching).

Payment

These providers handle financial data in relation to in-app purchases.

IT Providers

These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided.

Cloud Providers

These providers deliver data storage services. Philips is committed to store your personal data in your region, with cloud services in Europe, US, Latin-American, Tokyo or Sydney and China.

Grooming App service Providers

These providers deliver specific services for Grooming App such ascalculating heart-age, providing coaching (only for apps that use coaching).

Payment

These providers handle financial data in relation to in-app purchases.

IT Providers

These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided.

Cloud Providers

These providers deliver data storage services. Philips is committed to store your personal data in your region, with cloud services in Europe, US, Latin-American, Tokyo or Sydney and China.

Grooming App service Providers

These providers deliver specific services for Grooming App such ascalculating heart-age, providing coaching (only for apps that use coaching).

Payment

These providers handle financial data in relation to in-app purchases.

Grooming App service Providers

These providers deliver specific services for Grooming App such ascalculating heart-age, providing coaching (only for apps that use coaching).

Grooming App service Providers

These providers deliver specific services for Grooming App such ascalculating heart-age, providing coaching (only for apps that use coaching).

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Amazon Dash Replenishment Services

In some countries, we support our BrushSync Reorder services (“BrushSync”). When you subscribe to BrushSync, the App will place automatic brush head orders for you via Amazon’s Dash Replenishment Service (“DRS”). For such purposes, you will have to log in to your Amazon Account, and Amazon will provide its own services to you. Please read Amazon’s Terms and Conditions and Privacy Notice as they inform about its privacy practices, including, what type of personal data it collects, and how it uses, processes and protects them.

When you set-up your BrushSync suscription, we share the following data with Amazon: the serial number of your Device, the model (hx number) of your Device, and when it is time to order a new brush head (“BrushSync Data”). To keep track of your subscription, we store your Amazon Customer ID. If you unsubscribe to BrushSync, we will delete such Customer ID. You can at any time (i) pause or change orders using the Reorder Settings in the My Brush Head Page of the App; and/or (ii) cancel any order via Amazon.

Because your BrushSync Data and your Amazon Customer ID are only processed for the above purposes when you subscribe to BrushSync, we consider this processing to be necessary for the performance of a contract to which you are party and lawful under Article 6.1.(b) of Regulation (EU) 2016/679.

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Cross-border transfer

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. 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 privacy@philips.com.

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How long do we keep your data?

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 privacy@philips.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.

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.

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, our Services anymore.

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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.

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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 privacy@philips.com. If we become aware that a child has provided us with Personal Data, we will delete his/her data from our files.

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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 data (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 data 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 would like to make such a request, please visit our privacy website:
http://www.philips.com/a-w/privacy/questions-and-feedback.html.

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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.

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Contact Us

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 privacy@philips.com. Alternatively, you have the right to lodge a complaint with a supervisory authority competent for your country or region.

Philips Oral Healthcare, LLC

22100 Bothell Everett Highway,

WA 98042, Bothell