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Project Xian

General Privacy Notice

This Privacy Notice was last updated on December 1, 2020.


This Privacy Notice (“Notice”) is about the processing of your personal data for purposes of the Philips Project Xian study (“study”).  


The study will require you to download and use the Philips Oral Health Research App (“App”).    The App is subject to a different privacy notice [https://www.usa.philips.com/a-w/mobile-privacy-notice/sonicare-research-app-privacy-notice.html], which supplements the study’s Privacy Notice.


For the processing activities covered by this Notice, the controller of your data is Philips Oral Healthcare, LLC, with address at 22100 Bothell Everett Highway, Bothell WA 98021, USA (“we”, “us”)


Specific information regarding what data we may process is found below. We may associate your personal data with unique identifiers.


Pre-screening and registration details, including:

  • Your age and contact details, including first name, last name, email address, home address;
  • Your toothbrush details, including brand and usage information; whether you follow brush pacer and brushing segments;
  • If you own a Smartphone, if so your device details (including, model, version and if you have wi-fi capability);
  • If you are willing to mount your smart phone to your bathroom mirror using a provided accessory;
  • If you are a Philips employee (in which case you will not be able to participate in the study);
  • If you are willing to install a mobile app provided by the study and use the study equipment;
  • If you are willing to video record yourself while brushing with a toothbrush;
  • If you would be interested in purchasing a connected power toothbrush that can help track where you’ve missed brushing and provide recommendations on how to improve your oral health;
  • If you are left or Right handed and where you usually start brushing your teeth.
  • If you meet our exclusion criteria, including if you:
  •  Have known cardiac conditions or implanted cardiac defibrillator or pacemaker;
  •  Have had oral or gum surgery in the previous 2 months;
  • Are a Philips employee;
  • Are or have a household member 60 or older;
  • Have known insulin-dependent diabetes or non-controlled diabetes;
  • Have known autoimmune or infectious diseases (including AIDS/HIV/HepC);
  • Have lung disease or kidney disease;
  •  Within the past 14 days, have been in close contact (6 feet or closer for at least 15 minutes over a 24-hour period) with a person who is known to have laboratory-confirmed COVID-19;
  • Are you isolating or quarantining because you may have been exposed to a person with Covid-19 or are worried that you may be sick with Covid-19;
  • Have experienced loss of taste or smell in the past 48 hours;
  • Are currently waiting on the results of a COVID-19 test;
  • Currently have flu or flu like symptoms such as: fever, chills, cough, shortness of breath or difficulty breathing, fatigue.

If we select you to participate in the study, we collect the following data fields:

  • Your App data, including your:
  • Account data;
  • Brushing, video and motion data (measured by the Inertial Measurement Unit (IMU) sensor inside your power toothbrush) during at-home brushing sessions. Your videos will show your face, mouth, teeth and brushing behavior.
  • Cookies and analytics data.
  • Your survey and questionnaire answers; including product usage details, such as your use of tooth brush products, frequency of using a product, brand and type of product; how you experience or use products, such as multi-tasking, follow a brush pacer while brushing or where you usually start brushing your teeth.
  • Your comments, questions or doubts when you require assistance in connection with the study, including when you reach out to us by phone or email.


We process your personal data for purposes of the main objective of the study, which entails developing a machine-learning algorithm that will predict characteristics of your brushing based on your annotated brushing videos. To accomplish this objective, we process your personal data:


  • To invite you and select you to take part in the study, including sending you the study equipment, the study’s app; as well as reimbursing you for your participation;  
  • To conduct the study, including classifying the different types of brushing styles via collected video/IMU data; training and re-training the algorithm after a certain time, and identifying improvement opportunities on how to properly assess the data;
  • To record your study data, including annotating, combining, aggregating, pseudonymizing or anonymyzing such personal data where required;
  • To conduct scientific research and publish, present or report on the study;


Philips may also process your data for the following purposes:

  • To ensure its medical devices and services adhere to a high standard of quality and safety;
  • For audits, to check whether our internal processes function as intended and are in line with legal, regulatory or contractual requirements;
  • To respond to requests from public and government authorities, including law enforcement.


Philips processes your data for the purposes mentioned above only when we have a lawful basis to do so.

  • We process your data based on your express consent;
  • We process your data for the performance of an activity carried out in the public interest;
  • We process your data in order to comply with a legal or regulatory obligation to which Philips is subject, for example, if we are requested by a governmental authority to disclose your data for audit purposes.
  • We process your data to ensure Philips’ medical devices and services adhere to a high standard of quality and safety.
  • We process your data to conduct scientific research.


Providing your data to Philips for the above-mentioned purposes is completely voluntary. In case you do not want to provide your data to Philips, there will be no negative consequences for you.  However, you will not be able to participate in the study.


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.


From time to time, Philips may need to share your data with external third parties. Third parties may include:

  • The Institutional Regulatory Board (IRB) WIRB®, which has been tasked with overseeing your rights and welfare in connection with this study.
  • Service Providers.  We contract with trusted third party companies that provide products and services to us such as IT systems and support.
  • Public and Governmental Authorities.  When required by law, or as necessary to protect our rights, we may share your data to public and governmental authorities that regulate or have jurisdiction over Philips.
  • Other parties in connection with corporate transactions. We may also, from time to time, share your data in the course of corporate transactions, such as during a sale of a business or a part of a business to another company, or any reorganization, merger, joint venture, or other disposition of Philips’ business, assets, or stock.
  • Other categories of third parties.  We may share your contact details with trusted third parties that will process your personal data as required for this study.


Due to our global nature, your data may be transferred to or accessed by Philips affiliates and trusted third parties from various countries around the world in order for Philips to fulfill the purposes described in this Notice. As a result, if the study takes place in a member state of the European Economic Area, we may transfer your data to countries located outside of the European Economic Area. Philips is required to ensure a safeguard is put in place for transfers to these countries. Some of these countries are recognized by the European Commission as providing an adequate level of protection; however, for countries that are not recognized by the European Commission as providing an adequate level of protection, we have put in place appropriate legal, organizational, and procedural measures to protect your data, such as:

  • The Philips Privacy Rules (also known as the Binding Corporate Rules). These have been approved by the competent data protection authorities. The Philips Privacy Rules enable the transfer of your data between Philips affiliates;
  • Standard Contractual Clauses which have been approved by the competent European Institution. These Clauses enable the transfer of your data to external third parties.


We keep your data as long as we need to fulfill the purposes for which it has been collected.


The criteria used to determine our retention periods include:

  • How long your data is needed to perform the study.
  • How long your data is needed to fulfill the purposes for which it was collected.
  • Whether Philips is subject to a legal obligation to keep your data.


Philips is committed to maintaining the security of the data we process. To protect your data, we take appropriate measures. We also require our service providers to protect the confidentiality and security of your data. Depending on the state of the art, the costs of the implementation and the nature of the data to be protected, we put in place physical, technical, and organizational measures to prevent risks. These risks include destruction, loss, misuse, alteration, and unauthorized disclosure of or access to your data.


To the extent required by applicable law, you have certain rights with respect to the processing of your data which enable you to:

  • obtain information on the processing of your data,
  • obtain a copy of your data in a machine-readable format,
  • object to the processing of your data,
  • have your data rectified or deleted or their processing restricted (to the extent permitted by applicable law), and
  • withdraw consent (if applicable) that you might have given with respect to the processing of your data without any consequence for you.


To exercise your rights or to ask any other questions related to the protection of your data in Philips or regarding this Notice in general, you can contact the Philips Data Protection Officer via https://www.philips.com/contactprivacy or by regular mail at:

       Philips - Attn: Group Legal (Privacy),

       Philips Center HBT 16, Amstelplein 2,

       1096 BC, Amsterdam, The Netherlands.

If you are not satisfied with Philips’ response or believe that your data is not being processed in accordance with the law, you may contact or lodge a complaint with the competent data protection authority or seek other remedies under applicable law. 

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