Project Xian
General Privacy Notice
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:
If we select you to participate in the study, we collect the following data fields:
FOR WHICH PURPOSE(S) DO WE PROCESS YOUR DATA? 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: Philips may also process your data for the following purposes:
THE LEGAL BASES USED TO PROCESS YOUR DATA Philips processes your data for the purposes mentioned above only when we have a lawful basis to do so.
WHY DO WE NEED YOUR DATA? 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.
WITH WHOM DO WE SHARE YOUR 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. From time to time, Philips may need to share your data with external third parties. Third parties may include:
INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA 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:
HOW LONG DO WE KEEP YOUR DATA? 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 DO WE SECURE 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.
WHAT ARE YOUR PRIVACY RIGHTS? To the extent required by applicable law, you have certain rights with respect to the processing of your data which enable you to: 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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