Philips Privacy Notice

• Maintaining the safety and security of Philips employees, visitors, guests, and Philips property and assets;
  
• Safeguarding Philips’s legitimate interests, such as investigating non-compliance with Philips policies and procedures, potential criminal activities (e.g., suspected theft of company or personal property), and other incidents or accidents in our premises;
• Initiating disciplinary and judicial processes and procedures, including preserving evidence and disclosing recordings for the purpose of legal claims and proceedings.

What personal data we process
We process the following categories of personal data:

• When providing you with a personalized badge, which will enable you to access our offices, we generally ask for your name and visit information;
• When using CCTV systems, we process video recordings of you (e.g. your image as captured on the CCTV system).

Lawful basis for processing
The lawful basis we rely on to process your personal data for the purposes described in this section is our legitimate interest, in particular our necessity to protect fundamental rights such as the right to liberty and security, the right to property, the right of defense.

Who is the controller of your data
The controller of your personal data is the Philips affiliated company of the country where you visited our premises, identified in our Terms of use (see the footer) as being the operator of this website.

• investigating potential violations of our General Business Principles or which otherwise constitute a threat to Philips corporate integrity;
  
• taking any action that might be necessary to do business in a responsible manner and in line with local laws and regulations.

What personal data we process
If you report a concern via our Philips Speak Up, we process the following categories of personal data:

• If you reveal your identity: Your name, phone number, e-mail address, the best time to contact you, and your relationship with Philips (former employee, vendor, customer or other), if you choose to supply this information.
• The name and other personal data of any persons you name in your report, if you are willing and able to supply this information.
• Details about the incident which you are reporting (time, place, location, circumstances, a description of what has happened, the possible effects on the Philips entity and whether the management is aware of this issue).

Lawful basis for processing
The lawful basis we rely on to process your personal data for the purposes described in this section is our legitimate interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect fundamental rights such as the right to liberty and security, the right to property, the right of defense, the freedom to conduct a business.

With whom we share your personal data
Your personal data are registered in the Philips GBP Complaints Database, from where it will be sent, on a strictly need-to-know basis, to the appropriate persons within Philips. This means the information may be shared with the assigned investigator(s), assigned GBP Compliance Officer, and in some situations members of Group Internal Audit as well as Group Legal, or outside Philips (forensic auditors, legal counsel) who require this information to ensure compliance with the GBP Reporting Policy and legal or regulatory obligations, or as input for subsequent judicial proceedings.

What personal data we process
If you submit a privacy request to us, we require certain information from you as we need them in order to respond to you and adequately address your inquiry. In particular, we need the following information:

• Your e-mail address;
• Your relationship with Philips (consumer, job applicant, or other).

In addition, if you want, you can also disclose to us your full name, your country, your preferred language and any other information you decide to include in your inquiry.

Lawful basis for processing
The lawful basis we rely on to process your personal data for the purposes described in this section is our need to comply with the privacy and data protection laws and regulations we are subject to.

What personal data we process
We process the following categories of personal data:

• Full name and title
• Date of birth
• Postal address
• Email address
• Shareholder identifier
• Financial information (number of shares, dividend, etc.)
• Bank or intermediary
• Bank account number, securities account number
• Name of your authorized representative (if any)
• Proxy voting instructions or votes cast

• The content of questions, opinions or proposals you may express before or during meetings of shareholders

Lawful basis for processing
The lawful basis we rely on to process your personal data for the purposes described in this section is our need to comply with applicable laws we are subject to as well as our legitimate interest to conduct business in a responsible manner, for example when we audio-video record the meetings of shareholders.

What personal data we process
To subscribe to our latest press releases or investor relations notifications we ask your full name, email address and the company you work for (for investor relations notifications only and in case you represent an institutional investor or bank).

Lawful basis for processing
The lawful basis we rely on to process your personal data for the sending you our latest press releases or investor relations notifications is your consent. In any case, you can unsubscribe at any time via the link at the bottom of the emails or via the respective “Unsubscribe” buttons in Philips Investor Relations and press release webpages. 

• applying for a job in our career website;
  
• signing up for our career newsletters to receive the latest jobs and news right to your inbox;
• interacting with us (for example, with our recruiters) for job opportunities.

Why we process your personal data
We process your personal data for the following purposes:

• Providing the functionality of our career website to you, such as arranging access to your registered account and enabling you to submit applications via the career website;
• Assessing your skills, qualifications and suitability to work for Philips against the position you applied for and/or other career opportunities;
• Asking you if you would like your details retained in our talent pool. If you agree, we would proactively contact you should any further suitable vacancies arise.
• Depending from the country of employment and based on what is allowed by applicable laws, verifying your information, including through reference checks and, where applicable, background checks.
• Communicating with you about the recruitment process;
• Sending you via email news and updates about Philips jobs and recruitment activities (if you signed in);
• Preparing an offer, if your application is successful;
• Complying with applicable laws and regulations we are subject to and cooperate with regulators and law enforcement bodies.

What personal data we process
Depending on the specific recruitment activity, we process the following categories of personal data:

• Contact information (such as full name, email address, phone number, country of residence, home address, other contact information);
• Data about your skills and qualifications, contained in CVs, cover letter or other documentation provided to us in your application (such as education history, work experience, transcripts);
• Data required to conduct background or employment checks, when allowed by applicable laws (such as documents to proof your identity or qualifications);
• Information on the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences;
• Data required to make a conditional offer of employment (such as bank details to process salary payments, emergency contact details to know who to contact in case you have an emergency at work);
• Details of how your heard about the position you are applying for;
• Data originating from assessments or questionnaires completed by you (such as your answer to written assessments); 
• In certain cases, you may join optional video interviews. In this case we may process your image or other data captured by your camera.
• Information relating to any previous applications you may have made to Philips.
• Information that you make publicly available that we believe is relevant to your application or a potential future application (such as your information contained in your LinkedIn profile).
• If you're being referred, we process information that the person referring you provides about you.
• If required or permitted by local laws, we may also process information of sensitive nature, such information about disabilities, to the extent relevant for the performance of your work.

Lawful basis for processing
The lawful bases we rely on to process your personal data for the purposes described in this section are:

• our need to perform a contract to which you are subject, or to take pre-contractual steps at your request.
• our legitimate interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business.
• our need to comply with legal obligations we are subject to.
• your consent, for sending you via email news and updates about Philips jobs and recruitment activities and for keeping your details in our talent pool and contacting you for career opportunities.

Who is the controller of your personal data
The controller of your personal data for the purposes described in this section is the Philips affiliated company of the country which intends to recruit you (identified in our Terms of use - see the footer - as being the operator of this website) as well as Philips International B.V.

Why we process your personal data
We process your personal data for the following purposes:

• to answer your questions and provide you with required support, including keeping you up to date on the progress of your case and work order (this may include scheduling, delivering remote/field service activities, including parts ordering, in case you are a business customer);
• to verify your identity (e.g. if you already have a MyPhilips account) and support you accordingly;
• to deal with any subsequent issues that may arise from your inquiry, such as for establishing, exercising or defending ourselves from legal claims;
• to check and improve the level of service we provide; for example, if you contact us by telephone or chat we could record the conversation in order to educate our team during internal training so that we can always improve our customer service support.
• to improve, fix and customize our products and services;
• [in case you request our assistance about a Philips product produced by one of our brand license partners] to direct your request to the relevant brand license partner, so that they can provide you with the requested support. 
• to comply with compliance, regulatory and quality standards and regulations.
• to ask you if you want to receive promotional emails from Philips and stay up to date about new and existing Philips products and services and about our events (if you want to know more, see the section “Joining our marketing initiatives”).

What personal data we process
If you have a question or request our support, we need you to give us some information, such as your name, e-mail address, telephone number or other information necessary for dealing with your question or inquiry. If you have a MyPhilips account, we may use the information linked to your account to provide you with the requested support.

Lawful basis for processing
The lawful bases we rely on to process your personal data for the purposes described in this section are:

• our need to perform a contract to which you are subject, or to take pre-contractual steps at your request.
• our legitimate interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business.
• our need to comply with legal obligations we are subject to.

• to fulfill the repair/exchange and product warranty related service;
  
• to allow you to track and provide you with a status of your repair or exchange;
• to deliver the product to you;
• to contact you in case of issues with the delivery or to obtain additional necessary information to fulfill your service request.

What personal data we process
We process the following categories o f personal data:

• Contact information (such as your first name, surname, address, phone number);
• Product information (e.g. model number, date of purchase),
• Information necessary to review your service or repair request,
• Information necessary to confirm that your product is in the warranty period (e.g. proof of purchase).

Lawful basis for processing
The lawful bases we rely on to process your personal data for the purposes described in this section is our need to enter into and perform a contract with you, or to take pre-contractual steps at your request.

Why we process your personal data
We process your personal data for the following purposes:

• to create and maintain your MyPhilips account;
• to enable you to register your Philips products;
• to provide you extended warranty on selected products.

You can also use your MyPhilips account for other services, such as:

• Managing your marketing communication preferences: when you create your Philips account you can indicate if you wish to receive marketing communications from Philips. That way we are able to contact you if we have something that we think will appeal to you.
• Logging-in to Philips mobile apps.
• Purchasing Philips products and services in our Philips online shop for consumers, consulting your order history and managing your subscriptions;
• Joining our product tests and telling us what you think about our products.
• Participating to our promotions, such as cash backs or coupon promotions.

If you want to know more about how we process your personal data in the context of such other services, just select them in this privacy notice and you’ll find out.

What personal data we process
If you create a MyPhilips account we process the following categories of personal data:

• Contact information (such as your first name, surname and email address). If you decide to create a MyPhilips account with your social media account, the registration form will be pre-populated with the contact information provided by your social media provider.
• Information about your location (such as your country, language preference);
• Information about your registered product/service (such as the name of the purchased product and the date and proof of purchase).

In addition, if you want, you can also choose to provide to us:

• your salutation, which will be used to personalize our promotional or transactional communications to you; and
• your date of birth, which will be used to personalize our promotional communications to you (for example, when is your birthday).

If you want to create a MyPhilips account in your capacity as Professional (i.e. business customer, supplier and/or business partner of Philips), we may also process the following data:

• Company name
• Company address
• Company phone number
• Organization type
• Job title/specialty
• Customer account number.

You can delete your MyPhilips account at any time. To do so, you should log-in and find the deletion button in your settings. We will then remove your MyPhilips account and any data associated to it (this includes also data processed in the context of the other Philips services listed above and associated to your MyPhilips account), unless we are required by law to keep certain data.

Lawful basis for processing
The lawful basis we rely on to process your personal data for the purposes described in this section is our need to enter into or perform a contract with you, or to take pre-contractual steps at your request.

Why we process your personal data
We process your personal data for the following purposes:

• to handle your orders and process the payment. In this context, we may process your personal data to prevent and detect fraud and abuse in order to protect the security of our customers, Philips, and others. We may also use scoring methods to assess and manage credit risks;
• to deliver the purchased products and services to the delivery address you provide to us. To do so, we work together with our distribution partners which help us to prepare and correctly process your package, and with our logistic partners which deliver your package to the chosen address.
• to update you via email on the status of your order;
• to contact you via email for transactional and technical support;
• to enable you to consult your order history, save your favorites items or create wish lists, and manage your subscriptions, if any;
• To comply with laws and regulations we are subject to (for example, for tax purposes we are obliged to store the details of every purchase).

Keep in mind that certain Philips products and services available in our Philips online shop for consumers are sold to you by one of our partners, as indicated in the terms and conditions of sale that will be shown to you before finalizing your order. This means that if you place an order with one of our partners, we will share your personal data (such as your name and address) with that partner so that it can execute the agreement you have entered to and therefore fulfill your order and send you the invoice. The partner may also use your personal data to update you on the status of your order and to provide you with the required customer support. If you want to know more about how our partner will process your personal data, we invite you to read its privacy notice, which we will make available to you in our online shop.

What personal data we process
We process the following categories of personal data:

• Your Account data (in case you purchase a product with your Philips account);
• Name and Email (in case you purchase a product as a guest);
• Shipment and invoice address;
• Invoice/receipt information, which includes the purchased product and service;
• Payment information (such as your credit card number). Please note that we never store your payment information. When you submit a payment, your payment information will be directly sent to our trusted payment provider, which will connect to your bank to validate the transaction.
• You position/title in your company, your company name and type, your buying preferences, your company’s shipping/billing address, if you purchase our products or services in your capacity as healthcare professional.

In certain cases, you may choose to also provide us with your phone number (optional) if you want our trusted shipment provider to contact you via phone in case of delivery issues or if you want our support team to contact you via phone in case of issues with your order.

Lawful basis for processing
The lawful bases we rely on to process your personal data for the purposes described in this section are:

• our need to execute our Terms and conditions of sale with you, in particular our contractual obligation to manage your order;
• our legitimate interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business. This applies when we conduct fraud checks;
• our need to comply with legal obligations we are subject to. This apply, for example, when we process details of your purchase for tax purposes.

Who is the controller of your personal data
The controller of your personal data for the purposes identified in this section is the Philips affiliated company identified in our Terms and conditions of sale, made available to you in our website.
In case you place an order in our Philips shop for consumers with one of our partners, the controller of your personal data is: (i) Philips International BV for collecting your order and processing the payment; and (ii) the relevant partner identified in its terms and conditions of sale or in its privacy notice, for fulfilling your order, sending you the invoice and providing the requested customer support. 

• to respond to your comments and questions or provide to you the required support. In case your question or comment relates to a Philips product produced by one of our brand license partners, we may provide your personal data to the relevant brand license partner, so that they could respond to your question or give you the requested support.
  
• to gain a general understanding of what people are saying about us and our brands and therefore improve our products and services accordingly.

What personal data we process
For the purposes described above, we may process any information about you that are contained in any comments or other content about Philips that you make publicly available on social media and other public external sources. This may include information such as your name (or nickname), profile picture, country.

Lawful basis for processing
The lawful basis we rely on to process your personal data for the purposes described in this section is our legitimate interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect our fundamental right to conduct a business.

• to verify that your review is in line with our terms and that it does not contain misleading or inaccurate claims regarding the performance of the product (for example off-label promotion or not in line with our instructions for use);
  
• to publish your rating and reviews online and give the opportunity to anyone to learn from your experience with our products;
• to gain a general understanding of what people are saying about us and our brands and therefore improve our products and services accordingly;
• to contact you and offer our assistance in case you in case your review indicates that you are not satisfied with our product or service. In case such review relates to a Philips product produced by one of our brand license partners, we may provide your personal data to the relevant brand license partner, so that they could contact you and offer assistance.
• to contact you in case of health and safety or liability issues.
   

What personal data we process
We process the following categories of personal data: email, location, age, gender, number of people living in your household, period of usage of our Philips product.
 

Keep in mind that when you provide your rating and write a review, we will not make your email visible to other visitors. We will make visible the other information that you provide to us, as this helps us to create an open forum where our customers can find and exchange truthful and meaningful information around our products.
 

In addition, to respect your privacy, we encourage you to provide a nickname and not your real name when leaving your review.

Lawful basis for processing
The lawful bases we rely on to process your personal data for the purposes described in this section are:

• our need to execute our Terms and conditions;
  
• our legitimate interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business. This applies when we process your personal data to improve our products and services and when we contact you (or provide your personal data to our brand license partner so that they can contact you) in order to provide assistance.
• our need to comply with legal obligations we are subject to. This apply, for example, when we contact your for health and safety issues.

Why we process your personal data
We process your personal data for the following purposes:

• to evaluate if you can be selected to participate in the test, based on your answers to our questions during the selection procedure and based our terms.
• (if you are selected) to properly manage your participation to the test in accordance with our terms. This includes activities such as informing you by e-mail if you are selected to participate in the test, sending to you our product at the address specified in the registration process, receiving and analyzing the feedback you share with us about the product, verifying that you published online a review of our product, requesting back the product you have received (for example, in case you do not write the review within the specified time frame).
• to improve our product and develop new product and services.

What personal data we process
When you sign up to become a Philips product tester, we process the following categories of personal data:

• Account information, such as your first name, surname and email;
• Information about you, that you provide to us by responding to our questions during the selection procedure.
• Feedback about the product that you share with us;
• Shipment/fulfilment information, such as your home address, and telephone number;
• Overview of which tests you have participated in.

Lawful basis for processing
The lawful bases we rely on to process your personal data for the purposes described in this section are:

• our need to execute our Terms of use for Philips product tester program;
• our legitimate interest, in particular our necessity to protect fundamental rights such as the the right to property, and the freedom to conduct a business. This applies when we process your personal data to improve our products and services.

Who is the controller of your personal data
The controller of your personal data for the purposes identified in this section is the Philips affiliated company identified in our Terms of use for Philips product tester program, made available to you in in our website.

• to send you our customer satisfaction survey;
  
• [if you purchase a product online or receive services from Philips] to understand and measure how satisfied you are with the recent service experience you received from Philips;
• [if you purchase a product online or receive services from a Philips’ brand license partner] to understand and measure how satisfied you are with the recent service experience you received from the Philips’ brand license partner;
• to improve your level of satisfaction with Philips, based on your feedback;
• [if you are a business customer] to understand and measure how satisfied you are with your relationship with Philips;
• to contact you via phone or email to understand how we can improve our relationship with you.

What personal data we process
We process the following categories of personal data:

• Contact information, such as your name and email;
• [if you are a business customer] Professional information, such as your job title, the name of your company, phone number;
• Your feedback.
  
  

Lawful basis for processing
Unless differently required by applicable law, the lawful basis we rely on to process your personal data for the purposes described in this section is our legitimate interest, in particular our necessity to protect fundamental rights such as the right to property, and the freedom to conduct a business. 

Who is the controller of your data
If you purchase a product online or receive services from a Philips’ brand license partner, the controller of your personal data is: (i) the relevant Philips’ brand license partner identified in its privacy notice (made available to you when your personal data are initially collected), for collecting your personal data, measuring how satisfied you are with your recent service experience and for improving your level of satisfaction; and (i) Philips International B.V. for sending the survey to you.

If you purchase a product online or receive services from Philips or if you are a business customer of Philips, the controller of your personal data for the purposes identified in this section is Philips International B.V. as well as the Philips affiliated company with whom you have a commercial relationship.

• to organize and facilitate the event and provide you with an acceptable service. This may include activities such as contacting you about the event logistics, handling any dietary requirements or access provision you may need (if we do so, we don’t share this information in any identifiable way with the venue, and we delete it after the event), provide you access to the content of the event (e.g. link to the recording once the event has concluded);
• to contact you after the event for commercial opportunities about Philips products or services.

What personal data we process
We process the following categories of personal data:

• Contact information, such as your name and email, country;
• Professional information, such as your company name, job title, specialty, function.
• Product/service interest
  
  

Lawful basis for processing
The lawful basis we rely on to process your personal data for the purposes described in this section is our legitimate interest, in particular our necessity to protect fundamental rights such as the right to property, and the freedom to conduct a business.

Unless differently required by applicable law, when we collect any information about dietary requirements or other access requirements, we do so with your consent as this type of information is classed as special category of personal data.

Who is the controller of your personal data
The controller of your personal data is the Philips affiliated company of the country where you join the event or from where the event is organized, identified in our Terms of use (see the footer) as being the operator of this website.

• If you have accepted the targeted advertising cookie category when browsing our website, we track your interaction with our websites and mobile apps to see what you are interested in. If you also give us your consent to receive promotional communications we will use the data about your interaction with our websites and mobile apps to send you promotional communications that are relevant and of interest to you. For example, if you visited a certain product in our website, we may send you promotional emails about such product or similar products.
  
• If you give us your consent to receive promotional emails, we will send you such promotional emails. We track whether you open, read or click on the content of the promotional email that you’ve received from us. For example, if you click on a certain product (within the promotional email that you have received), we may send you promotional emails about such product or similar products.
  
• If you give us your consent to receive promotional communications while you are creating a MyPhilips account or purchasing a product or service in our online shop with a MyPhilips account, we will use certain data that you provide to us (such as information connected to your account or to your order or information that you provide to us, e.g. your date of birth) in order to send you promotional communications that are relevant and of interest to you. For example, if you have purchased a shaver in our online shop with your MyPhilips account, we may use your online purchasing data to let you know that we have discounts on shaver’s accessories or similar products.
• If you give us your consent to receive promotional communications via our dedicated forms published in our websites or social media pages, we will use that data that you provide to us via these forms (such as your name and email – and your job title/company, specialty or area of care in case you subscribe via the Customer forms directed at Professionals or Customer representatives) as well as information about your country to send you promotional communications that are relevant and of interest to you. For example, if we notice that you are regularly viewing our shavers from a specific country, we may send to you promotional communications about shavers or similar products in the language of that country.
• If you give us your consent to receive promotional communications while you are interacting with our support team, we will use certain data that you provide to us (such as your email and the type of product/service for which you requested assistance) in order to send you promotional communications that are relevant and of interest to you. For example, if you have requested assistance on a shaver, we may send to you promotional communications about shavers or similar products.

Keep in mind that we may combine the data we collect about you from the Philips sources listed above and place them in one or more segments (groups having certain characteristics in common) in order to tailor our promotional emails to your interest.

Lawful basis for processing
The lawful bases we rely on to process your personal data for the purposes described in this section are:

• Your consent; as a general rule, we will only send you promotional communications when you have provided your prior consent; Of course, you can withdraw your consent to receive our tailored promotional emails at any time. You can do so by clicking the unsubscribe button at the bottom of the promotional email that you have received from Philips and you will be automatically unsubscribed.
• Our legitimate interest, in particular our necessity to protect fundamental rights such as the freedom to conduct a business.

Who is the controller of your personal data

The controller of your personal data is the Philips affiliated company of the country where you signed up to receive promotional emails (identified in our Terms of use - see the footer - as being the operator of the website) as well as Philips International B.V.

Social media advertising
We use social media to keep you updated about new and existing Philips products and services and to build a commercial relationship with you.

Why we process your personal data and what personal data we process
As said above, we process your personal data to reach out to you - via social media – with promotional communications or ads about new and existing Philips products and services and about our events. For example, if you have accepted the Targeted advertising cookies in our website, we may track your usage of our websites (such as the actions you have taken on our website) and show you relevant Philips ad on your social media.
If you give us your consent to receive promotional communications (e.g. via our dedicated forms published in our websites), we may provide your personal data (such as your email) to social media providers so to show you relevant Philips ads on such social media.
If you are representative of an existing or potential Philips’ customer or business partner (or prospective), we may use your personal data to engage with you - via social media (e.g. LinkedIn) - for commercial opportunities.

Lawful basis for processing
The lawful bases we rely on to process your personal data for the purposes described in this section are:

• Your consent; this applies when before we collect your behavior on the website and place the relevant cookies and similar technologies in your device; and when we use your consent to receive marketing communications in order to target you on social media via our Partners.;
  
• Our legitimate interest, in particular our necessity to protect fundamental rights such as the freedom to conduct a business. This applies when we process your personal data to build your (prospect) customer profile and engage with you via social media for commercial opportunities.

Who is the controller of your personal data
The controller of your personal data is the Philips affiliated company of the country where you signed up to receive promotional emails (identified in our Terms of use - see the footer - as being the operator of the website) as well as Philips International B.V.

• Account information, such as your first name, surname and email; this means that your participation will be linked to your MyPhilips account.
  
• Information that you provide to us (such as your name and email), in case you participate by singing up to receive our promotional communications.
• Proof of purchase of product and other data that allows us to verify you meet the conditions of the promotion and to select the winner of the contest (based on the rules that you accept when you decide to participate).
• Email and Address information (if you are selected as a winner) to inform you that you are selected as a winner, to send our prize at the address specified in the registration process and to verify if you comply with the terms of the contest and act accordingly.
• Bank account number for cashback promotions where we will deposit the amount rewarded in the promotion.
• Material or content generated and provided by you that allows you to participate in the sweepstake, contest, game or other competition.

Lawful basis for processing
The lawful basis we rely on to process your personal data for the purposes described in this section is our need to enter into or perform a contract with you, or to take pre-contractual steps at your request, specifically to execute the terms of use of the relevant promotion.

Who is the controller of your personal data
The controller of your personal data is the Philips affiliated company identified in the terms of use of the relevant promotion, made available to you in our website.

• to report any serious incident to health authorities after they have established the causal relationship between that incident and the device, or that such a causal relationship is reasonably possible;
  
• to analyze and report on statistically significant increase (either frequency or severity) of non-serious incidents or side-effects that may affect the device's risk-benefit analysis;
• to analyze, investigate and take field corrective actions as appropriate in relation to serious incidents.

What personal data we process
We process the following categories of personal data:

• Log files
• Contact information relating to reporters of incidents
• Information about patients/other individuals contained in the incident/complaint/feedback.
• Log files or Medical images, which may contain patient’s details such as age, sex, weight.

Keep in mind that we have no access to directly identifiable information about patients as they are kept confidential by the relevant healthcare provider and not required for the processing operations we undertake.
 

Lawful basis for processing
We process your personal data in order to comply with a legal or regulatory obligation to which Philips is subject when we report (a) adverse events to competent authorities, and (b) trends of statistically significant increase (in frequency/severity) of non-serious incidents, and when we manage complaints;

We process your personal data for the performance of an activity carried out in the public interest when we investigate incidents to identify root cause and needed preventive, corrective, field safety corrective action; detect trends of statistically significant increase (in frequency/severity) of non-serious incidents.

How long we keep your personal data
Philips as a manufacturer is required to keep their devices' technical documentation, up to date and available for the competent authorities for a period of at least 10 (implantable devices 15) years after the last device covered by the same declaration of conformity has been placed on the market (i.e. sold).

Who is the controller of your personal data 
The controller of your personal data is the Philips affiliated company who is the manufacturer of the medical device as indicated in the regulatory label of the relevant device.

Why we process your personal data
We process personal data for the following purposes:

• to perform clinical evaluation aimed to confirm the safety and performance of our medical devices prior to placing them on the market;
• to conduct clinical investigations aimed to: (i) establish the suitability of the design, manufacturing and packaging of our medical device for its intended purpose under normal conditions of use,; and (ii) to establish and verify the clinical benefits of the medical device for patients and to establish and verify the clinical safety of the device; and (iii) to determine undesirable side-effects and to assess whether those risks are acceptable risks when weighed against the health benefits of the medical device.
• to perform and update the clinical evaluation of the medical device and to perform post-market surveillance.

What personal data we process
We process the following categories of (retrospective) data:

• General information about patients (such as age, category, sex);
• Data concerning health, depending on the type of medical device that was the subject of the clinical investigation.

Keep in mind that we have no access to directly identifiable information about patients as they are kept confidential by the relevant healthcare provider and not required for the processing operations we undertake.

Lawful basis for processing
Unless differently required by applicable law:

• When we conduct clinical investigations with the aim to comply with medical device manufacturer’s obligations (for example, when assessing the safety, performance, and quality of our medical devices) we do so in order to carry out an activity in the public interest. 
• When we conduct clinical investigations with the aim to make better products improving healthcare, we do so in order to carry out an activity in the public interest.
• When we report serious adverse events that take place during a clinical investigation, we do so in order to comply with a legal or regulatory obligation to which Philips is subject to.

Who is the controller of your personal data
The controller of your personal data is the Philips affiliated company who is the manufacturer of the medical device or whom is the sponsor of the clinical investigation, indicated in the study documentation or in other relevant documentation provided by the healthcare provider.

In some cases, clinical investigations are jointly performed by the Philips affiliated company who is the manufacturer of the medical device (indicated in the study documentation or in other relevant documentation provided by the healthcare provider) together with the Philips affiliated companies located in the Netherlands (Philips Electronics Netherlands B.V. or Philips International B.V.), France (Philips France Commercial SAS) and Germany (Philips GmbH).

Why we process your personal data
We process personal data for the following purposes:

• To perform clinical studies about the medical device based on legal obligations to which Philips is subject;
• to perform and update the clinical evaluation of the medical device and to perform post-market surveillance.
• to evaluate, assess, test, develop, improve the (safety or) performance of our medical device aiming to make better products improving healthcare.

What personal data we process
We process the following categories of (retrospective) data:

• General information about patients (such as age, category, sex);
• Data concerning health, depending on the type of medical device that was the subject of the clinical investigation.

Keep in mind that we have no access to directly identifiable information about patients as they are kept confidential by the relevant healthcare provider and not required for the processing operations we undertake.

Lawful basis for processing
Unless differently required by applicable law:

• When we conduct clinical studies with the aim to comply with medical device manufacturer’s obligations (for example, when assessing the safety, performance, and quality of our medical devices) we do so in order to carry out an activity in the public interest.
• When we report serious adverse events that take place during a clinical study, we do so in order to comply with a legal or regulatory obligation to which Philips is subject to.
• When we conduct clinical studies with the aim to evaluate, assess, test, develop, improve the (safety or) performance of medical devices aiming to make better products improving healthcare, we do so based on the scientific research exemption or, where required, based on consent.
   

Who is the controller of your personal data
The controller of your personal data is the Philips affiliated company who is the manufacturer of the medical device or whom is the sponsor of the clinical study, indicated in the study documentation or in other relevant documentation provided by the healthcare provider.

In some cases, clinical investigations are jointly performed by the Philips affiliated company who is the manufacturer of the medical device (indicated in the study documentation or in other relevant documentation provided by the healthcare provider) together with the Philips affiliated companies located in the Netherlands (Philips Electronics Netherlands B.V. or Philips International B.V.), France (Philips France Commercial SAS) and Germany (Philips GmbH).

Why we process your personal data
We process your personal data for the following purposes:

• to communicate with you, e.g. by answering your requests or sending transactional communications;
• to initiate, plan, and maintain our (contractual) relationship with the customer, supplier or business partner you represent, e.g. by contracting, processing payments, accounting/billing/invoicing, managing credits, managing shipping and deliveries, handling repairs;
• [if you are a business Customer] to provide you with the requested product and services, such as providing technical support;
• [if you are a business Customer] to give you access to our Customer Service portal.
• to provide you or your representatives with trainings or demo sessions;
• [if you are a business Customer] to extend to you credit, upon your request.
• to ensure compliance with our General Business Principles and other applicable laws and regulations we are subject to, such as conducting screenings in order to assess what compliance and (commercial/credit) risks are associated with potential business relationships or collecting/responding to quality complaints regarding our medical devices.

What personal data we process
To manage our business relationship with you and ensure compliance with applicable laws, we process the following categories of personal data:

• contact information, such as full name, job title/role, business email, business address, business phone number;
• payment information, such as data necessary to process payments;
• Publicly available data, such as information relating to owners, majority shareholders, and top-level management or executives of our suppliers and business partners collected from trusted publicly available sources;
• Data you provide to us, for example when you interact with a Philips representative;
• Information about individuals that report adverse events or make quality complaints, including healthcare professionals, such as name, email, postal address.
• Device data, such as log-files.

Lawful basis for processing
The lawful bases we rely on to process your personal data for the purposes described in this section are:

• our need to perform a contract to which you are subject, or to take pre-contractual steps at your request.
• our legitimate interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business.
• our need to comply with legal obligations we are subject to.

Why we process your personal data
We process personal data for the following purposes.

• Business process execution and internal management. This purpose includes activities such as conducting (internal) audits and investigations, management of alliances, ventures, mergers, acquisitions and divestitures, re-organizations or disposals and integration with purchaser.
• Development and improvement of applications, products and/or services. This purpose includes activities such as the development and improvement of Philips’ products, systems and/or services.
• Security and protection of interests and/or assets of Philips. This purpose includes activities connected to the security and protection of the interests and/or assets of Philips and its customers, Business Customers and business partners, including the safeguarding of the security and integrity of their business sector. In particular, it includes activities such as detecting, preventing, investigating and combating (attempted) criminal or objectionable conduct directed against Philips, its employees or other individuals, activities such as those involving health and safety, authentication of customer, supplier or business partner status and access rights and activities such as deploying and maintaining technical and organizational security measures.
• Protection of Philips’ intellectual property rights This purpose includes activities such as filing and managing intellectual property rights of Philips and it may require the processing of personal data of inventors and other individuals.
• Creation and disclosure of promotional material This purpose includes activities such using photos and videos (which may contain data relating to individuals) in promotional material, which may be disclosed to customers or made available online.
• Compliance with legal obligations. This purpose includes the Processing of Personal Data in connection with the performance of a task carried out to comply with a legal obligation to which Philips is subject, including the disclosure of Personal Data to government institutions or supervisory authorities, including tax authorities and other competent authorities for the sector in which Philips operates.
• Defense of legal claims.

This purpose includes activities such as preventing, preparing for or engaging in dispute resolution.

What personal data we process
Depending on the specific purpose, we process various categories of personal data (such as contact information data and any other information required to fulfill the above purposes).

Lawful basis for processing
The lawful bases we rely on to process your personal data for the purposes described in this section are:

• our need to perform a contract to which you are subject, or to take pre-contractual steps at your request.
• our legitimate interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business.
• our need to comply with legal obligations we are subject to.
• the consent of the relevant individuals;
• Any other legal ground anyhow permitted by applicable laws.