This Privacy Notice was last updated on 09/18/2020. This Privacy Notice applies to the personal data collected or processed by Philips Cares, mobile and web application (“App”) which is controlled by or under the control of Lifeline Systems Company, d/b/a Philips Lifeline or any of its affiliates or subsidiaries (”Philips”, “our”, “we” or “us”). Philips Cares are services (“Services”) comprised of an App that helps ensure the safety of Care Recipients (a person whose data is being collected and/or processed by the Lifeline) within their environment. The App permits the Care Recipient and/or their designated Account Administrator (a person authorized by the Care Recipient to act on their behalf), to create and access information related to the Care Recipient, and collaborate in a care circle of family, friends or other caregivers. This Privacy Notice is meant 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 inform you of your individual rights.
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, install or access the App, or use our Services. We may use this personal data to perform the Services requested by you as a contractual necessity, to operate, provide, improve, customize, support, and market our Services, or to comply with a legal obligation to which we may be subject. If you do not want us to collect and process your personal data, you may not be able to use the Services. Account Data We collect your personal data when you create an account. You may login to the App using a Philips Cares account. The personal data we collect to create your account includes your username, photo (optional), name (first, middle and last), email address, home address, gender, date of birth, preferred language, telephone number(s) and password. When you invite and permit caregivers to access the App and process data within the App they will receive an email with an invitation and will also create an account. The data collected includes their first name, last name, email address, phone number(s) and user name and password. The personal data collected is used to create and manage the account. You can use your account to securely login to the App. If you create a Philips Cares account to login to the App, we will send you a welcoming email to verify your username and password. We may also use your email to alert you to service-related announcements related to the App. Sensitive Personal Data Before we collect sensitive personal data, we will inform you or the Account Administrator and ask your explicit consent. You may withdraw your consent at any time including access permissions to your data by any caregiver(s) you may have identified. The type of sensitive data processed related to you includes your self-reported medical conditions and the location to the key for your home. You or your Account Administrator and individuals you invited to your care circle can also add notes related to your mobility, mood, comfort, memory, nutrition, social interaction and general well-being. Other data processed in the App includes information related to your Philips Lifeline service or other services such as your interactions with the service, information about Device(s) in use, information about the service account and information payment and billing for your service(s). Only you or your Account Administrator will have access to this information. Sensitive Personal Data We ask that you, your Account Administrator or any caregivers not send or disclose any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, criminal background or trade union membership) on or through the App or otherwise to us. Other Provided Data Cookies We use cookies, tags or similar technologies 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. You can view the cookies used via this link. 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 You may 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 you customer 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. Combined Data We may combine your personal data, including account data, other data provided by you, Device data, cookies and data collected during your interactions with the App. We combine this data and use it for analysis to provide you with Services such as insights into your well-being. We may also de-identify and aggregate data for research purposes to help us improve the content, functionality and usability of the App, Device and Services as well as to develop new products and services. 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. We may send you marketing and promotional communications via email. You may opt-out and unsubscribe from such communications at any time. Permissions The App may request your permission to access your phone or sensors (e.g. photos if wish to upload from your phone) on your mobile Device.
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. Individuals you or your Account Administrator have invited to participate in your cares circle will be able to access your Device data, any self-reported medical conditions and information related to your current well-being or status. They can also view any or all information reported by any caregiver within your care circle. They may also be notified of an alarm by push notification, email, and/or telephone call, if they are designated to do so. 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: 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. We work with service providers that may handle and process your financial data in relation to the payment features of this App, including app stores or other third parties processing your payment. These providers are v Secure Processing (VSP). 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. 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. If Philips shares personal data with a third party that uses your personal data for their own purposes, Philips will ensure to inform you and/or obtain your consent in accordance with applicable laws before we share your personal data. 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. How long do we keep your data? 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). 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. 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, of our Services anymore. 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. 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. 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. 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.
Additional information for California Residents 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 information (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 information 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 like to make such a request, please visit our privacy website: http://www.philips.com/a-w/privacy/questions-and-feedback.html Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following details regarding the categories of Personal Information that we collect, use and disclose about California residents. Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household. This section does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role at Philips. Sources of Personal Information We collect Personal Information from our interactions with you through the Device and/or the App. Categories of Personal Information Collected We collect, and have collected within the preceding 12 months, the following categories of Personal Information as listed in the CCPA: Use of Personal Information We use these categories of Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, as described above under “What Personal Data are collected and for which purposes?” Individual Rights and Requests If you are a California resident, you may request that we: • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information; • The specific pieces of Personal Information we collected about you; • The business or commercial purpose for collecting (if applicable) Personal Information about you; and • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable). To make a request for the disclosures or deletion described above, please contact us at: http://www.philips.com/a-w/privacy/questions-and-feedback.html or (866) 309-3263. We will respond to your request consistent with applicable law. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
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