Philips Sonicare App Privacy Notice
This Privacy Notice was last updated on 22 September 2022.
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 information and personal data we collect, why we collect it and what we do with it, as well as your individual rights. The controller of your personal data under this Privacy Notice is Philips Oral Healthcare, LLC with address at 22100 Bothell Everett Highway, Bothell WA 98021, USA ("Philips", "our", "we" or "us"). Please also read our Analytics Notice(s) and Terms of Use, which describe the terms under which you use our Services.
What Information and Personal Data do we collect and for which Purposes?
We receive or collect information and personal data, as described in detail below, when we provide our Services, including when you access, download and install the app. We associate your personal data with unique identifiers.
Sensitive Personal Data We collect the following oral care data: We collect this data to provide you with the Services, including providing feedback and real time guidance while you brush; sending your push notifications and/or In-app messages in connection with the Services; give you a customized 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 associate your oral care information with your account. For Israel-based users, we use consent as legal basis for processing any personal data we receive or collect. Please note that you are under no legal obligation for providing us with any personal data and you are doing so with your own free will and consent.
Ratings and Review Data If you write a review or rate the app on the app stores, we may process such information to respond to your comments and questions, understand how you feel when using the app, get familiar with your general perception of the app and our brand, and use these insights to improve the app. We can only see your app store username, ratings, comments and any other detail you decide to share with us or make publicly available. Unless you require us to do so, we do not link this information to your account credentials or any other information we hold from you. Where you require customer support, we may use your data to follow-up on your case and guide you through our customer support process. We consider the processing of your ratings and review data to be based on a legitimate interest of Philips and lawful under Article 6.1. (f) of Regulation (EU) 2016/679.
Customer Support Data 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. In some cases, we consider the processing of your Customer Support Data to be based on a legitimate interest of Philips and lawful under Article 6.1. (f) of Regulation (EU) 2016/679.
Combined Data We may combine your personal data, including 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 consent to receiving promotional communications about Philips products, services, events and promotions that may be relevant to you based on your preferences and online behavior, 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 analyze your Combined Data. You may opt-out and unsubscribe from such communications at any time. Before sending promotional communications to you, we will ask your consent in line with Article 6.1. (a) of Regulation (EU) 2016/679 or any other applicable law.
Permissions
The app may request your permission to access your mobile device’s storage capabilities, sensors or other features (e.g. photos, calendar, contacts, camera, Wi-Fi, geo-location, or Bluetooth). We require access when strictly necessary to provide the Services as detailed below.
With whom are Personal Data shared?
Philips may disclose your personal data to our affiliates, third party service providers, business partners, or other third parties in accordance with this Privacy Notice and/or applicable law. We may share your data with other Philips entities that are part of the Philips Group. For instance, some Philips entities may help us manage the app infrastructure or manage your inquiries. Only people that strictly require access to fulfil their jobs will process your data. We work with third-party service providers to help us operate, provide, improve, understand, customize, support, and market our Services. 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. If the option is available in your country, we may share your personal data with the following third parties: In this case, we may process and share your personal data based on your consent, to fulfill our contractual obligations when providing services to you or based on our legitimate interest. Please note that when you log in through your Facebook social media account via Android, you enable Facebook to collect the following information through the Facebook SDK: • App Events: This covers generic app Events (e.g. app Install, app launch) and other standard logging for product metrics (e.g. SDK loading and SDK performance). • Configuration data: After a user has logged in, the SDK makes periodic background requests to manage the lifetime of the access token automatically. • Error information: The SDK captures error information, including during initialization of the SDK, which may include a user ID of individuals who are logged in to Facebook. • Short-term data: The SDK measures some user activity for purposes of managing fraud and abuse. This data is only retained for a very short period for those not logged in to Facebook. Facebook may also collect analytics data on your use of the SDK, information about the name of the app you are using, the date when you authorized the login, and any URL associated with your login. You can find out more about how Facebook uses your information by reading Facebook's Data Policy. Please note that the Facebook login functionality is completely optional, we will always allow you to login using your Philips account. Finally, when required by law, or as necessary to protect our rights, we may share your data with public and governmental authorities.
Affiliates
Service Providers
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.
These service providers deliver the necessary hardware, software, networking, storage, and/or related technology that we require to perform app analytics or run surveys.
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 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.
Apple Health In some countries, we allow you to exchange data with Apple Health. If you are using iOS, you can authorize the app to read data from your Apple’s Health app as well as to write data to Apple’s Health app. The data you may exchange includes your brushing duration and is subject to your choices. Philips’ cloud solutions do not sync with Apple. This means that the exchange of data only happens locally in your mobile device. Make sure to check Apple’s privacy notice to understand how they handle your personal data.
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 or Israel, your personal data may be transferred to our affiliates, service providers or third parties 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 or Israel to countries not considered adequate by the European Commission, such as the United States, we (i) 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; or (ii) rely on your prior explicit consent if necessary. You may obtain a copy of these measures by following the link above or by contacting us here.
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 here. 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. Where we rely on performance of a contract to process your personal data for purposes of the Services, we may not be able to provide the Services if we do not receive your information.
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.
When we process your personal data based on a legal obligation to which we are subject, including when you interact with us to exercise any of your rights, we consider the processing to be lawful in accordance with Article 6.1.(c) of Regulation (EU) 2016/679.
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 here. 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 For purposes of article 27 of Regulation (EU) 2016/679, Philips International B.V. (High Tech Campus 5, Eindhoven, 5656 AE, the Netherlands) acts as our Representative in the European Union.
If you have any question about this Privacy Notice or about the way in which Philips uses your personal data, you may contact us (including our Data Protection Officer and/or Representative) here. Alternatively, you have the right to lodge a complaint with a supervisory authority competent for your country or region.
