The Philips Lumea IPL app helps you manage your hair removal treatments and goals when using your Lumea IPL device (“Device”), and provides you with personalized beauty and hair removal advice ("Services").
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 your individual rights.
This Privacy Notice applies to personal data processed by the app, which is controlled by Philips Consumer Lifestyle B.V., or any of its affiliates or subsidiaries ("Philips", "our", "we" or "us").
What Information and Personal Data do we collect and for which Purposes?
We process information and personal data, as described below, when we provide our Services, including when you access, download and install the app. We may process this personal data based on your consent or as requested by you as a contractual necessity, to operate, provide, improve, customize, support and market our Services based on our legitimate interest, or to comply with a legal obligation to which we may be subject. If you do not want us to process your personal data, you may not be able to use the Services.
Sensitive personal data
Before we collect sensitive personal data, we will inform you and ask your explicit consent. Subject to your choices, we allow you to securely store your beauty and hair removal details in your account so that you can easily re-store them if you install the app on another device. We also use your data to provide you with a personalized beauty and hair removal experience via for example, customized coaching programs, reminders and other services. The data processed includes your:
Based on your settings, we may send you emails, push notifications, in-app content and in-app messages. We may also combine, pseudonymize, anonymize or aggregate your data for personalization purposes. Account data We collect your personal data when you create an account. You may login to the app using a Philips account or by using your social media profile, including your Apple account. If you choose to log in via social media, the personal data we collect may include your basic public profile (e.g., profile photo, identifier, gender, profile URL, birthday, homepage, and location) and email for authentication purposes. In this case, your social media provider may collect information on the fact that you are using the app and logging in using your social media account. Please read your social media provider’s privacy notice (e.g., Facebook, Google, Apple) to learn about its privacy practices. Earlier versions of the app allowed you to use the Facebook SDK for login, which enables Facebook to process the following information:
The personal data we collect may include your username, name, email address, country, language, password, and demographic information such as gender (optional). We also process information on your app usage, including your session, login and authentication details, which we use to manage your account.
You can find out more about how Facebook uses information by reading their privacy policy. Facebook may process such information in countries outside of your country of residence, which may not provide adequate protection to personal data in line with Regulation (EU) 2016/679.
We use your Account Data to create and manage your account and provide personalized Services. You can use your account to securely login to the app. If you create a Philips account to login to the app, we will send you a welcoming email to verify your username and password, to communicate with you in response to your inquiries, to send you strictly service-related announcements, or direct marketing communications in case you have provided consent. You may also use your Philips account to order or register a Philips product or service, participate in a promotion or game, participate in a social media activity related to a Philips promotion (for example clicking "like" or "share"), and participate in product testing or surveys.
Analytics data
If you provide consent, you will help us improve the app and our connected products (as well as develop new personal health solutions for you!) based on the data we observe and collect when you use our services. We may also use these insights to further personalize our services. The data processed includes data you provide when using the app, mobile device identifiers, session and usage data, operating system, model, network information and (masked) IP addresses, and app information, such as app name, version, usage and events, pages visited and session information. We may use cookies, tags and/or similar technologies, and use service providers that process your details on our behalf and based on our instructions. We may combine, pseudonymize, anonymize or aggregate your data for statistical, analytics and personalization purposes. You can find more details under the app settings.
Cookies data
We process information from your mobile device and use cookies, tags, pixels or similar technologies (“Cookies”) to provide our Services. Our Cookies allow us to recognize your mobile device and collect information and personal data in accordance with this notice. The information we process may include your mobile device data (such as unique identifiers, session and usage data, operating system, model, carrier, network information and IP addresses) and app information (such as app name, version, usage and events, pages visited and session information). We may also use this information to show you country specific content (including information in your local language).
Marketing data
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 and online behavior, we may send you marketing and promotional communications via email, phone and other digital channels, such as mobile app 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 and combine your personal data. You may opt-out and unsubscribe from such communications at any time.
Survey & research data
We may invite you take surveys or join research studies. The personal data we collect includes your responses, which may relate to your opinion and experience when interacting with our Services or third-party services, as well as information about your beauty and hair removal routines or about any other personal health topics. We may process your survey data in combination with the analytics information we collect when you use the app. We use this data to gain an understanding of our users and use these insights to improve our apps and services in the Philips beauty domain. To do so, we analyze and aggregate your information and answers. We may run some of these projects on anonymous basis, in which case, we will not collect any personal data. In any event, whenever you join these projects, you will receive supplementary information on how your data will be handled.
Feedback data
We may ask for your feedback on your Lumea experience. In some cases, we will ask for your permission to publish your name and feedback in the app to help other users. Unless we tell you otherwise, we kindly ask you not to disclose any sensitive personal data to us, such as social security numbers, information related to racial or ethnic origin, political opinions, religious, philosophical or other beliefs, health, sex life or sexual orientation, biometrics or genetic characteristics, criminal background or trade union membership. You can always require us to delete your feedback at any time.
Customer support data
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, location data, data collected during your interactions and usage of the Philips digital channels, such as social media, websites, emails, apps and connected products, IP address, cookies, device information, communications you click on or tap, location details and websites you visit. Subject to your choices, we may analyze your combined data to provide you with the Services, such as to give you insights into your hair removal treatments and deliver personalized content, messages and tips in accordance with this notice. We may also use this data to improve the content, functionality and usability of the app and Services, as well as to develop new products and services in the beauty domain.
Ratings and reviews 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. When you require customer support, we may use your data to follow-up on your case and guide you through our customer support process in accordance with this notice.
Permissions
The app may request your permission to access your mobile device’s storage capabilities, sensors or other features. We require access when strictly necessary to provide the Services as detailed below.
In some cases, your operating system may request permissions that your mobile device needs for technical reasons, but that are not controlled or used by Philips. We will not collect any data associated with such permissions unless required to provide our services in accordance with this notice.
You may block or revoke these permissions at any time under the settings of your operating system.
Sharing your personal data with others
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.
Affiliates
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.
Service Providers
We also work with third-party service providers that help us operate, provide, improve, understand, customize, support and market our app. We may share your personal data with the following service providers:
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 information or 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 information or personal data with a third party that uses your personal data for its 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.
When required by law, or as necessary to protect our rights, we may share your data with public and governmental authorities.
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. 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, your personal data may be transferred to our affiliates or service providers 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 to countries not considered adequate by the European Commission, such as the United States, we 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. 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 process your data to provide our services based on our terms, we may not be able to provide the services if we do not process your data. Where we rely on our legitimate interests, we ensure that the processing does not outweigh your privacy rights and interests. Where we rely on consent, you may withdraw it at any time, without affecting the lawfulness of processing before your withdrawal.
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.
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 about the updates to the Privacy Notice.
Contact us
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.
Philips Consumer Lifestyle B.V.
High Tech Campus 5, 5656 AE,
Eindhoven, The Netherlands
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