IT Providers
These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided.
The Philips GroomTribe App (“App” ) provides you with personalised skin cleansing and shaving routine services; personal skin coaching and/or shaving programs; style and shaving advice; personalised advice on best facial styles; shaving and styling tips; and other services ("Services"). The App uses personal data collected or processed through the App, including personal data processed by any eligible Philips electric shaver that you decide to pair with the App (“Device”).
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. This Privacy Notice applies to personal data collected or processed by the App, which is controlled by or under control of Philips Consumer Lifestyle B.V. or any of its affiliates or subsidiaries (”Philips”, “our”, “we” or “us”). Please also read our Cookie Notice and Terms of Use, which describe the terms under which you use our Services.
We receive or collect information and personal data, as described in detail below, when we provide our Services, including when you access, download, install the Device or 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, customise, support and market our Services based on our legitimate interest, or to comply with a legal obligation to which we may be subject. We associate your personal data with unique identifiers. If you do not want us to collect and 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 in accordance with article 9.2.a. of Regulation (EU) 2016/679. This data may include your:
Skin or facial photo; physical attributes such as face shape, hair colour, hair growth; We use this data to provide our Services, including providing personalised style and shaving advice. We do this by sending you emails, push notifications, in-app content and in-app messaging. We also provide you with personalised Device settings. If you do not provide consent, this data will remain your mobile device, where Philips will not be able to see it. Please note that if you use the Skin Analyst Sensor (for your iPhone), the iPhone records a detailed picture of your skin and sends it to the App. This photo is stored on your iPhone. On devices that support it, the app uses the TrueDepth camera in order to allow for face tracking functionalities. Specifically, this app uses face tracking for previewing different beard styles on your face. Information from the TrueDepth camera is used in real time — we don't store this information on our servers or share it with third parties. Other than provided above, we ask you not to send or disclose any sensitive personal data (e.g., 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) to us, on or through the App, or by any other means.
Account Data We collect your personal data when you create an account. You may login to the App using a MyPhilips account or by using your social media profile, including your Apple account.
Because we use your Account Data to provide the Services, we consider this processing 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.
Cookies and analytics We use cookies, tags or similar technologies (“Cookies”) to operate, provide, improve, understand, and customize our Services. Cookies allow us to recognize your mobile device and collect information and 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. We may also show you country specific content (including information in your local language), based on your mobile device’s IP address and SIM card carrier information.
You can reject the collection of Cookie data in the App at any time. For further information about the use of Cookies in this App, please read our Cookie Notice, which you can find under the privacy settings of the App. Please note that to give you a more personalized experience, we may process your analytics data to show you the right content and send you recommendations, in-app messages and push notifications. We also use your Cookie and analytics information to ask you questions or inviting you to participate in surveys or research projects. When you decide to participate, we process your account credentials, responses, opinions and experiences. We use your personal data and information to improve the Services and develop new products for you in the male grooming appliances domain. Please note that we only process your analytics information after you have provided consent in accordance with Article 6.1.(a) of Regulation (EU) 2016/679. Ratings and reviews data If you write a review on the app stores, we review and process your comments for product improvement purposes. 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. We can only see your app store username and your comments. In this case, 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. Where you require customer support, we guide you through our customer support process in accordance with section Customer support further below.
When you consent to sharing your App data to help improve the App and receive personalized services, we collect and process your App usage data as detailed below. To do so, we may use several service providers that process your App data on our behalf and pursuant to our instructions. Our service providers use Cookies to help us collect your information:
Customer support data When you require 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 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 analyse your combined data to provide you with services such as a personalised skin cleansing and shaving routine; personal skin coaching and/or shaving programs; style and shaving advice; personalised advice on best facial styles; shaving and styling tips; and to help us improve the content, functionality and usability of the App, Device and Services, as well as to develop new products and services in the male grooming domain. 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. 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 behaviour, 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 behaviour and provide you with a more relevant and personalized experience, we may analyse your Combined Data. You may opt-out and unsubscribe from such communications at any time.
We may combine your personal data, including Account Data, Cookies, etc., with 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.
Permissions
The App may request your permission to access your mobile device’s storage capabilities, sensors or other features (e.g. photos, agenda, contacts, camera, Wi-Fi, geo-location, or Bluetooth). We require access when strictly necessary to provide the Services as detailed below.
With whom do we share your personal data? 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.
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: 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. 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. 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. At your request, we may share your personal data with the following third parties:Amazon (If Amazon DRS is available in your country – see further details below). These third parties may provide their own services to you. We may share your personal data with these third parties at your request and/or in accordance with applicable laws. Please note that when you log in to the App via the Facebook SDK, you enable Facebook to collect the following information through the SDK: 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. Amazon Alexa / Amazon Dash Replenishment Services (DRS).
Service providers
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, 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 http://ec.europa.eu/justice/data-protection/internationaltransfers/adequacy/index_en.htm). 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. IT Providers These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided. Cloud Providers These providers deliver data storage services. Philips is committed to store your personal data in your region, with cloud services in Europe, US, Latin-American, Tokyo or Sydney and China. Master service Providers These providers deliver specific services for Master such ascalculating heart-age, providing coaching (only for apps that use coaching). Payment These providers handle financial data in relation to online purchases, your program fee. IT Providers These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided. Cloud Providers These providers deliver data storage services. Philips is committed to store your personal data in your region, with cloud services in Europe, US, Latin-American, Tokyo or Sydney and China. Master service Providers These providers deliver specific services for Master such ascalculating heart-age, providing coaching (only for apps that use coaching). Payment These providers handle financial data in relation to online purchases, your program fee. IT Providers These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided. Cloud Providers These providers deliver data storage services. Philips is committed to store your personal data in your region, with cloud services in Europe, US, Latin-American, Tokyo or Sydney and China. Master service Providers These providers deliver specific services for Master such ascalculating heart-age, providing coaching (only for apps that use coaching). Payment These providers handle financial data in relation to online purchases, your program fee. IT Providers These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided. Cloud Providers These providers deliver data storage services. Philips is committed to store your personal data in your region, with cloud services in Europe, US, Latin-American, Tokyo or Sydney and China. Master service Providers These providers deliver specific services for Master such ascalculating heart-age, providing coaching (only for apps that use coaching). Payment These providers handle financial data in relation to online purchases, your program fee. IT Providers These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided. Cloud Providers These providers deliver data storage services. Philips is committed to store your personal data in your region, with cloud services in Europe, US, Latin-American, Tokyo or Sydney and China. Master service Providers These providers deliver specific services for Master such ascalculating heart-age, providing coaching (only for apps that use coaching). Payment These providers handle financial data in relation to online purchases, your program fee. IT Providers These providers deliver the necessary hardware, software, networking, storage, transactional services and/or related technology required to run the App or the services provided. Cloud Providers These providers deliver data storage services. Philips is committed to store your personal data in your region, with cloud services in Europe, US, Latin-American, Tokyo or Sydney and China. Master service Providers These providers deliver specific services for Master such ascalculating heart-age, providing coaching (only for apps that use coaching). Payment These providers handle financial data in relation to online purchases, your program fee. Master service Providers These providers deliver specific services for Master such ascalculating heart-age, providing coaching (only for apps that use coaching). Master service Providers These providers deliver specific services for Master such ascalculating heart-age, providing coaching (only for apps that use coaching).
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.
Please note that: We will only process your data for Philips’ legitimate interests when we’ve concluded that the processing will not outweigh your privacy rights and interests.
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.
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 If you have any question about this Privacy Notice or about the way in which Philips uses your personal data, you may contact Philips and/our Data Protection Officer 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
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: https://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 and process about California residents via the Device and/or the App. For details on how we handle Personal Information pursuant to the CCPA in other contexts, please go here. Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household. Sources of Personal Information We collect Personal Information from: Collection and Disclosure of Personal Information The following chart details which categories of Personal Information about California residents we plan to collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.
Categories of Personal Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes |
Identifiers, such as name, contact information, IP address and other online identifiers. | Our affiliates and subsidiaries; trusted third-party service providers; business partners; third-party sponsors of sweepstakes, contests and similar promotions; your social media account providers, in connection with the social sharing you choose to use in accordance with section “ With whom do we share your personal data?” |
Personal information as defined in the California customer records law, such as name and contact information. | Our affiliates and subsidiaries; trusted third-party service providers, in connection with the social sharing you choose to use in accordance with section “ With whom do we share your personal data?” |
Characteristics of protected classifications under California or federal law, such as age and primary language | Our affiliates and subsidiaries; trusted third-party service providers, , in connection with the social sharing you choose to use in accordance with section “ With whom do we share your personal data?”. |
Internet or network activity information, such as browsing history and interactions with our online services | Our affiliates and subsidiaries; trusted third-party service providers, in connection with the social sharing you choose to use in accordance with section “ With whom do we share your personal data?” |
Geolocation data, such as device location. | Our affiliates and subsidiaries; trusted third-party service providers, in connection with the social sharing you choose to use in accordance with section “ With whom do we share your personal data?” |
Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences, behaviour and characteristics | Our affiliates and subsidiaries; trusted third-party service provider, in connection with the social sharing you choose to use in accordance with section “ With whom do we share your personal data?” |
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 de we collect and for which purposes?” We do not sell and have not sold Personal Information in the preceding 12 months, as “sale” is defined in the CCPA. We do not sell the Personal Information of minors under 16 years of age. Individual Rights and Requests If you are a California resident, you may request that we: To make a request for the disclosures or deletion described above, please contact us at: https://www.philips.com/a-w/privacy/questions-and-feedback.html or (866) 309-3263. We will verify and respond to your request as described above in “Your Choices and Rights” and consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as email address, mailing address, or telephone number in order to verify your identity and protect against fraudulent requests. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA. Authorized Agents If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable: If you are making a request on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4000-4465, we may also require the resident to:
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