PHILIPS HEADPHONES APP – PRIVACY STATEMENT

Date: December 2025 (includes information on rights under the EU Data Act (Regulation EU 2023/2854)

TP Vision Europe B.V. ("us", "we", or "our") operates the Philips Headphones App (hereinafter referred to as the "App").

This Privacy Statement informs you of our policies regarding the collection, use, and disclosure of personal data when you use our App and the choices you have associated with that data.

We use your personal data to provide and improve the App. By using the App, you agree to the collection and use of information in accordance with this Privacy Statement. Unless otherwise defined in this Privacy Statement, the terms used in this Privacy Statement have the same meanings as in our Terms of Use, accessible from within the App.

Definitions

Service

Service is the App operated by us.

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personal Data may include:

·         User headphones MAC address

·         Headphones information (region, language. brand, model, type, SoC, manufacturer ID)

 

For headphones that offer the AI Translation feature the following Personal Data is processed in addition when the feature is activated:

 

·         E-mail address and password for account creation

·         IP address to identify the region and determine the appropriate server location (EU/non-EU)

·         Recorded voice data in order to provide the translation feature

·         Translations and/or transcripts of voice data

Usage Data

We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), MAC address, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Use of Data

We use the collected data for various purposes:

·         To provide and maintain the Service

·         To provide analysis or valuable information so that we can improve the Service

·         To monitor the usage of the Service

·         To detect, prevent and address technical issues

Transfer of Data

Your information, including Personal Data, may be transferred to - and maintained on - servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Europe and choose to provide information to us, please note that we transfer the data, including Personal Data, to Europe and process it there.

Your consent to this Privacy Statement followed by your use of the App represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Statement and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Legal Requirements

We may disclose your Personal Data in the good faith belief that such action is necessary to:

·         To comply with a legal obligation

·         To protect and defend our rights or property

·         To prevent or investigate possible wrongdoing in connection with the Service

·         To protect the personal safety of users of the Service or the public

·         To protect against legal liability

Your Rights and Account Deletion

Users that have created an account within the App have the option to delete their account including all associated data from within the App by navigating to the Account page and choosing “Cancel account”.

As a European citizen, under GDPR, you have certain individual rights. If you want make use of these rights, you can submit an application free of charge to gain access to this information.

Upon receipt of your request and details to verify your identity (such as a copy of your passport), you will be provided with a copy of the personal data held by us, the origin of the data, the purposes for which the personal data are used and the recipients. You can also indicate that certain changes in personal data, if you qualify them as incorrect or irrelevant, must be implemented. You can also have your personal data blocked, erased or completely deleted (right to be forgotten).

Your Rights under the EU Data Act (Regulation (EU) 2023/2854)

In addition to your rights under the General Data Protection Regulation (GDPR), users located in the European Union also benefit from specific rights regarding data generated through the use of connected products and related digital services under the EU Data Act (Regulation (EU) 2023/2854).

 

1. Scope of Device and Service Data

When you use the App and compatible connected headphones, the following categories of data may be generated:

·         Technical device data (e.g. identifiers, hardware characteristics, firmware information, diagnostic logs)

·         Usage and performance data of the headphones and App

·         Service-related data generated through use of App functionalities, including AI translation features where applicable

This data may consist of both:

·         Personal data, which is subject to the GDPR, and

·         Non-personal data, which is regulated under the EU Data Act.

2. Right of Access to Device and Service Data

You have the right to request access to the data generated by the connected headphones and the related digital services that concerns your use of the App. Upon request and where technically feasible, we will provide you with such data in a structured, commonly used and machine-readable format, in accordance with Article 4 of the EU Data Act. This right exists independently from your GDPR right of access under Article 15 GDPR.

 

 

 

3. Right to Data Sharing with Third Parties

You have the right to request that the data generated through your use of the connected product and related services be transmitted directly to a third party designated by you, where such transmission is technically feasible and does not adversely affect the rights of others.

Such transmission shall be carried out securely and in compliance with applicable legal and technical requirements in accordance with Article 5 of the EU Data Act.

 

4. Technical Feasibility and Attribution Limitation

The rights of access to data and of data sharing with third parties under the EU Data Act apply only to the extent that the relevant device-generated or service-related data can be technically attributed to the requesting user or their connected headphones and where the provision or transmission of such data is technically feasible. Where data is stored in an anonymized and non-attributable manner, individual extraction or transmission may not be possible.

 

5. Use of Device and Service Data

We use product-generated and service-related data exclusively for the following purposes:

·         To provide and technically operate the App and connected headphones

·         To ensure functionality, safety, security and performance

·         To maintain, diagnose and improve the Service

We do not use such data for unrelated commercial purposes or make it available to third parties for their own independent use unless:

·         You have explicitly requested such data sharing, or

·         A legal obligation requires us to do so.

6. Protection Against Unlawful International Access

Where device or service data is transferred outside the European Economic Area, such transfers take place in accordance with applicable data protection laws and appropriate safeguards, including standard contractual clauses and supplementary technical and organizational measures. We also take appropriate measures to protect against unlawful access by public authorities in third countries.

 

7. Relationship with GDPR Rights

Where device or service data qualifies as personal data, your rights under the GDPR (including access, rectification, erasure, restriction, portability and objection) continue to apply without limitation.

Requests under the EU Data Act may be submitted via the contact details provided in the “Contact Us” section of this Privacy Statement.

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Statement

We may update our Privacy Statement from time to time. We will notify you of any changes by posting the new Privacy Statement on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Statement.

You are advised to review this Privacy Statement periodically for any changes. Changes to this Privacy Statement are effective when they updated in the App.

Contact Us

If you have any questions about this Privacy Statement or under the EU Data Act, please contact us:

TP Vision Europe B.V., Prins Bernhardplein 200, 1097JB Amsterdam, the Netherlands

Or by e-mail: privacy@tpv-tech.com