隱私政策
Summary of Our Legal Policies
PRIVACY POLICY WITHINGS
The Withings Privacy Policy (this “Privacy Policy”) describes how Withings SAS ("Withings," "we," "us," or "our") collects, processes, stores, and discloses your personal data when providing services to users through its website, apps, products, and services (our "Services").
YOUR PRIVACY AT THE HEART OF OUR SOLUTIONS
We thank you for your trust and do our best to honor it. We process the personal data you entrust to us to help you improve your health with the utmost care. Respect for privacy is a core principle that we place at the heart of our strategy for developing our Products and Services. We are committed to a process of continuous improvement to ensure the utmost respect for your personal data. If you have any questions please contact us.
THE SECURED HOSTING OF HEALTH DATA, OUR DAILY PRIORITY
We pay maximum attention to the security of the hosting of your health data. We apply demanding regulations and standards. Thus, in addition to our compliance with the GDPR, we are certified ISO 27001 and HDS (Health Data Hosting) which allows us to provide you with the same level of security as health professionals. We host health data on our certified health data processing platform, whose servers are located in France, at a European operator (BSO). Withings is also ISO 27701 certified, an international standard guaranteeing a high level of protection for personal data.
GLOBAL AND UNIFORM APPLICATION
This Policy applies uniformly to all Users of the Withings App, regardless of where you live. We take into consideration the regulations on the protection of personal data applicable to the markets in which WITHINGS sells its Products and Services.
I. FEW KEY CONCEPTS
This Privacy Policy applies to the use of the Withings App published by WITHINGS. Withings App is an application (web and mobile) with paid versions (for the users of Withings +) that focuses on three areas: (i) health monitoring, (ii) motivation maintenance, (iii) installation of WITHINGS products. Withings App can be used alone or in conjunction with our products. The personal health data you entrust to us is sensitive data that we process in accordance with identified legal bases and with the highest security standards.
« Anonymized Data » means data resulting from the processing of personal data in such a way as to prevent the identification of the data subject in an irreversible manner, taking into account the techniques that can reasonably be implemented.
« Pseudonymized Data » means Personal Data that is not directly linked to a natural person without the use of additional information.
« Personal Data » means any information relating to an identified or identifiable individual. This includes all kinds of information: last name, first name, postal address, e-mail address, etc. It also covers the notion of Personally Identifiable Information (PII) provided for by the American regulation.
« Health Data » means personal data relating to your past, present or future state of health (physical or mental). Health Data is particularly sensitive data and is therefore subject to special protection measures.
GDPR: General Data Protection Regulation (EU) 2016/679. WITHINGS applies the GDPR all over the world.
II. SOURCE OF THE PERSONAL DATA WE PROCESS
Personal Data is collected when you visit our website, use our Products and Services, browse on the application.
- Our website: Regarding the data collected on the website of WITHINGS, please refer to our Cookies Policy.
- Account creation: When you create a WITHINGS account, you fill in personal data relating to your identity (name, surname, age, email address).
- Use of our Products and Services: Personal Data is collected (such as number of steps, distance traveled, calories burned, weight, heart rate, sleep patterns, and in some cases your location).
- Partner Applications: When you connect your Withings App account with third-party applications or products, data will be synchronized.
- Targeted communication: We create groups of users with similar interests to offer tailored communications and advertising content. We never share health data with these partners.
- Customer Support: No Health Data is accessible to our customer support staff without your prior consent.
III. YOUR CONSENT
We collect your consent to process Personal Data for creating your account, participating in research programs, sharing data with third-party apps, enabling 2FA, marketing communications, viewing routes, Withings+ programs, and AI algorithms. You can withdraw your consent at any time via the application settings or by deleting your account.
IV. PROCESSING PERSONAL DATA
We process your data based on contract performance, your consent, legitimate interest, or compliance with legal requirements. For example, billing data is kept for 10 years due to legal requirements, while customer support tickets are kept for a maximum of 10 years.
We share data with internal teams, expert subcontractors complying with GDPR, Heartbeat Health (US only for ScanWatch ECG activation), and when required by legal authorities.
V. DATA RETENTION
Your Withings App account will be considered inactive if for 10 years you have not used the application, performed measurements, or clicked on links in emails from WITHINGS. Following a 90-day notice, your account and associated data will be deleted.
VI. HOSTING, TRANSFER AND SECURITY OF DATA
Your Personal Data is hosted in France and Health Data is not transferred outside the EEA. Other non-health data may be communicated with partners located outside the EEA for specific purposes like telecommunications or banking security.
VII. EXERCISING YOUR RIGHTS
You may exercise your rights (Information, Access, Rectification, Limitation, Objection, Erasure, Portability) at any time by writing to privacy@withings.com. You also have the right to file a complaint with the CNIL.
VIII. PATIENT PRIVACY POLICY (RPM)
Specific provisions apply to users of the Withings Remote Patient Monitoring (“WRPM”) services. Questions regarding medical records provided by your healthcare professional should be directed directly to them.
IX. PRIVACY POLICY FOR CARDIO CHECK-UP FEATURE
This feature allows you to benefit from the rereading of your ECG by a certified doctor. If you reside in Europe, Canada or Hong-Kong, your data is shared with DPV Analytics. If you reside in the United States, your data is shared with Heartbeat Health.
Cookies and other trackers policy
This Policy explains how cookies and tracking technologies work, what Withings uses them for, and how you can manage your preferences.
What are cookies and how do they work?
A cookie is a small file stored by a server on a user's terminal (computer, mobile phone, etc.) and associated with a web domain. This file is automatically sent back for future contacts with the same domain. Cookies enable us to save your browsing preferences or keep items in your shopping cart.
What other tracking technologies are used?
We use "other trackers" on our websites and mobile application (Withings App) to track your navigation within the app, help us carry out debugging operations, or simplify the use of the app.
Categories of cookies used
- Essential cookies: Necessary to operate our websites or app (logging in, securing payments). They are enabled by default and cannot be disabled.
- Analytical/Performance cookies: Enable us to collect information about traffic and resolve potential bugs.
- Functionality cookies: Used to improve and personalize website functionalities.
- Marketing/Advertising cookies: Used to profile your interests and offer relevant advertising. Withings may share pseudonymized data (like hashed email addresses) with partners.
- Geolocation cookies: Used with your explicit acceptance.
How can you manage your preferences?
Your cookie preferences are kept for 6 months. You can modify them at any time by clicking on the “Set Cookies” link in the footer of each webpage, or by configuring your web browser options.
Contact
Withings SAS
DPO
2 rue Maurice Hartmann
92130 Issy-les-Moulineaux, France
Email: privacy@withings.com
Withings Feedback Policy
WITHINGS highly values your ideas to enhance your experience on our Products and Services. We actively encourage you to share with us your constructive ideas, inputs, comments, or feedbacks (« Feedback »).
Terms applying to Feedback
If you submit any Feedback to us, you agree to the following terms:
- Your Feedback will be non-confidential.
- WITHINGS is under no legal obligation to review nor implement changes suggested.
- Any Feedback submitted becomes the exclusive property of WITHINGS.
- WITHINGS is free to exploit, redistribute, and disclose any Feedback on an unrestricted basis and for any purpose without notification or compensation.
- You release WITHINGS from all liability and obligations that may arise from the use or disclosure of your Feedback.
Version history
Privacy Policy
Privacy Policy Supplement
| Langue | Version |
|---|---|
| Français | Version du 24 mai 2018 (version en vigueur) |
| Version du 20 juin 2017 | |
| English | Version dated May 24, 2018 (current version) |
| Version dated June 20, 2017 | |
| Deutsch | Fassung vom 24. Mai 2018 (aktuelle Fassung) |
| Fassung vom 20. Juni 2017 |