A. Privacy Policy
Shure Incorporated and its Affiliates (collectively “Shure”, "us", "we", "our") is committed to protect your privacy. In this policy we will outline as to how we ensure the privacy of the personal data we have collected from you.
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1. Who controls the processing of your personal data?
As defined under applicable data protection laws, “Controller” for this website is:
Shure Distribution GmbH
Jakob-Dieffenbacher-Str. 12
75031 Eppingen
Germany
Phone: +49 (0) 7262-9249-111
Fax: +49 (0) 7262-9249-168
2. Contact Details of our Data Protection Officer
In case you have any questions regarding this privacy policy or the processing of your data in general, please contact our Data Protection Officer at:
Steffen Emhardt
datenschutz@emetz.de
EmEtz GmbH
Mühlweg 25/3
71711 Murr
Germany
3. Our Data Privacy Principles
Shure is committed to follow the following principles:
- Lawfulness, fairness and transparency
- Purpose limitation
- Data minimization
- Accuracy
- Storage limitation
- Integrity and confidentiality
- Accountability
4. What information do we collect?
All information which is related to an identified or identifiable natural person (e.g., name, address, phone number, date of birth or email address) is personal data. The processing of your personal data entails for example the data's collection, recording, usage, transmission to third parties or deletion.
Depending on your interaction with us, we collect different information from you, some of which is personal data.
4.1 Information you provide to us
Shure collects a variety of information that you directly provide to us, such as through
- Processing of Orders,
- Requests or questions you submit to us via online forms or emails,
- Any communication with us through our website, at trade shows and other special events, over the phone, on third party social media sites, by mail or Email,
- Your participation in Shure sweepstakes, contests or research,
- Any reviews you submit about Shure’s products,
- Employment applications,
- Account and products registration including warranty registration, and administration of your account,
- Requests for customer support and technical assistance.
- Product registration
Considering the above means of sharing, the types of data we collect directly from you include:
- Contact Data – name, (work) address, telephone number, cell phone number, fax number, email address, and employer
- Customer Account Data – log-in credentials, shipping address, information about purchases or other transactions with us
- Demographic information such as your gender, age (range), DOB in month and date.
- Food allergies/preferences
- Purchase history
- Product serial number
- Interests and opinions related to Shure products and services
- How you use Shure products and services
4.2 Information we collect through automated means on our websites
- Website-activity data – information such as IP address, browser type, browser language, state or country from which you accessed the website, files you downloaded, clicks, etc. (please also refer to the sections "Log Files", “Website Analytics” and “Advertising by means of tracking technologies” for further information)
- Email-activity data -information regarding the opening of emails sent by us or weblinks shared by us
- Location information – we may collect general location information (e.g. parts of your IP address, city/state/ and/or postal code associated with an IP address) from your computer
4.3 Information we collect from Social Media and other Content Platforms
You can engage with us through social media websites or through features such as plug-ins or applications on our websites that integrate with social media sites. You may also choose to link your account with us to third party social media sites. When you link your account or engage with us on or through third party social media sites, plug-ins, or applications, you may allow us to have on-going access to certain information from your social media account (e.g., name, e-mail address, photo, gender, birthday, the posts or the 'likes' you make).
If you post information when you interact with our websites through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet. You can control what information you share through privacy settings available on some social media sites. For more information about how you can customize your privacy settings and how third party social media sites handle your personal information, please refer to their privacy help guides, privacy notices and terms of use.
For further information on social plug-ins please refer to the section "Social Plug-Ins".
4.4 Information we collect through contests, sweepstakes, or questionnaires
From time-to-time we may request personal data via contests, sweepstakes, or questionnaires made available to you through our website, social media sites, or in-person (such as at trade shows, conventions, or other special events). Participation in these contests or questionnaires is completely voluntary and you may choose whether or not to participate and therefore disclose this data. The data requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age). Contact information will be used to notify the winners and award prizes. Questionnaire information will be used for purposes of monitoring or improving the use and satisfaction of our products and related services, including this website.
4.5 Information we collect through market research surveys
From time-to-time when you visit our website or social media sites or use our apps or other software we may ask you to participate in market research surveys. We may also contact you by other means (e.g., postal mail or email) or ask you in person to participate in such surveys.
Participation in these market research surveys is completely voluntary and you may choose whether or not to participate and therefore disclose this data. The data requested may include contact information (such as name and email address), demographic information (such as country, occupation, age), information on how you use Shure products and services, feedback to us on our products and services, and your input on future product development and marketing efforts with regard to our products and related services including support.
For further information see section "How do we conduct market research?".
4.6 Information we collect from others
We may collect additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other third parties that we may attribute to you based on your assignment to certain statistical groups. We use this information in order to derive your possible interests and to provide more relevant experience for you and improve our products, analytics and advertising.
For further information on social plug-ins please refer to the sections "Cookies" and "Social Plug-Ins".
We may aggregate and/or anonymize any information collected from you so that it can no longer be linked to you or your device and does no longer constitute personal data. We may use such aggregate/anonymous data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners and sponsors.
In addition, in a business-to-business context we may also obtain information from your employer or from companies which sell our products to you or to your employer/the company you are working for (e.g. your contact details and information on the project requiring audio equipment you are currently working on).
5. What are the purposes and legal bases for the processing of your data?
We process your personal data for the following purposes, based on the legal bases listed:
|
No. |
Purpose for processing |
Legal basis for processing |
Description of legitimate interest for processing if applicable |
|---|---|---|---|
|
1 |
To provide our website |
Legitimate interest |
We have a legitimate interest in providing an internet site, in order to develop and further our business. |
|
2 |
To provide a protected website area for registered users only in accordance with our Terms of Use |
Performance of a contract |
n/a |
|
3 |
To contact you and provide you with information that you have requested and deal with any matters arising as a result of that contact |
Necessary in order to take steps at your request prior to entering into a contract or our legitimate interest |
We have a legitimate interest in communicating with you upon your request and to deal with any matters arising of that contact. |
|
4 |
To accept your purchase orders and send you acknowledgements |
Performance of a contract |
n/a |
|
5 |
To be able to provide you with direct marketing communication regarding the services and products we offer (including by email newsletter) with your consent |
Consent |
n/a |
|
6 |
To help us further develop our services, our goods and our website |
Legitimate Interest |
We have a legitimate interest in developing and improving our services in order to preserve and grow our business. |
|
7 |
To effectively manage our B2B contacts (companies and their employees and representatives, not consumers) with our joint CRM Tool (for details refer to section"Managing our B2B contacts") |
Legitimate Interest |
We have a legitimate interest in effectively managing our B2B contacts and sharing this information with other Shure affiliates and our distribution partners if they have a respective legitimate business interest |
|
8 |
To monitor and improve the use of and contentment with this website by carrying out surveys and contests |
Legitimate Interest |
We have a legitimate interest in developing and improving our services in order to preserve and grow our business by engaging our users and asking for their opinions. |
|
9 |
To record and evaluate website-activity data about the use of this website for interest-based advertising |
Legitimate Interest |
We and our partners have a legitimate interest in interest-based advertising to be able to show our users advertisements based on their personal interests. |
|
10 |
To collect statistical information about the use of this website (so-called web analytics). |
Legitimate Interest |
We have a legitimate interest in analysing the usage of our website in order to continuously improve it and to customise it to our users’ needs. |
|
11 |
To enable our users to recommend our website via social plug-ins or share information about our website with others |
Legitimate Interest |
We have a legitimate interest in the processing of data if our users activate a social plug-in and thus express that they would like us to transfer data to the respective social network. |
|
12 |
To determine disruptions and to ensure the security of our systems, including the detection and tracing of (the attempt of) unauthorised access to our web servers |
Compliance with the legal obligations regarding data security as well as legitimate interest |
We have a legitimate interest in resolving disruptions, ensuring the security of our systems and the detection and tracing of (the attempt of) unauthorised access. |
|
13 |
To conduct market research in order to develop new products and services and to improve our marketing and support by learning how our products and services are used by our customers and by gathering general customer feedback and opinions |
Legitimate interest |
We have a legitimate interest in gathering customer feedback and opinions provided by our customers on a voluntary basis in order to develop new products and services and to improve our marketing and support |
|
14 |
To safeguard and defend our rights |
Legitimate interest |
We have a legitimate interest in exercising and defending our rights. |
|
15 |
To comply with relevant legal obligations, such as keeping accounting records. |
Compliance with legal obligations |
n/a |
6. Log Files (websites only)
As set out above, we may collect information about your computer and website activity, including where available, your IP address, operating system and browser type, the internet address of the website from which you access our website and the date, time and duration of the access.
We save such log files for the purposes of determining disruptions and for security reasons (e.g., to investigate attack attempts) for a period of 7 to 10 days and delete them thereafter. Log files which need to remain stored for evidence purposes are excluded from deletion until the respective incident has been finally resolved and may be forwarded to investigating authorities on a case-by-case basis.
We also use such log files for website analytics and interest-based advertising by means of cookies (please also refer to the sections "Cookies”, “Website Analytics” and “Advertising by means of tracking technologies”.
7. Cookies
Shure uses cookies to improve performance and enhance the user experience for those who visit our website. Our Cookie Policy does clarify how we do this and how cookies are managed.
Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page in order to provide shopping functionality, help analyse the website’s performance and to recommend content relevant to your visit. The cookie will help the website, or another website, to recognise your device the next time you visit.
We use cookies to record the existence of a browsing session and to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. Most cookies won’t collect information that identifies you, and will instead collect more general information such as how users arrive at and use our websites. Cookies can, however, be used to create a usage profile. In this case, you will be informed about this in this privacy policy (please also refer to the sections "Log Files”, “Website Analytics” and “Advertising by means of tracking technologies”).
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or in most web browsers you can choose to turn off all or some cookies via your browser settings. Also, depending on what type of web browser and what browser version you are using, you may be able to change the properties on your cookie file so that cookies are not used or saved. Cookies can also be removed from your hard drive. Please check with your browser provider for more information on removing cookies.
Like most websites, if you decline to accept cookies, some of our services may not function properly (for example, you will not be able to log on to any part of the website which is accessible only to registered users). Where you are unable to log on to the website due to your declining cookies, you can still place orders by contacting customer service.
For further information on the use of cookies and how they are managed, please refer to our Cookie Policy.
8. Website Analytics
We require aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. For this purpose, we use the website analytics tools described in this section. The tools either do not collect IP addresses or anonymize these upon collection and any profiles created by these tools only contain aggregate data. The service providers providing these tools are not permitted to use the information collected on our behalf except to help us conduct and improve our business and subject to our instructions.
You will find information below on each tool's provider and how you are able to object to the collection and processing of data by the respective tool. Please note that tools may use so-called opt out cookies in order to remember your objection. This opt out function relates to a device or browser and is thus valid for the terminal device or browser used at this time. In case you use several terminal devices or browsers you must opt out on every device and in every browser used. Note that in case you remove all cookies from your hard drive, your “opt out” might not work any longer.
Alternatively, you can avoid the creation of usage profiles by website analytics tools by generally deactivating cookies. For more information on how to do so, please refer to the section "Cookies" or to our "Cookie Policy".
- Google Analytics: Google Analytics is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA (“Google”). You may object to the collection or processing of your data via this Link: https://tools.google.com/dlpage/gaoptout.
- Google Conversion Tracking: Google Conversion Tracking is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA (“Google”). You may object to the collection or processing of your data by this tool via this link: http://www.youronlinechoices.com/".
- Facebook Signal: Facebook Signal is provided by Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA ("Facebook"). You may object to the collection or processing of your data by this tool via this link: http://www.youronlinechoices.com/.
- DoubleClick Floodlight: DoubleClick Floodlight is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA (“Google”). You may object to the collection or processing of your data by this tool via this link: http://www.youronlinechoices.com/.
- Global Site Tag: Global Site Tag is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA (“Google”). You may object to the collection or processing of your data by this tool via this link: https://tools.google.com/dlpage/gaoptout.
- Bing Universal Event Tracking: Bing Universal Event Tracking is provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA. You may object to the collection or processing of your data by this tool via this link: http://www.youronlinechoices.com/.
- OWAPro: OWAPro is provided by Hurra Communications GmbH, Wollgrasweg 27, 70599 Stuttgart, Deutschland ("Hurra"). You may object to the collection or processing of your data by this tool via this link: http://ssl.hurra.com/opt-out?cid=4687&ln=en.
- Lucky Orange Web Analytics Service: Lucky Orange Web Analytics Service is provided by Lucky Orange, LLC, 8680 w. 96th Street, Suite 200, Overland Park, KS 66212, USA. You may object to the collection or processing of your data by this tool via this link https://privacy.luckyorange.com/.
- Pardot Tracking Code: Pardot Tracking Code is provided by Salesforce, The Landmark @ One Market Street, Suite 300, San Francisco, CA 91405. You may object to the collection of processing your data by this tool via this link: https://www.salesforce.com/company/privacy/full_privacy/.
9. Advertising by means of tracking technologies (websites only)
We use so-called tracking technologies on this website to better understand your preferences by analysing your behaviour on our website and offer you products or services more in line with your interests. In order to do so we contract with third-party service providers to assist us in better understanding our site visitors. The tools we use for this either do not collect IP addresses or anonymize these upon collection.
You will find information below on each tool's provider and how you are able to object to the collection and processing of data by the respective tool. Please note that tools may use so-called opt out cookies in order to remember your objection. This opt out function relates to a device or browser and is thus valid for the terminal device or browser used at this time. In case you use several terminal devices or browsers you must opt out on every device and in every browser used. Note that in case you remove all cookies from your hard drive, your “opt out” might not work any longer.
Alternatively, you can avoid the creation of usage profiles by advertising tracking technologies by generally deactivating cookies. For more information on how to do so, please refer to the section "Cookies" or to our "Cookie Policy".
- Google Remarketing: Google Remarketing is offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA ("Google"). You can find further Information on this tool here https://support.google.com/adwords/answer/2453998?hl=en. You may object to the collection or processing of your data by this tool via this link http://www.youronlinechoices.com.
- Doubleclick: Doubleclick is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). You can find further Information on this tool here https://www.doubleclickbygoogle.com. You may object to the collection or processing of your data by this tool via this link http://www.youronlinechoices.com.
10. Social Plug-Ins (websites only)
This website uses social plug-ins (“Plugins”) by the following providers:
- Plugins of the Facebook social network; Facebook is operated under www.facebook.com by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, and under www.facebook.de, www.facebook.fr, www.facebook.dk, by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland ("Facebook"). Find an overview of Facebook's plugins and their appearance here: https://developers.facebook.com/docs/plugins/; find information on data protection at Facebook here: http://www.facebook.com/policy.php.
- Twitter plugins; Twitter is operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA ("Twitter"). Find an overview of Twitter's plugins and their appearance here: https://dev.twitter.com/web/overview; find information on data protection at Twitter here: https://twitter.com/en/privacy.
- YouTube plugins; YouTube is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Find an overview of YouTube's plugins and their appearance here: https://developers.google.com/youtube/; find information on data protection at YouTube here: https://support.google.com/youtube/answer/7671399?p=privacy_guidelines&hl=en&visit_id=0-636627427965711081-3824708512&rd=1.
- Instagram Plugin; Instagram is operated by Instagram Inc., 1601 Willow Road, Menlo Park, CA 94025, USA. Find an overview of Instagram's plugins and their appearance here: https://www.instagram.com/developer/; Find information on data protection at Instagram here: https://instagram.com/about/legal/privacy/.
- Youku Plugin; Youku is operated by Alibaba Group Holding Limited (“Alibaba”)., c/o Alibaba Group Services Limited, 26/F Tower One, Times Square,1 Matheson Street, Causeway Bay, Hong Kong. Find an overview of Youku’s plugins and their appearance here: http://cloud.youku.com/ ; find information on data protection at Youku’s here: http://mapp.youku.com/service/flsm2?spm=a2hww.20027244.0.0.
- VK Plugin, VK is operated by “V kontakte” LLC (RUS: ООО «В Контакте), 191024, Saint Petersburg, Russia, Hersonskaya Street 12-14, liter A, room 1-H. Find an overview of VK’s plugins and their appearance here: https://vk.com/dev , find information on data protection at VK here: https://vk.com/privacy/eu.
The different providers of plugins are in the following summarized as “Plugin Providers”.
To increase the protection of your data when visiting our website, plugins are embedded using the so-called "Two Click Solution". This means that when a page of this website is accessed, a connection to the servers of the respective plugin provider is not yet established.
Your web browser establishes a direct connection to the respective plugin provider’s servers only when you activate the plugins. This way, the plugin provider receives information that your web browser has accessed the respective site of our website, even when you do not maintain a user account with the provider or are not logged in. Log files (including the IP address) are transmitted directly from your web browser to a server of the respective plugin provider and may be stored there (for further information on log files please refer to the section "Log Files"). This server may be located outside the EU or EEA (e.g. in the U.S.).
If you do not wish for the plugin providers to receive, save, and use data gathered through this website, you should not use the respective plugins. You can also block the plugins from being loaded with browser add-ons (so-called script blockers).
Find out more about the purpose and scope of the data collection as well as about processing and use of your data by plugin providers and about your rights and possibilities to change settings to protect your data in the privacy statements of the respective providers (see above).
11. Managing our B2B contacts
This section provides information relating to the processing of information relating to our B2B contacts (companies and their employees or representatives, not consumers).
11.1 General information and joint controllership
We are using a common cloud based application for managing our business relationships ("CRM Tool") together with our parent company Shure Incorporated located in the USA and some of our Affiliates and partners supporting us in sales and consultancy activities ("Participating Entities"). A current list of the Participating Entities can be requested by sending a request to privacy@shure.com. Each Participating Entity that is located outside the EEA and has access to personal data of a resident of a member state of the European Union is required to sign the Controller to Controller Model Clauses for the transfer of personal data to third countries as provided by the European Commission. In such way all of them need to obey the data privacy principles as outlined in this policy and by applicable data privacy law. For further information, please refer to the section "Transfers of your data to countries outside the EEA".
Data that is entered into the CRM Tool is stored in a cloud and can generally be processed by all Participating Entities which have a legitimate business reason to do so, but processing is limited to persons which require this information for their tasks, namely marketing and sales department on a need-to-know basis.
When processing this data, we and the relevant Participating Entities act as joint controllers in the meaning of Art. 26 GDPR, which is why we have entered into a joint controller agreement with the relevant Participating Entities for the processing relating to the CRM Tool.
This CRM Tool is provided to us by Salesforce Inc. in the U.S. ("Salesforce"), a company that acts as a processor on behalf of the Participating Entities. Salesforce is certified under the EU-US Privacy Shield.
11.2 What are the purposes of the CRM Tool and legal bases?
Our CRM Tool enables us and the other Participating Entities to facilitate and improve communication with our business partners in compliance with data protection law requirements. It provides us with the opportunity to share important contact details with any person involved in the marketing and sales of Shure products or providing consultancy services or technical support for Shure products that needs to access it. This way, we are able to approach our business partners in a more effective way and at the same time ensure consistency and accuracy of personal data stored about such business contacts.
The legal basis for the processing is our legitimate interest: We and the other Participating Entities have a legitimate interest in effectively managing our B2B contacts and sharing this information with other Shure affiliates and our distribution partners if they have a respective legitimate business interest.
To be able to provide you with direct marketing communication regarding the services and products we offer (including by email newsletter) we obtain your prior consent if required under applicable laws or rely on our legitimate interest in direct marketing if you have not objected to such marketing and if consent is not necessary.
11.3 Which categories of personal data are processed in relation to the CRM tool?
We enter the following categories of data into the tool: Business contact information like name, company name, business phone number, business email address, business mobile number, employer, description of historic events, management of preferences, created by and modified contact information.
If we provide consultancy services or technical support we may also enter information about your current projects requiring audio equipment (e.g., "equipment of conference room") and - if available - information on the seller you or the company you are working for has bought Shure products from in the past.
11.4 Which are the sources of our information?
Typically we collect your personal data directly from you (e.g., if you provide us with your business card or send us an email).
In addition, we may also obtain information from your employer or from companies which sell our products to you or to your employer/the company you are working for (e.g., your contact details and information on the project requiring audio equipment you are currently working on).
11.5 Which rights do you have?
You in particular have the right to object to the processing of your personal data that is based on our legitimate interest, on grounds relating to your particular situation, at any time and to object to the processing of your personal data for marketing purposes at any time. Please also refer to the section "Information on your rights to object".
Where we rely on your consent to process particular information, you also have the right to withdraw such consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.
For further information on your rights please refer to the section "What are your rights and how can you exercise them?"
11.6 Who is responsible for dealing with the rights I exercise as a data subject?
Each Participating Entity remains responsible for complying with any exercise of your rights as a data subject that relate to the processing of your personal data through our CRM Tool. Therefore, if you would like for example access to your data stored in the CRM Tool or would like to object to marketing you may contact the Participating Entity you usually deal with.
In addition to that, you can always get in touch with our single point of contact for the CRM Tool (please see the section "Single point of contact" for contact details).
11.7 Who is responsible for providing the information referred to in Articles 13 and 14 GDPR to me?
The information referred to in Articles 13 and 14 GDPR, e.g. purposes of the processing and storage periods, will be provided to you by the entity which has first entered your data in the CRM tool.
In addition to that, you can always get in touch with our single point of contact for the CRM Tool if you have any questions regarding this (please see the section "Single point of contact" for contact details).
11.8 Single point of contact
If you have any questions, concerns or complaints regarding our CRM Tool and the way we use it, would like to change your marketing preferences or update information we hold about you or have any other privacy related requests, please contact the single point of contact we have established to this end at:
privacy@shure.com12. How do we conduct market research?
12.1. General information and the controller of your data
Participation in market research surveys is completely voluntary and you may choose whether or not to participate and therefore disclose personal data. The data requested may include contact information (such as name and email address), demographic information (such as country, occupation, age), information on how you use Shure products and services, feedback to us on our products and services, and your input on future product development and marketing efforts with regard to our products and related services including support.
The controller of the personal data you provide in market research surveys will always be the entity identified to you as controller in the respective market research survey.
12.2 What are the purposes for market research and legal bases?
The Shure entity collecting the information from you (the controller of your data) will process the personal data you provide in these market research surveys in order to help the Shure group of companies to develop new products and services and to improve marketing and support by learning how Shure products and services are used by our customers and by gathering general customer feedback.
Your responses to market research questions and information will in particular be used to detect trends by analyzing aggregated data. Furthermore, your responses and information about how you connected to the survey will be used to administer the survey and may be also used to communicate with you about the survey and to provide you with incentives for completing it. In addition, your responses and information about how you connected to the survey may also be evaluated for future market research, including for the decision whether you are the person to ask to participate in a specific future market research study.
The legal basis are the respective controller's legitimate interests: It has a legitimate interest in gathering customer feedback and opinions provided by customers on a voluntary basis in order help the Shure group of companies to develop new products and services and to improve its marketing and support.
To be able to contact you and ask you whether you would like to participate in market research (including by email) we obtain your prior consent if required under applicable laws or rely on our legitimate interest in conducting market research if you have not objected to such contacts and if consent is not necessary.
The information you provide in market research surveys will be stored for the time necessary for the respective purpose of the survey but for no longer than four years after the survey has been conducted. In case we have obtained your consent in order to contact you about market research and you withdraw your consent or if you request us to delete your personal data, we will anonymize the information you have provided to us in market research surveys in the past. We will, however, continue to store your former consent (if any) for a certain time (typically two more years) for reasons of proof.
12.3 Do we share and disclose your data?
The Shure entity acting as data controller will not disclose any personal information you provide in the context of market research to any third party, including other Shure Group entities.
The controller will, however, engage service providers, in particular in order to provide a survey software platform (creation and distribution of surveys, analysis and reports on survey data, management of information on respondents who complete surveys). The controller may also hire a service provider for limited services such as packaging, mailing and delivering products. The respective service providers are engaged as data processors which only process personal data on the controller's behalf. Furthermore, they only receive the information they need to deliver the respective services. For further information see section "Service Providers", for potential transfers of data to service providers in countries outside the EEA see section "Transfers of your data to countries outside the EEA".
12.4 Which rights do you have?
You in particular have the right to object to the processing of your personal data that is based on our legitimate interest, on grounds relating to your particular situation, at any time and to object to the processing of your personal data for marketing purposes at any time. Please also refer to the section "Information on your rights to object".
Where we rely on your consent to contact you in order to contact you regarding participation in further market research, you also have the right to withdraw such consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.
For further information on your rights please refer to the section "What are your rights and how can you exercise them?"
13. How do we share and disclose your personal data?
Except as set out in this privacy policy, we do not sell, trade, or otherwise transfer your personal data to outside parties. Your personal data may be transferred to the following categories of recipients:
13.1 Service Providers
We provide access to or share your personal data with selected third parties who perform services on our behalf. Such parties might be concerned with the delivery of our products to you, data-hosting, collection of debts, analytics, etc. (see list below). We have signed with such providers contracts obliging them to obey at least the same data privacy rules as Shure does. They act only as so-called data processors on our behalf and subject to our instructions. We disclose your data to the following categories of service providers:
- Shipping and payment service provider (shipping and payment), Germany, UK, Netherlands;
- Customer administration (collection of debts), Germany, UK;
- Contact form provider (handling customer contact), USA;
- IT service providers (hosting service), Germany; Ireland, Singapore, USA;
- Provider of CRM-tool (Switzerland, USA);
- Newsletter service provider (handling of newsletters), USA;
- Provider of website analytics tools (website analytics), USA, please see also the section "Website Analytics");
- Map, location-based service providers, USA, China;
- Survey software platform (creation and distribution of surveys, analysis and reports on survey data, management of information on respondents who complete surveys), USA;
- Provider of content delivery network, USA
- Packaging, mailing and delivery of products, USA, China, Germany, UK, Russia, Dubai, Hongkong, Japan, Singapore, Mexico.
For transfers to service providers in non-EEA countries please refer to the section "Transfers of your data to countries outside the EEA".
13.2 Affiliates
We will share your personal data with other entities of the Shure global group (affiliates as mentioned below) for the purposes as described in this privacy policy. However, all affiliates within the Shure group have signed the Controller to Controller Model Clauses for the transfer of personal data to third countries as provided by the European Commission. In such way all Shure entities need to obey the data privacy principles as outlined in this policy and by applicable data privacy law. For further information please refer to the section "Transfers of your data to countries outside the EEA".
Affiliates including its branches as described herein can be found here.
- Shure Europe GmbH, Jakob-Dieffenbacher-Str. 12, 75031 Eppingen Germany
- Shure Incorporated, 5800 West Touhy Avenue, Niles, Illinois – 60714, USA
- Shure Distribution GmbH, Jakob-Dieffenbacher-Str. 12, 75031 Eppingen Germany
- Shure Distribution GmbH Niederlassung Österreich, Münchner Str. 11, 6130 Schwaz, Austria
- Shure UK Limited, Unit 2, The IO Centre, Lea Road, Waltham Abbey, EN9 1AS, United Kingdom
- Shure Scandinavia A/S, Winghouse, Oerestad Boulevard 73, 2300 Copenhagen S, Denmark
- Shure Distribution Benelux B.V., Newtonweg 9, 4104 BK, Culemborg, Netherlands
- Shure Distribution Benelux B.V. Belgium Branch, J.E. Mommaertslaan 20A, Park Hill, Gebouw C, 1831 Diegem, Belgium
- Shure Distribution Switzerland GmbH, Brandstrasse 26, 8952 Schlieren, Switzerland
- Shure France SARL, 5 Place de la Pyramide, Paris 92088, France
- Shure MEA DMCC, Unit No 2805, Swiss Tower, Cluster Y, Jumeirah Lakes Towers, Dubai , UAE
- Shure REE LLC, 143405, 4th Dobrinisky Lane 8, Office R01-211, 119049 Moscow, Russia
- Shure Asia Limited, 22/F, 625 King’s Road, Island East, Hong Kong
- Shure South Asia Limited, 22/F, 625 King’s Road, Island East, Hong Kong
- Shure Audio Technologies Private Limited, 819, 8 floor, SLN Terminus, Survey No.133, Beside Botanical Garden, Gachibowli, Hyderabad, Telengana 500032, India
- Shure Latin America Servicio de Analise de Mercado, Consultario e Promocao de Vendas Ltds (aka Shure do Brasil), Rua Professor Atilio Innocenti, n.° 165, Vila Nova Conceição, 10° fllor, Suíte 1001 - Edificio Vista Faria Lima - São Paulo – SP 04538-000 Brazil
- Danish Interpretation System Thailand Ltd., No.1497 Soi Latphrao 94 Latphrao Road, Plubpla, Wangtonglang, Bangkok 10310, Thailand
- Shure Japan Limited, 35/F, Shiroyama Trust Tower, 3-1, Toranomon 4-chrome, Minato-ku, Tokyo, Japan
- Shure China Trading Co., Ltd., 1003-005#, 10th Floor, Kinghai Building, No. 198, Xinghai Street, Suzhou, SIP, PRC
- Shure China Trading Co., Ltd. Shanghai Branch, 18A, Sino-Ocean Tower(II), 618 Yan An Road East, Shanghai 200001, PRC
- Shure China Trading Co., Ltd. Beijing Branch, Level 8th, Unit 13-17, China World Office 2, No. 1 Jian Guo Men Wai Avenue Beijing, PRC
- Shure China Trading Co., Ltd. Chengdu Branch, Suite 2505-6, Tower 1, International Finance Square, No. 1 Hongxing Road Section 3, Jinjiang District, Chengdu, PRC
- Shure Electronics (Suzhou) Co., Ltd., Block 6, Genway Factory EPZ 200 Suhong Zhong Road, SIP, PRC
- Shure Electronica S.A. de C.V., Mexico Calle Guillermo Griffin 7025, Parque Industrial Omega, Cd. Juarez, Mexico
- Shure International Inc., 5800 West Touhy Avenue, Niles, IL 60714, USA
- Shure Singapore PTE, Ltd., 3 Raffles Place #06-01, Bharat Building, Singapore 048617
- Shure South Asia Limited Singapore Branch, 8 Marina Boulevard, #05-02, Marina Bay Financial Centre, Singapore 018981
- Shure Korea Representative Office, 7F, 33, Jong-ro, Jongno-gu, Seoul, Republic of Korea
13.3 Third Parties
We also may disclose your personal data to trusted third parties who assist us in conducting our business, or servicing you and the fulfillment of your order, so long as those parties agree to keep this information confidential. We may disclose your personal data to the following categories of third parties:
- For joint management of B2B contacts with our trusted distribution partners (for details refer to section "Managing our B2B contacts");
- For the shipping of goods to postal service providers;
- To external auditors in the event of audits or investigations, if there is a legal requirement or legitimate business interest to do so;
- In the event that we are subject to a merger or acquisition to the new owner of the business, if legitimate under applicable laws;
- If we are required to do so by law, statute, regulation, or professional standard, or to respond to a subpoena, search warrant, or other legal request, in response to law enforcement authority or other government official request.
For transfers to third parties in non-EEA countries please refer to the section "Transfers of your data to countries outside the EEA".
14. Transfers of your data to countries outside the EEA
We also transfer personal data to service providers, affiliates or other third parties located outside the European Economic Area ("EEA"). In such cases we ensure prior to the transfer that the European Commission has decided that the third country ensures an adequate level of protection (Art. 45 GDPR, e.g. Switzerland) or that the transfer is either subject to appropriate safeguards, for example by self-certification of the recipient for the EU-US Privacy Shield (Art. 45 GDPR, for US recipients only) or by entering into so-called standard data protection clauses of the European Union with the recipient (Art. 46 GDPR). In specific situations we might also ask for your explicit consent to the transfer (Art. 49 GDPR).
You may also receive an overview of third country recipients and a copy of the appropriate or suitable safeguards in place. Please use the details provided in the section "Contacting Us".
15. For how long do we keep your personal data?
We store your data as long as it is necessary to provide this website and the services connected with it or as long as we have a legitimate interest in continued storage. In all other cases, we delete your personal data with the exception of such data that we are required to retain for the purpose of contractual or statutory (e.g., taxation or commercial law) retention periods (e.g., invoices). We keep your personal data for the following periods:
- Customer Account Data: 10 years from the end of the business/contractual relationship
- Lead Account Data: 6 years from the date of our last interaction with the lead
- User Data: 2 years from the end of the use
- Data relating to Marketing Initiatives: 2 years from the completion of the marketing activity
- Meta and communication data: 2 years from the end of the communication
- Data in our CRM Tool: 4 years from the end of the communication
- Market research surveys: 4 years from the completion of the survey
16. What are your rights and how can you exercise them?
You have the following rights:
- Right of access: You have the right to obtain confirmation from us as to whether or not your personal data is being processed and a right to access your personal data that is being processed by us.
- Right of rectification: You also have the right to obtain without undue delay the rectification of any inaccurate personal data relating to you and to have any of your personal data that is incomplete completed. In case we have transferred your personal data to third parties, we will inform them about this rectification and completion if required by law.
- Right to erasure ('right to be forgotten'): You have the right to obtain the erasure of your personal data from us without undue
delay and we have the obligation to erase your personal data without undue delay if one of the following grounds applies:
- your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the processing of your personal data is based solely on your consent and you have withdrawn your consent;
- you have objected to direct marketing;
- you have objected to the processing that is based on our legitimate interest on grounds that relate to your particular situation and there are no overriding legitimate grounds for the processing;
- your personal data have been unlawfully processed;
- your personal data have to be erased for compliance with a legal obligation
In case we have transferred your personal data to third parties, we will inform them about this erasure if required by law.
Please keep in mind that there are limitations to your right to erasure. We are for example not allowed to erase data that we are legally obliged to store (namely due to statutory retention periods). Also, your right to erasure does not apply if we need to store the data for the establishment, exercise or defense of legal claims.
- Right to restriction of processing: You have the right to restrict our processing of your personal data where
- you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
- the processing is unlawful but you do not want us to erase the data;
- we no longer need your personal data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims; or
- you have objected to processing based on our legitimate interest (see below) pending verification as to whether we have compelling legitimate grounds to continue processing.
Where personal data is subjected to restriction in this way, we will only process it with your consent or to a very limited extent, e.g. for the establishment, exercise or defense of legal claims.
- Rights to object: You have the right to object to the processing of your personal data that is based on our legitimate interest, on grounds relating to your particular situation, at any time. You also have the right to object to the processing of your personal data for marketing purposes at any time. Please also refer to the section "Information on your rights to object".
- Right to Data portability: Where we rely on your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that personal data has been provided by you and is processed by automated means, you have the right to receive all such personal data which you have provided to us in a structured, commonly used and machine readable format, and also to require us to transmit it to another controller where this is technically feasible.
- Right to withdraw consent: Where we rely on your consent to process particular information and you have provided us with your consent to process data, you have the right to withdraw such consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.
- Right to lodge a complaint with the Supervisory Authority: You have the right to lodge a complaint with a Supervisory Authority. You can appeal in particular to the Supervisory Authority, which is competent for your place of residence or your state or to the (lead) Supervisory Authority which is competent for us. This is:
Der Landesbeauftragte für den Datenschutz Baden-Württemberg
Königstraße 10a 70173
70173 Stuttgart
Germany
or
Postfach 10 29 32
70025 Stuttgart
Germany
poststelle@lfdi.bwl.de
Phone: +49 711 / 61 55 41 – 0
You may exercise your rights in connection with the processing through our website by contacting us via the contact details supplied in the section "Contacting Us". Please ensure for this purpose that a clear identification of your person is possible for us.
Please refer to the section "Who is responsible for dealing with the rights I exercise as a data subject?" for further information on how you can exercise your rights in connection with the processing through our CRM Tool.
In order to exercise your rights in connection with the processing of your data by any Shure group company you may also contact us at privacy@shure.com.
17. Are you required to provide us with your data?
You can also visit our website without disclosing your personal data to us. For registration purposes you are, however, obliged to provide us with the personal data needed for contract establishment and performance (for example the name, address, e-mail address); we mark these mandatory details with an asterisk *. If you decide not to provide us with this information, you will unfortunately not be able to register or use any of our services which require a registration.
18. How do we protect your information?
We take precautions to protect your information. When you submit sensitive data via the website, your data is protected both online and offline.
Wherever we collect sensitive data (such as credit card data) that data is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for "https" at the beginning of the address of the web page.
While we use encryption to protect sensitive data transmitted online, we also protect your data offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personal data. The computers/servers in which we store personal data are kept in a secure environment.
19. Links to other websites
This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personal data.
20. Changes to our Privacy Policy
We reserve the right to amend this privacy policy at any time to reflect changes in the law, our data collection and use practices, or advances in technology. We will make the revised privacy policy available on our websites. If we make a material change to the policy we will provide you with an appropriate notice in accordance with legal requirements. Our registered users will be informed about the changes beforehand.
21. Contacting Us
If you have any questions, concerns or complaints regarding our compliance with this privacy policy and the data protection laws, we encourage you to first contact us using the site’s "Contact Us" facility.
Alternatively you may reach us at:
Shure Distribution GmbH
Jakob-Dieffenbacher-Str. 12
75031 Eppingen
Germany
Phone: +49 (0) 7262-9249-111
Fax: +49 (0) 7262-9249-168
You may also contact our Data Protection Officer:
Steffen Emhardt
datenschutz@emetz.de
EmEtz GmbH
Mühlweg 25/3
71711 Murr
Germany
B. Information on your rights to object
Right to object to direct marketing
You may at all times object to the processing of your personal data for direct marketing purposes. Please take into account that, due to logistical reasons, there might be an overlap between your objection and the usage of your data within the scope of a campaign which is already running.
Right to object to processing based on legitimate interest
Furthermore, you may have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on the legal basis legitimate interests.
You may address your objections to:
Shure Distribution GmbH
privacy@shure.com
Jakob-Dieffenbacher-Str. 12
75031 Eppingen
Germany
Phone: +49 (0) 7262-9249-111
Fax: +49 (0) 7262-9249-168
You may also contact our Data Protection Officer:
Steffen Emhardt
datenschutz@emetz.de
EmEtz GmbH
Mühlweg 25/3
71711 Murr
Germany