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Shure Privacy Policy

Last updated: 8 October 2024

 

A. Privacy Policy

B. Information on your rights to object
C. Important Rights for CA residents

 

 

 

A. Privacy Policy

Last Updated: 26 June 2020

Shure Incorporated and its Affiliates (collectively "Shure", "us", "we", "our") is committed to protecting your privacy. In this privacy policy ("policy") we will outline as to how we ensure the privacy of the personal data we have collected from you.

Please find specific information for California residents in the section "Important Rights for CA Residents"

1. Who controls the processing of your personal data?

As defined under applicable data protection laws, "Controller" for this website is:

Shure Incorporated
5800 West Touhy Avenue
Niles, IL 60714
Phone: 847-600-2000
Fax: 847-600-1212

Contact

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2. 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

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3. 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.

3.1 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

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3.2 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

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3.3 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 be widely distributed on the Internet to all users you are connected to through the social media site (e.g., "friends" on Facebook) . 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".

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3.4 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.

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3.5 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?".

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3.6 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. In such cases we potentially collect the following categories of data: Business contact information like name, company name, business phone number, business email address, business mobile number, employer and information on the project requiring audio equipment you are currently working on.

We also may obtain information from companies which sell our products to you personally. This information potentially includes the following categories of data: Contact information like name, email address, postal address.

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4. What are the purposes and legal bases for the processing of your data?

We process your personal data for the purposes set forth in the table below. To the extent EU or UK data protection laws apply, the table below also identifies the legal basis for processing and associated legitimate interest (where applicable), pursuant to the GDPR:

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 contact you and provide you with information necessary to activate software or get access to other products/services you or your employer/the company you are working for purchased from a reseller Necessary in order to take steps at your request prior to entering into a contract (if you have purchased the software for yourself) or our legitimate interest (if you have purchased the software for a third party) We have a legitimate interest in fulfilling our contractual obligations towards your employer/the company you are working for as well as towards the respective reseller
6 To be able to provide you with direct marketing communication regarding the services and products we offer (including by email newsletter) and potentially tailoring marketing communication to your interests with your consent Consent n/a
7 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.
8 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
9 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.
10
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.
11 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.
12 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.
13 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.
14 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
15 To safeguard and defend our rights Legitimate interest We have a legitimate interest in exercising and defending our rights.
16 To comply with relevant legal obligations, such as keeping accounting records. Compliance with legal obligations n/a

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5. 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".

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6. 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.

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7. 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, unless we have explicitly notified you and asked for your explicitly consent in doing otherwise. The service providers providing these tools are in general not permitted to use the information collected on our behalf except to help us conduct and improve our business and subject to our instructions. We will notify you and ask for your consent, if service providers might use collected data for their own interests.

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/.
  • Facebook Pixel: 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 deactivating the "Third Party Advertising" Cookies in your Cookie settings.
  • 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.
  • TikTok: The TikTok Pixel is provided by TikTok Ltd., European Economic Area and Switzerland: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland. United Kingdom: TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, EC1A 9HP, United Kingdom. You can submit an objection to the processing of your personal data by using this form: https://www.tiktok.com/legal/report/privacy?lang=en

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8. 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 or are specifically disclosed to you as collecting IP addresses.

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/.
  • Facebook Pixel: 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 deactivating the "Third Party Advertising" Cookies in your Cookie settings.
  • TikTok: The TikTok Pixel is provided by TikTok Ltd., European Economic Area and Switzerland: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland. United Kingdom: TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, EC1A 9HP, United Kingdom. You can submit an objection to the processing of your personal data by using this form: https://www.tiktok.com/legal/report/privacy?lang=en

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9. Social Plug-Ins (websites only)

This website uses social plug-ins ("Plugins") by the following providers:

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).

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10. Linking your Facebook and Google accounts to Shure Apps

By linking your Facebook and/or Google accounts to any of our Apps, we may use data from your Facebook/Google accounts to enhance your App experience, subject to your own Facebook/Google account's privacy policies and/or settings. Additionally, when logging in with Facebook or Google, you may have the option to voluntarily disclose personal information such as your name, email address, phone number, photos, comments, and any other provided details. You may also have the chance choose to share your exact location by adjusting your device settings. In the event that you opt not to share your precise location, we may still use your IP address to estimate your location. Furthermore, you may have the choice to disclose other information about yourself, such as your gender, age, and preferred language. Your activity while connecting your Facebook and/or Google accounts to any of our Apps may also enable us to deduce additional details about you.

To learn more about how Google processes your personal data, please visit Google’s Privacy Policy at: https://policies.google.com/privacy
 
You can revoke your request to link your Google account with our apps at any time by access your Google security settings page at: https://security.google.com/settings/security/permissions

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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.

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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.

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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.

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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. In such cases we potentially collect the following categories of data: Business contact information like name, company name, business phone number, business email address, business mobile number, employer and information on the project requiring audio equipment you are currently working on.

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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?"

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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).

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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).

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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:

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12. 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.

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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.

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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".

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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" and for California residents please see the section "Important Rights for CA Residents".

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?" and for California residents please see the section "Important Rights for CA Residents"

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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
  • Provider of communication platform, 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".

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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".

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".

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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".

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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

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16. What are your rights and how can you exercise them?

Please find specific information for California residents in the section "Important Rights for CA Residents"

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.

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.

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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.

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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.

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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.

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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.

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20. 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 Incorporated
5800 West Touhy Avenue
Niles, IL 60714
Phone: 847-600-2000
Fax: 847-600-1212

Contact.

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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. For information about our CA resident’s rights, see "Important Rights for CA Residents"

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Right to object to processing based on legitimate interest

To the extent EU or UK data protection laws apply, pursuant to the GDPR, 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 Incorporated
privacy@shure.com
5800 West Touhy Avenue
Niles, IL 60714
Phone: 847-600-2000
Fax: 847-600-1212

C. Important Rights for CA residents

Additional Information for California Residents.

Below, we provide information, as required under California privacy laws, including the California Consumer Privacy Act ("CCPA"), which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA.

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Categories of Personal Information We Collect and Disclose.

Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. We may collect personal information about you directly from you, as well as automatically or indirectly related to your interactions with us or your use of our sites, services and mobile apps. In addition, we may receive information about you from third parties, such as ad networks, analytics services, social networking sites, platform providers, data aggregators, our affiliated companies, and other sales and marketing partners. The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect and disclose to third parties. We collect these categories of personal information for the purposes described in the "What are the purposes and legal bases for the processing of your data" section above.

Categories of personal information Do we collect? Do we disclose for business purposes?
Name, Contact Info and other Identifiers: identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. Yes Yes
Customer Records: paper and electronic customer records containing personal information, such as name, signature address, telephone number, bank account number, credit card number, debit card number, or any other financial or payment information. Yes Yes
Purchase History and Tendencies: commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. Yes Yes
Internet or Other Electronic Network Activity Information: internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, including access logs and other activity information related to your use of any company websites, applications or other online services. Yes Yes
Geolocation Data: precise geographic location information about a particular individual or device. Yes Yes
Audio, Video and other Electronic Data: audio, electronic, visual, or similar information such as, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars). Yes Yes
Inferences: inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes Yes

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Categories of Personal Information Sold.

The CCPA defines a "sale" as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration. While we do not disclose personal information to third parties in exchange for monetary compensation from them, we may disclose or make available personal information, including identifiers and internet or other electronic network activity information as well as purchase history and tendencies, to third party ad networks, analytics services and social networking platforms, such as when we allow third party tags to collect browsing history on our website in order to improve and measure our ad campaigns.

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California Residents’ Rights.

California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

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Do-Not-Sell.

California residents have the right to opt-out of our sale of their personal information. We do not sell personal information about residents who we know are younger than 16 years old without opt-in consent. CCPA opt-out rights can be exercised here, by opting out of third party advertising cookies on our Sites.

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Initial Notice.

We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

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Requests to Delete.

Subject to certain exceptions, California residents have the right to, at no charge, request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies.

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Request to Know.

California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, subject to certain exceptions. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:

  • categories of personal information collected;
  • categories of sources of personal information;
  • business and/or commercial purposes for collecting and selling their personal information;
  • categories of third parties/with whom we have disclosed or shared their personal information;
  • categories of personal information that we have disclosed or shared with a third party for a business purpose;
  • categories of personal information collected; and
  • categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

California residents may make a Request to Know up to twice every 12 months.

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Submitting Requests.

Requests to Know, and Requests to Delete may be submitted:

We will respond to verifiable requests received from California residents as required by law. Authorized agents may submit requests on behalf of consumers by emailing us at the same address. You must provide all information as required by us. We will take steps to verify your request by matching the information provided by you with the information we have in our records. If we are unable to adequately verify a request, we will notify the requestor. In some cases, we may request additional information in order to verify your request or where necessary to process your request.

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Right to Non-Discrimination.

California residents have the right not to be discriminated against for exercising their rights under the CCPA.

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Your Rights Under California’s Shine-the-Light Law.

We do not disclose personal information (as defined in Cal. Civ. Code 1798.83(e)(6)) that we have collected from individuals with whom we have an established business relationship to third parties for those third parties’ own direct marketing purposes.

For more information about our privacy practices, you may contact us as set forth in the "Contact Us" by clicking this link.

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