Mobile Privacy Policy

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 in connection with your use of the Shure Mobile Applications ("app"). If you would like to read the whole document in context or would like to print it, please click here.

For information on the processing of personal data by Shure that does not take place in connection with your use of a Shure application, please refer to our general privacy policy. For information on the processing of personal data by Shure that takes place in connection with your use of another Shure application, please refer to the privacy policy of the respective app.

1. Who controls the processing of your personal data?

Controller in the meaning of data protection law for apps is:

Shure Incorporated
5800 West Touhy Avenue
Niles, IL – 60714
USA
Phone: +1 847 6002000
Email address. datenschutz@shure.de

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

3. What information do we collect?

All information, which is related to an identified or identifiable natural person (e.g. name, address, phone number, 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 via the app, 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 via the app, such as through

  • Requests or questions you submit to us and you explicitly elect to include (you may be asked if you wish to include more detailed information about your device, which may for example include the number and types of Shure devices on your network. This information will be visible to you when composing your message to Shure.) via online forms or emails,
  • Any communication within our apps,
  • Requests for customer support and technical assistance via the app.

Considering the above means of sharing, the types of data we collect directly from you include:

  • Contact Data – name, telephone number, cell phone number, email address
  • Network settings of your personal device and Shure systems, which may include IP address

3.2 Information we collect through automated means

  • App-activity data – information such as device model/type, ID for the app on your particular device (a different ID will be assigned if you install the app on another device), app version, language settings, operating system version, whether and when you update the app, time spent in different portions of the application, non-fatal error messages displayed to you, etc. (please also refer to the sections " “App Analytics for further information)
  • Location information – we may collect general location information (e.g. country associated with an IP address) from your device

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

We process your personal data collected via the app 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 app

Legitimate interest

We have a legitimate interest in providing an app that adds value to our customers, in order to improve their experience with our products, which in-turn develops and furthers our business.

2

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.

3

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

4

To collect statistical information about the use of this app (so-called app analytics), usually in an anonymized way.

Legitimate Interest

We have a legitimate interest in analysing the usage of our app in order to continuously improve it and to customize it to our users’ needs.

5

To safeguard and defend our rights

Legitimate interest

We have a legitimate interest in exercising and defending our rights.

6

To comply with relevant legal obligations, such as keeping accounting records.

Compliance with legal obligations

n/a


5. App Analytics

We require aggregate data about app traffic and app interaction so that we can offer better app experiences and tools in the future. For this purpose, we use the app 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 anonymized and aggregated 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 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 this opt out function relates to a device and is thus valid for the terminal device used at this time. In case you use several terminal devices you must opt out on every device.

Alternatively, you can avoid the creation of usage profiles by app analytics tools by setting the Analytics setting to "Don't Send."

  • Flurry: Flurry is provided by Oath Inc., 770 Broadway, New York, NY 10003, USA ("Oath"). You may object to the collection or processing of your data by this tool by setting the Analytics setting to "Don't Send."
  • Google Play Console Analytics: Google Analytics is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA (“Google”).
  • Apple App Store Connect provided by Apple Inc., One Apple Park Way, Cupertino, CA 95014;
  • Dropbox sharing provided by Dropbox, Inc., 333 Brannan Street, San Francisco, CA 94107. You can avoid the collection or processing of your data by this tool by refraining from selecting it for sharing saved files.

6. 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:

6.1 Service Providers

We provide access to or share your personal data collected via the app with selected third parties who perform services on our behalf. Such parties might be concerned with analytics. 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:

  • Provider of app analytics tools (app analytics), USA, please see also the section "app Analytics");

For transfers to service providers in non-EEA countries please refer to the section "Transfers of your data to countries outside the EEA".

6.2 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 as described herein can be found here. companies:

  • Shure Incorporated, 5800 West Touhy Avenue, Niles, Illinois – 60714, USA
  • Shure Distribution GmbH, Jakob-Dieffenbacher-Str. 12, 75031 Eppingen Germany
  • 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 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 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

6.3 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 fulfilment 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 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" .

7. 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".

8. For how long do we keep your personal data?

We store your data as long as it is necessary to provide this app 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:

  • User Data: 2 years from the end of the use
  • Meta and communication data: 2 years from the end of the communication

9. 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 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 defence 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 defence 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 defence 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 are relying upon 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 have relied 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.

You may exercise your rights 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.

10. Are you required to provide us with your data?

You can also use our app without disclosing your personal data to us. Only if you voluntarily provide us with personal information such as your email address, we will process it in accordance with this policy.

11. How do we protect your information?

We take precautions to protect your information. When you submit data via the app, your data is protected both online and offline.

12. Links to third party websites

This app contains links to third party websites. Please be aware that we are not responsible for the content or privacy practices of such other websites. 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.

13. 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 app. 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.

14. Contacting Us

If you have any questions, concerns or complaints regarding our compliance with this privacy policy, any of our other privacy policies and the data protection laws, we encourage you to first contact us using the site’s ‘Contact Us’ facility.

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