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?

Controller in the meaning of data protection law for this website is:

Shure Distribution Switzerland GmbH

privacy@shure.com

Brandstrasse 26
8952 Schlieren
Switzerland

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, 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

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3.2 Information we collect through automated means on our websites

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3.3 Information we collect from Social Media and other Content Platforms

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3.4 Information we collect through surveys or contests

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3.5 Information we collect from others

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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 following purposes, based on the legal bases listed:

No.Purpose for processingLegal basis for processingDescription of legitimate interest for processing if applicable
1To provide our websiteLegitimate interestWe have a legitimate interest in providing an internet site, in order to develop and further our business.
2To provide a protected website area for registered users only in accordance with our Terms of UsePerformance of a contractn/a
3To 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 interestWe have a legitimate interest in communicating with you upon your request and to deal with any matters arising of that contact.
4To accept your purchase orders and send you acknowledgements Performance of a contractn/a
5To be able to provide you with direct marketing communication regarding the services and products we offer (including by email newsletter) with your consentConsentn/a
6To help us further develop our services, our goods and our websiteLegitimate InterestWe have a legitimate interest in developing and improving our services in order to preserve and grow our business.
7To 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 InterestWe 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
8To monitor and improve the use of and contentment with this website by carrying out surveys and contestsLegitimate InterestWe 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.
9To record and evaluate website-activity data about the use of this website for interest based advertisingLegitimate InterestWe and our partners have a legitimate interest in interest-based advertising to be able to show our users advertisements based on their personal interests.
10To collect statistical information about the use of this website (so-called web analytics).Legitimate InterestWe 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.
11To enable our users to recommend our website via social plug-ins or share information about our website with othersLegitimate InterestWe 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.
12To determine disruptions and to ensure the security of our systems, including the detection and tracing of (the attempt of) unauthorised access to our web serversCompliance with the legal obligations regarding data security as well as legitimate interestWe have a legitimate interest in resolving disruptions, ensuring the security of our systems and the detection and tracing of (the attempt of) unauthorised access.
13To safeguard and defend our rightsLegitimate interestWe have a legitimate interest in exercising and defending our rights.
14To comply with relevant legal obligations, such as keeping accounting records.Compliance with legal obligationsn/a

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”.

6. Cookies

Shure uses cookies to improve performance and enhance the user experience for those who visit our website. This policy clarifies 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.

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. 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/

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.

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”.

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).

10. 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).

 

10.1. General information and joint controllership

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10.2 What are the purposes of the CRM Tool and legal bases?

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10.3 Which categories of personal data are processed in relation to the CRM tool?

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10.4 Which rights do you have?

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10.5 Who is responsible for dealing with the rights I exercise as a data subject? 

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10.6 Who is responsible for providing the information referred to in Articles 13 and 14 GDPR to me?

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10.7 Single point of contact 

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11. 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:

11.1 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.

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

 

11.2 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.

11.3 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 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".

12. 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".

13. 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

14. 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 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 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.

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.

15. 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.

16. 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.

18. 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.

19. 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 Switzerland GmbH

privacy@shure.com

Brandstrasse 26
8952 Schlieren
Switzerland

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 Switzerland GmbH

privacy@shure.com

Brandstrasse 26
8952 Schlieren
Switzerland