Lautrupbjerg 7; DK-2750 Ballerup; Denmark; Reg. no. 1506 9511
Phone: +45 45 75 88 88; Email address: DPO@jabra.com Website: www.jabra.com
Data protection officer
If you have questions or concerns in relation to data protection, you are always welcome to contact our Data Protection Officer (DPO) by email at DPO@jabra.com, or by phone: +45 45 75 00 00
Personal data we collect about you
to identify you, either directly or in combination with other information that we possess. Your personal data may include for example your name, your contact details, information relating to purchases or information on how you use our websites and apps or how you interact with us. We collect personal data from you, for example when you use our websites and our apps, use our services or contact us.
The data we collect
We collect and process the following categories of information about you:
- Contact details
When you create an account on our website or when you purchase our products we will need your name, address and country, to be able to send the products to you. We also need your email to send order confirmations and order updates to you. We also collect your telephone number to contact you if you are not at home when the products are delivered at your address. There might be other reasons for us to have a need to contact you, such as when you use our Global Technical Support and when you participate in our contests or if you are a contact person for a business partner.
- The communications you exchange with us
When you contact us, or when we respond to you on inquiries of all types we collect emails, letters, calls, messages or chats. The Jabra web site offers qualified resellers tools that enable them to personalize online product presentations to make it easier to access the information that is of most interest to their customers. When you create a personal product profile account, you create for yourself a user name and password for future access to your profile, and you provide Jabra with personal contact information such as your name, address, phone, and e-mail address. Your user name, password and personal information will not be shared with other organizations.
- User IDs and Passwords
Provides you with access to your profile areas on our web shops.
- Information about payments
When purchasing products at Jabra’s websites, we cooperate with a third-party payment provider. We will not have access to your payments details, so here we refer you to the payment providers privacy policies.
- R&D Tests
Our User Experience Team performs surveys and analytics to provide you with better products in the future to come. If you volunteer to one of these tests, we will ask you to sign a consent letter which specifies the purpose and the data we collect. Normally we would collect your contact details (ref. A), as well as data related to that specific test. This could be opinions, interpretations, preferences, biometric data and fitness data. This data will be pseudonymized before it is shared within the project team and will be anonymized once the project no longer need to be able to go back to you (e.g. when the new product is launched).
- Use of data cookies
- Internet Protocol Reporting
Jabra uses your IP (Internet Protocol) address to monitor web site traffic and to help diagnose problems with our server. We do not use IP addresses to personally identify users. Jabra does use a log file of IP addresses to determine which areas of our site visitors like based on the volume of traffic and on aggregate geographic data. This information is used to better prepare future site content and design based on the interests of users.
- Opting Out and unsubscribe
We provide users the opportunity to opt out of receiving any further communications from Jabra when they receive distributions via e-mail. At the end of each email message, instructions on how to unsubscribe and be removed from the mailing list database are included. Jabra gives users the option of contacting Jabra at any time to remove their information from our database or to stop receiving future electronic distributions.
- Sensitive personal data
We also collect sensitive data as defined in the EU GDPR. For Jabra sensitive data is related to our Sports products, which is categorized as Fitness data (alias health data). In addition, we use sensitive data in R&D which is biometric data and data about human race.
Collection of personal data
Personal data is collected either directly from you, such as through the product registration process, the employee application process or other processes where you allow Jabra to collect, process and store your information, or data is collected from you via partner entities or subsidiaries where you have provided them with consent. E.g. when ordering products on Jabra.com the payment process is done by a 3rd party specialized in these transactions. Only data used to forward you the products you paid for is forward to us. Personal data could also be collected from third parties which may include LinkedIn and Facebook. Finally, data could be collected without your knowledge, such as device-specific information (your mobile devices unique device ID or Lap-top id, the type of device you use, the IP address of your device, Bluetooth name, Bluetooth MAC address and your operating system). The purpose of collecting this last category is to optimize headset sound as well as provide you with the best possible user experience when visiting our sites.
Jabra does not intentionally collect personal data from anyone under the age of 16. Nor do we entice children to divulge any personal data, by means of special prizes or games. Jabra web site visitors must be at least 18 years old to participate in any Jabra sponsored on-line contests or giveaways. Jabra encourages parents to participate actively in their children’s Internet experience. If Jabra learns that the company has obtained personal data pertaining to a child under the age of 16, the information will be deleted from the database.
Purposes and legal basis for processing of personal data
Jabra limits its collection, storing and processing of personal data to situations where a specific purpose exists. With reference to the EU General Data Protection Regulation (GDPR), we have listed the most relevant purposes and the legal basis together with some of the activities associated with those purposes: We process your personal data on the following legal bases:
EU GDPR Article 6.1.a (Consent) is used when you activate the opt-in function in our apps, subscribe on our emails, you provide us with feedback etc. Here you provide us with your consent to obtain and process relevant personal data and/or to send you emails.
EU GDPR Article 6.1.b (Necessary for the performance of the contract between you and Jabra) is used when it is necessary for Jabra to have your personal data to send you products (e.g. ordering at Jabra.com), help you in our service and support desk, etc.
EU GDPR Article 6.1.c (Necessary for Jabra to comply with a legal obligation). The legal obligation could be related to tax & duty, but there could also be other reasons why Jabra is obligated to deliver personal data to the authorities.
EU GDPR Article 6.1.f (Necessary for the pursuit of legitimate purposes of us) is used when we collect information (above called “device information”, “app number” and “log information”) about the services you use and how you use them. This then enables Jabra to identify the need to enhance existing apps and develop new applications. We collect this data to provide, maintain, protect and improve the services. Ref. the previously mentioned, this could be information about features that are used, how often they are used and the context they are used in.
EU GDPR Article 9.2.a (explicit consent) is used when the opt-in functions in our apps is activated. Jabra fitness data is a form of health data and thereby sensitive data. When you enable this functionality, you provide us with relevant health data directly and you provide us with your consent to obtain this personal data. It could also be in relation to projects where consent has been provided to obtain biometric data for R&D purposes.
Recipients of personal data
Jabra will generally limit sharing your personal data and always only to the extent necessary. Under no circumstances will Jabra sell your personal information; sharing your information will take place on a need to know basis only and only to fulfil the above-mentioned purposes. However, we might share your personal information with suppliers, business partners and vendors that we work with to assist our business (meaning service providers, technical support, supply services, and financial institutions); other collaborators (such as company benefits as internet providers); group entities; and/or public authorities.
Jabra is part of the GN Group, which has entities throughout the world. Some of your personal data is transferred across some countries and entities in connection to various deliveries, services, projects, assignments etc. Note that we generally use the same systems across Jabra.
Transfer to countries outside the EU/EEA
As mentioned, Jabra is part of the GN Group, which has entities throughout the world. Jabra processes personal information on own servers around the world and use same IT services across the entire Group, so Jabra may process your personal information on IT services located outside the country where you live and outside of Europe. If we transfer personal data to countries outside the EU/EEA, the transfers will only take place for the specific purposes mentioned above, and we will always ensure that appropriate safeguards are in place for such transfer as set out below, either: (a) If the country/countries has/have been deemed by the Commission of the European Union to have an adequate level of protection of personal data, or using EU US-Privacy Shield certified organisations; or (b) If the country/countries has/have not been deemed by the Commission of the European Union to have an adequate level of protection of personal data, Jabra will provide appropriate safeguards for the transfer, either through the use of "Model Contracts for the Transfer of Personal Data to Third Countries", as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities. You may obtain more information about the contract/agreement by contacting us.
Your personal information will be stored for as long as it is necessary to fulfil the purposes described above and comply with minimum retention periods under applicable law. In general, this means we keep data for a minimum time and data will be deleted when no longer necessary under the purpose for which it was collected.
Withdrawal of consent
We hereby inform you, that when the processing of your personal data is based on your consent, you may withdraw your consent at any time. However, please note that this does not affect Jabra's processing of your personal data prior to withdrawal of your consent. We encourage you to opt-out or use un-subscribe when the consent is withdrawn, however you may also withdraw your consent by writing directly to our Data Protection Officer, ref. above.
- Your rights
As the data subject we would like to inform that Jabra has taken all necessary and adequate steps to protect your personal data and ensure your rights. Please note, that there may be more conditions or limitations to these rights than stated below.
- Right of access
You have the right to request access to your personal data which we have processed about you and additional information in relation to the processing.
- Right to rectification
You have the right to get inaccurate personal data that we have stored about you rectified. That includes completion of incomplete personal data.
- Right to erasure (right to be forgotten)
Under certain circumstances, you have the right to erasure, which means that upon your request, we will erase stored personal data about you before our normal retention period ends.
- Right to object
Under certain circumstances, you have the right to object at any time to our processing of personal data concerning you. You have an unconditional right to object to the processing of your personal data for direct marketing purposes.
- Right to restriction
Under certain circumstances you have the right to restrict our processing of personal data concerning you.
- Right to data portability
Under certain circumstances, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format, and the right to have your personal data transferred to another data controller.
Exercising your rights
You may take steps to exercise your rights by writing DPO@jabra.com. Please note, that there may be more conditions or limitations on these rights than stated above. It is therefore not certain for example you have the right of data portability in the specific case - this depends on the specific circumstances of the processing activity.
Jabra is very committed to protecting your data from unauthorized access to or unauthorized alteration, disclosure or destruction of information in our possession. In particular when you register your device we encrypt data communication using SSL, we review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems and we restrict access to personal information to Jabra employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Filing of complaint
If you wish to file a complaint regarding Jabra’s processing of your personal data, please contact our DPO (contact details above, section 2). Please note that you are also entitled to contact the Danish Data Protection Agency in case of complaints that we are not able to resolve.
Danish Data Protection Agency (Datatilsynet)
Borgergade 28, 5; DK-1300 KBH K; Denmark
Phone number: +45 33 19 32 00; Email address: firstname.lastname@example.org Website: www.jabra.com
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