Privacy policy for applications

Your privacy is important to GN Audio (Jabra, us, we). Jabra supports the protection of consumer privacy on the internet and the principles of disclosure and fair information practices. With the range of applications (apps) Jabra has made available, there are many ways you can use these. When sharing information with Jabra, the experience and services provided in terms of quality as well as functionality, can be improved.

Your online privacy is our priority, and Jabra respects your privacy choices. If you share your personal information with Jabra, the information will be treated according to this policy, which we encourage you to read. Jabra want to keep this policy as simple as possible, but in case you are not familiar with terms like cookies, IP addresses, pixel tags, and browsers, you are encouraged to explore these key terms first.

If you have questions or concerns in relation to data protection, you are always welcome to contact our Data Protection Officer (DPO) by email DPO@jabra.com; or telephone number: +45 45 75 00 00

The entity responsible for the processing of your personal information (formally called the data controller) is:

GN AUDIO A/S;
Lautrupbjerg 7; DK-2750 Ballerup; Denmark; Reg. no. 1506 9511
Telephone number: +45 45 75 88 88; Email address: DPO@jabra.com; Website: www.jabra.com

Clarity and transparency

Jabra wants to make you feel safe and informed when using our mobile apps. Whenever you use our services, we aim to provide you with access to your own personal information and strive to give you ways to update it quickly or to delete it, unless prohibited for legal purposes.

Information jabra collects

Jabra collects information from your use of the app and the information you enter in to the app.

Furthermore, the app might collect personal information from your phone for the app to operate as intended. this can include phone number, contact details, date and time. this information is not sent to jabra.

To provide you with full functionality of the apps and to help us provide you with an improved jabra experience we are interested in information about how you use our mobile apps. when sharing information with jabra on how you use the app features we can learn about the capability of these apps and how they interact with our products, so we can improve and enhance future updates.

Our mission is to employ the user behavior insights to further develop the user experience of our future mobile apps. the information you provide to jabra will not be used for other purposes without asking for your permission. under no circumstances will jabra sell your personal information.

The information you enter in to the jabra apps
in general, the information you enter in to the app will stay in the app and will therefore not be forwarded to us by default. for example, when you use the app you might be asked for personal information such as your name, gender, height, weight, date of birth, profile picture, email address, and telephone number. this data will stay on your device unless you enable the functionality of sharing within the app.

If you opt-in the sharing functionality, we can also ask you to create a publicly visible jabra account, which include your name and photo. in some jabra apps you can share information on social media and a 3rd party vendor. to use such features, the app will need your credentials which is stored on your device but will not be forwarded to jabra.

The information we receive from your use of jabra apps
when you download the app and use the app, jabra collects the following information about the services you use and how you use them:

• Device information: Device-specific information (such as your mobile devices unique device id, the type of mobile device you use, the ip address of your mobile device, bluetooth name, bluetooth mac address and your mobile operating system).


• Unique app numbers: Some of our apps has a unique app number. this number and information about your installation (for example, the operating system type and application version number) will be sent to jabra when you install or uninstall that application or when that application periodically contacts our servers, such as for automatic updates.


• Log information: When you use jabra apps or view content provided by jabra, we collect and store certain information in server logs, like: details of how you used our application, internet protocol address, device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral url.

If you want to use the location service or the workout performance, you will share the following information:

• Location information – opt-in: Only, when you enable a location-enabled service, we collect and process information about your actual location, like gps signals sent by your mobile device. we may also use various other technologies to determine location, such as sensor data from your device that may provide information of nearby wi-fi access points and cell towers. when you opt-in the location service you agree and acknowledge we can collect and process this information.


• Fitness data – opt-in: When enabling the sharing features for our sports apps, we receive information about: performed workouts; heart rate over time, geographical coordinates (gps) over time, calories consumption over time, speed (pace) over time, date and time of workout, (activity) type of workout, total duration of workout, total distance, total calories consumed, snapshot (image) of map and path taken during the workout with heart rate zone color information (if applicable), average heart rate, average speed (pace), test result - heart rate, vo2 score, resting heart rate stress feedback.

Only, when you enable sharing, jabra use a 3rd parties to benchmark your workout performance. when you opt-in this functionality, you agree and acknowledge, that we may disclose to a specific 3rd party (currently flurry analytics) your user generated content, including time of workout, total time of workout, and workout activity. this information can also be uploaded to your icloud for backup purposes, however you do not share the information located on your icloud with us.

Purposes and legal basis for processing of personal data

As previously mentioned jabra utilizes the storage of data on the device to the extent possible. this way jabra limits its collection, storing and processing of personal data to situations where a specific purpose exists. with reference to the eu gdpr, we have listed below the most relevant purposes and the legal basis for these purposes together with some of the activities associated with those purposes.

EU GDPR article 6.1.a (consent) is used when you activate the opt-in function as mentioned in the section above called “location information opt-in”. when you enable the functionality, you provide us with relevant location data directly and you provide us with your consent to obtain personal data.

EU GDPR article 9.2.a (explicit consent) is used when the opt-in function as mentioned in the section above called “fitness data opt-in” is activated. jabra fitness data is a form of health data and thereby sensitive data. when you enable the functionality, you provide us with relevant health data directly and you provide us with your consent to obtain this personal data.

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.

Retention policy

You can at any time stop all collection of information by any jabra app, by uninstalling the app. you can do this by using the standard uninstall processes which is available as part of your mobile device or via the mobile app marketplace.

We aim to retain any information already collected only for as long as you use the jabra apps and for a minimum and reasonable period thereafter. we only retain information in accordance with applicable legislation.

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. you can withdraw your consent by opt-out this functionality.

Information security

Jabra is very observant of protecting your data from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. 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.

Transferring and sharing of information

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. dependent on the nature of the purpose we might therefore share your personal information with the legal entities jabra is part of (Group GN), business partners and vendors who deliver a specific service, like technical support, hosting and supply services as well as public authorities. such transfers will only take place for a specific purpose. to the extent possible, we refrain from sending personally data to countries outside the EU/EEA.

• 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. regardless, jabra will always ensure that appropriate safeguards are in place for such transfers by using countries 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. if the country has 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 using "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.


• Certain business partners and vendors process personal information on behalf of jabra and may only process your personal data in accordance with the instructions given by jabra and in compliance with this privacy policy and any other appropriate confidentiality and security measures. these third parties may not process your personal data for their own purposes. to the extent jabra disclose or transfer your personal data to these third parties who may use your personal data for their own purposes, such disclosure or transfer will only take place if it is in accordance with applicable law or with prior consent obtained from you.

If jabra is involved in a merger, acquisition or asset sale, jabra will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

Jabra may share aggregated, non-personally identifiable information publicly and with partners, which could be publishers, advertisers or connected sites. for example, jabra may share information publicly to display trends about the general use of our applications.

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. if you want to exercise your rights, please contact our DPO.

• Right of access: You have the right to request access to your personal data which we have processed about you and some other information in relation to the processing.


• Right to rectification: You have the right to get inaccurate personal data concerning 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 concerning 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 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.

Filing of complaint

If you wish to file a complaint regarding our processing of your personal data, please contact our DPO. if your complaint is not resolved, feel free to contact the danish data protection agency.

• Our DPO at GN AUDIO A/S;
  lautrupbjerg 7; dk-2750 ballerup; denmark; reg. no. 15069511
  telephone number: +45 45 75 00 00; email address: DPO@jabra.com; website: www.jabra.com


• Danish Data Protection Agency (Datatilsynet)
  Borgergade 28, 5; DK-1300 Copenhagen K; Denmark;
  Email address: dt@datatilsynet.dk; Website: www.datatilsynet.dk

Changes to the privacy policy

This privacy policy will be updated on a regular basis and when necessary due to changes in applicable laws and regulations. we will post any privacy policy changes on this page and notify you by updating this privacy policy as part of a general application update. if the changes of this privacy policy are regarded as material and significant, you will be expressly informed hereof.