UPDATED: November 14, 2023
Information Symphonic Collects
Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information“). The list below includes the categories of personal information that we have collected in the past twelve (12) months from users of the Services. The specific information collected from each category below is detailed in the Section of Symphonic’s Policy titled: “What Personal Information Does Symphonic Collect?”
- Identifiers such as a name, email address, IP address, account name, and information as listed in Symphonic’s Policy.
- Personal information described in Cal. Civ. Code Section 1798.80(e), such as a credit card number.
- Credit card number in combination with any required credentials.
- Commercial information relating to your use of the Services.
- Internet or other electronic network activity information relating to your use of the Services.
- Professional or employment-related information (if you apply for employment with Symphonic or are a Symphonic employee).
- Non-public education information (if you apply for employment with Symphonic or are a Symphonic employee).
Sources of Personal Information
We collect personal information from the sources identified in the Policy in the section titled: “How Does Symphonic Collect Your Personal Information?”
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the purposes as described in the Policy as set forth in the section titled: “How Does Symphonic Use Your Personal Information?”
Please also see the Notice at Collection for California residents below for additional details concerning how we use your personal information.
Symphonic will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes than as set forth in the Policy and herein without providing you notice, if required.
Disclosures of Personal Information to Service Providers
Symphonic may disclose your personal information to a service provider for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Symphonic has disclosed the following categories of personal information to service providers for a business purpose:
- Identifiers (as may be set forth on the list of information contained in the Policy and herein)
- California Customer Records personal information categories
- Commercial information
- Internet or other similar network activity
We disclose personal information for the business purposes described in the Policy as set forth in the section titled: “How Does Symphonic Use Your Personal Information?”
Sales and Sharing of Personal Information for Cross-Context Behavioral Advertising
In the preceding twelve (12) months, Symphonic has not sold personal information about California consumers for monetary consideration or shared personal information about California consumers for cross-context behavioral advertising (which also may be classified as a “sale” of personal information under California law).
We do not knowingly sell or share the personal information of persons under 18. The Services are not intended for children under the age of 18 and if you are under age 18, you must not use or provide any information on the Services.
Symphonic does not sell or share sensitive personal information for any purpose outside the exemptions identified in the CPRA regulations.
Your Rights and Choices
The CPRA provides California residents with specific rights regarding their personal information. This section describes your CPRA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Symphonic disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- In instances where we have disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Symphonic delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion and Correction Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny some or all of your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Change or Correct Personal Data
You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion and Correction Rights), we will change or correct (and direct our service providers to delete) your personal information from our records.
Exercising Access, Data Portability, Deletion and Correction Rights
To exercise the access, data portability, deletion and correction rights described above, please submit a verifiable consumer request to us at firstname.lastname@example.org.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to confirm receipt of your request within 10 days, as well as provide general information about how the business will process the request. We also endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CPRA that can result in different prices, rates, or quality levels. Any CPRA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
California Notice at Collection
Information we collect:
We have collected the following categories of personal information within the past 12 months: (1) identifiers, (2) personal information categories listed in the California Customer Records statute, (3) protected classification characteristics under California or federal law, (4) Commercial information, (5) Internet or other similar network activity, (6) professional or employment-related information, and (7) non-public education information.
Purpose of collecting the information:
We collect the above information in order to manage your account, provide customer support, notify you of additional Symphonic products and services, improve our Services and your experience, promote our Services via customized advertising on third party sites, for customer relationship management purposes, to recognize you across devices, and for the safety and security of our Services.
For job applicants and employees at Symphonic only:
We also collect certain additional information such as professional or employment-related information and non-public education information to execute and improve hiring and recruitment at Symphonic in compliance with applicable laws and regulations.
Sources of information:
We obtain the above categories of personal information directly and indirectly from the information you provide us when signing up for an account and adding information to your profile, from your use of Facebook or Google to log in to the Services, from your accessing the Services through other third-party social media platforms, from your support requests, and from your use of our forums, message boards, blogs and/or news groups.
For job applicants and employees at Symphonic only:
We collect information as part of the application process which includes employment-related and non-public education information that you provide us throughout the hiring process. We collect information that you provide in your resume, CV, and/or cover letter such as identifiers, professional or employment-related information, including your prior work history, and education information, such as where you have gone to school. We also may collect information from our employment application form, during your conversations and interviews with us in connection with your application for employment, and through information you provide through third-party recruiters and professional networking sites.
Purposes of disclosure:
We share your information to help us operate, provide, improve, understand, customize, support, and market our services. We track the usage of our Services and websites to maintain, promote, and improve those services, for example ensuring that Symphonic is secure and protected against fraud, spam, misuse, and abuse.
For job applicants and employees at Symphonic only:
We may disclose certain data that you provide through the job application and hiring process to comply with government reporting requirements. We may also provide this information to certain service providers such as those that we use to process job applications and applicants and third-party recruiting firms that we use to manage the hiring process.
Retention of information:
For job applicants and employees at Symphonic only: The length of time we retain personal information and sensitive personal information that you submit to us when applying for a job at Symphonic depends on the outcome of your application. Symphonic complies with minimum retention periods for this information required by federal and state law. If you become a Symphonic employee, we will retain your personal information in accordance with our policies regarding the maintenance and preservation of personnel records.
Sensitive Personal Information:
We do not sell your sensitive personal information or share it for purposes of targeted advertising.
For job applicants and employees at Symphonic only:
During the job application process, you may voluntarily provide us with certain sensitive personal information including your racial or ethnic origin, your gender identity, information concerning your sexual orientation, and health information. We collect information concerning your racial or ethnic origin, your gender identity, and your sexual orientation to help Symphonic monitor its recruiting programs and comply with certain government reporting obligations. We collect your health information to evaluate the need for reasonable accommodations to qualified individuals with disabilities.
We do not sell your personal information for monetary consideration or share your personal information for cross-context behavioral advertising (which also may be classified as a “sale” of personal information under California law).
Changes to Our Privacy Notice
Symphonic reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the www.symphonic.com website and update the notice’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which Symphonic collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us via email at email@example.com.