Published on: December 13, 2023
1. INTRODUCTION AND SCOPE
Our websites, apps, and services are designed for businesses and their representatives. We do not target consumers – individuals who seek to use products and services for their personal or household use. Accordingly, we treat all personal data we collect as pertaining to individuals in their business capacity and not their individual capacity.
SymphonyAI as a Data Processor or Service Provider.
SymphonyAI acknowledges that you may have the right to access your personal data. SymphonyAI has no direct relationship with the data subjects whose personal data we process on behalf of our Customers. An individual who seeks to access, correct, amend, or delete personal data about them that we process on behalf of our Customers should direct their requests or queries to our Customer (i.e., the data controller). In addition, we will forward to the applicable Customer any request by a data subject received by SymphonyAI regarding personal data processed on behalf of that Customer.
SymphonyAI as a Data Controller
International Data Transfers
When SymphonyAI operates as a data controller (i.e., when we determine the manner, purposes and means of the processing of others’ personal information), SymphonyAI may collect from, transfer to, or process, and store your personal information in the United States and other countries other than the country where you live. When we transfer personal data from the EU, Switzerland, or UK to any other country, we will do so according to an adequate mechanism of transfer as required by applicable laws or regulations.
2. SYMPHONYAI COLLECTION AND USE OF PERSONAL INFORMATION
2.1. What categories and specific types of personal data does SymphonyAI collect?
Information that we collect from or about you includes the following:
|Categories of collected personal data
|Identification and Contact Information
|Details such as name, postal address, e-mail address, or telephone number, either actively or passively, and billing information such as tax address.
|Information that you provide when you fill in forms on our websites, such as your job title, and other contact details.
|Information about your Internet connection and Internet protocol (IP) address, your login data, the equipment you use to access our websites and applications, time zone settings and location, browser plug-in types and versions, operating system and other technology on the devices you use to access or use our websites.
|Marketing and Communications Data
|Your preferences in receiving marketing from us and our partners and your communication preferences and consents. Your responses to surveys that we might ask you to complete for research purposes. Records and copies of your correspondence (including email addresses and LinkedIn URLs), if you contact us. This information may contain contact details you include within your correspondence.
|Inferred or assumed information relating to your behavior and interests, based on your online activity and your use of our websites.
We do not collect any “Special Categories of Personal Data” or Sensitive Information as defined by California Consumer Privacy Act about you. This includes details about your race or ethnicity, religious or philosophical beliefs, financial account information, precise geo-location data, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offenses.
Legal Basis and Purpose for Processing Personal Data
Where we process personal data as a processor or a service provider pursuant to service contracts with our Customers, we only process personal data on the instructions of the Customer, and only as necessary, appropriate and customary to provide our services.
If you are an individual located in the European Economic Area (EEA) or an individual whose personal data is protected by laws similar to the General Data Protection Regulation (“GDPR”), our legal basis and purpose for collecting and using the personal data described above in this Section 2.1 will depend on the personal data concerned and the specific context in which we collect it. However, we will normally collect personal data from you only where: (a) we have your consent to do so, (b) where we need the personal data to perform a contract with you (e.g. to deliver the services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person.
Examples of Legitimate Basis and Purpose for Collecting Your Personal Data
In connection with your use of our services, we collect and process personal data to perform our contractual obligations related to the services that you have requested. Where we collect personal data in connection with operating our websites and services, we have a legitimate interest in ensuring our websites, services and associated networks and IT systems operate properly and securely. Where you have requested to receive information about our products, services and business or other marketing communications, then we process personal data based upon our legitimate interest in engaging in direct marketing with Visitors, Customers, Attendees, individuals and companies that have requested to receive information from us.
Where you have responded to a job posting on our websites, we collect and process personal data as part of our consideration of your application. Where we rely on your consent to process the personal data, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
2.2 How does SymphonyAI collect my personal data?
SymphonyAI may directly collect personal data you provide us in the following ways:
- When you complete forms on our websites, such as requesting a demo, or applying for a job.
- When you perform search queries on our websites.
- When you use our publicly accessible blogs.
- When you contact us outside of our websites, such as via email or LinkedIn.
- When you request assistance from our support team.
- When you respond to surveys we ask you to complete for research purposes.
- When you register for or attend our marketing activities.
- When you submit an entry to a sweepstakes or contest that we sponsor.
2.3 Does SymphonyAI collect personal data automatically?
As is true of most websites and services provided using the Internet, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), the referring page that you navigated to our websites from, the page that you navigated to from our websites, the files viewed on our site (e.g. HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
The information we collect automatically is statistical data, which we may associate with personal data we collect in other ways or receive from third parties. This information helps us to improve our websites and to deliver better and more personalized service.
We partner with a third party to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on our websites and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union, click here). Please note that this does not opt you out of being served ads, you will continue to receive generic ads.
2.4 How does SymphonyAI use my personal data?
We use your information to enhance your experience using our websites and services.
We use personal data that we collect about you or that you provide to us, including any personal data about Visitors, Customers, and Attendees:
- To present our websites and their content to you.
- To provide you with access to our services and to maintain access controls over secured areas of our websites.
- To provide you services for which you have engaged us.
- To provide you with information, products, or services that you request from us, including technical instructions for implementing your service and responding to customer support and sales inquiries.
- To fulfill any purpose for which you provide it.
- To provide you with notices about your account and/or subscription, including expiration and renewal notices.
- To provide you with information or services that you request from us.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To save your preferences (including requests to not receive communications).
- To allow you to participate in interactive features on our websites.
- To personalize our websites to optimize your experience and match your preferences.
- To send you promotional materials about our services and events, including newsletters, product updates, information about and invitations to marketing events.
- To process and deliver contests or sweepstakes entries and rewards.
- To plan and host marketing activities.
- To communicate with you about corporate marketing events, which may include promotional information.
- In any way we describe when you provide or we collect the information.
- To comply with applicable legal and regulatory requirements.
- To assure the safety of your account and our platform.
- For any other purpose with your consent.
2.5 How long does SymphonyAI retain my information?
We retain your information for as long as needed to provide you our services or perform our contractual obligations, unless a longer retention period is required or permitted by law. The retention period shall not exceed the duration of our business relationship with you plus (7) years unless we have a legitimate business interest need to retain the information for a longer period, which include maintaining a record of your preferences, securing the integrity of databases, conducting audits, complying with our legal and contractual obligations, resolving disputes, and enforcing our agreements.
3. THIRD PARTY COLLECTION AND USE OF PERSONAL DATA
3.1 Does SymphonyAI share my personal data with others?
Third-Party Service Providers
We engage third-party service providers in the operation of our business or to support our business. We consequently share information, including personal data, with these contracted third-party service providers in connection with using their services. These include cloud-based productivity and collaboration tools, customer relations management, security tools, staffing service providers, backup, storage, payment processing, analytics and other services. We also engage and share information with third-party service providers for fraud protection, credit risk reduction and payment collection associated with our accounts. Our service providers may have access to, process or store your personal data for the purpose of providing us with their contracted-for services.
Our service providers are not authorized to process your personal data for purposes other than as necessary, appropriate or reasonable to provide the service we have purchased.
SymphonyAI LLC and its subsidiaries and affiliates share information, including personal data, in the operation of our global business because our SymphonyAI LLC, and/or subsidiaries and affiliates may provide you services under our contracts or other functions, consistent with the purposes described in Section 2.4 above.
Third Party Cookies
We may disclose your personal data to any third party with your consent and appropriate notice.
Compliance with Laws; Law Enforcement Requests; Protection of Our Rights
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may disclose personal data to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary or appropriate in order to protect our rights, property, or safety of SymphonyAI, our Visitors, Customers, or Attendees, Job Applicants, our personnel or others, to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our contracts, or as otherwise required by law.
We may share your personal data to a potential buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SymphonyAI’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by SymphonyAI about our websites users is among the assets transferred. We may also share your personal data with potential investors, financing sources, auditors or agents that may conduct due diligence of our business. You will be notified via email and/or a prominent notice on our websites of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.
If you provide us with contact information for persons you would like to refer, we will communicate with the referred persons and may disclose you as the source of the referral. If you believe that one of your contacts has provided us with your personal data and you would like to request that it be removed from our databases, please contact us at firstname.lastname@example.org.
3.2 Data Supplementation
We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal data about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. If we receive personal data about you from a third party in order to engage in marketing of our services, then we will market to you only in your capacity as representatives of companies we wish to sell to and we will present you an opportunity to opt-out of future communications.
Examples of the types of personal data that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include:
- Contact information about you, including your name, email address telephone number, from third party sources to verify your address so we can properly prevent fraud or communicate with you; or
- Data purchased from third parties, such as social networking sites and conference attendee lists, that is combined with information we already have about you, to create more tailored advertising and products. If you receive a marketing communication or promotion from us, you may opt-out of these communications at any time by clicking the unsubscribe link provided in the email or by sending a request to email@example.com.
3.3 How is my personal data handled by third-party sites?
4. YOUR CHOICES AND RIGHTS
The following table explains your rights with respect to your Personal Data that SymphonyAI controls:
|Be informed of the personal data we collect about you and how we process it
|Know & Access
|Request to know and access the personal data we collect about you
|To request a copy of your personal data from SymphonyAI please contact firstname.lastname@example.org
|Request that we amend, correct, or update your personal data.
|You can request we delete your information by emailing email@example.com
|Right to Limit
|Under California law, you may request that we limit the processing of sensitive personal data if we are using or disclosing it for purposes other than those specified in Section 7027(m) of the CCPA Regulations.
|Currently, we are not using or disclosing any sensitive personal data for the purposes of providing our products and services to you.
|Request that we stop processing all or some of your personal data.You can do this if:your personal data is inaccurateour processing is unlawfulwe do not need your information for a specific purpose, oryou object to our processing and we are assessing your objection request.You can request that we stop this processing temporarily or permanently.
|Object to us processing your personal data.You can do this if:SymphonyAI is processing your personal data on the legal basis of legitimate interests, orSymphonyAI is processing your personal data for business to business purposes.
|To exercise your right to object, you can contact firstname.lastname@example.org
|Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service. You can request us to transmit your data when we are processing your personal data on the legal basis of consent or performance of contract.
|Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal data or if we have retained your personal data after the closure of your account. To request this information please contact us via the information supplied in the Contact Information section below.
|Not be subject to automated decision making
|Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
|SymphonyAI does not employ automated decision making as part of providing its products or services to you where the decision would have a legal effect on you or produce a similarly significant effect.
|Withdrawal of consent
|Withdraw your consent to us collecting or using your personal data or update your subscription preferences
|You can modify the settings by following the link at the bottom of any email communications.
|Withdraw or opt-out of sharing or selling data
|Under California Law you have the right to withdraw or opt-out of consent to sell and/or share your data
|SymphonyAI does not sell your data to third-parties. Please see Section 3 on sharing data with third-parties.
4.2 How can I report abuse?
If you need to report abuse, please contact us by email at email@example.com. SymphonyAI’s language for official communications is English.
5. SECURITY AND PRIVACY MEASURES
5.1 How does SymphonyAI protect my information and data?
We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure.
Information you provide to us is stored on our secure servers behind firewalls. Any sensitive information is encrypted using Transport Layer Security (TLS) (sometimes referred to as Secure Sockets Layer or SSL).
You must also make sure that your personal data is safe and secure. Even if we give you (or you have chosen) a password for access to certain parts of our websites, you are responsible for keeping this password confidential. Do not share your password with anyone. We urge you to be careful about giving out information in public areas of our websites, for example, message boards. The personal data you share in public areas may be viewed by any user of our websites.
Information that is transmitted via the Internet is not completely secure. We cannot guarantee the security of your personal data transmitted to our websites. Any transmission of personal data is at your own risk. We are not responsible if you circumvent any privacy settings or security measures on our websites.
5.2 How does SymphonyAI limit access to my personal data?
We limit access to certain pages on our websites and allow you to set certain privacy settings via your account profile; however, be aware that no security measures are perfect or impenetrable.
Additionally, we cannot control the actions of other users of our websites with whom you may choose to share your user contributions. Given that, we cannot and do not guarantee that your user contributions will not be viewed by unauthorized persons.
6. OTHER IMPORTANT INFORMATION
6.1 Children Under the Age of 16
Our websites are not intended for children under 16 years of age. No one under age 16 may provide any personal data to or on the websites.
We do not knowingly collect personal data from children under 16. If you are under 16, do not use or provide any information on our websites or on or through any of their features, register on the websites, make any purchases through the websites, use any of the interactive or public comment features of our websites or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 16, we will delete that information immediately.
If you believe we might have any information from or about a child under 16, please contact us via the Contact Information section below.
6.2 California Privacy Rights
California Civil Code Section § 1798.83 permits users of our websites that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail or write to us at our mailing address noted in the Contact Information section below.
7. CONTACT INFORMATION
or SymphonyAI LLC, Attn: Legal Department, 3300 Hillview Ave, Palo Alto, CA 94304.
SymphonyAI’s language for official communications is English.
Starting on January 1, 2020, the California Consumer Privacy Act (“CCPA”) governs how businesses handle the personal information of California residents. CCPA was amended by the adoption of the Consumer Privacy Rights Act (“CPRA”) effective March 29, 2023. SymphonyAI LLC and its subsidiaries and affiliates (collectively, “SymphonyAI”) is committed to our customers’ success, including their compliance efforts with respect to the CCPA.
How does SymphonyAI address its customers’ compliance with the CCPA?
For SymphonyAI’s customers, SymphonyAI is a “service provider” under the CCPA. We process personal information only on behalf of our customers, pursuant to written contracts. Those contracts, which are already in place, permit SymphonyAI to process our customers’ data (including personal information) only for the purpose of providing our services. While we necessarily have to process personal information submitted to any of our services, we do not sell that information to third parties.
How does SymphonyAI address consumer rights under the CCPA?
If you or anyone in your organization has questions about how SymphonyAI helps your organization comply with the CCPA, contact firstname.lastname@example.org.
Published on December 13, 2023.
When you visit SymphonyAI websites, information is stored on your device in the form of a “cookie.” Cookies are small files that are stored on your device and save certain settings and data to exchange with our websites via your browser. For example, cookies enable us to tailor a website to better match your interests or remember your username or password so that you do not have to re-enter it every time.
Web beacons and other similar files can perform similar functions and we use “cookie” in this Policy to refer to all files that collect information in this manner.
When you first visit our websites, we send one or more necessary cookies to your device. Upon your return to our websites, any necessary cookies and other device cookies that you opt in to enable us to recognize your web browsers. SymphonyAI uses session-based cookies, which last only during one browsing session. A session-based cookie is erased from your device when you close your web browser or turn off your device. SymphonyAi also uses persistent cookies, which remain on your device after you have closed your browser or turned off your device.
SymphonyAI may use web beacons, tags and scripts in our websites or in emails to help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our service/analytics providers on an individual and aggregated basis. We use this information collected from web beacons for determining which of our emails are more interesting to you and other users and improve our websites, our services and email communications.
If you opt in to cookies that collect analytics information, we collect analytics information when you use our websites to help us improve them. We may also share data about activity on our websites with third-party service providers for analytics of our website performance.
|These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
|These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
|These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
|These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
|These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.
5. How to Manage and Disable Cookies
Please note that certain functions of our website may no longer work, or not work correctly, without cookies.
When you apply to a job on this site, the personal data contained in your application will be collected by SymphonyAI LLC. (“SymphonyAI”), which is located at 3300 Hillview Ave, Palo Alto, CA 94304, United States of America, and available by email at email@example.com. Your personal data will be processed for the purposes of administering SymphonyAI’s recruitment related activities, which include setting up and conducting interviews, evaluating and assessing the interview results, and as is otherwise needed in the recruitment and hiring processes. Such processing is conducted in accordance with Art. 6(1)(f) of Regulation (EU) 2016/679 (General Data Protection Regulation) for the purposes of the legitimate interests pursued by the Fastly, which are the solicitation, evaluation, and selection of applicants for employment.
Your personal data will be shared with iCIMS, Inc. (“ICIMS”), a cloud services provider located in the United States of America and engaged by SymphonyAI to help manage our recruitment and hiring process, subject to an agreement between SymphonyAI and ICIMS that limits the collection and use of your personal data related to SymphonyAI’s recruitment and hiring activities. If you are located outside of the United States, your personal data will be transferred to the United States once you submit it through this site.