Supplemental Privacy Notice for California Residents

 

First Implemented: January 1, 2020

Last Updated: January 1, 2020

The California Consumer Privacy Act (“CCPA”), which is effective as of January 1, 2020, regulates how businesses handle “personal information” (as such term is defined in the CCPA) of California residents and gives California residents certain rights with respect to their personal information. If you are a resident of California, we are required to inform you of how we use and disclose your personal information, as well as of certain rights you may have. This supplemental privacy notice (this “Notice”) is effective as of January 1, 2020, shall apply only to residents of California who are Direct Users and Visitors of our Services, and supplements Symphony’s general Privacy Policy. We will review this Notice at least annually and, to the extent we make any revisions, we will update this Notice and the “Last Updated” date above to indicate that changes were made. Any capitalized terms used in this Notice have the same meaning as in the Privacy Policy.

Symphony is both a “business” and a “service provider” under the CCPA, depending on which kind of User you are. This Notice applies only to personal information we collect in our role as a business. We act as a business when we collect and use personal information about Direct Users of the Symphony Services and Visitors of the Site.

If you are an Authorized User: (1) we act as a service provider to, and follow the instructions of, your Company (e.g., your employer) with respect to how we process your personal information; and (2) if you would like more information about how your personal information is processed or your rights under the CCPA, please contact your Company directly.

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for business purposes* the following categories of personal information about Direct Users and Visitors (and, depending on whether you are Direct User or a Visitor, we may not have collected or disclosed any or all of this information):

  • Identifiers, such as your name, IP address, email alias, email address, mobile device identifier, zip code, and date of birth. This information is collected from you and/or your device when you access the Services or register for an Account, and it is collected to create your Account and to provide, improve, and personalize the Services.
  • Internet or other electronic network activity information, such as Cookies and Usage Data. This information is collected directly from you and your device to provide, improve, and personalize the Services.
  • Geolocation data derived from your IP address or obtained from your device’s location services (including GPS coordinates or coarse location). This information is collected directly from your device to improve and personalize our Services.
  • Visual information such as Direct Users’ profile pictures which are uploaded into the Symphony Services by you and are collected to provide the Services.
  • Professional or employment-related information such as your employer name, job title, and job description. This information is collected directly from you and is collected to provide, improve, and personalize the Services.

*We collect and disclose the above categories of personal information for “business purposes” as defined in the CCPA, which include providing our Services, maintaining and servicing accounts, providing customer service and support, detecting and protecting against security incidents and malicious or fraudulent activities, identifying and repairing errors within the Services, verifying and maintaining the quality of the Services, improving, upgrading, and enhancing the Services, and conducting research and development activities.    We may also disclose your information to comply with laws and protect the rights and safety of Symphony or third parties, as described in the Information Disclosed for Our Protection and the Protection of Others section of the Privacy Policy.

Symphony does not, and during the past 12 months did not, “sell” personal information of California residents (as such term is defined in the CCPA).

Rights under the CCPA 

If you are a Direct User or a Visitor who is a California resident, you have the right to:

  • Request we disclose to you, free of charge, the following information covering the 12 months preceding your request:
    • the categories of personal information about you that we collected;
    • the categories of sources from which the personal information was collected;
    • the purpose for collecting personal information about you;
    • the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
    • the specific pieces of personal information we collected about you;
  • Request we delete personal information we collected from you, unless the CCPA recognizes an exception; and
  • Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA.

How to Exercise Your Rights

If you are a Direct User or Visitor to whom the CCPA applies, you may contact us to exercise your rights at [email protected]. Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. If we need additional information to verify your identity or to respond to your request, we will let you know. We aim to fulfill all verified requests within 45 days pursuant to the CCPA.  If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

Additionally, if you are a Direct User, you can access the following types of your personal information at any time by logging into your Account:

  • Name;
  • Email address;
  • Email alias;
  • Any personal information you have elected to include in your Profile Data;
  • Any other personal information contained in your Posted Data