First Implemented: October 2014
Last Updated: September 1, 2023
Symphony Communication Services, LLC (“Symphony”), together with its wholly owned subsidiaries—including Cloud9 Technologies, LLC (“Cloud9”), StreetLinx, Inc. (“StreetLinx”), and Amenity Analytics, Inc. (“Amenity”)—strongly believes in protecting the integrity and privacy of your personal information. Unless otherwise specified, Symphony, Cloud9, StreetLinx, and Amenity are collectively referred to as “us”, “our”, or “we.” The individual that accesses our Sites and/or Services is referred to as “you” and “your.”
For purposes of the applicable data protection laws, any questions regarding our policies or practices should be directed to our General Counsel at [email protected].
SECTION 1: DEFINITIONS
“Authorized User” is a User (generally an employee) that has been granted access credentials to the Service(s) from their Company pursuant to a Service Agreement between us and the Company.
“Company” is the company or organization that has paid us to use the Services pursuant to a Services Agreement and who has provided the User with access credentials to the Service(s). In most cases, this will be your employer.
“Direct User” is a User that has been granted access credentials to the Service(s) directly from us. For example, if you are using a non-paid version of the Symphony Services (whether through the Site, through your mobile phone, as a sponsored institution on the Symphony Community Pod, or otherwise).
“End User License Agreement” (“EULA”) refers to the terms and conditions applicable to your use of the Site and/or Service. The EULA governs your relationship with us.
“Personal Data” refers to any data, information, or combination of information, or combination of data and information that is provided by you or your Company relating to your use of the Sites or Services that relates to an identifiable individual.
“Site(s)” refers collectively to the public-facing websites maintained by Symphony, as well as its subsidiaries Cloud9, StreetLinx, and Amenity. This includes www.symphony.com.
“Service(s)” refers collectively to the Sites, cloud-based communication services, voice collaboration services, mobile applications, directory services, analytic services, and any other services provided by us.
“Service Agreement” refers to the contractual agreement providing terms and conditions applicable to your Company’s use of our Service(s). The Service Agreement governs your Company’s relationship with us.
“User” refers to Visitors, Direct Users, and Authorized Users.
“Visitor” refers to individuals that access the Sites.
SECTION 2: INFORMATION WE COLLECT ABOUT YOU
Our primary goals in collecting and using information are to provide and improve our Services, to administer your use of the Services, to respond to your comments and questions, to use your email address or other contact information to send you information related to the Services and to enable you to enjoy and easily navigate our Services. We have implemented and will maintain reasonable security controls to protect the confidentiality, integrity, and availability of the Personal Data that we process.
Visitors: If you are a Visitor, we will collect the following information about you:
- Information Collected Using Cookies and Other Web Technologies. Like many website operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information about your use of the Sites.
- “Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that could be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services and to monitor how many visitors viewed our Services.
- Other Information. You may choose to provide us with other information by contacting us or by submitting your information through our Services. For example, if you submit your contact information through our Services (“Other Information”), such as to request more information about the Services or to register for events or webinars, we will use your contact information to send related communications that may be of interest to you, including information about the Services, promotions, or upcoming events.
Direct Users and Authorized Users. If you are a Direct User or an Authorized User, we will collect and use the following information about you in connection with your use of the Services:
- Account Information. You will need an account to use the Services. When an account is created, we will collect certain Personal Data that can be used to identify you. We may collect the information from you directly (in the case of a Direct User) or from the Company that sets your account (in the case of an Authorized User) (each an “Account”). The information collected may include biographical information (e.g., first name, last name), location and address (e.g., location, email alias, email address), employment information (e.g., title, job description, job histories), investment focus areas (e.g., asset classes and sectors that User trades, researches or invests in), educational information (e.g., schools attended), and, in certain cases, a profile photo. We will only use such data for the purposes of providing the Services to you and, if applicable, your Company. For Authorized Users of the StreetLinx Services, from time to time, we may update or augment your account information with data collected from publicly available sources, such as information you have disclosed on professional networking platforms.
- Other Information. If you provide user feedback or contact us for user support, we will collect your name and email address as well as any other content included in your communication, in order to send you a reply or in order to improve the Services.
- Information Related to Use of the Services. We collect certain information about how our Services are used (we refer to this information as “Usage Data”). Usage Data could include information such as a User’s Internet Protocol (“IP”) address, browser type, operating system, a User’s interactions and/or activities within the Services, including the pages or features of our Services to which a User browsed, the time spent on those pages or features, frequency with which our Services and its features are used by a User, search terms, and other statistics. We use Usage Data to administer the Services and we analyze (and could engage third parties, who are under an obligation of confidentiality, to analyze) Usage Data to improve, customize, and enhance our Services. For Authorized Users, all use of your Usage Data will be subject to the terms and conditions of the Service Agreement between us and your Company (as applicable). Any use of Usage Data by third parties on our behalf will be subject to requirements that such third parties access such Usage Data on an unattributed basis (such that the identity of the individual User cannot be ascertained by the third party) and that such third parties maintain the confidentiality and integrity of such Usage Data.
- Posted Data. When you use Symphony Services to post, send, or receive messages (including voice or video chat messages), files or any other information or text, audio, or video communication exchange posted to the Services, we will transmit and store the content of such exchange (“Posted Data”) as necessary to provide the Services. With respect to the Cloud9 Services only, we store recordings of all voice communications made through the Services, including information about those communications, such as when placed, by whom, and how long they lasted.
- Information Sent by Your Device. We may collect certain information that your device may send when you use our Services, like a device identifier, user settings, and the operating system of your device, as well as information about your use of our Services. Such information helps us to, and will only be used in order to improve, customize, and enhance our Services.
- Location Information. When you use our Services and you enable location services on your device, we will collect and store information about your location by converting your IP address into a rough geo-location or by accessing your device’s location services (including GPS coordinates or coarse location). We will only use location information to improve and personalize our Services for you. How much of this information we collect depends on the type and settings of the device you use to access the Services.
Please note that if you decide not to provide us with the Personal Data that we or the Services request, you will not be able to access or use certain features of the Services.
SECTION 3: HOW LONG WE KEEP YOUR INFORMATION
Following your termination of Services, we will retain Personal Data as follows:
- Authorized Users. If you are an Authorized User, we will retain your Personal Data in accordance with your Company’s instructions, including any applicable terms in the Service Agreement, and subject to the requirements of applicable law. For Authorized Users of the StreetLinx Services, we may keep your Personal Data on file in the event you want to sign up for the StreetLinx Services at a Company.
SECTION 4: WHO WE MAY GIVE YOUR INFORMATION TO
Below is an explanation of who we may give your information to and for what purpose:
- We may disclose to others in our group
- We may disclose to our service providers
We engage certain third-party services providers to work with us to administer and provide a portion of the Services. Such third parties include, but are not limited to:
- customer relationship management software providers, including Salesforce, headquartered in the US, which process your Personal Data globally, in order to assist us in providing the Services and contacting you;
- internet hosting and cloud service provider services, such as Amazon Web Services and Google Cloud Platform, headquartered in the US, which process certain Personal Data globally and enable us to offer a Software as a Service (“SaaS”) platform;
- distributors, shipping, and logistics companies to fulfill orders and ensure delivery of packages;
- customer support services and software providers, headquartered in the US and which process certain Personal Data globally, which allow us to deal with any service issues that Users may face and respond quickly to any questions about our Services;
- business analytics and billing service providers, headquartered in the US and which process your Personal Data in the US, which allow us to provide the Services to you and better understand how the Services are used; and
- software engineering service provider, headquartered in Vietnam, which allows us to efficiently build and maintain our platform.
Symphony is accountable for Personal Data that we receive and transfer to third parties. Accordingly, Symphony requires that these third-party services providers access and use Personal Data only for the purpose of performing services on our behalf, and in compliance with applicable laws and regulations (including, without limitation, the CAN-SPAM Act of 2003, the EU General Data Protection Regulation (“GDPR”) and the EU-US Data Privacy Framework Principles, as applicable). Such performance can include the processing of Personal Data, provided that in the case of Symphony Services, no such third-party service provider has access to your unencrypted Posted Data.
Such third parties will be required to maintain the confidentiality of all Personal Data that they process on our behalf and to implement and maintain reasonable security controls to protect the confidentiality, integrity, and availability of such Personal Data. For Authorized Users, we will comply with the terms and conditions of the Service Agreement in effect between us and your Company (who is the data controller of your Personal Data) in connection with any such onward transfer of your Personal Data. Any such service provider to whom we transfer Personal Data for processing on behalf of us is also required to only employ staff who have committed themselves to confidentiality or are under a statutory obligation of confidentiality with respect to your Personal Data.
- We may disclose to third parties to improve user experience
We may collect and share aggregated and de-identified information with third parties for industry research and analysis, demographic profiling and other similar purposes, and for third-party programs to access the Services in a manner that extends the user experience and helps us operate and improve the Services.
- We may disclose to third parties if we sell our business
Information that we collect from our Users, including Personal Data, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third-party acquirer in connection with the transaction. The disclosure and transfer of any of your Personal Data to such third-party acquirer will be done in compliance with applicable law and regulation (including but not limited to the GDPR and the EU-US Data Privacy Framework Principles, as the case may be), and only as necessary in order to enable us or the relevant acquiror to continue to perform services to you or your Company.
- We may disclose to third parties where required by law, or in order to protect the rights, property, and safety of our company and our customers
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. In certain circumstances, we may disclose any of your Personal Data to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas), law enforcement requests and national security requests; (ii) to protect the property, rights and safety of Symphony and its affiliates, our customers, and others; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity. In the event of such disclosure or transfer of your Personal Data to public authorities, there is a chance that we will not be able to require such public authorities to implement and maintain reasonable security controls to protect the confidentiality, integrity, and availability of your Personal Data.
- We may disclose to other Users
For Direct Users and Authorized Users of the Symphony Services, the information that is listed in your user profile, including, but not limited to, your profile photo, your Company and your name (collectively “Profile Data”), will be published and viewable by other Users in our directory of Users so that other Users can find you. For Authorized Users of the Symphony Services, the content of your Profile Data and its publication will be controlled by your Company. For Authorized Users of the StreetLinx Services, your Personal Data may be shared with other participating Companies for which your company administrator has approved access and visibility, as well as may be incorporated into the Symphony directory of Users and viewable by other Symphony Users.
SECTION 5: OUR PROMOTIONAL UPDATES AND COMMUNICATIONS
Where permitted in our legitimate interest or with your prior consent where required by law, we may use your Personal Data for marketing analysis and to provide you with promotional update communications by email and social media platforms about our products/services. You can object to further marketing at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by sending us an email at [email protected].
SECTION 6: WHERE WE STORE YOUR INFORMATION AND INTERNATIONAL TRANSERFERS
We are headquartered in the U.S. with offices and servers located in the U.S., among other places. We may store and process information on servers and equipment in other countries depending on a variety of factors, including the location of our Users and service providers and the demands of local law. We will use appropriate technical and organizational security measures to try to protect your Personal Data from loss, misuse, alteration, or destruction.
When we transfer Personal Data from the European Economic Area (“EEA”), the UK, or Switzerland to other countries, we make sure that such Personal Data is sent with appropriate safeguards, including the following:
- Model Clauses: In addition, we may execute model contractual clauses applicable to the transfer of Personal Data. For transfers from the EEA, we may utilize the European Commission’s model clauses, also known as the Standard Contractual Clauses, to ensure an adequate level of protection for the transfer of Personal Data to third countries such as the U.S. For transfers from the UK, we may utilize the UK’s International Data Transfer Agreement and/or Addendum.
Our data processing activities may be subject to the regulatory oversight of various applicable data protection authorities in the jurisdictions in which we operate or process data. In addition, the Federal Trade Commission has jurisdiction over Symphony’s compliance with the EU-US Data Privacy Framework (EU-US DPF) and the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF).
SECTION 7: YOUR RIGHTS
EU, UK, and Swiss Users
If you are a User located in the EU, UK, or Switzerland, depending on whether you are a Visitor, a Direct User, or an Authorized User, we will offer you certain choices regarding the collection, use and sharing of your Personal Data.
Authorized Users: If you are an Authorized User, the Personal Data associated with your Account and your Profile Data is managed by your Company’s administrator. We can only act on the instructions of your Company, so you must contact them directly to exercise any rights over your Personal Data.
Visitors and Direct Users: If you are a Visitor or a Direct User, you have specific rights over the Personal Data that we control which you can exercise in specific circumstances, such as:
- Access: to know whether we process Personal Data about you, to access that Personal Data and find out how we use it and who we share it with;
- Portability: to receive a subset of the Personal Data we collect from you in a structured, commonly-used and machine-readable format, and to request that we transfer such Personal Data to another party.
- Correction: to require us to correct Personal Data about you that is accurate or incomplete;
- Erasure: to request that we erase Personal Data we hold about you in certain circumstances. Note that in cases where we grant your request for deletion, copies of erased Personal Data could remain in archived/backup copies for our records, as we are not always able to delete information from those locations;
- Restriction: to require us to stop processing the Personal Data we hold about you other than for storage purposes in certain circumstances; and
- Objection: to object to our processing of Personal Data about you and we will consider your request.
Please contact us at [email protected] with such requests. We will respond to your request as soon as we reasonably can and we will attempt to respond to all requests within 30 days of verifying your identity.
- California Users
If you are a California resident, please refer to our Supplemental Privacy Notice for California Residents.
SECTION 8: CHILD SAFETY
The Services maintained by us are intended for use by adults, primarily in their business or professional capacities. Our Services are not directed to individuals under the age of 18 and we do not knowingly collect information from individuals under the age of 18. If we learn that we have collected Personal Data on an individual under 18, we will take appropriate steps to delete such information from our systems.
SECTION 9: CONFLICT BETWEEN THIS POLICY AND OTHER AGREEMENTS
SECTION 10: REVISIONS TO THIS POLICY
- Visitors and Direct Users: We will update the Site and comply with any notification requirements under applicable law.
SECTION 11: CONTACT US; QUESTIONS AND COMPLAINTS
Symphony Communication Services, LLC
565 5th Avenue, 18th Floor
New York, NY 10017
Attn: General Counsel
Complaints and Data Requests
For the purposes of EU data protection laws, our representative in the EU is Symphony Communication Services Sweden AB, registered at c/o Head Office, Vasagatan 28, 111 20 Stockholm, Sweden with the contact email address [email protected].
For the purpose of the Data Privacy Frameworks, you can at any time submit a complaint, personal data access request or communicate any other issues arising under the Data Privacy Framework with respect to your use of the Services or our processing of your Personal Data to Symphony’s General Counsel at [email protected], or by courier to:
Symphony Communication Services, LLC
565 5th Ave, 18th Floor
New York, NY 10017
Our London-based Office Manager, a representative of our UK subsidiary, Symphony Communication Services UK Ltd., can also be used as a point of contact for Europe-based and UK-based Users. The address of our UK office is:
Symphony Communication Services UK Ltd.
London, EC2M 3TP
Our Head of Sales – APAC, can also be used as a point of contact for Asia-based Users. The address of our Singapore office is:
Singapore Communication Services Singapore Pte. Ltd.
8 Marina Blvd
Marina Bay Financial Centre Tower 1
We encourage you to first raise any complaints or inquiries with respect to our processing of Personal Data with our General Counsel, who may be reached by email at [email protected]. We will respond promptly to any such complaints or inquiries, within one month from the date on which we receive such complaint or inquiry and have verified your identity. This is without prejudice to your right to launch a complaint with the data protection authority in the UK, Switzerland, or in the EEA country in which you live or work.
In compliance with the EU-US DPF and the UK Extension of the EU-US DPF and the Swiss-US DPF, Symphony commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-US DPF and the Swiss-US DPF.
In addition, under certain conditions, you could be entitled to invoke binding arbitration for complaints regarding compliance with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) that are not resolve by any of the other mechanisms listed above. For additional information on arbitration, review the following link.
Legal Basis Table (see Section 2 for further information)
Please note that this table is only for Visitors and Direct Users located in the EU, the UK, or Switzerland and applies where we are the data controller. For Authorized Users, please contact your Company for information about its legal basis of processing.
|Data Field||Data Field Processing Purpose||Legal Basis|
(as defined above)
|Information collected using cookies and other web technologies|
|Information sent by your mobile device|
|Location information|| |