Symphony Talent Privacy Policy Notice

Effective Date: January 1, 2023

This Privacy Notice describes how Symphony Talent, LLC (“our,” “we”) collects, uses, and shares personal information via its website, job posting service, other software, and online services (collectively, our “Services”). Symphony Talent offers a platform that helps our business clients, including recruiters, search for and hire job seekers.

We collect information you choose to give us and other information that may be automatically collected from your use of our Services, including from your device. We use that information to operate our business, and for a variety of other purposes set forth below.  Below, we also describe choices we offer with respect to your data.

This Privacy Notice does not apply to third parties or their services. This Privacy Notice does not apply to information that cannot be identified to any individual, household, or their devices, such as de-identified or anonymized data. We are not responsible for our clients’ or other third parties’ privacy practices, you should contact these parties directly to understand their practices.

If you are a resident of the European Economic Area, please see our EEA Privacy Notice.

Information We Collect
How We Use Information We Collect
How We Secure Information
How We Share Information
What Choices Do I Have
Updates to Our Privacy Notice
Contact Information

Information We Collect

To provide our Services, we collect data by which you may be personally identified. We may also collect information about the devices and equipment you use to access our Services, including usage data.

We collect this information from a variety of sources, including:

• Directly from you when you provide it to us.
• Automatically as you utilize the Services.
• From third parties, including analytics providers.
  

Information directly from you. If you are a job seeker using our Services, the information we collect on or through our Services may include information that you provide directly to us, including your first and last name, email address, phone number, internet protocol (IP), mailing address, education information, desired salary, job title, job history, previous employer, company name, headquarters state, and referral source. As required under equal opportunity employment laws, we may ask you to provide equal opportunity employment data, including, but not limited to, ethnicity, sex, military service and disability. Information we collect from you may be collected on behalf of our business clients.

Information we collect through automatic data collection technologies. We may collect data regarding your use of our Services through cookies, web beacons, and other automatically collected information. This data may include your IP address, date and time you access our Services and the pages and content you access during your visit, websites that you link to or from, emails from us that you open, and the links you click on within those emails. We may also collect information from your mobile device or your computer about how you interact with our Services, including IP address, operating system, and browser type. This information helps us address client support issues, provide you with a personalized experience, prevent fraudulent use of our services, and manage the Services we provide you, including gathering aggregated data about engagement. Cookies are small identifiers sent from a web server that are stored on your device for the purpose of identifying your browser or storing information or settings in your browser. Cookies may also be used to personalize your visit by storing your preferences or displaying content based upon what you have viewed through our Services and other websites.  Web beacons or pixel tags connect web pages to web servers and their cookies. We and others may use these and similar technologies on our services and other websites.

Other parties may collect personally identifiable information about your online activities over time and across third-party websites when you use our website or Services. We do not respond to “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services.

Information we collect from third party sources. We may collect additional information from third-party analytic services who help us better understand our contacts, including advertisers, ad networks and servers, content providers, and application providers. These third parties may provide us information both in connection with our Services and through tools they use to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information about your online activities over time. They and we may use this information to provide you with interest-based advertising or other targeted content, and for other purposes (such as to better understand our Services’ audience).

How We Use Information We Collect

We may use data we collect for a variety of purposes, including the following (which includes activity on behalf of our business clients):

• To create profiles for job applicants based on information that they provide to us, including any information imported from other sites or applications.
• To enable recruiters to find and hire job applicants.
• To provide information about the job applicants and their potential interest in jobs to employers.
• To maintain, analyze, customize, measure, and improve our Services, which includes generating internal reports about the use of our Services.
• To send transactional communications, including requests for information, responses to requests for information, and other Service updates.
• To provide client support.
• To communicate with our clients, including about products updates and offerings that we think they may be interested in.
• For account management, finance, dispute resolution, and reporting purposes.
• To monitor and enforce our legal terms or similar terms.
• For internal business reasons, including internal audits or investigations, company research, insurance purposes.
• To comply with law and satisfy our regulatory compliance obligations.
• To detect and prevent fraud and other prohibited, illicit or illegal activity, and to protect you, others, and ourselves.
• For other purposes permitted by law or to which you consent.
  

Please note that we may combine the information we gather about you in identifiable form, including information from third parties. We may use this information, for example, to improve and personalize our Services, content, and advertising.

How We Secure Information

We are committed to maintaining measures to protect the security of your information. Of course, despite these measures, no network or system is ever entirely secure and we cannot guarantee the security of networks and systems that we operate or that are operated on our behalf.

How We Share Information

We may share your information with third parties as permitted or required by law or as directed or authorized by you. For example, we may share information about you:

• With recruiters and employers who may be interested in hiring you.
• With vendors and service providers, including our website host.
• With our professional advisors who provide legal, compliance, accounting, banking, or consulting services.
• To comply with our legal obligations or to protect the interests, property, or legal rights of you, ourselves, or third parties.
• With law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar law enforcement request, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of this Privacy Notice or other applicable terms.
• With companies or other entities in connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business.
• For other legal purposes, such as to enforce our legal terms, or to exercise or defend legal claims.
• With your direction or consent.
  

What Choices Do I Have?

Update personal information. If you are an employer or recruiter who maintains a client account with us, you can log in to that account to review and change certain information you have provided to us. If you are a job applicant who uses our Services, please contact the company to which you applied to change account information under their control.

Marketing communications. You may receive marketing information from Symphony Talent, including updates from our blog. You may opt out of receiving marketing emails, by following the unsubscribe link in each email, or by contacting us at privacy@symphonytalent.com. Please note that you may continue to receive non-marketing emails from us after you opt-out.

Cookies. You have a number of choices regarding certain cookies. Most web browsers automatically accept cookies, but you may modify your browser’s setting to notify you of cookie placement or decline cookies. If you choose to decline cookies, certain features of our website may not function properly as a result. Please see our Symphony Talent cookie policy.

Rights to your data. To exercise your rights with respect to our clients (such as recruiters, employers, prospective employers) you should contact them directly.

Updates to Our Privacy Notice

We may update this Privacy Notice from time to time in order to provide clarification or notice of changes to our practices. If we make changes, we will revise the Effective Date at the top of this Privacy Notice. Changes to this Privacy Notice will be effective once they are posted unless otherwise indicated.

Contact Information

If you have any questions or concern about this privacy notice or the privacy practices at Symphony Talent, please contact us at privacy@symphonytalent.com.

Last Updated: January 1, 2023

Additional Notice for California Residents

This Addendum to the Privacy Notice applies to residents of California only.

Collection of Personal Information

We collect personal information as necessary to operate our business, to comply with our legal and regulatory obligations, and to provide our Services to you. We may collect the following types of personal information from you:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, , or other similar identifiers.
• Personal information categories such as name, signature, address, telephone number, education, employment, employment history.
• Protected classification characteristics.
• Internet or other similar network activity including browsing history, search history, information on a consumer’s interaction with a websites, application, or advertisement.
• Geolocation data (such as enables us to provide job postings in a candidate’s general location).
• Professional or employment information such as current or past job history.
  

To learn more about the information we collect, see the Information We Collect section in our Privacy Notice.

Collection of Sensitive Personal Information

We may also collect or process sensitive personal information as necessary to operate our business, to comply with our legal and regulatory obligations, and to provide our services to you. We may collect the following types of sensitive personal information from you:

• Account log-in.
• Racial or ethnic origin, religious or philosophical beliefs, or union membership.
  

How Personal Information Is Collected

We collect personal information directly from you. However, we may also collect personal information from the following:

• Directly from you. For example, from online forms you complete.
• Indirectly from you. For example, from observing your interactions with our Services.
• From third parties, including analytics providers.
  

Purposes for Which Personal Information Is Collected

The purposes for which we will collect or use your personal information are described in the How We Use Information We Collect section in our notice and include:

• To fulfill or meet the reason you provided the information. For example, creating candidate profiles and sharing them with recruiters and employers.
• To operate, improve or maintain our Services.
• To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
• To comply with our legal and regulatory requirements.
  

Disclosure of Your Personal Information

We may share your information with third parties for a specified, legitimate business purpose. Within the last 12 months, we may have shared your information with the following third parties:

We may also share information to comply with law, to protect the interests of ourselves or others, and in connection with a merger, sale, or acquisition of all or part of our business. To learn more about how we share data, please see the How We Share Personal Information section
.

As described above, in the last 12 months we may have disclosed your personal information to third parties in connection with providing you with Services and for other business purposes, including network identifiers and inferences about your preferences to third party analytics providers. Under the broad definition of what constitutes a “sale” under CCPA, such disclosure may constitute a “sale” of your personal information. You may opt out of the sale of your personal information by contacting us at privacy@symphonytalent.com.  We do not sell the personal information of individuals who we know to be under 16 years of age.

Your California Privacy Rights

If you are a California resident, you have the following rights to your personal information.

1. Right to Access. You have the right to access the personal information we have collected about you. If requested, we will provide you with a copy of the personal information we have collected.
   
2. Right to Know. You have the right to request that we disclose the following about your personal information in the preceding 12 months:
   • What personal information we have collected;
   • The categories of personal information we collected;
   • The categories of sources from which we collected your personal information;
   • The business purposes for collecting or sharing your personal information;
   • The categories of personal information we may disclose for business purposes; and
   • The categories of third parties to whom we share your personal information.
     
3. Right to Delete. You have the right to request that we delete your personal information. Upon verifying your identity and the validity of your request, we will delete your personal information from our records and instruct our service providers, affiliates, or third parties to delete your information as required by law. We may deny your deletion request if retaining the information is permitted under law.
   
4. Right to Correct. You have the right to correct inaccurate personal information. Upon verifying your identity and the validity of your request, we will use reasonable efforts to correct your personal information as directed. In certain circumstances, we may not be able to satisfy this request depending on the nature of the personal information and purposes for maintaining it.
   
5. Right to Opt-out of Selling. If you are age 16 or older, you have the right to direct us to not sell your personal information at any time. To exercise the right to opt out, you (or your authorized representative) may submit a request by visiting How to Exercise These Rights. Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize personal information sales. You do not need to create an account with us to exercise your opt out rights.
   
6. Right to Limit Use of Sensitive Personal Information. We already limit our use of sensitive personal information as permitted by law. We use sensitive personal information as necessary to provide Services in accordance with a user’s reasonable expectation. Therefore, at this time we do not offer a separate right to further limit our use of such information.
   
7. Right to Opt-Out of Sharing Personal Information for Behavioral Advertising. You have the right to opt of the sharing of your data for cross-context behavioral advertising purposes. Please visit How to Exercise These Rights.
   

How to Exercise These Rights

You can exercise any of the rights described in this Addendum by sending your request to privacy@symphonytalent.com.

Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. To verify your identity, the request must come from the original email on file. We may limit our response to your exercise of the above rights as permitted by law.

If we have processed your data through our Service as submitted by or for a business client of ours, we may act only as a data processor on behalf of such business clients. In that case, should you wish to exercise any rights you may have under applicable laws, please contact these entities (who may be your employer, prospective employer, or recruiter) directly.

We may not discriminate against you for exercising any of your rights under California law.  This means that we may not deny you Services, or charge you different prices or rates for Services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under California law.  However, we may charge different prices or rates, or provide a different level or quality of Services, where that difference is reasonably related to the value provided to us by your personal information.

You may designate an authorized agent to make a California rights request on your behalf.  An agent may be an individual, or a business entity registered with the California Secretary of State.  To designate an authorized agent, you must provide the agent with written permission to submit the request.  We may still require you to confirm that you have authorized an agent to act on your behalf and to verify your identity directly (subject to certain exceptions) as permitted by law. We may refuse a request if the agent does not provide adequate proof of their authorization as permitted by law.

Data Storage and Security

We will store your personal information until the initial purpose for which we collected such data has been satisfied, including the purpose described in our How We Use Information We Collect section. If you consent to a new or additional purpose for retaining your data, your personal information may be stored for longer. We have implemented measures designed to secure your personal information against unauthorized use, loss, destruction or alteration. We cannot guarantee the security of your personal information.

We retain your data according to a set retention schedule, which can be generally described as follows: Data is maintained indefinitely during the duration of an active client contract unless a custom purge schedule defined by the client is agreed upon in such contract.  At the end of that retention schedule, all data is deleted unless subject to an independent legal obligation which requires us to retain it.

Contact Us

If you have any questions or concerns about privacy at Symphony Talent, please contact us by emailing at privacy@symphonytalent.com.