Privacy Policy


SCOPE

This privacy policy (“Policy”) applies to the processing of personally identifiable information (PII) also referred to as personal data. by Symphony, a SYKES Company, Sykes Enterprises, Inc., or any of its subsidiaries or affiliates (“SYKES”). This privacy policy applies to all personal information processed by Symphony specifically to the processing of personal data in the context of the activities of an establishment of a Symphony as controller or a processor in the European Economic Area (EEA), regardless of whether the processing takes place in the EEA or not, and to the processing of personal data of data subjects who are in the EEA by Symphony as controller or processor not established in the EEA, where the processing activities are related to the offering of goods or services, irrespective of whether a payment of the data subject is required, to such data subjects in the Union; or the monitoring of their behaviour as far as their behaviour takes place within the Union, in any format, including electronic, paper or oral.

Please take a moment to read this Policy to learn more about our information practices. When you use the Sites you are interacting with a United States-based company and the Sites are intended to meet the laws of the United States.

PERSONAL INFORMATION

As used herein, the term “personal information” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (such as user’s name, address, e-mail address, telephone number or other identifier that permits the physical or online contacting of a specific individual) or that is associated with an identifiable person (such as demographic information or information about a person’s activities when such information is linked to personally identifying information). Personal information does not include “aggregate” information, which is data we collect about the use of the Sites or categories of Sites users, from which any personal information has been removed. We collect aggregate data for a number of purposes, including helping us understand trends and user needs so that we can better consider new publications, products and services, and tailor existing publications, products and services to user desires. This Policy in no way limits or restricts our collection of aggregate information.

PROCESSING OF PERSONALLY INDENTIFIABLE INFORMATION

Symphony processes personal data in accordance with the following data protection principles:

  • Symphony processes personal data lawfully, fairly and in a transparent manner.
  • Symphony collects personal data only for specified, explicit and legitimate purposes.
  • Symphony processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
  • Symphony keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
  • Symphony keeps personal data only for the period necessary for processing.
  • Symphony adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

COLLECTION OF PERSONAL INFORMATION

We may collect personal information in a number of ways when you visit our Sites or use the various services available on our Sites. We may collect certain information you voluntarily provide to us which may contain personal information. For example, if you register for the Sites, we may collect your name, address, email address, telephone number, date of birth, and city and country and we may collect other demographic information that you provide. Personal information may also be collected in connection with leaving comments, posting content, sending an email or message to another user or participating in any interactive areas or features on the Sites. The collection of personal data is done solely for normal business operations and as part of supporting our clients where appropriate.

In addition, from time to time we may collect demographic, contact or other personal or demographic information you provide in connection with your participation in surveys, contests, promotional offers and other activities on the Sites. The information we collect from you is provided by you voluntarily, although if you choose not to provide information, your access to and participation in certain services, features, or activities on the Sites may be restricted.

We may also receive information from third parties with whom we have business relationships. If we combine this information with the other personal information we have collected from you, this Policy governs our use and disclosure of such information.

RIGHTS OF DATA SUBJECTS

As a data subjects, individuals have a number of rights in relation to their personal data.

Right of access:

Individuals have the right to make a subject access request. If an individual makes a subject access request, Symphony will tell him/her:

  • whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
  • to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
  • for how long his/her personal data is stored (or how that period is decided);
  • his/her rights to rectification or erasure of data, or to restrict or object to processing;
  • his/her right to complain to the Information Commissioner if he/she thinks Symphony has failed to comply with his/her data protection rights; and
  • whether or not Symphony carries out automated decision-making and the logic involved in any such decision-making.

Symphony will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.

If the individual wants additional copies, Symphony will charge a fee, which will be based on the administrative cost to Symphony of providing the additional copies.

To make a subject access request, the individual should send the request to [email protected] or use Symphony’s form for making a subject access request. In some cases, Symphony may need to ask for proof of identification before the request can be processed. Symphony will inform the individual if it needs to verify his/her identity and the documents it requires.

Symphony will normally respond to a request within a period of one month from the date it is received. In some cases, such as where Symphony processes large amounts of the individual’s data, it may respond within three months of the date the request is received. Symphony will write to the individual within one month of receiving the original request to tell him/her if this is the case.

If a subject access request is manifestly unfounded or excessive, Symphony is not obliged to comply with it. Alternatively, Symphony can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which Symphony has already responded. If an individual submits a request that is unfounded or excessive, Symphony will notify him/her that this is the case and whether or not it will respond to it.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require Symphony to:

rectify inaccurate data;

  • stop processing or erase data that is no longer necessary for the purposes of processing;
  • stop processing or erase data if the individual’s interests override Symphony’s legitimate grounds for processing data (where Symphony relies on its legitimate interests as a reason for processing data);
  • stop processing or erase data if processing is unlawful; and
  • stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override Symphony’s legitimate grounds for processing data.

Individuals have also:

  • right to data portability which is the right to receive the personal data concerning them, which they provided to Symphony on the basis of consent or for the performance e of the contract;
  • right to object to processing on grounds relating to their particular situation;
  • right not to br subject to a decision based only on automated processing

Symphony shall communicate any rectification or erasure of personal data or restriction of processing to any recipient to whom data was disclosed unless this would be impossible or would involve disproportionate effort and inform the persons about those recipients if the persons request it.

To ask Symphony to take any of these steps, the individual should send the request to [email protected].

PROVISION OF PERSONAL DATA AS STATUTORY OR CONTRACTUAL REQUIREMENT

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes, it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

ONLINE PRIVACY NOTICE

We process personal information for certain legitimate business purposes, which include some or all of the following:

Where the processing enables us to enhance, modify, personalize or otherwise improve our services/communications for the benefit of our customers

  • To identify and prevent fraud
  • To enhance the security of our network and information systems
  • To better understand how people interact with our websites
  • To provide postal communications which we think will be of interest to you
  • To determine the effectiveness of promotional campaigns and advertising

Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing if you wish, and if you wish to do so please click here. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit.

TRANSFERRING YOUR PERSONAL INFORMATION

Information about our customers, including personal information, may be disclosed or transferred as part of any merger, acquisition, debt financing, sale of company assets, as well as in the event of an insolvency, bankruptcy or receivership in which personally identifiable information could be transferred to third parties outside of EEA as one of the business assets of the Company.

To ensure that the transfers of PII will be subject to the provisions of Regulation 679/2016. Specifically such processing will be based either on adequacy decisions or will be subject to appropriate safeguards such as standard data protections clauses adopted by the European Commission. ,. You can access a copy of standard clauseby contacting our Data Protection Officer. In addition, Symphony is certified under EU-US Privacy Shield, a scheme approved by the European Commission as providing adequate safeguards for transfers of personal information to the USA.

EU-US PRIVACY SHIELD PRIVACY STATEMENT

Symphony, a SYKES company, Sykes Enterprises, Incorporated and its affiliates certifies that it adheres to the privacy shield framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union. To learn more about the Privacy Shield program, and to view Symphony’sSYKES certification, please visit https://www.privacyshield.gov/.

Symphony, a SYKES company, Sykes may need to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We shall ensure that any third party for which Personal Information may be disclosed are subject to law providing the same level of privacy protection as is required by EU-US–Privacy Shield and agree in writing to provide an adequate level of privacy protection. We may be liable in cases of onward transfers to third parties without your permission.

SPECIAL NOTICE REGARDING CHILDREN

Our Sites are not designed for, nor do we knowingly collect, personal information from children under the age of 16. If you are under 16 years of age, please do not provide your personal information to us.

USE OF COOKIES, IP ADDRESSES AND WEB BEACONS

The Sites may contain “cookies.” A cookie is a piece of data that is stored on your hard drive and records your preferences and other data about your visit to the Sites. If we combine cookies with or link them to any personally identifiable information, we will treat this information as personal information; otherwise, it is treated as and used in the aggregate. Most internet browsers will allow you to erase cookies from your hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. If you block cookies, some portions of the Sites may not function properly, and some features of the Sites may be slowed down or less efficient. The cookies we use do not make any changes to software or hardware of your devices. We will process cookies based on your consent except for the cookies the essential cookies needed for the proper functioning of the service or Site.

USAGE AND DISCLOSURE OF PERSONAL INFORMATION

In general, we use personal information we collect to facilitate your use of the Sites, to provide you with information, products and services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to administer and assist us with the operation of the Sites and of our business. For example, we may use the information we collect to:

  • contact you about your use of the Sites, such as for administrative purposes or to provide you with customer service;
  • provide you with the services, products or information you requested;
  • respond to your emails, submissions, comments, requests or complaints;
  • contact you about our products, services, activities, events, promotions or offers and for other marketing, informational, product development and promotional purposes;
  • request feedback and to enable us to develop, customize and improve our information and services; and
  • enhance compliance with the policies, rules, and other agreements governing the Sites in order to protect the online community and the overall integrity of the Sites.

We offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, we give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. To ensure fair and transparent processing, we give individuals the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing, as well as the right to data portability.

We shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information. We use personal information we collect to facilitate your use of the Sites, to provide you with information, products and services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to administer and assist us with the operation of the Sites and of our business. For example, we may use the information we collect to:

  • contact you about your use of the Sites, such as for administrative purposes or to provide you with customer service;
  • provide you with the services, products or information you requested;
  • respond to your emails, submissions, comments, requests or complaints;
  • contact you about our products, services, activities, events, promotions or offers and for other marketing, informational, product development and promotional purposes;
  • request feedback and to enable us to develop, customize and improve our information and services; and enhance compliance with the policies, rules, and other agreements governing the Sites in order to protect the online community and the overall integrity of the Sites.

DURATION OF DATA STORAGE

The data sent by us and linked to cookies, user-identifiers (e.g. User-IDs) or advertising-identifiers are automatically deleted after 14 months. Data whose retention period has been reached is automatically deleted once a month.

AUTOMATED DECISION-MAKING

As an organization that uses automated decision-making, including profiling, we allow our customers to inspect and correct any inaccuracies in the personal data used in the profiles assigned to them. As well as addressing any errors, this also helps improve the precision of the system used to carry out the processing.

SHARING OF PERSONAL INFORMATION

If we collect any personal information, we share and disclose such personal information only as described in this Policy (as amended from time to time). We may share personal information with third-party vendors, consultants and other service providers who are engaged by or working with us in connection with the operation of the Sites or performing any services on our behalf. Whenever the processing is to be carried out on behalf of Symphony, the we shall use only processors providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of data protection laws and ensure the protection of the rights of the data subjects. Such processing shall be governed by a contract or other legal act under EEA or Union Member State law, that is binding on the processor with regard to the controller and that sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller. That contract or other legal act shall stipulate, in particular, that the processor.

We may also use a third party to screen certain content before it is posted to, or to remove postings from, the Sites. In addition, we may offer various features through a third-party service provider.

When you use these services, you are providing information directly to the provider of these services, and the provision of such information is subject to such party’s own privacy policy. We are not responsible for any information you provide to these parties directly, and we encourage you to become familiar with their practices before disclosing information directly to such third parties with which you come into contact.

We also may disclose personal information when we are required to or we believe it is appropriate to comply with the law (e.g., a lawful subpoena, warrant or court order); to enforce or apply this Privacy Policy or our other policies or agreements; to initiate, render, bill, and collect for amounts owed to us; to protect our or our customers’ rights, property or safety; to protect our customers from fraudulent, abusive, or unlawful use of our Site; or if we believe that an emergency involving the danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of personal information. In addition, information about our customers, including personal information, may be disclosed or transferred as part of any merger, acquisition, debt financing, sale of company assets, as well as in the event of an insolvency, bankruptcy or receivership in which personally identifiable information could be transferred to third parties as one of the business assets of the Company.

The Sites may contain links to other sites, or other interactive forums hosted by a third party. Please be aware that although we may participate in or utilize such other sites, we are not responsible for the privacy policies or any other practices of such other sites. We encourage you to be aware when you leave our Sites and to read the privacy policies of any Web site that collects personally identifiable information. Similarly, if you entered the Sites through a link on another Web site, we are also not responsible for the privacy practices of that site, and you should review the privacy policy of the originating site before providing any personal information to that site. This Policy applies solely to information collected by us.

ONLINE COMMUNITIES

The Sites may include certain online communities and other interactive features, such as user profiles, forums, message boards and chat rooms. You may be asked to choose a user or member name in order to participate in certain features of the Services, which will be available to the general public while you participate in some features of the Services, such as the online communities. We recommend that you not use your real name or other personally identifying name. Information you post in such public areas of the Sites is publicly available and may be viewed by and shared with other users. You can restrict user access to certain information through the privacy preferences setting on your account. However, although we strive to use commercially reasonable efforts to implement these privacy preferences, no system or security measure is perfect or impenetrable. You should always be cautious when giving out personal information to others in public online forums. We are not responsible for protecting such information that you may disclose to third parties through the Sites (e.g. sending your contact information to another user through the chat service).

PROTECTING PERSONAL INFORMATION

We strive to protect personal information while it is under our control. Your account information is accessible online only through the use of a password. To help protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of, and acts on the Sites by any person using your password. Please advise us immediately if you believe your password has been compromised or misused.

[email protected]

Symphony, a SYKES company, VenturesSYKES has further committed to refer unresolved Privacy Shield complaints to TrustArcAmerican Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your

Under certain conditions, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change the provisions of this Policy at any time by posting the revised Policy on the Sites and indicating on the Policy the date it was last updated. We encourage you to review this Policy whenever you visit our Sites to determine if any changes have been made and to make sure that you understand how personal information you provide will be treated
We will occasionally update this privacy policy to reflect changes in our services and customer feedback. We encourage you to periodically review this policy to be informed of how Symphony Sykes Enterprises, Incorporated is protecting your information.