Privacy

TRUSTe

Effective as of January 1, 2020

Introduction

Symphony Talent respects your privacy and is committed to protecting it through our compliance with this policy. This privacy policy applies to each Symphony Talent website, product, and other service (each, a “Service”) that refers or links to this privacy policy.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. Also, You acknowledge that this Privacy Policy is designed to be read in connection with the Sites’ Terms of Use, which are available at https://www.symphonytalent.com/terms-of-use/and that by accessing or using our Sites, whether as an individual seeking a job (“Job Seeker”) or as a party seeking to hire potential employees (“Recruiter”), you explicitly accept the collection, use and transfer of your information as described in this Privacy Policy, and you agree to be bound by the Sites’ Terms of Use.

If you do not want your information to be collected, used, and transferred as described by this Privacy Policy, you may revoke your consent to our Privacy Policy by emailing us at privacy@symphonytalent.com.

We reserve the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat your personal information by either placing a prominent notice on our Sites or sending a notice to the primary email address you provided to us prior to the change becoming effective, or both. We will also update our privacy information on this page with the latest update date and effective date. It is your responsibility to review any updates to our Privacy Policy. Your continued use of Symphony Talent Sites and/or Services after any such modification to our Privacy Policy will constitute your acknowledgment of the modified Privacy Policy and your agreement to abide and be bound by the new Privacy Policy.

Children’s Privacy

Symphony Talent Websites are not intended for children under 16 years of age. No one under age 16 may
provide any personal information on the Website. We do not knowingly collect personal information from
children under 16. If you are under 16, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us by emailing us at privacy@symphonytalent.com.

Information We Collect

We collect three types of information when you use our Sites: Personal Information (“PI”), Company
Information, and Passively collected Information. You acknowledge that any and all materials you upload to the Symphony Talent Sites (“Submissions”), are subject to this Privacy Policy.

Personal Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities on this Site, such as registering, purchasing a product or service, or sending us feedback, we may ask you to provide certain information about yourself.

When you use our Sites as a Job Seeker or as a Recruiter, you create a profile, which contains a core set of PI, which acts as a login authentication to identify you (a “Profile”). We store this Profile in the United
States.

You use your Profile to access our Services, and you add, update and delete information on your Profile as you use the Services. The Services that you choose to use determines the type of information collected, the use of that information by Symphony Talent and by others, and your control over that information.

Personal data collected by category and product:

Categories

Group 1
Basic profile data, including but not limited to First Name, Middle Name, Last Name, Suffix, Email, PhoneNumber, Internet Protocol (IP) Address, and Physical Address (city, state).

Group 2
Background data, including but not limited to Education, Desired Salary, Title or Job Title, Work History,Previous Employer, Company Name, Headquarters State, and Referral Source.

Group 3
Site interaction data, including but not limited to Job Categories Searched, Resume, Site Interactions, and Areas of Interest.

Group 4 (As required under equal opportunity employment laws)
Federally mandated Equal Opportunity Employment data, including but not limited to Ethnicity, Sex,
Military Service, and Disability.

Products by Category

Symphonytalent.com – Categories collected: Group 1 and 2.

Hosted Career Websites – Categories Collected: Group 1 and 3.

Candidate Relationship Management tool – Categories Collected: Group 1, 2, and 3.

Assessments – Categories collected: Group 1.

Employee Advocacy Platform – Categories collected: Group 1.

Programmatic Media Platform- Categories collected: Group 1.

Applicant Tracking System – Categories collected: Group 1, 2, and 4.

Intelligence Assistant – Categories collected: Group 1 and 2

You may delete your Profile (which deletes your Supporting Documents), from our Sites at any time. Some Countries and States require that we, and/or Recruiters that use our Services, retain a copy of the information you provided. Deleting your Profile from our Sites does not guarantee that copies of your information required by law are also being deleted.

If you provide us with details of a reference, it is your responsibility to ensure that the person is aware that you have forwarded his or her contact information and has consented in writing for you to do so. By providing the details of a reference, you warrant and represent that you have obtained that individual’s consent. We will only use the reference’s information for the specific reason for which it is provided. If you believe that one of your contacts has provided us with your personal information as reference and you would like to request that it be removed from our database, please contact us at privacy@symphonytalent.com.

Company Information: Your Profile only contains information about you. If you are using our Sites as a Recruiter, you will undertake activities on behalf of your company, (such as posting jobs, writing job descriptions, adding notes, documents, comments, and sending email to Job Seekers, etc.), and these activities create and store information for your company (“Company Information”), that is separate to your Profile.

If you delete your Profile, Company Information that you may have added as a Recruiter will be deleted
according to the company’s agreement with Symphony Talent, and the various legal laws pertaining to
data storage.

Passively collected Information: This refers to information that we collect automatically about you based upon where you visit on our Sites and what other sites may have directed you to us. We automatically collect information about how you use our Sites, the areas of our Sites that you visit, as well as information about your computer including your IP address, device ID, physical location, browser and operating system type, screen size and referring URLs. This information is necessary for providing personalized and locationbased content as well as for analyzing the use of resources, troubleshooting problems, preventing fraud, and improving our Services. We may combine this information with information in your Profile to help prevent fraud, or to improve the value and relevant outcome of the services you use.

If you choose to login, add, or otherwise connect with LinkedIn, Facebook or other such similar social
network sites (“Social Information”), you authorize us to import and/or show the Social Information that you choose to share with us as part of your Profile, and use that information in the aggregate.

Aggregated Data: We also aggregate data and information from users that access our site, our products, our services, and through externalsources. We do this aggregation for various purposes, including without limitation, to conduct analyses, product testing, to determine user and performance trends, for statistical purposes, and to improve our products. When we aggregate your data in this manner, we de-identify or anonymize the data to remove any user or customer identifying information.

Grounds for Processing

When we collect from you any Personal Information we do so:

  • where necessary to provide the Service, fulfill a transaction or otherwise perform a contract with you or at your request prior to entering into a contract;
  • where necessary for our compliance with applicable law or other legal obligation;
  • where applicable, with your consent; and/or
  • as necessary to operate our business, protect the security of our systems, customers and users, detect or prevent fraud, enable our customers to comply with legal obligations, or fulfill our other legitimate interests as described in the “Information We Collect”, ”How We Use Your Information” and “Sharing of Your Information” clauses above, except where our interests are overridden by your privacy rights.

Where we rely on your consent to process Personal Information, you have the right to withdraw your
consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.

Certain categories and uses of Personal Information may be separately regulated and excluded from the
definition of Personal Information. This include:

  • Publicly available information from government records;
  • De-identified or aggregated consumer information;
  • Other types of information excluded from local, state, and federal amendments.

How We Use Your Information

We use the information we collect to provide our Services, operate and improve our Sites, and respond
to you. By registering with Symphony Talent, by using the Sites and/or Services you choose, by managing your Profile, or by opting in when presented with choices, you have consented for us to use your information in the following ways:

  1. to create a profile for you based on information that you have provided to us, information
    imported from other sites or applications;
  2. to use information about you, and others like you, to help you acquire a job or advance
    your career;
  3. to provide information about you and your potential interest in jobs to employers;
  4. to provide products and services to employers so they can complete the recruitment and
    hiring process;
  5. to use information about you, and others like you, to help you use and get more value out
    of our Services;
  6. to provide personalized, targeted, or location-based content and services from us and
    third parties;
  7. to allow you to import information about yourself or your contacts from other sites or
    applications or to export your information to other sites or applications;
  8. to allow you to find and hire people;
  9. to allow you to purchase Symphony Talent services;
  10. to contact you about feature updates, informational and service-related communications,
    including important security updates;
  11. to provide you with additional communications, information, and promotions such as
    newsletters;
  12. to inform you of other products or services available from Symphony Talent or its
    affiliates;
  13. to enable you to contact us and for us to respond to you to conduct surveys, promotions
    and contests, and to publish the results thereof;
  14. to prove the effectiveness of our Services, and to provide research data in support of white
    papers we may choose to publish;
  15. to generate internal reports about the use of our Site;
  16. to give search engines access to public information;
  17. to detect, investigate and prevent activities that may violate our policies or be illegal; and
  18. to make suggestions and draw inferences about you. For example, we may make
    suggestions about additional jobs, products or services that might be of interest to you,
    or people you should consider hiring.

We use the information we have about you to determine whether you might be interested in jobs and/or
career opportunities. We may show you targeted ads on our Sites or other sites with which we have a
business relationship. These ads are targeted based on information we collect about you while utilizing Symphony Talent services.

We retain all the aggregate non-identifying information we gather about you such as recruiter notes,
selection status, and others in an effort to make your, and other’s use of our Sites more efficient. Where required by law, or necessary to maintain historical record, we may keep this non-identifying information even if you delete your Profile.

Tracking Technologies

We and our partners (who work with us to provide services such as marketing, advertising, ongoing
engagement, skills testing, career training and other career content), affiliates or analytics or service providers use technologies such as cookies, beacons, scripts, tags or similar technologies. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies.

Social Media Widgets

Our Site includes Social Media Features, such as the Facebook Like button and Twitter button or
interactive mini-programs that run on our Site. These features may collect your IP address, which page
you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Information Collected on Behalf of our Clients

The use of information collected through our Services shall be limited to the purpose of providing the
service for which the Client has engaged Symphony Talent.

Symphony Talent collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly via channels outlined on their Privacy Policy. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

Symphony Talent acknowledges that you have the right to access your personal information. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Symphony Talent’s Client (“the data controller” or “service provider”). If requested to remove data we will respond within a reasonable timeframe.

We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Symphony Talent will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may use de-identified data for our business purposes solely to the extent permitted in our agreements with our Clients as a service provider.

Information We Share

We will share your personal information with third parties only in the ways that are described in this
Privacy Policy. We do not sell your personal information to third parties. One of the primary purposes of our Service is to maximize your career opportunities and job search efforts. The information we gather may be shared within the Symphony Talent group of companies on a worldwide basis. We do not share information with third parties for their direct marketing purposes unless you specifically agree to such disclosure – for example, by joining the Talent Network of one of our clients.

We share your information with third parties who have legally contracted with us, in order to help deliver our Services to you. Such third parties may include companies which provide our web servers and database storage, those who analyze data, provide marketing assistance, process payments, provide
verification and testing services for jobs, evaluate education and provide education guidance, perform job searches, improve Site usage, provide phone-based help centers, and other services that may help you use our Sites, acquire a job, advance your career, manage your hiring process, or hire people. These companies only have access to information as necessary to perform their functions, and they may not use that information for any other purpose. We will remain responsible for any information shared in this way.

We may disclose information to third parties if you consent. Your consent and subsequent disclosures are assumed when you perform the following:

  1. by applying to a job, indicating interest in a job and/or employer, accepting a job referral
    from a friend, or playing a ‘careers’ game promoted by an employer, you consent to the
    disclosure of your information to that one employer and their Recruiters;
  2. by completing a background check, assessment, or reference check as part of a hiring
    process at the request of an employer, you consent to the disclosure of your information
    to the third-party who may provide such Services, and you also consent to the results of
    such Services being shared with that one employer and their Recruiters;
  3. by participating in our Employee Referral Service, you consent to the disclosure of your
    information to that employer and their Recruiters;
  4. by using any of our Services as a Recruiter or employee, you consent to the disclosure of
    your information to the employer, agency or entity that is paying for your access or
    otherwise providing the Services to you;
  5. by opting in to add credentials to your Profile, you consent to the disclosure of your
    information to the third-party who may provide such credentialing Services, and if you
    pass (obtain) the credential, you also consent to the credential ‘badge’ being displayed on
    your Profile;
  6. if you opt in to receive information about the employment opportunities, products, or
    services of third parties, we supply your contact information to those third parties so they
    may contact you; and/or
  7. if you previously chose to receive newsletters, commercial emails or other
    communications from Symphony Talent or third parties, but subsequently change your
    mind, you may opt out in those emails by following the unsubscribe instructions included
    in those emails or by editing your account profile and opting out.

We also share passively collected information (including location data) about Symphony Talent Site
visitors with third parties to serve advertisements to you on our Sites, on other sites with which we have a business relationship, and via our Services. We may also aggregate data regarding employment
qualifications, education, age, experience level or other information relevant to improving the relevancy of the Services we offer you and the advertising we display and/or send to you. This aggregated data does not identify you personally.

At times we may be required by law enforcement or judicial authorities to provide information to the
appropriate governmental authorities. In such cases, we will disclose information upon receipt of a court order, subpoena, bankruptcy proceedings, or other legal process or to cooperate with a law enforcement investigation when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. We fully cooperate with law enforcement agencies in identifying those who use our Services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

We may disclose and transfer information to a third party who acquires any or all of Symphony Talent’s
business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. You will be notified via email and/or a prominent notice on our Sites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Retention of Personal Information

We may retain your personal information for (1) only long as your account is active or as needed to provide you services as described in this policy, (2) to comply with our legal obligations and disclosure requirements under state, federal, and international law, (3) as necessary to resolve disputes, and (4) as agreed upon with Clients.

Your Rights in Relation to your Personal Information

You have rights relating to your Personal Information that we process. When it comes to marketing
communications, you can ask us not to send you these at any time – just follow the unsubscribe
instructions contained in the message, or send your request to privacy@symphonytalent.com.

You also have the right to:

  • know what Personal Information we hold about you,
  • make sure it’s correct and up to date
  • request a copy of your Personal Information (including in machine readable form)
  • ask us to restrict processing your Personal Information or delete it
  • object to our continued processing of your Personal Information

You can exercise these rights at any time by sending an email to privacy@symphonytalent.com. Symphony
Talent will respond to information access requests within thirty (30) days of receipt. If we require
additional time to respond, we will acknowledge receipt of your request within a reasonable timeframe
and supplement our response within the time period required by applicable law.

If you’re not happy with how we are processing your personal data, please let us know by sending an
email to privacy@symphonytalent.com. We will review and investigate your complaint, and get back to you within a reasonable time frame. You can also complain to your local data protection authority, and if required they can advise you how to submit a complaint to them.

Depending on what Services you use, you may be able to access, update or delete your information in
different ways. For instance, some services such as Background Checks delivered by third parties may be legally required to keep your information for a period of time.

1) If you had taken an Assessment as part of applying for a job with a specific company via the
SkillCheck.com website, you need to contact us at privacy@symphonytalent.com in order to have your
assessment results deleted from that system.

2) If you had applied to a job for a specific employer via the HRApply.com system, you need to visit that employer’s career website to log in and delete your profile.

3) If you have joined an employer’s Talent Community, signed up for job alerts, participated as an
employee in the Employee Referral program, attended a recruiting event, or are a user of any of the
Symphony Talent Sites, you may access, review, correct, update, change or delete your Profile or any
Supporting Documents at any time.

While you are able to change and delete your Profile from our Sites, anyone who previously had your
consent or otherwise viewed your Profile and/or used our Sites may have kept a copy of it. Some Countries and States require that we, and/or Recruiters that use our Services, retain a copy of the information you provided as you used the Services. Deleting and/or changing your Profile from/on our Sites does not guarantee that these copies are also being deleted/changed.

If you wish to delete or close your account and remove your Profile altogether, you can do so at any time by emailing privacy@symphonytalent.com. Unless required by law, your profile data will be deleted from our services. We may keep logs and/or de-identified information that may relate to your activity on our Site, as required by law.

Your California Privacy Rights and Privacy Notice for California Residents Pursuant to California Consumer Protection Act (“CCPA”)

Upon your request, California Civil Code Section 1798.83, known as the “Shine the Light” law, requires us to provide to you (a) a list of your personal information, if any, which we have disclosed to third parties for direct marketing purposes in the preceding calendar year, and (b) the names and addresses of those third parties. You may make such a request once per calendar year, and we will provide the information to you free of charge. Please send any requests made pursuant to this section by emailing us at privacy@symphonytalent.com. However, as defined under Section 1798.83, we do not currently share any personal information with third parties for their direct marketing purposes.

Additionally, California Civil Code Section 1798.100-1798.199, known as the California Consumer Privacy Act (“CCPA”), provides the ability for California consumers to make requests and received notices as further outlined below. For complete information about all of your rights under CCPA please visit the California Attorney General’s Website at: https://oag.ca.gov/privacy/ccpa

Your Rights under CCPA

Under CCPA, California consumers have enumerated rights to their Personal Information. These rights
include that:

  1. You have the right to know what Personal Information we have collected in the past 12 months
    including specific categories (see – Information We Collect);
  2. You have the right to know whether we have sold any of your Personal Information (see – How
    We Use Information);
  3. You have the right to know whether we have used any of your Personal Information for business
    purposes (see – Information Collected on Behalf of our Clients);
  4. You have the right to request disclosure of your Personal Information collected by us in a readily
    useable format within 45 days of such a verifiable request and to delete that personal information
    (see information below or – Your Rights in Relation to your Personal Information);
  5. You have the right to know you will not be discriminated against for exercising your rights under
    the CCPA (see information below); and
  6. You have the right to Opt-Out of the sale of your Personal Information (see information and link
    below).

Requesting Access to Personal Information, Data Portability, and Deletion

As required under CCPA, Symphony Talent will respond to verifiable consumer requests within 45 days of
receipt of such a request from you. This may include requesting additional information to verify you are indeed the person making the request or you can make such a request through your Profile.

If Symphony Talent requires additional time beyond 45 days (up to 90 days) to fulfill such a request or otherwise verify your request, a Symphony Talent team member will inform you as soon as possible, but no later than permitted under CCPA, in writing. All requests and responses will cover the 12 months immediately preceding such a request from you.

A request for your Personal Information can be done via email to privacy@symphonytalent.com or by logging in to your account. We do not charge a fee for this request unless such a request exceeds those permitted under CCPA, become too excessive, or burdensome. You are entitled to your data in a readily usable format that is freely transferable, which we often provide by electronic letter or email.

As for deletion, you can request that we delete your personal information via email to privacy@symphonytalent.com or by logging in to your account.

As you use your Profile to access our Services, and you add, update and delete information on your Profile as you use the Services. The Services that you choose to use determines the type of information collected, the use of that information by Symphony Talent and by others, and your control over that information. This is the best method to make such a request for your Personal Information from us for your Personal Information or for deleting your Personal Information.

Non-Discrimination Notice and Financial Incentives

Symphony Talent does not and will not discriminate against you for exercising any of your rights under
the CCPA. Unless otherwise permitted under the CCPA, Symphony Talent does not and will not:

  • Charge you different rates for any of our services. This means that we do not provide separate
    discounting, benefits, or penalties to users;
  • Deny access to any of our services;
  • Provide you with a variable level of quality of our services; or
  • Indicate different pricing or rates for any services or a different level or quality of services

As permitted under CCPA, Symphony Talent may offer you or other users financial incentives that can
reflect different rates, prices, or qualities of our services. In such instances, you will be required to opt-in consent which is revocable by you at any time. These incentives will be related to the value of your personal information and describe the material terms of the incentive.

Personal information sales opt-in and opt-out rights

As provided under CCPA, California consumers can Opt-Out of the sale of their personal information by
submitting in to our DO NOT SELL MY INFORMATION list. We do not sell personal information, but
maintain a list for those who wish to opt-out nonetheless.

For additional information or to request your opt-out of the sale of your personal information, please clickthe link above or email us at privacy@symphonytalent.com.

Information Transferred for Business Purposes

In the past 12 months, Symphony Talent has not sold any personal information collected for monetary
consideration. We have, however, transferred, disclosed, and shared information we collect on behalf of existing service agreements with our Clients. Within each product you use requires your express consent to use that information and the information collected for each product is outlined in Information We Collect. The information is transferred, disclosed, and shared is exclusively for the business purpose and subject to the terms and conditions of our service agreements. Additional information can be found in Information Collected on Behalf of Clients and Information We Share.

Privacy Shield and International Transfers

Symphony Talent participates in and has certified its compliance with the EU-U.S. Privacy Shield
Framework and the Swiss-U.S. Privacy Shield Framework. Symphony Talent is committed to subjecting all
personal data received from European Union (EU) member countries and Switzerland, respectively, in
reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.

Symphony Talent is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Symphony Talent complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks,
Symphony Talent is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Symphony Talent may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Data Security

Symphony Talent takes measures to safeguard your personal information against loss, theft and misuse
and unauthorized access, disclosure, alteration and destruction through the use of appropriate technical and organizational measures.

Legal Use and Other Protected Uses of Data

We may collect, store, disclose, or transfer your personal data to comply with all laws, regulations, and litigation matters.

Contact Information

Your data is submitted to Symphony Talent, LLC, a Delaware limited liability company, whose principal
place of business is at 19 West 34th Street, Suite 1000, New York, NY 10001, USA, and your data is hosted and stored in databases and on servers situated throughout the United States.

If, at any time, you have questions or concerns about this Privacy Policy, please contact us at privacy@symphonytalent.com or at:

Symphony Talent, LLC
Data Protection Officer
19 West 34th Street, Suite 1000
New York, NY 10001
dpo@symphonytalent.com

Symphony Talent (UK) Limited
Bacta House
9 Regents Wharf
All Saints Street
London N1 9RL
dpo@symphonytalent.com