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Symphony Talent European Economic Area Privacy Notice

If you are a resident of the European Economic Area (EEA), the following additional EEA-specific provisions apply to our processing of your personal information. For EEA residents, the provisions of this EEA Addendum prevail over any conflicting provision in our Symphony Talent Privacy Notice.
 

Information We Obtain


We may collect, use, store and transfer certain personal information in order to provide our Services, such as your name, IP address, mailing, and phone number. For a complete list of the categories of personal data we collect and how we collect this personal data, please see the Information We Collect section in our Symphony Talent Privacy Notice. Where such information is required, we may be unable to provide you with our Services unless you provide us with this information.

As you interact with our Services, we will automatically collect technical personal data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. If you disable or refuse cookies, please note that some parts of our Services may become inaccessible or not function properly. We do not engage in automated decision-making, including profiling.

How We Use the Information We Obtain


The legal bases for which we collect, use, transfer or disclose your personal information include (i) where we have your consent, (ii) our legitimate interests; and (iii) where we need to comply with a legal obligation.

Please note that if you choose to withdraw your consent, you may not be able to participate in or benefit from our Services for which you provided consent.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. The purposes for which we process your personal information are systematically included in the How We Use the Information We Gather section in our Symphony Talent Privacy Notice. We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

Under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases above.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. We also collect and process personal information in our capacity as a data processor to our business customers. In that case, our business customer is responsible to have an adequate basis.

Disclosures of Your Information


To learn more about the other categories of third parties to who your personal information is disclosed, see the How We Share Information section in our Symphony Talent Privacy Notice.

Data Retention


All personal information is retained according to our internal policies. Your personal information will not be stored for longer than necessary for the purposes for which they were collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We will take into account the length of time your personal data is required to:

  • Continue to develop, tailor, upgrade, and improve our Services;
  • Maintain business records for analysis and/or audit purposes;
  • Comply with record retention requirements under the law;
  • Defend or bring any existing or potential legal claims; or
  • Address any complaints regarding the Services.


We may use any aggregated, anonymized data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

Your Rights


If you are a resident of the EEA, you have certain data rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us at privacy@symphonytalent.com. In certain circumstances, you have the following data rights:

(i) You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

(ii) You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.

(iii) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete.

(iv) You have the right to object to the processing of your information if the processing is carried out on the legal basis of our legitimate interest, necessary to perform tasks in the public interest, or in the exercise of an official authority vested in us. Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.

(v) You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verification of whether our legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, exercise or defense of legal claims, for the protection of the rights of another natural, legal person, or for reasons of important public interest.

(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure such as where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, to exercise or defense of legal claims.

(vii) You have the right to receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.

(viii) You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satisfied with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority. To find your relevant data protection authority and their contact details, please see the list at: https://edpb.europa.eu/about-edpb/about-edpb/members_en. For more information, please contact your local data protection authority in the EEA. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.

You may exercise these rights free of charge unless the request is unfounded, excessive, or otherwise unreasonable, for instance because it is repetitive. To exercise these rights, you may be asked to verify your identity and/or provide other details to help respond to your request.  In some situations, we may refuse to act or may impose limitations on your rights, as permitted by law. For the exercise of your rights, please contact us using the contact information provided in the Contact Us.  section of our Symphony Talent Privacy Notice; please note that if you contact us where we act as a data processor to our business customers, we may refer you to such customer to exercise your rights directly with them. In all cases, you have a right to file a complaint with the relevant Data Protection Authority (DPA). We would, however, appreciate the chance to deal with your concerns before you approach your DPA, so please contact us in the first instance.

International Data Transfers


We may transfer and store your personal information to countries outside of the EEA. Where these transfers are to countries that have not been found by the European Commission to provide adequate protection, such as the United States, Symphony Talent takes necessary contractual measures to ensure that your personal information receives an adequate level of protection (including, for example, standard contractual clauses). For further information about Symphony Talent’s international data transfer practices, and to consult the said contractual measures, please contact us using the contact details in the Contact Us section of the Privacy Notice.

Identity of Controller


Symphony Talent, LLC whose mailing address is 19 West 34th Street, Suite 1000, New York, NY 10001, USA, manages this website. Symphony Talent, LLC acts as a data processor for our Services as provided to our business customers.  Our business customers act as the data controller and you should contact them to exercise your rights.

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