Effective Date: July 11, 2022
Last Updated: August 8, 2022
Information We Collect
When you use the Services, we collect the following types of Information:
“Non-Personal Information” means information that does not directly, personally identify you, but provides insights regarding your use of the App. For example, we collect information about your use of the App, including but not limited to your connections, mobile device, or other device, computer equipment, date/time stamps, the time of your visits, content viewed, ads viewed, and other similar information about traffic and usage, as you navigate to, through, and away from our App.
“Personal Information” means information that may identify, relate to, describe, or that could be linked or associated with, you or your household. Personal Information that we collect through the Services may include, but is not limited to, your full name, full physical address, telephone number(s), and email address.
Personal Information and Non-Personal Information are collectively referenced as “Information.”
Third-Party Social Networking Service(s).
If you choose to access, visit, and/or use any third-party social networking service(s) that may be integrated with our Services, we may receive your Personal Information and other information about you and your computer, mobile, or other device that you have made available to those social networking services, including information about your contacts through those services. Your decision to use a social networking service in connection with our Services is voluntary. However, you should make sure you are comfortable with the information your third-party social networking services may make available by reviewing privacy policies of those providers and/or modifying your privacy settings directly with those networking sites/services.
Where/How We Collect Information
We collect Personal Information and Non-Personal Information about you from a number of sources, as described in greater detail below.
When you download the App, register to use our Services, complete online forms or surveys, request to receive information or support, or communicate with us or our representatives, whether through the App, standard mail, email, or telephone, you may provide your information to us.
Cookies and Other Technology
How We Use Information
We use Non-Personal Information collected by cookies, web beacons, and other Internet tracking technology to store your preferences, improve the Apps operation, make personalized features and other services available to you, to generate statistical information, monitor and analyze user traffic and usage patterns, monitor and prevent fraud, investigate complaints and potential violations of our policies, to improve the our content and the products, services, materials, and other content that we describe or make available through the Services, and otherwise help administer and improve the Services.
We may identify you from your Personal Information and merge or co-mingle Personal Information and Non-Personal Information. Except as otherwise stated, we may use Information we collect from you for the legitimate business purpose of providing our Services to you, including, but not limited to the following:
- To fulfill or meet the reason you provided the Personal Information. For example, if you share your name and contact information to ask a question about our Services, we will use that Personal Information to respond to your inquiry.
- To establish and secure accounts to use the Services, check on your account status, and to validate your username, e-mail, password, and/or other login credentials.
- To provide, support, personalize, and develop our Services, including without limitation, to conduct aggregate or research analysis and develop business intelligence that helps us to enhance, improve, evaluate, operate, protect, make informed decisions about, and report on the performance of our Services.
- To communicate information and promotional materials to you, where you have not expressed a preference otherwise, and to send you information and updates about the Services and any changes to relevant agreements, policies, or other terms, and to enforce such terms.
- To prevent or investigate fraud, or for risk management purposes, and to help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business.
- To comply with legal obligations, court orders, or in order to exercise any legal claim or to defend against any legal claim.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our consumers is among the assets transferred.
- As otherwise described to you when collecting your Personal Information.
In addition, we may use third‐party e‐mail providers to deliver communications to you. If you no longer want to receive these e-mail communications, you may opt-out of receiving e-mail communications through the “unsubscribe” link or by contacting us at email@example.com.
We may, from time to time, invite you to participate in online surveys. The information requested in these surveys may include, but is not limited to, your opinions, beliefs, insights, ideas, activities, experience, purchase history, and purchase intent regarding products, events, and Services. The information collected by these surveys is used to research market trends, company growth, community needs, etc. Your input will help us to improve customer experience and shape development of our products and Services.
How We Share Information
We may share Non-Personal Information, such as impressions and click data, with business partners and service providers. We do not share your Personal Information with such parties, although we may share traffic and transaction Information with them on an aggregated and anonymized basis. We do not sell or rent Personal Information to marketers or other unaffiliated third parties.
We may share your Personal Information with the following parties:
- Service providers that help us administer and provide the Services (for example, a web hosting company whose services we use to host our platform). These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf. We have entered into contractual relationships with these service providers and require them to comply with all applicable information privacy laws and regulations and to use the Information only for the purposes for which it was disclosed. We require that any third-party service providers limit their use of your Information solely to providing services to us and that they maintain the confidentiality, security, and integrity of your Information and not make unauthorized use or disclosure of the Information. A current list of these third parties is available upon request but includes Google Analytics, reCAPTCHA, Google Places, FreshDesk, Facebook, and Instagram;
- As we believe necessary: (i) under applicable law; (ii) to enforce applicable terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; and (vi) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence; and
- Pursuant to your express consent.
We take reasonable steps online and offline to safeguard the Personal Information that you provide to us. We will ensure our corporate IT and infrastructure assets are protected from cyber-attacks to ensure continuance of operation, decrease the risk of sustaining a data breach, and keep corporate and personal information private and secure, including:
- Train Employees in Basic Security Principles. We communicate requirements and guidance for building strong passwords and establish internet use guidelines that detail penalties for violating corporate cyber security policies.
- Install Antivirus Software. We will ensure corporate antivirus software is up to date and set to scan the device after each update.
- Enable or Install Firewall. We will ensure that every digital device used by employees has a firewall installed to prevent outsiders from accessing data on the corporate network.
- Create Security Requirements for Mobile Devices. We will require employees to password-protect their devices, encrypt their data, and install approved security apps.
- Control Physical Access to IT Devices.
- Employee laptops should be locked and password protected when not in use.
- Assign each employee their own user account.
- Ensure only trusted IT staff and key personnel should have administrative privileges.
- Secure WiFi Network. We ensure our corporate Wi-Fi networks are secure, encrypted, and hidden. We will password protect access to the corporate Wi-Fi router and change the password as needed.
While we endeavor to protect your Information, it is common knowledge that transmission of information via the internet is not wholly secure, and we cannot guarantee the security of your Personal Information, or any other information, transmitted to or through our App or Services. Any transmission of Personal Information, or other information, is at your own risk. By using our App and/or Service, you acknowledge and accept these risks.
If you have any questions about security on our Services, or if you become aware of any unauthorized use of an account, loss of your account credentials, or suspect a security breach, notify us immediately via email at firstname.lastname@example.org. If our security system is breached, we will notify you of the breach to the extent required under applicable law.
Additional Information for California Residents
California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to email@example.com. For more information regarding these rights, please see our Privacy Notice for California Residents.
Additional Information for EEA Residents
EEA residents whose Personal Information we have collected (“Data Subjects”) may have additional rights respecting their Personal Information, including rights to specific disclosures and rights to control their Personal Information. Please see below for more information.
- Legal Bases for Processing Your Information
We process your Personal Information for the purposes set forth in Section 4, above, on the bases further described below.
- For Legitimate Interests. We may use your Personal Information for the legitimate business purpose of providing our Services to you. For example, we use your Personal Information to administer the Services, help diagnose problems with our Services and provide support, to communicate information to you, to improve our Services and customize our Services to your preferences, to work with our service providers, to show you content and sponsored messaging, to prevent or investigate fraud or to comply with legal obligations, and for other purposes identified to you and as requested by you.
- Your Choices, Access, and Rights to Your Personal Information
Data Subjects may have the following rights and options with regard to accessing, reviewing, correcting, and updating their Personal Information:
- Right to Access. We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your Personal Information.
- How to Access Your Personally Identifiable Information. You may choose to access or update Personal Information, by logging into the account you have created with our Service(s), if applicable.
- Access to Personal Information. You may choose to access your Personal Information by contacting us and requesting access, a process which shall include our identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
- Updating Communications Preferences (Opt-Out) and Unsubscribing. You may choose to receive promotional offers, newsletters, and similar communications from us regarding our products and services and the products and services of our affiliated organizations. You may opt out of receiving such communications from us by communicating your preferences to us at firstname.lastname@example.org, or in the case of e-mails, by following the unsubscribe instructions contained in the applicable e-mail.
- Right to Rectify — Correction and Deletion. Citizens of some jurisdictions, including the EEA, have the right to correct or amend their Personal Information if it is inaccurate or requires updating. You may also have the right to request deletion of your Personal Information; however, this is not always possible due to legal requirements and other obligations and factors. Remember that you can update your account information by contacting us at email@example.com.
- Right to Erasure / Be Forgotten. Data Subjects may have the right to request that we delete your Personal Information in certain circumstances, such as if holding the Personal Information is no longer necessary or if part of your Right to Object (below). Please note that if you request erasure of your account, we, in complying with your request, shall also delete any and all research data that has been submitted to us through our Services. It is your responsibility at all times to ensure that you are in compliance with all applicable rules, policies, and regulations at the institutional, administrative, and federal levels regarding retention of research data, including, but not limited to, United States regulations governing retention and disposal of research records.
- Right to Object. Data Subjects may have the right to object to the use of Personal Information for direct marketing uses, scientific uses, or historical research. If you do not wish to have your Personal Information shared with third parties, contact our Data Protection Officer as described at the end of this document. If you do not wish to receive future commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive. (But note that you may continue to receive certain communications from us, such as transactional or relationship messages, and/or messages about your account/profile).
- Right to Restrict Processing. Citizens of some jurisdictions, including the EEA, have the right to request that we stop processing their Personal Information.
- Right to Data Portability. A Data Subject has the right to request that we provide your Personal Information for the purpose of sharing it with another service provider (through a secure process).
- Filing a Complaint. A Data Subject who is not satisfied with how we manage your Personal Information has the right to make a complaint to a data protection regulator. A list of National Data Protection Authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
- Geographic Information Transfers
However, this does not change our commitments to safeguarding your privacy, and we will comply with all applicable laws relating to cross-border data disclosure of your Personal Information. Where required, we implement Standard Contractual Clauses with our third parties pursuant to the requirements of the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), and you may request a copy of the Standard Contractual Clauses by emailing us at firstname.lastname@example.org. Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before disclosing any Personal Information.
- Data Protection Officer
Please see below for information regarding our appointed Data Protection Officer.
If you have an inquiry regarding your Personal Information, pursuant to the rights listed in the preceding section (above), please send your message to the following:
Attention: Website Inquiry
Links to Third Party Sites
We do not sell products or services for purchase by anyone under the age of thirteen (13). In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will never knowingly request or solicit Personal Information from anyone under the age of thirteen (13) without verifiable parental consent. In the event that we receive actual knowledge that we have collected such Personal Information without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Service(s).
How to Contact Us
By e-mail: support@iSymphony.net
By telephone: 281-902-5900
By regular mail:
101 Parklane Blvd
Sugarland, TX 77478