Privacy Policy

Last Updated: November 2024

Symphonic Digital (the “Company,” “we,” or“us”) recognizes the importance of data privacy, and this Privacy Policy setsforth the terms and conditions for how we process your personal information.This Privacy Policy describes, among other issues, the types of personal datawe collect, the purposes for which we use it, the types of third parties withwhom we share it, and any rights and responsibilities you may have concerningsuch personal information.

This Privacy Policy applies to the personalinformation you provide us when you visit any website that we own, license, orotherwise operate and that links to this Privacy Policy, or when you interactwith other content we provide online such as webinars, blogs, orpractice-specific content (each, a “Site”). For purposes of this PrivacyPolicy, the Site and all information, content, and material contained in oroffered by the Company through a Site shall be referred to collectively as the“Services.”

This Privacy Policy is incorporated intoand made a part of any other agreement that references this Privacy Policy orgoverns access to or use of the Site.

PLEASE READ THIS PRIVACY POLICY CAREFULLYAS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING ORUSING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARECONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND OUR  SITE.

By using our Site, you hereby represent andwarrant that you (i) are at least 18 years of age, and (ii) acknowledge,understand, and agree to this Privacy Policy, including all other terms andconditions referenced herein.

1. Scope

This Privacy Policy applies to personalinformation that the Company receives in connection with our business when weoperate as a “data controller” - which means when we determine the purpose andmeans of processing such personal information.

For purposes of this Privacy Policy, theterm “personal information” means any information that, alone or in conjunctionwith other information or data, identifies or can be linked to a particularindividual or household and that is subject to, or otherwise affordedprotection under, a data protection law, statute, or regulation. The term“personal information” does not include anonymized or de-identified data thatis not attributable to a particular individual or household and that is nototherwise subject to a data protection law, statute, or regulation. The Companymay anonymize or de-identify personal information, and such data is not subjectto this Privacy Policy, and the Company may use such data for any purpose.

This Privacy Policy is not intended to anddoes not cover our collection and use of your personal information collected INCONNECTION WITH OUR PROVISION OF LEGAL SERVICES.

2. The Types andCategories of Personal Information We Collect

When you visit a Site, we may collect thefollowing types and categories of personal information:

3. Collection ofTechnical/Online Data

In addition, when you access the Site, wecollect certain data automatically using technical means and tools. This datarelates to your device, as well as your experience on the Site and otherwebsites, including the following:

●     Usage and Device Data: When youaccess and use the Site, we may automatically collect details of your access toand use of the Site, including traffic data, usage logs and other communicationdata, and the resources that you access and use on or through the Site (e.g.,browsing history, search history). We may also collect information about yourdevice and internet connection, including the device’s unique identifier (e.g.,device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, andmobile network information. The Site may collect “diagnostic” data related toyour use of the Site, such as crash data and logs, performance data (e.g.,launch time, hang rate, or energy use), and any other data collected to measuretechnical diagnostics.

●     Cookies and Tracking Data; Social Media: We use “cookies” and other tracking technologies within the Site. Acookie is a small file placed on your smartphone or other device. It may bepossible to refuse to accept cookies by activating the appropriate setting onyour smartphone or device. However, if you select this setting, some parts ofthe Site may become inaccessible or not function properly. In addition, theSite may contain small electronic files known as web beacons (also referred toas clear gifs, pixel tags, and single-pixel gifs) that permit us to analyzedata on your use of the Site (e.g., recording the popularity of certain contentand verifying system and server integrity). From time to time, we may use onour Site certain third-party cookies and pixels provided by our marketing partners,including social media companies. To the extent we use such third-party cookiesand pixels, you hereby agree to the terms and conditions set forth by thosethird parties, which may include, X (formerly Twitter), among others.

●     Site Monitoring:  Please be aware that we, and our service providers and partners, usecookies and other tracking technologies within the Site to monitor and recordany and all activities and communications to, from, and on, the Site. For theavoidance of doubt, you hereby acknowledge, agree, and consent to, suchmonitoring and recording by us and our service providers and partners.

●     Non-Cookie Technologies: We maydeploy on our Site certain types of “Non-Cookie Technologies” provided by ourservice providers to support our digital advertising programs.  These technologies often include browsercache, locally stored objects, or the creation of a statistical identifierwherein an identifier, much like a cookie identifier, is calculated based onthe characteristics of a browser or device that distinguishes it from otherbrowsers or devices. These identifiers are calculated either from the data yourbrowser or device shares automatically or with additional data specificallyrequested from your browser or device.

4. Sources ofInformation

We collect personal information from thefollowing sources:

●     First Party /Direct Collection. We collect personal information directly from you when youuse our Services, or whenever you directly engage with us, such as when youvisit our offices or premises or otherwise contact us.

●     AutomatedCollection. As described above, we may collect information and data, such asusage data and cookies, through automated means when you use the Site (see“Technical Data” above)

●     Third-PartySources. We also obtain data from third parties. These third-party sources varyover time, but they are sources deemed credible by us and may be publiclyavailable or available on a commercial basis. They can include: to supplementthe data we collect; fraud prevention agencies or credit reporting agencies inconnection with credit determinations, if applicable; publicly availablesources such as open government databases or other data in the public domain;social networking providers; advertising companies; and, third-partyreferences.

5. How We Use YourInformation / Purpose of Collection

We may use the personal information wecollect about you to perform our Services, comply with our legal obligations,and promote our business interests. Please see below for more information onhow we use personal information:

●     Provide, operate,maintain, improve, and promote our Services.

●     Enable you toaccess and use our Services.

●     Send you messagesand communications related to our Services (e.g., responses to your comments,questions, and requests, customer services).

●     Furnish technicalnotices, updates, security alerts, and support and administrative messages toyou about our Services.

●     Provide you withpromotional and marketing communications (e.g., information about our Services,features, surveys, newsletters, and events).

●     Monitor and analyzetrends, usage, and activities in connection with our Services to promote ourbusiness interests.

●     Investigate andprevent fraudulent transactions, unauthorized access to or use of our Services,and other illegal activities.

The company may collect and use yourpersonal information for any other purpose for which we obtain your consent.

6. SharingInformation / Third-Party Disclosures

We may share your personal information withcertain organizations and third parties in accordance with applicable law,including as set out below. However, we do not share personal information withthird parties that we have reason to believe use such information for their owndirect marketing purposes.

Service Providers: We may share your personal information withcompanies that provide services on our behalf, such as hosting and analyzingthe Site, conducting surveys and marketing on our behalf, processingtransactions, tracking and responding to customer questions or complaints, andperforming analyses to improve the quality of our Services.

Distributors and Business Partners. We mayshare your personal information with third parties that distribute ourmarketing materials.

Business Restructuring:Circumstances may arise where, for strategic or other business reasons, theCompany decides to sell, buy, divest, merge, or otherwise reorganize ourbusinesses. We may disclose your personal information to the extent reasonablynecessary to proceed with the negotiation or with the completion of a merger,acquisition, divestiture or sale of all or a portion of the Company’s assets.

Legal; Compliance: LegitimateInterests. We may disclose personal information (i) if required by law orgovernment order, or with a legal process, (ii) to protect and defend ourrights or property, or (iii) in urgent circumstances, to protect the health andpersonal safety of any individual. In addition, the Company may disclose yourpersonal information with any third party when we believe such disclosure isnecessary to defend or protect our legal, regulatory, or business interests. Wemay also disclose your information upon your express consent.

Consent. In addition to the reasons fordisclosure set forth herein, we may also disclose your personal informationupon your consent.

In the event that you facilitate atransaction with the Company, or request information from or otherwise engagewith us, and such activities require the Company to share your personalinformation with a service provider or other third party, you hereby consent tosuch disclosure and/or direct the Company to intentionally disclose yourpersonal information to the service provider or third party.

7. Social Media/Platform Data Rights

We may engage with you on various socialmedia platforms (e.g., Facebook, LinkedIn, X, formerly Twitter, Pinterest,Instagram, etc.), and you may have the opportunity to comment on those socialmedia platforms regarding us or to submit or upload related photographs andother materials. We reserve the right to post on the Site, other websites, andsocial media pages any comments, photographs, or content that you post on oursocial media pages or provide to us through social media.

If you contact us on a social mediaplatform for customer support or for other reasons, we may contact you via thesocial media’s direct message tools. Those communications to and from us aregoverned by this Privacy Policy. However, your use of a social media platformis also subject to the policies and terms of the relevant social mediaplatform.

Certain social media platforms may alsoautomatically provide us with your personal information, the information wereceive will depend on the terms that govern your use of the social mediaplatform(s) and any privacy settings you may have set. The Site includes socialmedia features and widgets (e.g., the “Facebook Like” button, the “Share This”button) or interactive mini-programs that run on the Site. These features maycollect your IP address and which Site page you are accessing and may set acookie to enable the feature to function properly. Social media features andwidgets are either hosted by a third party or hosted directly on the Site.

Your interactions with these features aregoverned by the privacy statement of the relevant social media platform thatprovides them. According to the terms and conditions governing certain socialmedia platforms, you may request that the information, data, or other contentwe obtain from or through the social media platform (“Platform Data”) bedeleted or modified. If you would like Platform Data related to you deleted ormodified, please contact us in accordance with the “Contact Us” section belowand (i) identify the social media platform at issue and (ii) the Platform Datathat you would like deleted and/or modified, and if modified, the modificationto said Platform Data. We may also delete Platform Data if requested by thesocial media platform.

8. Links to OtherWebsites; Your Direct Third-Party Disclosures

As a resource to you, the Site may includelinks to third-party websites or provide you the opportunity to discloseinformation directly to third parties. Our Privacy Policy does not apply tosuch third-party websites or organizations. You assume all privacy, security,and other risks associated with providing any data, including personalinformation, to third parties via the Services. For a description of theprivacy protections associated with providing information to third parties, youshould refer to the privacy statements, if any, provided by those thirdparties.

Video Links.

We may include videos and similar mediaplayers on our Site. By clicking on such videos and similar media players onour Sites, (i) you may be redirected to a third party’s website to play thevideo, or (2) it may play the video on our Site, although this functionalitymay be supported by a third party’s website or technology (e.g., YouTube,YouTube API, Vimeo). In any such case, by playing the videos or similar mediaplayers, you shall become subject to the third party’s terms and conditions,including, but not limited to, its terms of service and personal informationprivacy policies and practices, including the terms governing.

9. Data Retention andLocalization

The period during which we retain yourpersonal information varies depending on the purpose of the data processing.For example, we retain personal information for as long as needed to provideyou with our Services, to facilitate transactions you have requested, to complywith our legal obligations, to engage in marketing activities, and for as longas is necessary to defend our legal or business interests. In all other cases,we retain your personal information for as long as is needed to fulfill the purposesoutlined in this Privacy Policy. The Company is based in the United States, andthe personal information that we collect and process is retained and stored inthe United States. By continuing to provide us such information, you herebyacknowledge and agree that your personal information will be transferred to,and stored in, the United States and in the countries where our serviceproviders are located.

10. Security

We seek to protect the security of yourpersonal information and use a variety of security technologies and proceduresto help protect your personal information from unauthorized access, use, ordisclosure. However, no information system can be fully secure, and we cannotguarantee the absolute security of your personal information. Moreover, we arenot responsible for the security of personal information you transmit to thesite and/or the services over networks that we do not control, including the internetand wireless networks, and you provide us with any personal information anddata at your own risk.

To the extent permitted by law, we shallnot be liable or otherwise responsible for any data incident or event that maycompromise the confidentiality, integrity, or security of your personalinformation caused by a third party. The safety and security of your personalinformation also depend on you. Where we have given you (or where you havechosen) a username and password to access our Services, you are responsible formaintaining the security and confidentiality of those credentials and notrevealing them to others.

You must contact us immediately (and in anyevent within twenty-four (24) hours) if you have reason to believe that yourusername or password to our Services has been compromised. You acknowledge andagree that we may contact you via email or other electronic communications inthe event we are legally required to notify you of a data security incident orevent related to your personal information.

11. No DataCollected from Children

The Site is not directed at, nor intendedfor use by, children. As a result, if you are under the age of eighteen (18)you are prohibited from accessing or using the Services (including the Site) orproviding us with your personal information.

12. U.S. StatePrivacy Rights (California Privacy Rights)

●     Data PrivacyRights. Under the California Consumer Privacy Act of 2018, as amended by theCalifornia Privacy Rights Act of 2020, California residents are entitled tocertain data privacy rights:

●     Right to Know(Specific Pieces of Personal Information). You have the right to know thespecific pieces of your personal information that we have collected about you.

●     Right to Know(Categories of Personal Information). You have the right to know (i) thecategories of personal information we have collected from you; (ii) thecategories of sources from which the personal information is collected; (iii)the categories of your personal information we have sold or disclosed for abusiness purpose; (iv) the categories of third parties to whom your personalinformation was sold or disclosed for a business purpose; and (v) the businessor commercial purpose for collecting or selling your personal information.

●     Right to Delete.You have the right to request that we delete the personal information that wehave collected and retained.

●     Right to Correct.You have the right to request that we correct inaccurate personal informationthat we have collected and retain.

●     Nondiscrimination.You have the right not to be subject to discrimination for asserting yourrights under the CCPA.

●     Submit a PrivacyRequest. To submit a privacy request, you (or your authorized agent) maycontact us in accordance with the “Contact Us” section listed below. However,any such authorized agent must be registered with the California Secretary ofState to conduct business in California.

●     Privacy RequestVerification Process. If you (or your authorized agent) make any requestrelated to your personal information, the Company will ascertain your identity(and the identity of the authorized agent, to the extent applicable) to thedegree of certainty required or permitted under the law before addressing yourrequest. In particular, the Company will, to the extent required or permittedby law, require you (or your authorized agent) to verify your request viaemail, request certain contact information or government identifiers, and wewill match at least two pieces of such personal information with data that wehave previously collected from you before granting you access to, erasing, orcorrecting, specific pieces or categories of personal information, or otherwiseresponding to your request. We may require written documentation thatdemonstrates a third party is authorized to serve as your agent for thepurposes of submitting the requests set forth herein, unless you have providedthe authorized agent with power of attorney pursuant to California Probate Code§§ 4121 to 4130. None of the CCPA’s rights are absolute, and such rights aresubject to legal and regulatory exceptions and exemptions. For more informationabout the CCPA, please see: .

●     Opt-Out Rights / DoNot Sell My Personal Information. California residents have the right to optout of the “sale” of their personal information. However, the Company does notsell your personal information to third parties for profit or monetary or othervaluable consideration, and therefore we do not provide opt-out requestprocesses for the sale of personal information (because we do not undertakesuch activities).

●     Opt-Out Rights / DoNot Share My Personal Information. California residents have the right to optout of the “sharing” of their personal information. The Company usesthird-party analytical and targeted advertising features on our Site andsimilar web tools provided by our marketing partners, and such features, toolsand marketing relationships involve the disclosure of your personal informationto third parties and may constitute the “sharing” of your personal informationfor CCPA purposes. To opt out of this sharing of your personal information inthese circumstances, please click on the cookie management tool (sometimesvisible as a “Your Privacy Choices” link) on the footer of the Site to set yourcookie preferences. You, or your authorized agent, may also contact us inaccordance with the “Contact Us” section listed below.

●     Children. The Siteis not directed at, and should not be used by, minors under the age of eighteen(18), and therefore the Company does not knowingly sell or share the personalinformation of minors under sixteen (16) years of age.

●     Limit Use ofSensitive Personal Information. The Company does not use or disclose sensitivepersonal information for reasons other than those set forth in the CCPA, andtherefore we do not provide individuals with the ability to limit how we use ordisclose such sensitive personal information.

13. U.S. StatePrivacy Rights (General)

Data Privacy Rights. Pursuant to certainU.S. state privacy laws you may have the following privacy rights with respectto your personal information:

●     To confirm whetheror not we are processing your personal information and access such personalinformation.

●     To correctinaccuracies in your personal information, taking into account the nature ofthe personal information and the purposes of the processing of your personalinformation.

●     To delete personalinformation provided by, or obtained about, you.

●     To obtain a copy ofyour personal information processed by us, in a portable and, to the extenttechnically feasible, readily usable format that allows you to transmit thedata to another entity without hindrance.

Submit a Privacy Request. To submit theseabovementioned privacy requests, please contact us in accordance with the“Contact Us” section below. Where permitted by U.S. state law, you maydesignate an authorized agent to submit a privacy request on your behalf.

Privacy Request Verification Process. Ifyou make any request related to your personal information, the Company willascertain your identity (and the identity of the authorized agent, to theextent applicable) to the degree of certainty required or permitted under thelaw before addressing your request. In particular, before granting you accessto, erasing, or correcting, specific pieces or categories of personalinformation or otherwise responding to your request, the Company will, to theextent required or permitted by law, (i) require you (or your authorized agent)to verify your request via email, (ii) request certain contact information orgovernment identifiers, and (iii) match at least two pieces of such personalinformation with data that we have previously collected from you. None of yourprivacy rights are absolute, and such rights are subject to exceptions andexemptions.

Privacy Requests Appeals Process. If youwould like to appeal a decision the Company has made with respect to yourprivacy request, please email us in accordance with the “Contact Us” sectionlisted below, with the subject line “ATTN: Privacy Appeals,” and describe thenature of your request, and the reason for requesting an appellate review.

Opt-Out Rights / The Sale of PersonalInformation. You may have the right to opt out of the “sale” of their personalinformation. However, the Company does not sell your personal information tothird parties for monetary consideration or other valuable consideration, andtherefore we do not provide opt-out request processes for the sale of personalinformation (because we do not undertake such activities). Nevada residents maysubmit a request directing us to not sell personal information we maintain aboutthem to third parties who will sell or license their personal information toothers. If you would like to exercise this right (even though we do not sell orlicense personal information), please contact us in accordance with the“Contact Us” section listed below.

Opt-Out Rights / Targeted Advertising. Youmay have the right to opt out of having their personal information used fortargeted advertising purposes. The Company uses third-party analytical andtargeted advertising features on our Site and similar web tools provided by ourmarketing partners. To opt out of the disclosure of your personal informationto these third parties in these circumstances, please click on the cookiemanagement tool (sometimes visible as a “Your Privacy Choices” link) on thefooter of the Site to set your cookie preferences.

Opt-Out Rights / Profiling. You may havethe right to opt out of having their personal information used for profiling infurtherance of decisions that produce legal or similarly significant effects.However, the Company does not engage in such activities.

Complaints. You may file a complaint aboutour data processing activities with your local authorities, which may includethe following:

●     The ColoradoAttorney General at: https://coag.gov/file-complaint/.

●     https://portal.ct.gov/DCP/Complaint-Center/Consumers---Complaint-Center.

●     The MontanaAttorney General at: https://dojmt.gov/consumer/.

●     The Nevada AttorneyGeneral at https://ag.nv.gov/Complaints/File_Complaint/.

●     The Oregon AttorneyGeneral at: https://www.doj.state.or.us/consumer-protection/contact-us/.

●     the Texas AttorneyGeneral at: https://www.texasattorneygeneral.gov/consumer-protection.

●     The VirginiaAttorney General at https://www.oag.state.va.us/contact-us/contact-info.

However, we would like the opportunity toresolve any concern you may have with respect to our data processingactivities, and we will seek to resolve any concern you may have.

14. European/UKPrivacy Rights

●     Data PrivacyRights. For individuals in the European Economic Area (EEA), Switzerland, andthe United Kingdom, you are entitled to the following privacy rights:

●     Right to Know. Youmay have the right to know about what personal information the Company collectsand processes about you, including the types of personal information we collectand process, the sources of such personal information, our retention criteria,with whom we share your personal information, cross-border data transfers, andhow to file complaints and inquiries.

●     Access Rights. Youmay have the right to ask us whether we process any of your personalinformation and, if so, receive access to such personal information. Whencomplying with an access request, we will also provide you with additionalinformation, such as the purposes of the processing, the categories of personalinformation concerned as well as any other information necessary for you toexercise the essence of this right.

●     Rectification. Youmay have the right to have your personal information corrected/rectified incase of inaccuracy or incompleteness. Upon request, we will correct inaccuratepersonal information about you and, taking into account the purposes of theprocessing, update any incomplete personal information, which may include theprovision of a supplementary statement.

●     Erasure. You mayhave the right to have your personal information erased, which means thedeletion of your personal information by us. However, your right to erasure issubject to statutory limits and prerequisites (e.g., where your personalinformation is no longer necessary in relation to the initial purposes forwhich it was processed, your personal information was processed unlawfully).

●     Restriction ofProcessing. You may have the right to obtain the restriction of the processingof your personal information, which means that we suspend the processing ofyour personal information for a certain period of time. Circumstances which maygive rise to this right include situations where the accuracy of your personalinformation is contested, but we need time to verify the inaccuracy (if any) ofyour personal information.

●     Data Portability.You may have the right to request we provide you with your personal informationin a structured, commonly used and machine-readable format and to have suchdata transmitted directly to another controller, where technically feasible.

●     Right to Object.You may have the right to object to the processing of your personalinformation, which means you may request we no longer process your personalinformation. This only applies in case the “legitimate interests” ground(including profiling) constitutes the legal basis for processing (see below“Legal Basis for Processing”). However, at any time (and free of charge) youcan object to having your personal information processed for direct marketingpurposes.

●     Automated DecisionMaking. You may have the right to object to having us use your personalinformation to conduct automated decision making. However, the Company does notengage in any activity that subjects our customers, website users, surveyparticipants, or others to a decision based solely on automated processing,including profiling, which produces legal effects, or similarly significantresults, impacting them.

●     WithdrawingConsent. You also may withdraw your consent at any time if we are solelyrelying on your consent for the processing of your personal information.However, this will not impact our legal basis to process such personalinformation prior to the withdrawal of your consent.

●     Submit a PrivacyRequest. To submit these abovementioned privacy requests, please contact us inaccordance with the “Contact Us” section below. You may designate an authorizedagent to submit a privacy request on your behalf.

●     Privacy RequestVerification Process. If you make any request related to your personalinformation, the Company will ascertain your identity (and the identity of theauthorized agent, to the extent applicable) to the degree of certainty requiredor permitted under the law before addressing your request. In particular,before granting you access to, erasing, or correcting, specific pieces orcategories of personal information or otherwise responding to your request, theCompany will, to the extent required or permitted by law, (i) require you (oryour authorized agent) to verify your request via email, (ii) request certaincontact information or government identifiers, and (iii) match at least twopieces of such personal information with data that we have previously collectedfrom you. None of your privacy rights are absolute, and such rights are subjectto exceptions and exemptions.

Legal Basis for Processing. For purposes ofthe EU/UK GDPR, we can collect and process your data under one of the followinglegal bases:

●     Consent. We cancollect and process your data with your consent. For example, if you have givenyour consent to receiving marketing material from us at the point we collectedyour information.

●     ContractualObligations. We need your personal information to comply with our contractualobligations. For example, if you have subscribed to one of our services, we useyour personal information to fulfill, and deliver that service to you.

●     Legal Compliance.If the law requires us to, we may need to collect and process your data.

●     Legitimateinterest. We may use your data as required in the normal course of operatingour businesses and services unless our legitimate interests are overridden byyour rights.

●     Vital interests. Wemay need to process your personal information if the processing is necessary toprotect your vital interests (for example, health and safety reasons if youattend a meeting at a the Company location).

Complaints. Depending on applicable law,you may have the right to submit a complaint to a data protection authorityresponsible for overseeing our compliance with data protection law in yourjurisdiction. Please see a list of potentially applicable regulatoryauthorities:

●     https://edpb.europa.eu/about-edpb/about-edpb/members_en.

●     https://www.edoeb.admin.ch/edoeb/en/home.html).

●     www.ico.org.uk).

We would, however, appreciate theopportunity to address your concerns, so please feel free to contact usregarding any complaint you may have. We will not discriminate againstindividuals for exercising their data privacy rights or filing a privacy complaint.

15. Marketing Preferences

We will provide you with updates or othercommunications to the email address you provide. We will use this informationto send you updates and promotional and other electronic communications. Youmay, at any time, opt-out from receiving marketing emails from us.

To opt-out from such marketing, please usethe “unsubscribe” or “preference” features within our email communications, orcontact us in accordance with the “Contact Us” section below. Note that, evenif you opt out of receiving marketing communications from us, you may stillreceive administrative communications from us with respect to your use of theSite.

16. Do-Not-TrackSignals

Some web browsers may transmit“do-not-track” signals to the website with which the user communicates. Becauseof differences in how web browsers incorporate and activate this feature, it isnot always clear whether users intend for these signals to be transmitted, orwhether they are even aware of them. Unless otherwise required by law, wecurrently do not take action in response to these signals.

17. Persons withDisabilities

The Company strives to ensure that everyperson has access to information related to our Services, including thisPrivacy Policy. Please contact us if you would like this Privacy Policyprovided in an alternative format, and we will seek to meet your needs.

18. EmploymentApplications and Talent Management

As part of our recruitment and talentmanagement process, we collect personal information with respect to individualswho are interested in working for us. In this context, we collect employmentand application data, such as the following: contact information (e.g., name,title, residential or postal address, telephone number, and personal emailaddress); information in a curriculum vitae, resumé, cover letter, or similardocumentation; details regarding the type of employment sought, willingness torelocate, job compensation and benefit preferences; health data (e.g., medicalconditions); information related to your background, education, criminalrecord, credit history and similar data; information provided about or by yourreferences or other third parties related to your employment history, skills,qualifications, or education; and information related to previous applicationsto us or previous employment history with us. When permitted by law, we maycollect information about your race and ethnicity to assist with our diversityand inclusion programs.

We use this information for the followingpurposes: to identify and evaluate job applicants; to verify your information;to complete employment, education, background and reference checks; tocommunicate with you about the recruitment process and your application; tocomply with our legal, judicial, regulatory, administrative, or other corporaterequirements; to analyze and improve our application and recruitment process;to accommodate individuals who may have specialized needs during the employmentprocess; and to protect the rights, interests, and property of our business,other job applicants, employees, or the public, as required, or permitted, bylaw.

We share this personal information withthird parties (see “Sharing Information / Third-Party Disclosures”), and we mayalso use this employment and application data for any other purpose set forthin this Privacy Policy.

Please see above for any privacy rights youmay have with respect to this personal information.

19. Events andVideo Teleconferencing

The Company hosts and uses videoteleconferencing platforms to facilitate conferences, meetings, trainingevents, and other programs. We often use online platforms that are owned andadministered by a third-party service provider (e.g., Google, Zoom, WebEx,Skype for Business). Please be aware that our video teleconferencing may recordthe content, conversations, and discussions thereon, and such records may bestored or retained by our third-party service providers. By participating inour events and video teleconferencing, you hereby consent to the collection andretention of any information provided therein, and you hereby consent to therecording of such activities.

20. Changes to thePolicy

We reserve the right to amend this PrivacyPolicy at any time. We will notify you if this Privacy Policy is amended byupdating the “Last Updated” section listed above. It is your responsibility toperiodically review the Privacy Policy to determine whether any amendments havebeen made hereto. Your use of the Services, and continued use of the Servicesafter any amendments are made to this Privacy Policy, signifies your consent tothis Privacy Policy and any amendments hereto.

We may, in our sole discretion, provide youcommunications, including via email or text messages, about changes to ourPrivacy Policy; however, such communications do not abrogate or otherwise limityour responsibility to periodically review the Privacy Policy to determinewhether any amendments have been made hereto.

21. Contact Us

If you have questions regarding thisPrivacy Policy or our handling of your personal information, would like torequest more information from us, or would like to exercise a data privacyright, please contact us or at our contact information below:

Symphonic Digital, LLC

4500 Park Granada,Suite 202, Calabasas, CA 91302

+1 888-964-3498

steffen@symphonicdigital.com

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