In this document (“Privacy & Data Policy”) Symphonova UK Ltd. (“Symphonova”), as otherwise identified in its website, explains how Symphonova uses data and handles privacy and why and how Symphonova collects and uses information. Symphonova also covers the choices available to you in accordance with your rights and its obligations. This document reflects policy as from 6 May 2018. “You” means anyone reading this document, who may be a client (or customer), prospective client, a business interaction party, or visitor to the website.
Symphonova is a UK business providing products and services to those clients with whom it enters into contracts as such within the music and Symphonova Versatile Acoustic System™ (SVAS™) sectors. In referring to “Services” or Symphonova’s activities we are referring to our day-to-day business in those sectors, including in meeting the needs of Symphonova’s existing and prospective clients, those it communicates and interacts with for its business purpose, and the need for maintenance of books and records.
Symphonova complies with requirements of privacy and confidentiality, and with applicable data protection legislation, including the Data Protection Act 1998 and the EU General Data Protection Regulation, or GDPR, effective 25 May 2018.
Symphonova determines data management practices and safeguards according to the above stated purposes and is controller of all relevant information along with GDPR compliant data processors. Symphonova’s guiding principle is only to use information fairly and for the bona fide purposes of its business doing so at all times with regard to the consent obtained from you and your instructions in relation to the use of information.
For the purposes of the proper running and administration of Symphonova’s business, including accounting, it may handle, including via a data processor, the following “Other Information”:
Symphonova uses your information to provide, maintain and improve the Services and in protecting, enhancing and administering its business.
Symphonova accesses and makes reasonable use of Customer Data in accordance with the terms of a customer’s consent and instructions, and applicable terms and conditions, in order to (a) provide, maintain and improve the Services, (b) address service, security, technical issues or in accordance with a customer’s request for assistance or support, or in addressing any grievance or complaint (c) comply with the law or any lawful data request or instruction and (d) to service any matter arising from Symphonova’s terms and conditions from time to time in accordance with them. This Symphonova does in accordance with its statutory and contractual security and confidentiality obligations.
Symphonova uses Other Information for the following purposes, to:
Subject to retaining information necessary to maintain an active client account, Symphonova will always respect your wishes in relation to Customer Data. Symphonova has only basic and simple records, so there is no self-management of your customer profile. You may always elect to close your account or advise Symphonova by email, telephone or through the ‘CONTACT’ page as to your particular requests or instructions.
Many browsers have functions which provide you with privacy, security and control tools, for example in relation to cookies and other aspects of data storage. Your mobile device will include a broad range of settings options for you tailor what the device and your use of it may reveal to other parties, for example, location data and notifications. These controls are not within our remit or control and are matters of your preferred use of options available to you in your particular devices operating systems and installed apps. If we offer any mobile device app, it will be subject to this Privacy & Data Policy.
If you have any questions about our use of Other Information you may contact Symphonova at any time with your enquiry.
On occasion information described in this Privacy & Data Policy may be shared by Symphonova.
Symphonova may share Customer Data in accordance with any agreement with any client and the client’s instructions, and this may be with third party service providers and agents. Symphonova may engage third party companies or individuals to process Customer Data on its behalf. Symphonova may combine with other businesses and partners in conducting business and delivering services. Symphonova may for the purposes of its business and in servicing clients integrate elements into its platforms and client resources, which may include integrations added by a client or by someone else with the client’s consent.
Symphonova does not assume responsibility for and has no liability in respect of the use of third parties of information which is not gathered directly from Symphonova or which is provided by the choice of the client or other relevant business partner.
Symphonova may share Other Information in the lawful operation of its business, and for purposes of assessment and review of quality control and performance indicators and in order to resolve any issue or controversy that arises between Symphonova and a client or otherwise in connection with or because of our business. Symphonova may use third parties to process and analyze Other Information.
Below are examples of when Symphonova may otherwise disclose Customer Data and Other Information which may occur:
• During changes to Symphonova’s business structure, for example if it engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets, financing, acquisition of all or a portion of its business, a similar transaction or proceeding, or steps in contemplation of such activities (including so-called “due diligence”);
• To comply with applicable laws and regulations or to confirm to any code of practice or conduct to which the firm is subject, including in relation to proper and valid requests for disclosure, or the requirements of a court order or police or other authority’s investigation;
• To enforce Symphonova’s rights, prevent fraud and for safety. To protect and defend the rights, property, or safety of Symphonova or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud;
• In the case of aggregated or de-identified information, then for any purpose. For example, Symphonova may share aggregated or de-identified information for bona fide business or research purposes.
Symphonova takes security seriously and has appropriate and up to date systems to protect information you provide to us from loss, misuse, and unauthorized access or disclosure and ensures the same is the case with its own service providers. These systems take into account the sensitivity of the information we collect, process and store, and the current state of available technology having regard to the nature, size and scale of Symphonova’s business from time to time. Details of Symphonova’s prevailing security practices may be requested at any time by any party entitled to make such a request.
Symphonova will only enter into client relations with persons over the age of 18 at the relevant point of contract, unless the lawful parent/s or guardian/s with appropriate authority confirm otherwise and provide all required GDPR-compliant consents. For this reason, Symphonova will neither hold nor process any information relating to such persons other than on the same basis. In the event that Symphonova discovers that any account has been opened with it in breach of this policy, Symphonova will take appropriate steps, including in respect of safeguarding and closure of the account.
Symphonova may change this Privacy and Data Policy from time to time, and if it does so it will post any changes on this page. If you use the Services or deal with Symphonova after those changes are in effect, you will be deemed to have agreed to and accepted the revised policy.
Please also feel free to contact Symphonova if you have any questions about this Privacy & Data Policy or the company’s associated practices.
To contact Symphonova Senior Data Officer: Unit 1, Cambridge House, Camboro Business Park, Oakington Road, Girton, Cambridge CB3 0QH, UK.