Last updated: 22-Dec-2020

About us

This Privacy Policy (or “Policy”) tells you how Symphony Retail Solutions group of companies (“Symphony Retail Solutions”, ”we,” or “our”), including : SymphonyEYC France, Symphony RetailAI and Symphony Retail Solutions S.à.r.l collects, uses, shares, and protects personal data about you.

It also tells you how you can access and update your information and make choices about how your information is used. More information on how to contact us to exercise your data subject rights below.

About this privacy policy

When you use our website, (the “Website” or the “Service(s)”), we collect personal information about you. The purpose of this privacy policy is to explain the types of information we collect, how we use it and with whom it is shared.

This privacy policy applies to all users of our Services across the world as required by local laws. If you are accessing the Services in the European Union, then you will have additional rights which we explain this privacy policy.

This privacy policy is divided into the following sections:

How to contact us

If you have any questions about this privacy policy, or about how we use your personal information, you may contact us by email: at privacy@symphonyretailai.com, or by writing to us at: Data Protection Officer, SymphonyEYC France S.A.S, 37, rue du Colonel Pierre Avia, 75015 Paris, FRANCE.

What is personal information?

As used in this privacy policy, the term “personal information” means any information that specifically identifies an individual, (such as a name, user name, e-mail address, postal address, phone number) is any data which relates to an individual who may be identified from a combination of a set of data, and other information which is in possession of us.

What personal information do we collect about you?

As a Data controller, we might collect and process your Personal Information in the following contexts:

  • As part of our Marketing and Sales process, to market and sell our Solutions and Services, including our marketing and promotional events
  • During your visit to our websites and availing of related services, either through designated web-forms or through automated means, including Cookies.
  • As a part of the Recruitment Process
  • As a part of visitor management when you physically visit any of our offices.

Personal information which you provide to us

The following personal information about you is provided to us by you:

  • your name, company, job title, email address, telephone number and postal address;
  • Additional information such as your profile, employment, and other specific details such as Education, Qualification, Family and Salary details as part of the recruitment and employment process
  • Information you provide to us when you communicate with us as part of the Services, for example when you call us, text us, email us, or whenever you use a contact or registration form;
  • Information about you that you have made publicly available and which we use as part of the Services.

You may decide not to provide certain personal information. However, if you choose not to provide it, you may not be able to use our Services for which certain information is essential.

We collect certain information about you automatically

When you use our Websites and related Services, some information is also automatically collected, such as:

  • Information about other websites that contain link to our Website.
  • Information about how you use our Website (for example, how long you spend using it, how often, and when you last used it).
  • We may collect certain technical and device-specific information, such as your IP address, your hardware model, operating system version, unique device identifiers, and mobile network information.
  • Other personal information from third parties. For example, information obtained when you use social media accounts.

We collect personal information about you using cookies

We may also automatically collect certain information through the use of “cookies.” Cookies are small data files stored on your hard drive at the request of a website. Among other things, cookies help us to improve our Services and your experience. If you wish to block, erase, or be warned of cookies, please refer to your browser manufacturer to learn about these functions.

You can learn more about the cookies we use in our Cookie Policy.

Learn how to manage cookies from aboutcookies.org.uk

However, if you choose to remove or reject cookies, this could affect our ability to provide our Services to you.

We may also employ the use of anonymous identifiers, which are random strings of characters that are used for the same purposes as cookies on platforms, including certain mobile devices, where cookie technology is not available.

We may use web beacons or similar technology on our Services. Web beacons are small, invisible graphic images that may be used on our Services or in emails relating to our Services to collect certain information and monitor user activity on our Services, such as to count visits, understand usage effectiveness, and to tell if an email has been opened and acted upon.

How do we use the personal information we collect?

We use the personal information we collect for the following purposes:

  • To ensure that content from our Website is presented in the most effective manner for you and for your computer;
  • To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
  • To provide you with information, products or services of carefully-selected third parties which we think may be of interest to you; where you have consented to be contacted for such purposes.
  • As a part of our Recruitment process, to process your profile for consideration for employment
  • As part of our sales and marketing process to promote our products and services that might be relevant for and in interest to you and your organization.
  • We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your unique personal information to a third party.
  • To allow you to participate in interactive features of our service when you choose to do so;
  • To request feedback and to otherwise contact you about your use of our Services;
  • To respond to your emails, questions, comments, requests and complaints, and to provide customer service;
  • To monitor and analyze how you use our Services, your usage and trends;
  • To personalize and improve our Services, and our users’ experiences with our Services and to increase our Services’ functionality and user-friendliness;
  • To send you confirmations, updates, security alerts and support and administrative messages, and otherwise facilitate your use of, and our administration and operation of, our Services;
  • To notify you about important changes to our Services;
  • To investigate and protect our users from fraudulent, abusive, inappropriate, or unlawful use of our Services.

In addition to the above, as a Data Processor, we may receive personal information via our global customers, as a part of, and as required for the fulfillment of our Solution and/or Service commitments to them.

The collection and processing of personal information in such scenarios is strictly under the authorization and instructions from the respective Data controllers (our customers), governed by the specific Scope of Work (SoW) and Data Processing Agreement (DPA) with, in alignment with the applicable laws and regulations.

With whom do we share your personal information?

We share your personal information with the following third parties, which may vary from time to time and may be different according to where you are located when you access the Services:

Service providers

We employ other companies and people to provide services to visitors to our Websites, our customers and may need to share your personal information with them to provide information, products, or services to you. Examples may include removing repetitive information from prospect lists, analyzing data, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service. In all cases where we share your personal information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.

Third parties requiring information for legal reasons

We may share your personal information with others if the law requires us to, or if we think it is necessary to comply with the law. We may also share your personal information if we need to do so to protect or defend our legal rights, or those of others.

Third-party investigators, authorities, or law enforcement bodies

We may share your personal information to investigate and protect our users from fraudulent, abusive, inappropriate, or unlawful use of our Services.

Potential buyers or investors

In the unlikely event that we wished to sell our business, we may need to share your personal information with a potential buyer or an investor.

Group companies

We share your personal information with members of our group of companies where required for business operational reasons.

When we process your personal information, we will only do so where at least one of the following Legal bases applies:

  • We need to use your personal information to perform our responsibilities under our contract with you (e.g. processing payments for and providing our Services).
  • It is in our legitimate interests to use your personal information in certain circumstances. For example, it is in our legitimate interests to use your personal information in connection with our Services; to improve our Services; to ensure that our Services are secure; to, tell you about changes to our Services; to tell you about new services or products we are offering; for business reasons (for example to develop our business or if we are thinking of selling our business); to tell you about offers or promotions we are running; or for operational purposes.
  • Where you have given explicit consent or the collection and processing of personal information. For example, when you submit a form on the website or tick an online box, you are giving your consent to use your personal information submitted. In these circumstances, your consent will be our legal basis for processing your personal information.
  • If you have provided consent, you may withdraw it at any time. You may do this by “opting out” where we give you the opportunity to do so, or by contacting us using the contact details above

For how long do we keep your personal information?

We store your information for a duration that is proportionate to the purpose for which we collect and process them in alignment with the applicable laws and regulations in each jurisdiction.

We apply a general rule of keeping personal data only for as long as required to fulfill the purposes for which it was collected

We don’t retain the data beyond the tenure required by the specific purpose for which it was collected, by our Customer and/ or any applicable laws/ regulations

The retention of any customer-specific data including Personal Data in our systems will be limited to the terms agreed in our contracts/agreements with our customers, as well as the requirements in applicable laws and regulations.

We may transfer your personal data outside the European Economic Area

In connection with the abovementioned purposes, we try to avoid as much as possible the transfer of personal information that we collect from you to third-party data processors located outside the European Economic Area. When we transfer personal information that we collect from you to third-party data processors located in countries that are outside of the European Economic Area and which do not offer an adequate level of protection, we ensure the use of appropriate data transfer tools such as the entering into of the standard contractual clauses issued by the European Commission.

We are not responsible for personal information you provide to other websites

Our Services may contain links to other websites. Any personal information you provide on the linked pages is provided directly to that third party and is subject to that third party’s privacy policy. We are not responsible for the content or privacy and security practices and policies of these websites or any other websites that are linked to/from our Services. We encourage you to learn about their privacy and security practices and policies before providing them with any personal information.

What choices and rights do you have regarding the use of your personal information?

You may “opt-out” of receiving marketing or promotional messages from us by following the instructions in those messages. You may also opt-out of such marketing by contacting us at the address above.

In addition, you have the following rights as a data subject:

  1. the right to access to personal information that we hold about you;
  2. the right to ask us to update or correct any out-of-date or incorrect personal information that we hold about you;
  3. where the processing is based on your consent, the right to withdraw consent at any given time, without affecting the lawfulness of processing based on consent before its withdrawal;
  4. the right to erasure where the conditions of article 17 of the GDPR have been met;
  5. the right to restriction of processing where the conditions of article 18 of the GDPR have been met;
  6. the right to data portability insofar the conditions of article 20 GDPR apply to you;
  7. the right to give us instructions on the management of your data after your death,
  8. the right to object to processing of personal data concerning you, insofar the conditions under article 21 GDPR have been met;
  9. the right to lodge a complaint with a supervisory authority.

If you need help or wish to exercise any of the above rights or have questions about them, please contact us by email at privacy@symphonyretailai.com, or by writing to us at: Data Protection Officer, SymphonyEYC France S.A.S, 37, rue du Colonel Pierre Avia, 75015 Paris, FRANCE.

We will consider all such requests and provide our response as soon as we can. Please note, however, that personal information may be exempt from such requests in certain circumstances, which may include needing to keep processing your personal information for our legitimate interests or to comply with a legal obligation. Please note that we may request you provide us with information necessary to confirm your identity and we reserve the right to charge a fee where permitted by law, especially if your request is manifestly unfounded or excessive. We will endeavor to respond to your request within all applicable timeframes.

If you contact us regarding Data collected by or on behalf of our customers, as part of our solutions and services offered to them, for which we are acting as a data processor, we will attempt to refer your request to the relevant Customer who acts as the Data controller for your personal data at the earliest, and/or inform you accordingly.

Information from children

We do not solicit or collect any type of information from a person known to be under the age of 16. If we discover that we have accidentally collected information from a child, we will remove that information from our records as soon as feasibly possible.

Complaints and queries

If you have any complaints, queries or questions about how we use your personal information, you may contact us using the contact details above. We will then get in touch with you to see how we can help.

If you have a complaint about how we use your personal information, we would always prefer you to contact us first. However, you may also make a complaint to the relevant data privacy regulator (i.e. CNIL) if you wish to do so. Please let us know if you are unsure about how to get in touch with the data privacy regulator.

Security

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We take appropriate technical and organizational measures to safeguard the personal information that you provide to us against unauthorized or unlawful processing and against accidental destruction, loss, or damage.

We take Data protection and privacy very seriously. All our systems and processes are planned, designed, and managed by keeping Security and Privacy in mind. We contractually require our agents, service providers, and affiliates who may process data related to services to provide the same level of protection for data as required under the principles and applicable laws and regulations.

Changes to this privacy policy

We may amend this privacy policy from time to time. Please review this privacy policy periodically so that you understand how your personal information will be used.

Governing law

This privacy policy is governed by the laws of the country where Symphony Retail Solutions is established and, as of 25 May 2018, by the General Data Protection Regulation 2016/679 of 27 April 2016 (“GDPR”) and/or the local implementing provisions on the GDPR of the related state. Please note that this privacy policy may evolve in order to take into account new rules deriving from the GDPR.

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