Privacy Policy

Last Updated: March 7, 2023

Symphony Risk Enterprises, LLC, and its affiliates (“Symphony”, “we”, “us”, or “our”) is in the business of providing full service insurance brokerage, risk management advisory, and employee benefits brokerage and consulting advisory. Symphony is committed to protecting your privacy and the privacy of our clients.

This Privacy Notice (“Notice”) describes how Symphony collects, uses, stores and discloses personal information when you use our website at https://www.symphonyrisk.com/ (the “Site”) or engage with any other websites, portals, pages, features or content owned and operated by Symphony that direct to this Notice (collectively, the “Services”). This Notice applies to any personal information you provide and any personal information about you we collect from other parties, including your employer. This Notice does not apply to personal information you provide to us as part of a job application. For more information about such practices, please refer to our California Job Applicant Privacy Notice found at https://www.symphonyrisk.com/california-job-applicant-privacy-notice/.

We may update this Privacy Notice from time to time to reflect changes in the law or our privacy practices, as permitted by law. We will post changes to this page, so be sure to check back periodically. We may also decide to notify our users by email of material changes prior to the change becoming effective and update the “Last Updated” date at the top of this Privacy Notice. Changes to this Privacy Notice are effective as of the date noted.

CONTENTS

 

  1. Personal Information We Collect
  2. How We Collect Personal Information
  3. How We Use Your Personal Information
  4. Sharing and Disclosure of Your Personal Information
  5. Data Security
  6. Retention
  7. Children
  8. Cookies and Other Tracking Technologies
  9. Your Privacy Rights and Choices
  10. International Transfers
  11. Additional Information for California Residents
  12. Third-Party Links
  13. Contact Us

 

  1. Personal Information We Collect

Personal information is any information that identifies or makes an individual identifiable. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Notice. In the course of interacting with you or providing our products and Services, Symphony may collect personal information from you or other sources, including your employer,  which may include but is not limited to the following:

  • Contact Information.  Name and contact information (e.g., e-mail address, mailing address, phone number, mobile number, etc.).
  • Insurance.  Insurance policy and claim information.
  • Verification Details.  Government-issued identification and record details (e.g., social security number, driver’s license number, motor vehicle record, passport information, etc.).
  • Demographic.  Demographic information (date of birth, gender, employment status, benefit coverages, marital status).
  • Health.  Physical or mental health information in relation to evaluating risk and placing insurance policies.
  • Other Information. Signature, credit information, photographs, records of personal property, products or Services purchased.
  1. How We Collect Personal Information
    Symphony collects personal information when:
  • You Provide It Directly to Us. We collect your personal information directly from you when you interact with us, such as when:
    • You contact us or we perform Services for you.
    • You register on our Site or email distribution lists.
    • You RSVP to or attend our events.
  • We Collect It Automatically. As you navigate through and interact with our site or Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, such as which pages you view or interact with, your IP address, operating system, and browser type. For more information, please refer to the “Cookies and Other Tracking Technologies Section” below.
  • When We Receive It From Third-Party Sources. We may collect your personal information when we receive it from third-party sources, specifically when we provide Services to our clients, our clients may provide us with your personal information so that we can provide our Services to them. We may also collect information about you when you interact with us through social media platforms.
  1. How We Use Your Personal Information
    We will only use your personal information as described in this Privacy Notice or as disclosed to you prior to such processing taking place. We use your personal information for the following commercial and business purposes:

a.) To Provide Services to You or Our Clients. We process your personal information to provide our Services to you and to our clients.

b.) To Personalize Your Website Experience.

c.) To Conduct Our Events. We may process your personal information in order to conduct our events for which you sign up.

d.) To Provide You with Service-Related Communications. These include communications about your current Services and to provide you customer support.

e.) To Engage in Marketing Activities.

f.) To Ensure the Security of Our Systems. We may process your personal information to help maintain the safety, security, and integrity of our websites, products and Services, databases and other technology assets, and business.

g.) To Assess Potential Transactions. We may process your personal information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Symphony’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Symphony is among the assets transferred.

h.) To Enforce Compliance with Our Terms and Agreements or Policies.

i.) To Maintain Legal and Regulatory Compliance.

j.) For Any Other Purpose to Which You Consent.

We may also aggregate or deidentify any personal information that we collect in connection with our Services, such that the information is no longer personally identifiable or attributable to you. We may use such aggregated information for our own legitimate business purposes without restriction.

  1. Sharing and Disclosure of Your Personal Information
    We will not sell, share, or otherwise disclose your personal information for purposes unrelated to those detailed in this Privacy Notice. To that end, we will take reasonable precautions to allow access to your personal information to only our employees, agents, contractors, or similar entities to the extent necessary for the purposes set out in this Privacy Notice. We may share your personal information in the following ways:
  • With Service Providers. We may employ companies and individuals to facilitate our Services (“Service Providers”), provide the Services on our behalf, perform Services-related services or assist us in analyzing how our Services are used. The Service Providers are bound by contractual obligations to keep personal information confidential and use it only for the business purposes for which we disclose it to them.
  • Within Our Corporate Organization. Symphony is a part of a corporate organization that has different legal entities, business processes, affiliates, management structures and technical systems. Symphony may share your personal information with this organization to provide you with the Services and take actions based on your request.
  • As Part of a Corporate Transaction. If Symphony is involved in a merger, acquisition or asset sale, your personal information may be transferred. We or our successor will provide notice before your personal information is transferred if the likely new uses of your personal information are incompatible with the purposes for which it was originally collected.
  • With Your Consent. We may disclose your personal information for any purpose with your consent.
  • As Necessary to Comply with Our Legal Obligations. We may also disclose personal information in order to assist with or otherwise enable our compliance with a legal or regulatory obligation, protect and defend our rights or property, protect the safety of our users or the public, and to exercise establish or defend our legal rights. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
  1. Data Security

We take precautions to protect personal information under our control from misuse, loss, or alteration. Our security measures include physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your personal information. All Symphony employees receive training on the importance of protecting personal information, and only authorized employees have access to personal information. Subcontractors and agents are contractually bound to maintain protection of personal information and are not permitted to use the information for any unauthorized purpose.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.

  1. Retention
    We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Notice, unless we are otherwise required to retain it to: (i) comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws); (ii) resolve disputes; or (iii) enforce our legal agreements and policies. We may also retain de-identified, aggregate website, and services usage data for internal analysis purposes.
  2. Children
    Symphony’s Services are not directed toward children under the age of 16, and we do not knowingly collect information from children who have not reached the age of consent under relevant data privacy laws. If we learn that we have collected personal information from a child who has not reached the age of consent, we will delete it immediately.
  3. Cookies and Other Tracking Technologies

Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables our websites or provider’s system to recognize your browser and remember certain information. We use first-party and third-party cookies for the following purposes: to make our services function properly, to improve our websites or services, to recognize you when you return to our websites, to track your interaction with the websites or services, to enhance your experience with the websites or services, to remember information you have already provided, and to provide a secure browsing experience during your use of our websites or services. The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e. after you have finished browsing).

The following types of cookies are used on our websites:

  • Strictly Necessary Cookies. These cookies are essential because they enable you to use our websites. For example, strictly necessary cookies measure the stability and effectiveness of our website. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our website to work and they cannot be disabled.
  • Functional or Preference Cookies. We use functional cookies to remember your choices so we can tailor our website to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our website. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our websites.
  • Performance or Analytic Cookies. These cookies collect passive information about how you use our websites, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our websites. We do not use these cookies to target you with online marketing. You can disable these cookies.

Other Tracking Technologies

We may also use tracking technologies to collect “clickstream” data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our website, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the website for the same purposes.

Pages of our website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Pages of our website may also use JavaScript, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or “cached” within your browser to retrieve data in HTML5 pages when the website is revisited.

Your Choices. We think that you benefit from a more personalized experience when we know more about you and what you like. However, you can limit the information you provide to us. In particular, you may manage how your browser handles cookies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available.

You can opt out of being targeted by certain ad-service companies and Symphony-served ads online by using the National Advertising Initiative’s Opt-Out Tool (http://optout.networkadvertising.org/?c=1) or the Digital Advertising Alliance’s (DAA) About Ads Opt-Out Tool (http://www.aboutads.info/choices/). In addition, your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies on our Site by taking the steps outlined below.

  • First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the website may not work properly.
  • Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies, visit http://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers.

We may use third-party service providers to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.

Do Not Track. Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

  1. Your Privacy Rights and Choices
  2. International Transfers
    Our Site and Services are intended to audiences in the United States only. If you are not a resident of the U.S. and you engage with our Services, your personal information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer the data, including personal information, to United States and process it there.

We transfer your personal information subject to appropriate safeguards as permitted under the data protection laws, including: (i) through the use of standard contractual clauses approved by an appropriate regulatory authority, such as the European Commission or the U.K. Information Commissioner’s Office; (ii) an Article 49 derogations in specific situations; or (iii) any other compliant transfer mechanism.  We may also rely on an adequacy decision of the appropriate regulatory authority confirming an adequate level of data protection in the jurisdiction of the party receiving the information. We will take all the steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice and no transfer of your personal information will take place to an organization or a country unless there are appropriate safeguards in place as required under the applicable data protection laws, and to ensure the security of your personal information maintained. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Services.

  1. Additional Information for California Residents
    The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, grants California consumers certain rights in their personal information. These rights, and how to exercise them, are described above in the Your Privacy Rights and Choices Section. As part of these rights, you have the right to know the categories of personal information that we have collected and disclosed.

We have collected and disclosed the following categories of personal information about California residents:

  • Identifiers (such as name, postal address, and Internet Protocol (IP) address);
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
  • Customer Records Information (such as name, address, and credit card or debit card number);
  • Protected classification characteristics under California or federal law;
  • Internet or Other Electronic Network Activity Information (such as information regarding a consumer’s interaction with our website);
  • Professional or Employment-Related Information; and
  • Visual information, specifically photographs.

We disclose the categories of personal information listed above to our service providers in connection with the products and Services we provide to our customers.  We also disclose the categories of personal information listed above to obtain quotes or proposals or to underwrite insurance.

For more information about how we collect, process, and disclose your personal information, please refer to the “Personal Information We Collect”; “How We Collect Personal Information”; “How We Use Your Personal Information”; and “Sharing and Disclosure of Your Personal Information” sections above.

We do not process your sensitive personal information to infer characteristics about you.

We do not knowingly process personal information of individuals under the age of 16.


  1. Third-Party Links
    Please note that our website may contain links to third-party websites. These links are intended for your convenience only. These third-party websites and services are not related to Symphony and may have separate privacy policies and data collection practices. We have no responsibility for the third-party websites or their privacy practices and encourage you to read the privacy policies of all websites you visit.
  2. Contact Us
    If you have any questions or complaints about this Notice, or about our data privacy or security policies in general you may contact us by mail at, Attention: Privacy Officer, 2425 N. Central Expressway, Suite 900, Richardson, TX 75080 or by telephone at 1-972-202-3945, or by email at privacy@symphonyrisk.com.