Effective April 1, 2018

Privacy Policy

We at Symba, Inc. (“Symba,” “we,” and “us”) respect your privacy and are committed to protecting it through our adherence to this Privacy Policy (the “Policy”).

This Policy describes the types of information we may collect from you when you use our website located at https://symba.io/ and any of our other websites, their respective subdomains, and any of our applications containing a link or reference to this Statement (collectively, our “Platform”), or from other sources. The Policy explains how we may use, maintain, and disclose that information, as well as ways in which you may control the information. We hope that reading our Policy helps you understand how we manage information about you and the measures we take to protect it.

By using the Platform, you agree to the terms of this Policy, so please do not use the Platform if you do not agree with these terms.  We may update this Policy at any time.  Any changes to the Policy will become effective upon the date of our posting of the revised Policy on the Platform.  If you use the Platform following the effective date of the revised Policy, you will be deemed to have accepted the Policy’s updated terms, so we encourage you to check the Policy periodically as you continue to use the Platform.

Data We Collect

When you visit and use our Platform, we may ask you to provide certain data about yourself, and we also may collect data from your computer or device as you use our Platform and interact with us.  Some of this data may be what we consider “Personal Data”:  any data that identifies you or that we can link to other information that identifies you.  The information that we collect through your computer or other device that you use to connect with the Platform is generally not Personal Data.

If you create a user account on the Platform as a manager, administrator, or intern, you will need to provide your first and last name, your company-provided email address, your hometown city, the college or university you attend(ed), your department at the company and your role or job title at the company.  At your discretion, you also can share public links (URLs) to your social media profiles, such as on Facebook, Instagram, and LinkedIn.  We also will collect data you provide to us to receive technical assistance or during customer service interactions.

We may engage third parties to collect data about you, such as vendors who provide intake forms on our Platform into which you submit your Personal Data.  We make reasonable efforts to verify that the third parties we engage for data-collection purposes are reputable and law-abiding and we will not solicit them to disclose to us any data that they or we not have a lawful purpose to collect and process.  For example, we use Google Analytics to collect information on Platform usage.   Google Analytics places cookies on our Platform so that we can learn how users are navigating the Platform.   A cookie is a commonly used automated data-collection tool.  Cookies are small text files that are placed on your computer or device by websites that you visit or HTML-formatted emails you open, to make websites work, or work more efficiently.   The date we or Google Analytics may collect about Platform usage includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, pages visited, length of visit, operating system, date/time stamp, and/or clickstream data.

The Platform does not currently respond to a “Do Not Track” browser signal from a user.

How We Use Your Personal Data

We use your Personal Data for the purposes outlined below on the following grounds:

If we enter into a contract with you, to fulfill the terms of the contract, which might include:

– Creating and managing any Symba account you choose to create;
– Verifying your identity and entitlement to the Platform, when you contact us or access our Platform;
– Providing you with technical and customer support.

On the basis of your consent, in order to:

– Subscribe you to marketing emails, send Platform updates or technical alerts;
– Send you marketing communications and information about our Platform;
– Communicate with you about, and manage your participation in, your internship program; or
– Solicit your opinion or feedback.

On the basis of our legal obligations, such as to keep records for tax purposes or to answer orders to compel or provide information upon lawful request to public authorities.

On the basis of our legitimate interests in the effective delivery of our Platform and communications to you as well as to our other customers, such as to:
– Evaluate and improve the performance and quality of our Platform;
– Provide you with a customized experience when you visit our Platform;
– Secure our systems and applications, including to detect, block, or mitigate cyber-threats ;
– Allow for the provisioning of services; and
– Enforce our legal rights.

When and With Whom We Share Your Personal Data

Other Platform Users. 

If you create a user account on the Platform, the Personal Data you provide, or the company you are working with provides, that Personal Data will be accessible through the Platform to your company’s managers and administrators.

Service Providers

We may share Personal Data with unaffiliated third-party contractors who provide us with services, such as providers that assist us with email administration, surveys, analytics, data storage, data analysis, or similar services.

Public Authorities

In certain instances, we may be required to disclose your Personal Data to public authorities or as otherwise required by applicable law.  For example, we might need to disclose your Personal Data in response to:

• A subpoena, warrant or other process issued by a court or other public authority of competent jurisdiction;
  • A legal process having the same consequence as a court-issued request for the data;
  • Where such disclosure is necessary for Symba to enforce its legal rights pursuant to applicable law;
  • A request for data with the purpose of identifying and/or preventing fraud; or
  • Where such disclosure of Personal Data is necessary to prevent or lessen a serious and imminent threat of bodily or other significant harm to the data subject or other individuals potentially concerned.

Company Reorganization

If we are involved in a reorganization, merger, acquisition or sale of our assets, your Personal Data may be transferred as part of the diligence for and the execution of the transaction.

We do not sell, lease, or rent your Personal Data to third parties, and we do not share it with unaffiliated third parties for them to use in marketing their own products or services to you. 

Cross-Border Transfers of Personal Data

If you are located in a jurisdiction outside of the United States, you should be aware that the Personal Data you provide to us will collected by us in the United States, and that the data protection laws in the United States may not protect your Personal Data in the same way as the laws of your jurisdiction.  We also may, as part of our business, receive Personal Data in the United States from third parties located worldwide.  All transfers will be conducted to comply with the data transfer requirements of applicable laws and regulations.

How We Protect Your Personal Data

We take reasonable measures in accordance with applicable laws to help ensure that the Personal Data in our possession is adequately protected against accidental or unlawful destruction, damage, loss or alteration, unauthorized or unlawful access, disclosure or misuse, and all other unlawful forms of processing.  You should be aware that no Internet transmission is ever fully secure or error-free. In particular, e-mail transmissions may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Moreover, where you use passwords, user IDs, or other special access features on the Platform, it is your responsibility to safeguard them from disclosure or misuse.

Links to Other Websites

Our Platform may contain links to websites owned or operated by entities unaffiliated with Symba. If you choose to visit any linked third-party websites, we encourage you to review the privacy policies on those websites carefully.  If you provide Personal Data through any such third-party website, the Personal Data will be collected by, and controlled by the privacy policy of, that third party. We are not responsible for the content or privacy practices of websites that are owned by companies that are unaffiliated with Symba.

Children’s Privacy

Our Platform is not directed to, nor do we knowingly collect Personal Data from, children under 13 years of age.  If we learn that we have inadvertently collected Personal Data from a child under age 13, we will delete it.  Please inform us if you believe we have collected any Personal Data from a child under age 13. 

Our Retention of Personal Data

We will retain Personal Data about you on our systems for the longest of the following periods: (a) as long as necessary to maintain our ongoing business relationship, or as needed to provide you with the Platform or information which you are entitled to or can otherwise reasonably expect to receive from us; (b) as long as necessary for the purpose for which we collected it or for which you supplied it to us in accordance with any Platform relevant activity or process; (c) any retention period that is necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements; or (d) the end of the period in which litigation or investigations might arise in respect of our business relations or other interactions with you.

Your Privacy Rights

Depending on where you are located and the laws applicable in that jurisdiction, you may have the right:

1. a) to ask us to provide you with information regarding the Personal Data we process concerning you;
2. b) to rectify, update or complement inaccurate or incomplete Personal Data concerning you;
3. c) to delete or request the erasure of Personal Data concerning you;
4. d) in certain circumstances, to limit the way in which we process Personal Data concerning you;
5. e) to withdraw any consent you may have given for us to process Personal Data concerning you;
6. f) to object to our processing of Personal Data concerning you;
7. g) to have your Personal Data held by us be portable; and
8. h) if you are located in the European Economic Area, to lodge a privacy complaint with a supervisory authority if you are unhappy with the way we have handled your Personal Data or any privacy query or request that you have raised with us. Where your exercise of any of the rights above is dependent on Symba’s action, we will abide by our legal obligation to take reasonable measures to ascertain your identity and the legitimacy of your request, and may ask you to disclose to us any information necessary for that purpose. We will respond to legitimate request within 1 (one) calendar month or 31 (thirty-one) calendar days (whichever is longer). In certain limited circumstances, we may need to extend our response period as permitted by applicable law. Pursuant to any such requests, we may retain certain data necessary to prevent fraud or future abuse or as otherwise required or permitted by law, including to comply with legal obligations we are subject to, as well as to establish, exercise and defend our legal claims.

Communication Choices

You may update your email preferences or unsubscribe to our general marketing communications via the unsubscribe link at the bottom of any Symba email.

Contact Us

To exercise any of your rights, or if you have any other questions or complaints related to this Policy or our use of your Personal Data, please contact us:

Symba, Inc.
Four Embarcadero Center, Suite 1400, San Francisco, CA 94111
Email Us: support@symba.io