Effective Date: November 1, 2021
We refer to the above website and all related websites as “sites” and to each of them as a “site.” When we refer to “we,” “us,” or “our,” we mean Symbeo, or any affiliate that operates a site, provides its content, or processes information received through it, each as appropriate and applicable. When we refer to “you” or “your,” we mean the person accessing the site. If the person accessing the site does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization.
Business information. We collect your business contact information, such as your full name and your business name, email address, telephone number, address and other work-related information you provide to us in the course of providing our Services to you or your organization.
We take your privacy and the protection of your personal information seriously. We will only store, process and disclose your personal information in accordance with applicable law. We will make it clear when we collect personal information and will explain what we intend to do with it. We do our best to protect your privacy through the appropriate use of information security measures.
Symbeo may collect personal information about you either directly from you, your Connected Device, and from select external sources.
1. CATEGORIES OF PERSONAL INFORMATION THAT WE COLLECT
The following categories of personal information are provided to help you better understand the information we may collect directly from you, either through your use of the sites (including from your mobile and/or other Internet connected devices (“Connected Device”)) or in the course of us providing our Services from our customers and service providers.
We may collect, use, store and process different kinds of personal information about you, which we have grouped into the following categories:
2. INFORMATION THAT WE RECEIVE from select external PARTNERS
We may receive information about you from our customers, if, as an example, your employer utilizes our Services. We may also utilize select and vetted service providers that give us information about you relevant to our Services. These service providers may include our data analytics providers.
We may receive information about you when you access our sites through external platforms, such as Facebook. If you use our sites on or through an external platform, including via your Connected Device, or click on external links, the collection, use, and disclosure of your information and your use of the sites will also be subject to the privacy policies and other terms of such external parties and platforms. You should review such privacy policies, terms and other agreements.
3. COLLECTION OF TECHNICAL INFORMATION AND USAGE INFORMATION
When you access Symbeo’s sites, we automatically collect certain information. This information may include without limitation: (a) technical information about your Connected Device, such as your IP address, geolocation information, device type, operating system type and version, unique device ID, browser, browser language, domain and other systems information or platform types (collectively “Technical Information”); and (b) usage statistics about your interaction with Symbeo’s sites, including pages accessed, referring website address(es) time spent on pages, pages visited, search queries, click data, date and time and other information regarding your use of Symbeo’s sites (collectively “Usage Information”).
We may use information about you for a number of purposes, including:
1. Providing, Improving And Developing Our Services
2. Communicating With You About Our Services
3. Protecting Our Services And Maintaining A Trusted Environment
4. Advertising And Marketing
5. Other Uses
1. We Do Not Sell Your Information
We do not sell your personal information nor the personal information of minors under sixteen (16) years of age to third parties.
2. When And How We May Share/Disclose Your Information With Our Service Providers and Customers
We require all service providers to respect the security of your personal information. We do not allow our service providers to sell personal information or to use your personal information for their own purposes. All of our service providers are only permitted to process your personal information in accordance with our instructions and solely for the reasons for which we disclosed it to them..
3. Corporate Transactions
4. Disclosure Of Information For Legal Purposes
Symbeo may disclose all or part of your personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating any agreement with Symbeo, or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of our sites, or anyone else that could be harmed by such activities. We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, legal process or other law enforcement measures. Symbeo may disclose or access personal information when we believe in good faith that the law requires it, to establish our legal rights or to defend against legal claims, and for administrative and other purposes that we deem necessary to maintain, service and improve our Services.
5. Analytics And Data Enrichment Services
We use external analytics such as Google Analytics to help understand your usage of our sites and to improve our Services.
6. Aggregated, Anonymized Or De-identified Information
We may disclose or use aggregated, anonymized or de-identified information for any purpose. Aggregated, anonymized or de-identified information is information that can no longer reasonably identify a specific individual. Although such information may be derived from your personal information, it can no longer directly or indirectly reveal your identity.
Like many online platforms, Symbeo and its analytics vendors use server logs and automated data collection tools, such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytics purposes to enable Symbeo to understand how users interact with the sites and Services. Symbeo and its analytics vendors may tie the information gathered by these means to the identity of users.
Cookies are small text files placed on a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about user activities. Symbeo uses both session cookies and persistent cookies.
Session cookies are used to identify a particular visit to Symbeo’s sites and collect information about your interaction with the sites. These cookies expire after a short time or when the user closes their web browser after using the sites. Symbeo uses these cookies to identify a user during a single browsing session, such as when you log into the sites. This helps Symbeo improve the sites and Services as well as improve the users’ browsing experience.
A persistent cookie will remain on a user’s device for a set period of time specified in the cookie. Symbeo uses these cookies to identify and recognize a specific user over a longer period of time. They allow Symbeo to:
Examples of persistent cookies include: (i) preferences cookies to remember information about a user’s browser and settings preferences, such as preferred language – preference cookies make a user’s experience more functional and customized, (ii) authentication and security cookies to enable a user to log in or stay logged in to access the sites and Services, to protect user accounts against fraudulent log-ins by others and to help detect and protect against abuse or unauthorized usage of user accounts and (iii) functional cookies to make the experience of using the sites and Services better, like remembering the sound volume level selected by the user.
Symbeo uses tracking technology to: (i) determine if a certain page was visited or whether an email sent by Symbeo was opened or clicked on by a user; and (ii) to customize the experience of individual users by recommending specific content.
We also use clear gifs in HTML-based emails sent to our users to track which emails are opened and clicked on by recipients. We may use the information we obtain from the cookie in the administration of the sites, to improve the usability of the sites and for marketing purposes. We may also use that information to recognize your computer when you visit our sites, and to personalize our sites for you.
Cookies and information captured through our sites are stored for a certain retention period, however you can eliminate these cookies any time before the expiration date. Below is our TABLE OF COOKIES.
You can adjust the settings in your browser in order to restrict or block cookies that are set by the sites (or any other website on the Internet). Your browser may include information on how to adjust your settings. Alternatively, you may visit www.allaboutcookies.org to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers. This site also explains how to delete cookies from your computer.
You can control and delete these cookies through your browser settings through the following:
Or you can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout.
Please be aware that restricting cookies may impact the functionality of the Services. Most browsers allow you to refuse to accept cookies. Additional general information about cookies, including how to be notified about the placement of new cookies and how to disable cookies, can be found at www.allaboutcookies.org.
For instance, information collected through Google Analytics is shared with Google and its partners who may combine it with other information you provided to them or they collected from your use of their services. This information is stored in Google’s servers according to their privacy practices.
We may collect information from other sources, such as social media platforms that may share information about how you interact with our social media content. We do not control how your personal information is collected, stored or used by third-party websites or to whom those websites disclose your information. You should review the privacy policies and settings on any social media website that you subscribe to so that you understand the information they collect and may be sharing. If you do not want your social media websites to share information about you, you must contact that website and determine whether it gives you the opportunity to opt-out of sharing such information. Symbeo is not responsible for how these third-party websites may use information collected from or about you.
We generally retain your information as long as reasonably necessary to provide you the Services or to comply with applicable law and in accordance with our document retention policy. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal requirements. We may retain copies of information about you and any transactions or Services you have used for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce other applicable agreements or policies or to take any other actions consistent with applicable law.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. This allows the specific information collected (name, email, address, phone number, etc.) to become anonymous, but allows Symbeo to keep the transaction or engagement data. For example, Symbeo will not be able to tell if John Smith registered for an event, but we will be able to tell that a person registered for an event and maintain headcount and transactional history. This will allow Symbeo to maintain a level of information that helps us develop and improve our sites and Services.
You may opt-out of receiving marketing and promotional messages from Symbeo, if those messages are powered by Symbeo, by following the instructions in those messages. If you decide to opt-out, you will still receive non-promotional communications relevant to your use of our Services.
The Children’s Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13. It is our policy to refrain from knowingly collecting or maintaining personal information relating to any person under the age of 18. If you are under the age of 18, please do not supply any personal information through the sites. If you are under the age of 18 and have already provided personal information through the sites, please have your parent or guardian contact us immediately using the information provided under CONTACT US so that we can remove such information from our files.
We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We hold information about you both at our own premises and with the assistance of service providers. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please feel free to contact us directly using the information provided under CONTACT US . To ensure that our employees comply with our privacy policies, we have developed a training program that provides all employees with the tools and knowledge to protect your personal information in all aspects of their work. Any employee who violates our privacy policies is subject to disciplinary action, including possible termination and civil and/or criminal prosecution.
The California Consumer Privacy Act (“CCPA”) permits residents of California to have the following additional rights. For more information, or if you have questions, you can contact us using the information provided under CONTACT US. For your protection, before Symbeo can respond to your request, Symbeo may be required to collect certain information from you to verify your identity. This may include asking for your full name, aliases, current home addresses or alternative e-mail address. The information you provide to verify your identity will only be used for verification purposes, and a record of your request, including certain information contained within it, will be maintained by Symbeo for its files.
1. California Residents Have The Right To Request Symbeo Disclose What Information It Collects, Uses And Discloses
California residents have the right to request that Symbeo disclose what personal information Symbeo collects, uses and discloses about them. The general categories of personal information Symbeo collects about California residents are listed above under WHAT INFORMATION WE COLLECT. If you are a California resident and would like to request the specific personal information that Symbeo collects, uses and discloses about you, please complete this REQUEST FORM and send it to Symbeo using the information provided under CONTACT US or contact Symbeo at the toll-free number provided in this Policy.
2. California Residents Have The Right To Request The Deletion Of Their Personal Information Maintained By Symbeo
California residents have the right to request that Symbeo delete the personal information Symbeo maintains about them. Symbeo will make every effort to comply with California residents’ requests to delete their personal information, however, certain laws or other legal requirements might prevent some personal information from being deleted. If you are a California resident and would like to request the deletion of your personal information, please complete this REQUEST FORM and send it to Symbeo using the information provided under Contact Us or contact Symbeo at the toll-free number provided in this Policy. To verify any request to delete personal information, you will be required to provide the information contained in the REQUEST FORM. Failure to do so could result in Symbeo’s inability to comply with your request.
3. California Residents Have The Right To Non-Discrimination For The Exercise Of Their Privacy Rights Under The CCPA
Under the CCPA, California residents have the right not to receive discriminatory treatment by Symbeo for the exercise of their privacy rights. However, the exercise of certain privacy rights by California residents will make it so that Symbeo is no longer able to provide those residents with certain services. For example, if, at the request of a California resident, Symbeo deletes all of the California resident’s personal information that it maintains, Symbeo will no longer be able to send marketing communications to that California resident.
4. California Residents Have the Right to Opt-Out of the Sale of The Personal Information
Under the CCPA, California residents can request that a company stop selling their personal information. However, as described above, Symbeo does not sell your personal information.
5. California Residents Can Designate An Authorized Agent To Make A Request Under The CCPA On Their Behalf
California residents can designate an authorized agent to make requests under the CCPA related to the residents’ personal information. Symbeo can deny any request made by an agent who does not submit proof that he or she has been authorized by the California resident to act on the California resident’s behalf. For more information on submitting a request on behalf of a California resident as an authorized agent, you can contact us using the information provided under CONTACT US.
6. Do Not Track
Attention: Privacy Officer
111 SW Fifth Ave., Suite 200
Portland, OR 97204
Toll-Free Number: 855-872-6674
The Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the European Union General Data Protection Regulation (“GDPR”) imposes requirements regarding the collection, use, and disclosure of personal data in relation to our commercial activities, as does private-sector privacy legislation in their local jurisdictions, provinces and territories.
THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL DATA ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH A SITE OR OTHERWISE).
1. Personal Data
In this International Policy, personal data is as defined by applicable European Union and Canadian law. It generally means any information about an identifiable individual. It may include your name, age, mailing address, residential and cellular phone number, or e-mail address, personal history (including financial and credit information, personal health information, billing history, personal family and relationship matters, and penal or criminal information), personal information related to corporate involvements, work experience (past and present), discipline, income and benefits, medical records, tax records and security clearances.
2. Collection Of Personal Data
We collect personal data from the site(s), as well as through correspondence, faxes, live chats, e-mails, telephone inquiries, web forms, and other means of communication. We collect such information when we provide our services to you and our customers.
We (our affiliates and authorized service providers) may collect, store and use the information discussed above in WHAT INFORMATION WE COLLECT.
We also may collect information about your computer and your visits to the site(s) such as your IP address, geographical location, browser type, domain names, referring website addresses, access times, length of visit and number of page views. We may use this information in the administration of the site(s), to improve the usability of the site(s), to provide better service, to send you newsletters, updates, marketing communications, and other information or that may be of interest to you. We also use outside services such Google Analytics to gather data about visitors to our site(s). We may sometimes permit our authorized service providers to have access to aggregate statistics about our customers, sales, traffic patterns, usage and related information.
We often collect personal data from you or from external partners and as agents on behalf of external partners, where we have obtained the requisite consent to do so or as otherwise permitted by law. These external partners include, as examples, organizations for whom we provide services to you or on your behalf, and organizations that perform outsourcing and other services for us (such as payment processors, warranty and other service organizations, and systems development and maintenance organizations).
As appropriate, where we collect, use, or disclose your personal information in the course of our commercial activities or where we are the Data Controller with regard to that data, you may exercise your rights as data subject, including the right to object to the processing of your personal data when it is processed based on legitimate interests as provided in this International Policy below.
3. How We Use Personal Data
As a general matter, we collect your personal data primarily to provide services to our customers, for administrative or management requirements and to enhance our relationship with customers.
Symbeo collects and uses your personal data to operate its site(s) and deliver the Services you have requested and provide Services to our customers.
Symbeo may also use your personal data to inform you of other products or services available from Symbeo and its affiliates.
Symbeo does not sell, rent or lease its customer lists to third-parties.
Symbeo 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, your personal data (e-mail, name, address, telephone number) is not transferred to the external business partner. Symbeo may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such service providers are prohibited from using your personal data except to provide services to you, and they are required to maintain the confidentiality of your data.
Symbeo may keep track of the websites and pages our users visit within Symbeo, in order to determine what Services are the most popular. This data is used to deliver customized content and advertising within Symbeo to customers whose behavior indicates that they are interested in a particular subject area.
Symbeo will disclose your personal data, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Symbeo or the site; (b) protect and defend the rights or property of Symbeo; and, (c) act under exigent circumstances to protect the personal safety of users of Symbeo, or the public.
4. The Basis On Which We Process Your Personal Data
As allowed by the applicable international law, we rely on the following legal grounds to process your personal data, namely:
We will only process personal data for a specific purpose or for any other purposes specifically permitted by applicable data protection legislation.
5. Obtaining Consent
Except when otherwise permitted by law, we obtain the requisite consent prior to collecting and, in any case, prior to using or disclosing your personal data for any purpose. You may provide your consent to us orally, in writing, by electronic communication or any other means reasonably capable of conveying your consent or we may obtain your consent through our customers (e.g., your employer) who has lawfully obtained your consent. We will obtain your express consent if we collect, use or disclose sensitive personal data in our capacity as a Data Controller. We may also share data with external partners for whom you have given us consent. Your consent may also be intrinsic to the circumstances such as in the case where you have already provided personal data to us and you maintain your relationship with us or where you provide our representatives with your phone number so that we can contact you. Except when otherwise permitted by law, we will only use the data for the purpose for which it was given.
When your consent is required, you may withdraw your consent at any time (unless withdrawing the consent would frustrate the performance of legal obligations) upon providing to us a 30-day notice. However, the withdrawal of your consent may adversely affect our ability to provide Services to you and to maintain our relationship.
6. Service Providers
We remain responsible for all personal data communicated to our service providers for processing related to our Services. As such, we ensure that service providers that are engaged to provide products or services on our behalf and are provided with personal data are required to observe the intent of this International Policy by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclosure the personal data for any purpose other than the purpose for which the personal data was communicated.
We only collect the personal data necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.
We do not use or disclose your personal data, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.
We do not, as a condition of providing services to you or on your behalf, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal data beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law.
8. Retention Of Personal Data
We may keep a record of your personal data, including correspondence or comments, in a file specific to you. We will utilize, disclose, or retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We have established minimum and maximum retention periods and procedures for maintaining and destroying your personal data. When personal data is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal data retention policies.
9. Access And Rights To Your Personal Data
If you are located in Canada, PIPEDA provides you the rights of access, rectification, restriction or objection in line with the type of services being provided. For example, subject to the exceptions provided by the applicable law, we will make available to you any of your personal data that we have collected, utilized or disclosed, upon your written request.
If you are located in European Economic Area (“EEA”), the GDPR provides you the rights of access, rectification, erasure, restriction, objection or portability in line with the type of services being provided. For example, subject to the exceptions provided by the applicable law, we will make available to you any of your personal data that we have collected, utilized or disclosed, upon your written request. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes and using an alternative format, if required.
Simply send your request, using the REQUEST FORM provided, to the Privacy Officer listed below. Please be as specific as possible in your request so that we can meet the applicable time lines.
If you are located in the EEA, you also have the right to lodge a complaint to your Supervisory Authority.
10. Response Times
We will make every reasonable effort to respond to each of your written requests not later than 30 days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority with respect to this time limit.
We expect to be able to respond to your request without charge as a general matter. However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction or transmission of such information. We will notify you, following your request for transcription, reproduction or transmission of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.
12. Identifying You In Connection With Requests
We may require that you provide to us sufficient information to identify yourself before we provide information about the existence, use or disclosure of your personal data in our possession. Any such information shall be used only for this purpose.
13. Opt-Out And Unsubscribe
We respect your privacy and give you an opportunity to opt-out of receiving certain information. Users may opt-out of using the instructions located in e-mails sent by Symbeo or by contacting us using the information under Contact below.
We will use reasonable efforts to ensure that your personal data is kept as accurate, complete and up-to-date as possible. We will not routinely update your personal data, unless such a process is necessary. In order to help us maintain and ensure that your personal data is accurate and up to date, you must inform us, without delay, of any change in the data you provided to us.
You can at any time, challenge the accuracy or completeness of the personal data we have about you, subject to the exceptions provided by applicable law. If you demonstrate that the personal data we have on you is inaccurate or incomplete, we will amend the personal data as required. Where appropriate, we will transmit the amended data to source providers to whom we have previously communicated your personal data.
We use security safeguards appropriate to the sensitivity of personal data to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption.
Attention: Privacy Officer
111 SW Fifth Ave., Suite 200
Portland, OR 97204
Type of Cookie and Purpose
This cookie implements anti-forgery measures for web form submissions.
This cookie manages visitors’ web sessions to ensure a smooth browsing experience.
This cookie allows proper handling & routing of the website request from the host.
These cookies allow us to measure the number of Visits to the website and hence understand the Customer’s website experience and segment visitors who are new to the site from those who are returning. This cookie tracks the visitors’ behavior such as visits and interactions with the site.
The information collected is used for analytical and advertising purposes.
These cookies allow us to understand visitors’ activity on this site and integrate that information with various internal Marketing campaigns.
These cookies allow us to verify that visitors’ web browsers meet the minimum requirements to provide a positive user experience.
These cookies store bandwidth measurement and visitors’ preferences for YouTube video playback.