Privacy Policy

PRIVACY POLICY

Symphony Limited (“Symphony Website” or “we” or “us” or “our”) takes the privacy of your information seriously. This Privacy Policy describes the Data we collect from you through our website, including sub-domains microsites (“Platforms”).It also describes the purposes for which we collect that personal information, the other parties with whom we may share it and the measures we take to protect the security of your data. It also tells you about your rights and choices with respect to your personal information, and how you can contact us about our privacy practices.
This Privacy Policy (hereinafter called as “Policy”) is published in accordance with Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information or Data) Rules, 2011 read together with Rule 3(1) of the provisions of Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
You are advised to carefully read this Policy before using or availing any of the products and/or services offered on our Platforms.

This Policy is published in compliance with: – Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, read together with Rule 3(1) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, Digital Personal Data Protection Act, 2023 (“DPDP Act”).

 

DEFINITIONS

In this Privacy Policy, the following definitions are used:

• Cookies shall mean and include a small file placed on your device by our Platforms when you either visit or use certain features of our Platforms. A cookie generally allows a website to remember your actions or preference for a certain period of time.
• Data shall mean and include non-personal information, personal information and sensitive personal information about you, which either directly or indirectly in combination with other information, could allow you to be identified when you visit our Platforms.
• Data Protection Laws shall mean any applicable law for the time being in force relating to the processing of Data.
• Partners shall mean and includes selected third parties with whom we have contracts for the businesses described in this Policy.
• Service Providers shall mean and include entities to whom we may disclose your Data in order to process information for a specific purpose pursuant to written contract.
• Symphony Limited shall mean Symphony Limited, a company incorporated in India whose registered office is at Symphony House, FP12-TP50 Sarkhej - Gandhinagar Highway, Bodakdev, Ahmedabad, Gujarat 380059.
• User or you shall mean the natural person who accesses our Platform.

WHAT DATA DO WE COLLECT ABOUT YOU

• We collect Data for various purposes set out in this Policy.
• This Data may include, without limitation, the following categories:
• Contact information: first and last name, email address, postal address, country, company name, phone number and other similar contact data.
• Financial information: payment instrument information, transactions, transaction history, preferences, method, mode and manner of payment, spending pattern or trends, and other similar data.
• Technical information: website, device and mobile app usage, Internet Protocol (IP) address and similar information collected via automated means, such as cookies, pixels and similar technologies.
• Transaction information: the date of the transaction, total amount, transaction history and preferences and related details.
• Product and service information: Your account membership number, registration and payment information, and program-specific information, when you request products and/or services directly from us, or participate in marketing programs.
• Personal information: Age, sex, date of birth, marital status, nationality, details of government identification documents provided, thumb impression, occupation, or any other personal information provided in product reviews or responses to surveys or questionnaires.
• Your reviews, feedback and opinions about our products, programs, and services.

HOW WE COLLECT DATA

We collect Data in the following ways:

• Information You Give Us:We receive and store any information you enter on our Platforms or give us in any other way (e.g., at outlets, stores, hotels, kiosks). Please see the section titled “Data Shared by You” for more information.
• Automatic Information We Collect:We use “cookies”, pixels and similar technologies to receive and store certain types of information whenever you interact with us. Please see the section below, titled “Data that is Collected Automatically” for more information.
• E-mail Communications:To help us make e-mails more relevant and interesting, we often receive a confirmation (if your device supports such capabilities) when you open e-mail from us or click on a link in the e-mail. You can choose not to receive marketing emails from us by clicking on the unsubscribe link in any marketing email.
• Automatic Information We Collect from Other Websites:We receive and store certain types of information when you interact with third-party websites that use our technology or with whom we have a specific agreement. Because we process this information on behalf of the applicable website operators, collection, processing, and use of such information is subject to the applicable website operators’ specific privacy policies and is not covered by our Privacy Policy.

You can make choices about our collection and use of your Data. For example, you may want to access, edit or remove your Data on our Website. When you are asked to provide Data, you may decline.

DATA SHARED BY YOU

We may collect your Data in several ways from your use of our Website. For instance:

• when you register with us to purchase products from our Website;
• when you conduct a transaction with us or attempt a transaction on our Website;
• when you complete surveys conducted by or for us;
• when you elect to receive any communications (including promotional offers) from us;
• from the information gathered by your visit to our Website;

If you provide Data on behalf of any corporation, company, institution, association or other entity, you represent that you are providing the same under authority from such corporation, company, institution, association or other entity.

• DATA THAT IS COLLECTED AUTOMATICALLY: We automatically collect some information when you visit on our Website. This information helps us to make improvements to our content and navigation. The information collected automatically includes your IP address.
• Our web servers or affiliates who provide analytics and performance enhancement services collect IP addresses, operating system details, browsing details, device details and language settings. This information is aggregated to measure the number of visits, average time spent on the site, pages viewed and similar information. We use this information to measure the site usage, improve content and to ensure safety and security, as well enhance performance of our Website.
• We may collect your Data automatically via Cookies, pixels and similar technologies in line with settings on your browser. For more information about Cookies, please see the section below, titled “Cookies”.

OUR USE OF DATA

Any or all the above Data may be required by us from time to time to provide information relating to Symphony and to work on the experience when using our Platform. Specifically, Data may be used by us for the following reasons:

• carry out our obligations arising from any contract entered into with Symphony and you  on the Website;
• provide products and/or services and communicate with you about products and/or services offered on our Website;
• enable Symphony Partners to offer their products and/or services and communicate with you about such products and/or services;
• processing, disclosing, transmitting, and/or sharing the data/information with Symphony, and other third parties which have business or contractual dealings with us;
• provide you with offers (including for financial products and/or services), personalized services and recommendations and improve your experience on our Website;
• operate, evaluate and improve our business and our Website;
• generate aggregated data to prepare insights to enable us to understand customer behaviour, patterns and trends with a view to learning more about your preferences or other characteristics;
• provide privileges and benefits to you, marketing and promotional campaigns based on your profile;
• communicate with you (including to respond to your requests, questions, feedback, claims or disputes) and to customize and improve our services;
• enforce the terms of use of our Website;
• protect against and prevent fraud, illegal activity, harm, financial loss and other legal or information security risks; and
• serve other purposes for which we provide specific notice at the time of collection, and as otherwise authorized or required by applicable law.

We treat these inferences as personal information (or sensitive personal information, as the case may be), where required under applicable law. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
Where required under applicable law, we will only use your personal information with your consent; as necessary to provide you with products and/or services; to comply with a legal obligation; or when there is a legitimate interest that necessitates the use.

MINORS

Our Platforms do not offer products for use by minors. If you are under 18, you may use our Website only with the involvement of a parent or guardian.

SHARING OF DATA

We may share your Data with/ for:

• Partners:We may make available to you services, products, or applications provided by Partners for use on or through our Platforms. If you choose to use such service, customer information related to those transactions may be shared with such Partner. Such Partners will be required to respect the security of your Data and to treat it in accordance with this privacy policy and applicable law.
• Providers: We may share your Data with Service Providers. Examples include storing and analyzing Data, protecting and securing our systems, providing search results and links, providing customer service, credit analysis, processing your information for profiling, user analysis and payment processing. These Service Providers will be required to only process Data in accordance with express instructions and as may be necessary to perform services for purposes set forth in this Privacy Notice. The Service Providers will also be required to safeguard the security and confidentiality of the Data they process by implementing appropriate technical and organizational security measures and confidentiality obligations binding employees accessing Data.
• Protecting Symphony Limited: We may release Data when we believe release is appropriate to comply with applicable law or legal process, enforce or apply the 
• Terms of Use of our Website and other agreements, protect Symphony Limited against harm or financial loss, when we believe disclosure is necessary to protect individuals’ vital interests, or in connection with an investigation of suspected or actual fraudulent or illegal activity. This may include exchanging information with other companies and organizations for fraud protection, risk management and dispute resolution. This does not include selling or otherwise disclosing personally identifiable information from users for commercial purposes in violation of this Privacy Policy .
• Business Transfers: As we continue to develop our business, we might sell or buy subsidiaries or business units. Your Data may be transferred as part of such transaction.
• Third Parties: We may also share your Data with other third parties where:
• You request or authorize us to do so;
• We need to comply with applicable law or respond to valid legal process; or
• We need to operate and maintain the security of our Platforms, including to prevent or stop an attack on our computer systems or networks.

We require these third parties by contract to only process sensitive personal data in accordance with our instructions and as necessary to perform services on our behalf or in compliance with applicable law. We also require them to safeguard the security and confidentiality of the sensitive personal data they process on our behalf by implementing appropriate confidentiality, technical and organizational security measures.

Please note that Symphony and its Partners may have privacy practices that differ from those of Symphony Limited. The use of your Data will be governed by their privacy statements when you provide Data on their websites.

KEEPING DATA SECURE

We will use technical and organizational measures to safeguard your Data and we store your Data on secure servers. Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us by e-mail.

RETENTION OF DATA

We retain Data for as long as necessary for the use of our Platforms or to provide access to and use of our Website, or for other essential purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements and as long as processing and retaining your Data is necessary for our legitimate interests. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly.

Even if we delete your Data, including on account of exercise of your right under the following clause viz. Your rights and Choices, it may persist on backup or archival media for audit, legal, tax or regulatory purposes.

YOUR RIGHTS AND CHOICES

When we process Data about you, we do so with your consent and/or as necessary to operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests of Symphony Limited as described in this Privacy Policy.

You may submit a request as described in the “Customer Support Team” section below. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

You may write to us for the following rights in relation to your Data:

• Right to Correction- the right to have your Data rectified if it is inaccurate or incomplete.

• Right to request deletion- the right to request that we delete or remove your Data from our systems.

• Right to Withdraw Consent– the right to withdraw your consent provided earlier.

YOUR RIGHTS UNDER THE DIGITAL PERSONAL DATA PROTECTION ACT, 2023 (DPDP ACT)

As a Data Principal (i.e., the individual to whom the personal data relates), you are entitled to the following rights under the Digital Personal Data Protection Act, 2023, subject to conditions and limitations as provided therein:

a) Right to Access Personal Data
◦ You have the right to obtain confirmation from us regarding whether your personal data is being processed. Upon such request, we shall provide you with a summary of:
◦ The nature and categories of personal data processed;
◦ The processing activities undertaken with respect to such data;
◦ The identities of any Data Processors or third parties with whom the data has been shared; and
◦ Any other information as prescribed under the Act.

b) Right to Correction and Erasure
You have the right to:
◦ Request correction or completion of any inaccurate or misleading personal data;
◦ Request erasure of your personal data where it is no longer necessary for the purpose for which it was collected, or where such retention is not required under any law for the time being in force.
◦ We shall take reasonable steps to verify your identity and assess the validity of your request before taking action.

c) Right to Withdraw Consent
◦ Where the processing of your personal data is based on your consent, you may withdraw such consent at any time by submitting a request through the designated contact details below. Upon withdrawal of consent, we shall cease further processing of such personal data unless such processing is required under applicable law or for compliance with a legal obligation.
◦ Please note that withdrawal of consent shall not affect the lawfulness of data processing based on consent prior to its withdrawal.

d) Right to Grievance Redressal
◦ In case you are dissatisfied with our response or the manner in which your request has been handled, you have the right to file a grievance. We will acknowledge and resolve your grievance within the timelines stipulated under the DPDP Act or the applicable rules thereunder.

e) Right to Nominate
◦ You have the right to nominate another individual to exercise your rights in the event of your death or incapacity. Such nomination must be made in a manner prescribed under the DPDP Act and accompanying rules.

For information about managing your Data and promotional communications, please connect with us by accessing Contact us. It is important that the Data we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold it.

WHERE WE STORE DATA

Data collected under this privacy notice is hosted on our highly secured servers having multiple levels of encryption.

PROCESSING YOUR DATA

We take steps to ensure that the Data we collect under this Privacy Policy is processed according to the provisions of this Policy and the requirements of applicable law.
To ensure that your Data receives an adequate level of protection, we have put in place appropriate written contracts with Partners and Service Providers that we share your Data with. This ensures your Data is treated by such parties in a way that is consistent with applicable law.

COOKIES, PIXELS AND SIMILAR TECHNOLOGIES

Our Platform may place and access certain Cookies on your device. Cookies are unique identifiers that we transfer to your device to enable our systems to recognize your device. We also use pixels and similar technologies to analyse traffic on our website and mobile application to improve your experience of using them. When you first visit our Platform, you might be presented with a pop-up screen informing you of our use of Cookies and asking you to provide your consent for such use. The pop-up screen may not reappear for all your subsequent visits to our Platform, but you may adjust your web browser software if you do not wish to receive Cookies or web beacons, but this may prevent you from taking advantage of some of the features of our website. Please refer to your browser instructions or help pages to learn more about these functions.

SECURITY

Symphony Limited implements standard measures to protect against unauthorized access to and unlawful interception of Data. However, no internet site can fully eliminate security risks. Symphony Limited endeavours to take all measures to protect the security, integrity and confidentiality of the Data against unauthorized breach and hacking. For the purpose of checking possible vulnerabilities and attacks, we may conduct periodical internal review of data and security measures on the Platforms. However, the internet is not absolutely a secure environment, and the Platforms cannot ensure or warrant a 100% security of the Platforms.

If you are provided with any identification code, password or any other piece of information as part of the Website’s security procedure, you should treat such information as confidential and not disclose it to any third party including to other users. You are solely responsible for the activities that occur under your account including the confidentiality of your password and we shall not be responsible for the same. Notwithstanding anything contained in this Policy or elsewhere, We shall not be held responsible for any loss, damage or misuse of the Data, if such loss, damage or misuse is attributable to a Force Majeure Event. A "Force Majeure Event"means any event that is beyond the reasonable control of Symphony Limited and includes, without limitation, fire, flood, explosion, acts of God, civil commotion, strikes, lock outs or industrial action of any kind, riots, insurrection, war, acts of government, power failure, sabotage, computer hacking, unauthorised access to computer data and storage device, system failure, virus, attacks, bugs, computer crashes, breach of security and encryption.

SEVERABILITY

If any court or competent authority finds that any provision of this Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Policy will not be affected.

CHANGES TO THIS POLICY

Our business changes constantly and our Policy will change also. This policy is subject to change without any prior notice and hence you should check our Platforms frequently to see recent changes. The updated version will be effective as soon as it is accessible. Any changes will be immediately posted on our Platforms, and you are deemed to have accepted the terms of the updated Policy on your first use of our Platform or first purchase of the products and/or services following the alterations. We encourage you to review this Policy frequently to be informed of how we are protecting your information.

HOW TO CONTACT US

To request to review, update, or delete your personal information or to otherwise reach us, please submit a request by e-mailing us at info@symphonylimited.com You may contact us for information on Service Providers and Partners  with whom we may share your Data in compliance with this Privacy Notice and applicable law. We will respond to your request within 30 days.

CUSTOMER SUPPORT TEAM:

Any queries or concerns relating to the Privacy Policy may be directed by you to our customer support team who can be contacted at:

Contact Details: Symphony Limited
Address: Symphony House, FP12-TP50, Bodakdev, Off SG Highway, 380059 Ahmedabad Gujarat, India
Email: info@symphonylimited.com
Customer Care Number: 95109 76161
(Operational days Monday-Saturday 10:00 AM – 07:00 PM)