Introduction

Symphony Service Corp. (the “Company”, “we”, “us” or “our”) believes in protecting your privacy. When we collect personal information from you in connection with the performance of telecommunications expense management services, call detail recording services and/or the performance of telecommunications expense audits, we follow the privacy principles (“Safe Harbor Principles”) and comply with the U.S.-EU Safe Harbor Framework developed by the U.S. Department of Commerce and the European Union regarding the collection, use and retention of personal data from the European Union. For more information about the Safe Harbor program, please visit the U.S. Department of Commerce’s website at http://www.export.gov/safeharbor/. This privacy policy outlines our general policy and practices for implementing the Safe Harbor Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all Personal Information received by the Company whether in electronic, paper or verbal format.

Definitions

“Personal Information” or “Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individuals; and (4) can be linked to that individual.

Safe Harbor Principles

Notice

The Company collects Personal Information for the purposes of providing telecommunications expense management services, call detail recording services, and/or telecommunications expense audits. When we collect your Personal Information we shall provide you with the choice and means for limiting the use and disclosure of such Personal Information.

Choice

We will give you a choice about the ways we use and share your Personal Information as the Information is only collected and processed as authorized and directed by our clients. If you wish to opt-out of any use of your Personal Information by us, you can let us know by contacting us at safeharbor@symphonysv.com.

Onward Transfers

Prior to disclosing Personal Information to an unaffiliated third party, the Company shall notify you of such disclosure and allow you the choice (opt out) of such disclosure. The Company shall ensure that any third party to which Personal Information may be disclosed subscribes to the Safe Harbor Principles or are subject to law providing the same level of privacy protection as is required by the Safe Harbor Principles and agree in writing to provide an adequate level of privacy protection.

Data Security

The Company shall take reasonable steps to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. The Company has put in place appropriate physical, electronic and managerial procedures to safeguard and secure Personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction. These procedures include SSL encryption, high password protection protocols and staff training on security. Please note that the Company cannot guarantee the security of Personal Information on or transmitted via the Internet.

Data Integrity

The Company shall only process Personal Information that is relevant for the purposes listed under the section on “Notice”. To the extent necessary for those purposes, the Company shall take reasonable steps to ensure that Personal Information within Company’s control is accurate, complete, current and reliable for its intended use.

Access

The Company shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, as permitted under applicable laws.

Enforcement

The Company uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and in compliance with the Safe Harbor Principles. Any disputes may be resolved using an independent resource mechanism such as a third party resolution provider.

Amendments

This privacy policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on this website.

Contact Information

Questions, comments or complaints regarding the Company’s Safe Harbor policy or data collection and processing practices can be mailed or emailed to:

Safe Harbor Compliance Officer
Symphony Service Corp.
14881 Quorum Drive, Suite 800
Dallas, TX 75254
privacy@symphonysv.com
With simultaneous copy to

Symphony Service Corp.
Attn: Legal Dept.
2475 Hanover Street
Palo Alto, CA 94304
Effective date: September 14, 2009