California Privacy Policy

CALIFORNIA WEBSITE PRIVACY POLICY (this “Privacy Policy”)

Siris Capital Group, LLC (“Siris”, “we”, “us”, or “our”) is committed to protecting the privacy of personally identifiable information (“PII”) of residents of California who visit https://siris.com/ (the “Site”) and inquire about or use services associated with our business (the “Services”) available through the Site, or express interest in our business. This Privacy Policy contains disclosures required by the California Consumer Privacy Act (the “CCPA”). This Privacy Policy is only relevant to residents of California and applies only to the collection or other use of “personal information” that is subject to the CCPA.

The privacy of your PII is important to us at Siris. This Privacy Policy discloses the privacy practices for Siris and for the Site, and localized versions of the Site, including the type of PII collected and tracked, how the information is used, and with whom the information is shared.

In order to provide you with services you may request, it is necessary for us to possess some PII of yours. This Privacy Policy explains our PII policies and practices for California residents. It includes, but is not limited to, explanations of the types of PII we may collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, your rights regarding your PII, and the way to contact us to exercise those rights.

Amendments to this Privacy Policy will be posted to the Site and will be effective when posted. Your continued use of the Site or any Services following the posting of any amendment to this Privacy Policy shall constitute your acceptance of such amendments.

Types of Information We Collect

This section explains the PII that may be collected when using the Services, and the other information we may receive from other sources. Some examples are listed below:

  • contact details, such as name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, passport number, or other similar personal identifiers;
  • background information, such as description, age, race, citizenship, marital status, sex, veteran or military status, education, employment, or employment history;
  • usernames and passwords;
  • feedback submitted to Siris for support;
  • interests and communication preferences including marketing permissions where appropriate;
  • internet or other similar network activity, such as browsing history, search history, or application usage; and
  • investment documentation, such as financial information, wire transfer instructions, assets, income, and other details (as needed).

Restricted Use Regarding Minors

This Site is not intended or designed to be used by minors under the age of 18. We do not collect PII from any person we know to be under the age of 18 and instruct minors under 18 not to send us any information.

Purposes for Collecting Your PII

When you provide PII to Siris in order to fulfill a Service, you are entering into a business relationship with Siris and are agreeing to the use of that data by Siris and its applicable worldwide affiliated companies, as stated in this Privacy Policy. We request PII for a variety of purposes throughout your interaction with Siris, some of which are listed below:

  • contacting you or your designated representative by phone, email, fax, or mail;
  • providing you or your representative with marketing communications;
  • creating and managing your account with us;
  • sharing information about the Services;
  • facilitating financial transactions related to your account;
  • fulfilling any legal and regulatory obligations;
  • the performance of obligations under any applicable agreements;
  • ongoing communication with you and/or your designated contacts;
  • the ongoing administrative, reporting and other processes and communication required to operate the business in accordance with its agreements and any other applicable documentation; or
  • any other purpose that has been notified, or has been agreed, in writing.

Our Site and Use of Cookies

We use various technologies to collect other types of information, including PII, automatically. For example, in order to measure the usefulness and efficiency of the Site, we automatically track certain information from all visitors to the Site. The types of information we might track include the Internet address that you just came from, which Internet address you go to, what browser you are using, your IP address, your internet service provider, date and timestamp information, or clickstream information.

Additionally, like most interactive web sites, we use “cookies” on certain pages of the Site. “Cookies” are small data files that are stored on your hard drive that store certain information, including certain PII, accessible to the Site, such as your password and any information content preferences you may voluntarily set at the Site. This technology helps us recognize you, customize your experience on the Site and analyze your use of the Site to make it more useful to you. By visiting the Site, you agree to our use of cookies.

We also use analytics providers, such as Google Analytics, to help us evaluate the Site. To opt-out of the aggregation and analysis of data collected about you on the Site by Google Analytics, visit https://tools.google.com/dlpage/gaoptout and download and install the Google Analytics Opt-out Browser Add-on.

Sharing Your PII

Receiving PII from Third Parties

Siris may receive information about you from other sources and combine that information with the PII we collect directly from you. Additionally, to promote the protection of your identity, we also may collect identity information that we use to help prevent and detect fraud.

Sharing PII with Third Parties
Siris will not sell your PII. We may share your PII with our affiliates, business partners, and other third parties. We may do so for the purposes of operating our business, delivering and improving the financial services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending marketing and other communications related to our business or in response to a request from law enforcement, government authorities, or other third parties as necessary to comply with legal process or to meet national security requirements.

Your Personal Data Rights under the CCPA

If you are an individual who resides in California and whose personal data is collected and processed by Siris, you may have the right to:

  • Request that we disclose, free of charge, the categories and specifics of the PII we collect about you (and/or, if applicable, sell or otherwise disclose to a third party for business purposes).
  • Choose to opt-out of the sale of personal information. Currently, however, Siris does not sell personal information.
  • Request that we delete the PII we have collected about you. Following our verification of your request, we will comply with the request and delete any or all the PII in our possession that we collected from you and/or any or all such PII in the possession of our service providers unless otherwise restricted by law or regulation.

Please note that the rights under the CCPA do not apply to PII collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act (Public Law 106-102) and the Fair Credit Reporting Act (12 CFR 1022).

Non-Discrimination for Exercising Your PII Rights

We follow the requirements of California Civil Code §1798.125 and will not discriminate against any consumer who exercises the rights set forth in this Privacy Policy.

Questions or Concerns and Exercising Your PII

If you have any questions or concerns regarding the information in this Privacy Policy or would like to exercise any of your rights set forth in this Privacy Policy, please email us at compliance@siris.com or call at 212-231-0095.

Changes to this Privacy Policy

From time to time we may update this Privacy Policy. This Privacy Policy was posted on February 3, 2020.