Privacy Notice

Our Commitment to Privacy

Siris Capital Group, LLC, (“Siris”, “we”, “us” or “our”) is committed to protecting the privacy of our individual limited partners, investors and prospective investors.  We have policies and procedures to protect the confidentiality and security of information of individuals who visit https://siris.com (the “Site”) and contact us about our business  (the “Services”).  We are providing you this notice to help you better understand what information we collect on the Site and how we collect that information, why and how we collect certain personal information, the care with which we treat that information, and how we use that information.

Depending on your jurisdiction of residence, please refer to the “APPENDIX A: DATA SUBJECT RIGHTS” section in relation to the legal rights you may have with respect to the personal data that we hold about you. Certain rights under this Privacy Notice are only available to residents of California, Cayman Islands, Europe, and the United Kingdom, as applicable. The privacy of your personal data is important to us at Siris.

Scope

This Privacy Notice discloses the privacy practices for Siris and for its Site, and localized versions of that site, including the type of personal data 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 process your personal data. Similarly, without your personal data, we cannot inform you about the Services we have available or that you may request (though if you are currently receiving marketing communications from us, you may opt-out of receiving further communications at any time).

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

 

Privacy Notice

Types of personal data collected

In connection with offering, forming and/or operating the private investment funds (each, a “Fund,” and, together with any future private investment fund to which Siris or its affiliates provide investment advisory services, collectively the “Funds”), Siris and the Funds (each an “Authorized Entity” and collectively, the “Authorized Entities”) collect, record, store, adapt, and otherwise process and use personal data either relating to;

• website visitors;
• potential financing providers; or
• any other data subjects from the following sources:
  1. information gathered via the “Contact” details section on the Site;
  2. information related to user authentication via the “Investor Login”;
  3. information gathered using cookies on the Site;
  4. information gathered in relation to at-will employment with Siris; and
  5. information received from potential or existing business partners and service providers;

Any Authorized Entity may collect on the Site and process the following categories of personal data:

1. contact details, including name, personal or business addresses (including e-mail address, Internet Protocol address and telephone number);
2. professional and educational history; and
3. information regarding the use of an Authorized Entity’s website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history).

Legal basis for processing personal data

There is a need to process personal data for the purposes set out in this Privacy Notice, in connection with providing our Services and in the legitimate interests of the Authorized Entities (or those of a third party including the Authorized Entities’ administrators, accountants, legal and other advisors and agents) to operate their respective businesses. From time to time, an Authorized Entity may need to process personal data on other legal bases, including: with your consent; or to comply with regulatory or legal obligations.

Purpose of processing

The applicable Authorized Entities process personal data for the following purposes (and in respect of paragraphs (c), (d) and (f) below, in the legitimate interests of the Authorized Entities):

1. website operations.
2. any legal or regulatory requirement, or when we believe in good faith that disclosure is legally required.
3. keeping existing and potential financing or other business partners informed about our Services.
4. for Human Resources or for contacting potential employees.
5. any other purpose that has been notified, or has been agreed, in writing.

Sharing of personal data

Your personal data may be combined with information we receive from other sources, or it may be provided to other organizations we work with. This section details that sharing of your personal data.

In addition to disclosing personal data amongst themselves, any Authorized Entity may disclose personal data, where permitted by applicable data protection law, to other service providers, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them in order to fulfil the purposes described in this Privacy Notice including, but not limited to 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, tax information exchange authorities, or other third parties as necessary to comply with legal process or to meet national security requirements; or to actual or potential purchasers and their advisors in the context of any sale, merger or acquisition of an Authorized Entity or any of its assets, as well as tax authorities, auditors and tax advisors (where necessary or advisable to comply with law).

Siris will not sell your personal data. Siris does not disclose personal data to anyone except as stated in this Privacy Notice or as permitted by law or regulation.

Protection of Personal Data

Siris and its affiliates consider the protection of personal data to be a sound business practice. We maintain physical, electronic, and procedural security measures that comply with applicable legal and regulatory standards to safeguard your personal data. Access to such information is generally restricted to those employees who are trained in the proper handling of client information and have a legitimate business need to access that information. We follow generally accepted standards to protect the personal data you submit to us, whether that information is in transit or at rest.

Data Storage and Retention

Personal data may be kept for as long as it is required or advisable for legitimate business purposes, to perform contractual obligations, created or saved as a result of computer or other electronic or archival backup procedures and as is required by applicable legal or regulatory obligations.

Our Site and Use of Cookies

We use various technologies to collect other types of information, including personal data, automatically. For example, in order to measure the usefulness and efficiency of our Site, we generally track certain information from all visitors to our Site. The types of information we might track include the Internet Protocol (IP) 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 our Site. “Cookies” are small data files that are stored on your hard drive that store certain information, including certain personal data , accessible to our Site, such as your password and any information content preferences you may voluntarily set at our Site. These technologies help us recognize you, customize your experience on the Sites and analyze your use of the Site to make them more useful to you.

You may opt-in to accept cookies automatically by changing the settings on your browser. You can refuse the use of cookies by selecting the appropriate browser setting. If you opt-out, please note that your experience using the Site may not be optimal, and you may not be able to use certain features on our Site. For information on how to remove or manage cookie functions and adjust your privacy and security preferences, access the “help” menu on your internet browser, or visit: http://www.aboutcookies.org/how-to-control-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/gaoptout and download and install the Google Analytics Opt-out Browser Add-on.

Data Transfers

Siris may transfer, process and/or store your personal data in a country other than the one in which your personal data is collected. When transferring your personal data to the US or other countries, we have implemented procedures to ensure that adequate safeguards in compliance with applicable laws are in place to protect personal data regardless of where it is being transferred.

Any Authorized Entity is expected to transfer personal data to a non-equivalent country (i.e. a country or territory other than; (i) a member state of the European Economic Area (“EEA”); (ii) the United Kingdom (“UK”); or (iii) a country or territory which has at the relevant time been decided by the European Commission, or UK Government (as applicable) in accordance with European Union (“EU”), or UK, law (as applicable) to ensure an adequate level of protection for personal data), in order to fulfill the purposes described in this Privacy Notice and in accordance with applicable law, rule or regulation, including where such transfer is a matter of contractual necessity to enter into, perform and administer subscription agreements with respect to the applicable Funds, and to implement requested pre-contractual measures. For information on the safeguards applied to such transfers, please contact compliance@siris.com.

Your Data Subject Rights

Siris is committed to giving prospective, existing, and former clients transparency and control over their data as required by applicable data privacy laws around the globe. Depending on your jurisdiction of residence you may have legal rights in relation to the personal data that we hold about you.  For a list of data subject rights in the relevant jurisdiction, as well as contact information to inquire about and/or exercise one or more of these rights, please see Appendix A below.

Questions or Concerns and Exercising Your Data Subject Rights

If you have any questions or concerns regarding the information in this Privacy Notice, or would like to exercise any of your rights set forth in Appendix A of this Privacy Notice, please contact this number 212-231-0095 or send an e-mail to compliance@siris.com.  Please include a description of what right you want to exercise and the information to which your request relates.

Changes to the Notice

From time to time we may update this Privacy Notice. If revisions are made to the privacy notice, we will update the statement with a new revision date. We encourage you to regularly review this and any updated Privacy Notice to ensure that you are always aware of how personal data is collected, used, stored and disclosed.

This privacy notice was last revised and posted on September 28, 2021.

 

Appendix A: Data subject rights

Data Subject Rights For EU and UK Residents

To the extent that EU and UK Data Protection Legislation applies to the processing of personal data by an Authorized Entity or you are a resident of the UK, the EU or the EEA, “EU and UK Data Protection Legislation” shall mean all applicable legislation and regulations relating to the protection of personal data in force from time to time in the EU, the EEA, or the UK, including (without limitation): Regulation (EU) 2016/679 (the General Data Protection Regulation or “GDPR”) and any national implementing or successor legislation, the GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018, the Data Protection Act 2018, the Privacy Directive 2002/58/EC, the Privacy and Electronic Communications (EC Directive) Regulations 2003, or any other legislation which implements any other current or future legal act of the EU or the UK concerning the protection and processing of personal data (including and any national implementing or successor legislation), and including any amendment or re-enactment of the foregoing.

The terms “data controller”, “data processor”, “data subject”, “personal data” and “processing” in this Privacy Notice and Appendix A shall be interpreted in accordance with the applicable EU and UK Data Protection Legislation.

EU and UK Data Protection Legislation grants EU and UK residents increased control over their personal data. Specifically, EU and UK Data Protection Legislation provides data subjects with certain rights regarding their personal data. If you are an individual who resides in the EU or UK and whose personal data is collected and processed by an Authorized Entity, you have the right to:

• Obtain information about the processing of your personal data
• Request access to, and a copy of, your data
• Rectify your personal data
• Take your personal data (in a readable, “portable” format) to another service provider
• Restrict or object to the processing of your personal data
• Lodge a complaint with a competent data protection supervisory authority in the relevant jurisdiction
• Exercise your right not to be subject to automated decision-making
• Request information about the processing of personal data, or (where applicable) withdraw previously given consent to collect and process personal data (which will not impact personal data processed before the withdrawal)
• Erase your personal data. Please note that the right to erasure is not absolute, and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal or regulatory obligation or where personal data is created or saved as a result of computer or other electronic or archival backup procedures. In addition, erasure of the personal data requested to fulfill the purposes described in this Privacy Notice may result in the inability to provide the services as contemplated by the governing documents of the relevant Funds.

If you have any questions or concerns regarding the information in this Privacy Notice, or would like to exercise any of your rights set forth in this Appendix A, please contact this number (212-231-0095) or send an e-mail to compliance@siris.com.

Your Cayman Islands Data Subject Rights

The Cayman Islands Data Protection Act of (As Revised) (“DPA”) gives individuals certain rights around their personal data processed in the Cayman Islands, including:

• the right to be informed as to how we collect and use your personal data;
• the right to access your personal data;
• the right to require us to stop direct marketing;
• the right to have inaccurate or incomplete personal data corrected;
• the right to withdraw your consent and require us to stop processing or restrict the processing, or not begin the processing of your personal data;
• the right to be notified of a data breach (unless the breach is unlikely to be prejudicial);
• the right to complain to the Data Protection Ombudsman of the Cayman Islands. You can access their website here: ky; and
• the right to require us to delete your personal data in some limited circumstances.

We may collect, store and use personal data for lawful purposes, including, in particular:

• where this is necessary for compliance with a legal and regulatory obligation to which we are subject (such as compliance with anti-money laundering and FATCA/CRS requirements); and/or
• where this is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms.

Any transfer of personal data by us or our authorized third parties outside of the Cayman Islands shall be in accordance with the requirements of the DPA.

If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or partnerships) that provides us with personal data on individuals connected to you for any reason in relation to your investment with us, this will be relevant for, and applicable to, those individuals and you should transmit this document to such individuals or otherwise advise them or its content.

Data Subject Rights for California Residents

The California Consumer Privacy Act (“CCPA”) requires us to make certain additional disclosures and provides California residents with the ability to request additional information about their personal information. If you are a California resident and it is determined that the CCPA applies to you, this section details those rights, how you may exercise them, and what Siris will do in response.

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

If you are an individual who resides in California and whose personal information 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 personal information we collect about California residents, the sources from which the personal information was collected (and/or, if applicable, sell or otherwise disclose to a third party), and the business purpose for collecting personal information.
• Choose to opt-out of the sale of personal information. Currently, however, Siris does not sell personal information.
• Request that we delete the personal information we have collected, subject to certain exceptions, including, our compliance with foreign or domestic laws, rules and regulations.

Non-Discrimination for Exercising Your 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

 Verifying Your Identity:  If you choose to contact us with a request, you will need to provide us with identifying information that matches the personal information we currently have about you.

 Authorized Agent: You have the right to appoint an authorized agent to exercise your rights on your behalf. If you would like to do so, please contact: compliance@siris.com.

 Accessible Information: For consumers with disabilities who need to access this policy in an alternative format, please contact: compliance@siris.com.