Privacy Notice

Last Modified: July 2025

INTRODUCTION

Purpose

This website privacy notice aims to give visitors of this Siris website information on how their personal data is collected and used by Siris in the course of their interactions with Siris through this website.

Key Definitions

Website Visitor – We use the general term “website visitor” throughout this notice to inclusively refer to each individual member of the public who displays the consents of any part of this website in their device web browser, without further consideration of their other interactions with Siris based on other relationships they may have apart from their interactions with this publicly accessible website. As this notice is intended specifically for such individuals, we also refer to those individuals throughout this notice using second-person pronouns (i.e., “you”, “your”, and “yours”).

This Site – We use this term in this notice (as well as “this website” or “the site”) to refer to all the content accessible publicly under the website address for the main siris.com domain name.

Siris – All legal entities owned or controlled by Siris Capital Group, LLC (whose principal office is located at 825 Third Avenue, Suite 2850, New York, NY 10022. We refer to these legal entities throughout this notice as, “Siris”, “we”, “us”, “our”, and “ours”).

Personal Data – Various laws and regulations use different terms and definitions for information about individuals that is personal and should be protected. Some laws and regulations consider only very limited types of information to be protected and private. Others include much broader categories. In this notice, personal data (or “personal information”) refers to data that could be used, alone or in combination with other data, to identify you as an individual. It can include name, physical address, email address, IP address, mobile device identifiers, date of birth, Social Security number or other tax identification number, online login and password information, credit card or other financial or payment information, and more.

Scope

This privacy notice does not concern your interaction with Siris in any manner other than your use of this site. This privacy notice also does not address our privacy practices with respect to any non-public personal information we may collect from you as an investor or employee or applicant of Siris. We address these practices in separate notices to investors and to our workforce.

Changes

If we update our website privacy practices, we will post applicable updates on this page of the site. Any such changes will be effective once we post them. We encourage you to review this privacy notice each time you visit this site. If you do not agree with any provision of the privacy notice, you should not visit or use this site.

What Information We Collect

Your privacy is important to us.  This privacy notice seeks to help you understand whether and how we collect information about you when you visit this site, and how we use such information.

When you enter and browse this site, we may collect two different types of information about you:  information you provide to us and information we collect through technology.

You may choose to contact us using links or contact information available on our site. In such instances, you may provide information that we collect and store in a way that allows us to relate it to you personally, including but not limited to your name, e-mail address, mailing address and phone number. Such information is referred to as “personal information” throughout this policy. Additionally, we may collect and retain a record of all communications with you, and we may monitor and record other activity on our site for any reason.

We may collect information about you through technology. For example, we may collect your IP address each time you request a page during a visit to this site. At times, we may also use IP addresses to collect information regarding the frequency with which you or other users browse various parts of this site. This site may also use other technical methods to track and analyze the traffic patterns on the site, such as the time at, frequency with, and the website from which our users visit various parts of this site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect and process information on our behalf. We may collect the information from use of these technical methods in a form that is personally identifiable.

During some visits to our site, we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. We may use this information to measure site activity, to develop ideas for improving our websites and for any other purpose to the extent permitted by applicable law.

How We Use Cookies

Our site may use “cookies” to facilitate your ongoing access to and use of our site and help us in the ongoing maintenance of our site. Cookies are small text files that may be placed on your browser when you visit our site.

Using the settings of your Internet browser, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. Consult your browser’s help menu to learn your options with respect to cookies. If you choose to turn off cookies, you may not have access to many features that make your browsing of our site smoother, and some of our services may not function properly.

How We Use Information We May Collect

Siris does not disclose any personal information about our site users to any non-affiliated third party, except as set forth below.

We may use or disclose certain personal information we collect about you or that you provide when you visit and browse this site as part of our normal business operations, including to respond to requests from you. We may also use service providers in connection with this site. These companies and individuals may have access to and use your personal information, as needed to perform their functions related to the site.

We will disclose personal information we collect from you when we believe that such disclosures are required by law, regulation, legal process, subpoena, or governmental request. We may also do so to help enforce our broader website terms of use, protect your safety or security, or protect the safety and security of tangible or intangible property that belongs to us, to you or to third parties. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve this site and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.

Also, if Siris, or any portion of our assets or businesses, are acquired by or merged with another entity, whether an affiliate or a third party, user information may be one of the transferred assets. We may transfer all user information (which may include personal information) to our acquirers or successors. Other than as part of such transaction, we will not sell any of your personal information without your consent.

Protection of Information

We work to protect your personal information. We use technical, administrative, and physical methods to maintain the integrity and security of our databases, including encryption-at-rest for any personally identifiable data, computer safeguards, and secured files and buildings where our websites are managed. Please be aware though that there is no such thing as “perfect security” on the Internet, and third parties may unlawfully intercept or access transmissions or private communications. We will not be responsible or liable for any damages, losses, or causes of action arising out of or in connection with any access to or disclosure of your personal information related to your use of the site and your own browser, network, and Internet connections. You use our site and send us information at your own risk.

Do Not Track

We do not track visitors of this site over time and across third-party websites to provide targeted advertising and therefore do not respond to “Do-Not-Track, or DNT, signals”.  However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You may consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

International Transfers of Personal Data

Our web servers are located in the United States. If you are accessing this site from outside the United States, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and by those third parties with whom we may share your personal information as outlined in this privacy notice in the United States, and in other countries.

Depending on what country you reside in or are a citizen of, the United States and other countries where Siris may transfer data may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will, however, take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law and we work to only transfer your data in compliance with all applicable laws.

Individual Rights

Under applicable privacy laws that govern where you live and where you interact with this Site from,  you may have certain rights in relation to your personal data.

These rights may include:

•       The right to ask us to correct your personal information where it is inaccurate or incomplete, and

•       The right to ask us to access the personal information we hold about you and be provided with certain information about how we use your personal information and who we share it with.

We process personal data to perform any of our contracts with you, for compliance with legal obligations or requirements and/or to pursue our legitimate business interests. In certain circumstances, you have the right to ask us to delete the personal information we hold about you, including:

•       Where you believe that it is no longer necessary for us to hold your personal information,

•       Where we are processing your personal information based on our legitimate business interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing, or

•       Where you believe the personal information we hold about you is being unlawfully processed by us.

In certain circumstances, you have the right to ask us to restrict (i.e., to stop any active) processing of your personal information:

•       Where you believe the personal information we hold about you is inaccurate and while we verify accuracy,

•       Where we want to erase your personal information as the processing is unlawful, but you want us to continue to store it,

•       Where we no longer need your personal information for the purposes of our processing, but you require us to retain the data for the establishment, exercise or defense of legal claims; or

•       Where you have objected to us processing your personal information based on our legitimate interests and we are considering your objection.

In addition, you can object to our processing of your personal information based on our legitimate interests and we will no longer process your personal information unless we can demonstrate an overriding legitimate ground.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note, however, that this will not affect the lawfulness of the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

To exercise any of these rights above, please contact us using the information in the Contacting Us to Exercise Your Rights section of this notice at the end.

Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or the interests of Siris and its related parties (including their proprietary information, trade secrets, or intellectual property), or where there are overriding public interest reasons or where we are required by law or bona fide internal policies and procedures to retain your personal information.

In the event that you wish to make a complaint about how we process personal information about you, please contact us using the information in the Contacting Us to Exercise Your Rights section at the end of this notice and we will work to respond to your request as soon as possible. This is without prejudice to your right to raise a complaint with the data protection supervisory authority in the applicable country in which you live or work or where you think we have infringed data protection laws.

Information and Deletion Requests

Based on the applicable laws of your country or state, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. Once we receive your request and verify your identity, we will disclose such information to you or delete the same, unless a legal exception applies. For example, we may deny your deletion request if retaining the information is necessary for us or our providers to complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

We will not discriminate against you if you exercise your privacy rights.

Exercising your Rights

To exercise any of your rights as described above, please submit a request to us by using the information in the Contacting Us to Exercise Your Rights section at the end of this notice. Your request must:

•       Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person, and

•       Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the requested personal information relates to you. We will use the information provided in a request solely to verify your identity or authority to make the request.

Governing Law

The laws of the United States and the state of New York govern this privacy notice and your use of this site in all respects. Any dispute relating to this policy and your use of this site shall be resolved solely in the courts located in New York. You consent and submit to the personal jurisdiction of such courts for the purposes of any such dispute, controversy, or claim and agree to waive trial by jury in any such dispute.

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Contacting Us to Exercise Your Rights

If you would like further information on the collection, use, disclosure, transfer, or processing of your personal data or would like to exercise of any of the rights listed in this privacy notice, please address questions, comments, and requests to compliance@siris.com.  

Verifying Your Identity

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

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Authorized Agent

You have the right to appoint an authorized agent to exercise your rights on your behalf.

Accessible Information

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

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