Privacy Policy

Your privacy is important to us.

Last Updated: February 10, 2021

Table of Contents

Siro Technologies Inc. (“Siro”, “we”, “our” or “us”) puts great efforts in making sure that the personal data processed by us is safe and used properly, and that our data practices are properly communicated to our customers, users and prospects.

This Privacy Policy describes how we collect, store, use and disclose the following types of personal data:

(i) Customer Data: data relating to identifiable individuals (“Personal Data”), which we analyze, process and manage on our customers’ behalf (“Services”). Specifically, this is data which is contained in call recordings, transcripts, and other communications and content, as well as data submitted by our customers (including by connecting their systems with the Services);

(ii) Siro User Data: account, contact and activity data relating to individuals who use the Siro platform, mobile application, and other tools and features provided by us as part of the Services (collectively – “Platform”);

(iii) Siro Website, CRM & Prospect Data: data relating to our customers, visitors of our website (www.siro.ai), participants at our events, and any other prospective customer or partner who visits or otherwise interacts with any of our websites, online ads and content, emails or communications under our control (“Sites”).

Specifically, this Privacy Policy describes our practices regarding –

  • Data Collection & Processing
  • Data Uses
  • Data Location
  • Data Retention
  • Data Sharing
  • Cookies and Tracking Technologies
  • Communications
  • Data Security
  • Data Subject Rights
  • Data Controller/Processor
  • Additional Notice & Contact Details

If you are our customer, user, visitor or prospect (“you”), please read this Privacy Policy carefully and make sure that you fully understand and agree to it.

You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please avoid any interaction with us or use of our Services. If you are a user of the Platform on behalf of any of our customers, we suggest that you contact your account administrator with any questions.

1. Data Collection & Processing

How we collect personal data

We may collect personal data from you in a variety of ways, such as:

  • Directly From You: We collect personal data that you provide to us directly, for example, if you choose to contact us, request information from us, sign up to receive updates, enter into a sweepstake or contest, or otherwise utilize our Sites or Services.
  • From Third Parties: We may collect personal data from third parties, including but not limited to, business partners, referral partners, advertising networks, social networks, data analytics providers, mobile device providers, Internet or mobile service providers, recruiters and job application portals, and background check providers. When we run a sweepstake or contest, or host an event, we may also collect/obtain your personal data from third parties, such as when you are a guest of another person.
  • Through Online Tracking Technologies: We use cookies and similar technologies to collect personal data automatically as you navigate our Site and Services. For additional information regarding our use of these technologies, see the Cookies and Tracking Technologies section below.

Personal data we collect

(i) Customer Data: Our Services enable Siro customers to record, transcribe, analyze and share the contents of their communications, including phone calls (collectively, “Customer Data”).

Customer Data may contain data which relates to identifiable individuals, such as the customer’s sales representatives, prospects, and other parties either taking part in their communications or mentioned there.

Certain privacy and data protection laws require that call recordings may only be initialized pursuant to one or more of the parties’ consent (whether explicit or implicit, depending on applicable law), or subject to certain restrictions. Accordingly, whilst Siro supports these laws by providing our customers with features and options for how they use our Services – our customer is solely responsible for determining whether and how they wish to use our Services and such features, and to ensure that all individuals using Siro on their behalf or at their request have given their informed consent to these practices, and that all legal requirements applicable to the collection, recording and use of data through our Services are fully met by them, including specifically in the context of an employment relationship.

Siro processes Customer Data, and the personal data contained in it, strictly on our customer’s behalf, in accordance with their reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such customer.

Accordingly, to the extent that the EU’s General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), UK Data Protection Act (UKDPA) or any similar laws apply, our customer will be deemed the ‘data controller’ (under the GDPR, UKDPA and similar laws) or ‘business’ (under the CCPA or similar laws) of such Customer Data; and Siro will be deemed the ‘data processor’ or ‘service provider’ when processing such data.

(ii) Siro User Data: We collect and generate the following types of personal data concerning users of our Platform: user account information (e-mail address and, when applicable, hashed password);

profile and contact information (name, title, team, company, e-mail and phone number, and additional information and media submitted by them, their teammates or their organization);

Platform usage information (connectivity, technical and aggregated usage data, activity logs, session recordings, and the cookies installed or utilized on their device; and

direct interactions and communications with us (including recordings and transcripts of your calls and emails with us, e.g. for user enablement, support and training purposes).

Whilst Siro processes such Siro User Data on its customers’ behalf (where it is included in Customer Data), we also use it for our own purposes, as described in Section 2 below. Accordingly, to the extent applicable – our customer will be deemed the ‘data controller’ or ‘business’ with respect to such data; Siro will also be deemed an independent and separate ‘data controller’ or ‘business’ with respect to such data; and with respect to those portions or copies of Siro User Data that we process on behalf of our customer – we will also be deemed a ‘data processor’ or ‘service provider’.

(iii) Siro Website, CRM & Prospect Data: We collect and generate the following types of personal data concerning our website visitors, customers and prospects –

  • Website usage information (connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data, activity logs, session recordings, and cookies and pixels installed or utilized on their device;
  • Customer account information (contact, contractual and billing details concerning our customers, which may also contain the details of their internal focal persons who directly engage with Siro concerning their organizational account);
  • Information concerning our customers and prospects (contact and business details, our communications with such customers and prospects, as well as any needs, preferences, attributes and insights relevant to our potential engagement).

2. Data Uses

We use other types of Personal Data (Siro User Data and Siro Website, CRM & Prospect Data) as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services.

3. Data Location

We and our authorized Service Providers maintain, store and process Personal Data in the United States of America, Israel and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law;

4. Data Retention

We retain Customer Data strictly on our customer’s behalf, in accordance with their reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such customer.

5. Data Sharing

Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement).

Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own.

6. Cookies and Tracking Technologies

We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes.

7. Communications

We engage in service and promotional communications, through e-mail, phone, SMS and notifications.

8. Data Security

We and our hosting services implement systems, applications and procedures to secure your personal data.

9. Data Subject Rights

If you wish to exercise your privacy rights under any applicable law, please contact us by e-mail at: help@siro.ai.

10. Data Controller/Processor

Siro is the “data controller” of Siro Website, CRM & Prospect Data.

11. Additional Notices

Questions, concerns or complaints: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your Personal Data held with us, please contact Siro’s support at help@siro.ai. Effective Date: February 10, 2021