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.
(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”).
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
(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.
In particular, at our customer’s choice, we may also use their Customer Data in order to identify and create unique “voice prints” of each of their users, in order to better distinguish them in those communications they take part in.
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. Certain laws also deem unique voice prints as ‘biometric’ data, which is subject to special protections and care. 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 (including any voice prints generated via such communications), , 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);
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 –
We collect such data either automatically, through the data subject’s interaction with us or with our website, Platform or Services; or through third party services, social media, analytics tools, events we organize or participate in, and other business initiatives.
2. Data Uses
Siro processes Customer Data, and the personal data contained in it, , in accordance with their reasonable instructions and as further stipulated in our lData Processing Addendum and other commercial agreements with such customer.
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, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our customers, users, visitors, prospects, ourselves and our Services.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
Specifically, we use Siro User Data and Siro Website, CRM & Prospect Data for the following purposes:
3. Data Location
We and our authorized Service Providers (defined below) 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; provided that Customer Data may only be processed in such locations as permitted in our Data Processing Addendum and other commercial agreements with such customer.
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.
We retain Siro User Data and Siro Website, CRM & Prospect Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at [email protected]
5. Data Sharing
Legal Compliance: In exceptional circumstances, and except as stipulated otherwise in our Data Processing Addendum and other commercial agreements with you, 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), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), speech-to-text services, data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“).
Our Service Providers shall each be deemed as a ‘data processor’ or ‘service provider’ in circumstances where Siro assumes the role of ‘data controller’; and where Siro acts as the ‘data processor’ or ‘service provider’ for our customer, the Service Provider shall be deemed as our ‘sub-processor’ or ‘service provider’ (as further described in Section 10 below).
Accordingly, these Service Providers may have access to Siro User Data and Website, CRM & Prospect Data; and if we have expressly listed them in our Sub-Processor List, they may also have access to Customer Data — all depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such limited purposes as determined in our agreements with them.
Sharing Personal Data with our Customers and other Users: Customer Data is typically shared and is available to the users belonging to such customer’s account. Siro User Data is shared with the administrator of the customer’s account to which such user belongs (including data and communications concerning such user’s account). In such cases, sharing such data means that the administrator(s) or other users of the same account may access it on behalf of the customer, and will be able to monitor, process and analyze the Personal Data contained therein. This includes instances where you may contact us for help in resolving an issue specific to a team of which you are a member (and which is managed by the same customer).
Please note that Siro is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the customer, that itself acts as the ‘data controller’ of such data (as further described in Section 10 below).
Protecting Rights and Safety: We may share Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Siro, any of our users or customers, or any members of the general public.
For the avoidance of doubt, Siro may share Siro User Data, Website, CRM & Prospect Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
6. Cookies and Tracking Technologies
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.
Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.
We also use analytics tools, including Google Analytics, Hotjar, Intercom, and UXCam. These tools help us understand users’ behavior on our Sites and Platform, including by tracking page content, and click/touch, movements, scrolls and keystroke activities.
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset notices, etc. Our customers, and other users on the same customer account, may also send you notifications, messages and other updates regarding their or your use of the Services. Such notifications and messages may also be sent by them to their own customers (for example, invites, recordings or meeting summaries created through our Services). You can typically control your communications and notifications settings from your Siro User profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our customer, user or prospect. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, Platform or Sites, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Siro at any time by sending an e-mail to: [email protected] or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
8. Data Security
We and our hosting services implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.
These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that our Sites, Platform or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
9. Data Subject Rights
Individuals have rights concerning their Personal Data. If you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as the right to request access to, and rectification or erasure of your Personal Data held with Siro, or to restrict or object to such Personal Data’s processing, or to port such Personal Data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at: [email protected]
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 4 above.
We may redact from the data which we will make available to you, any personal data related to others.
If you would like to make any requests or queries regarding Personal Data that we process on our customer’s behalf, please contact the administrator of such customer’s account directly. For example, if you are our customer’s customer or prospect, or if you are a user of Siro on behalf of our customer, and wish to access, correct, or delete data processed by Siro on behalf of our customer, please direct your request to the relevant customer (who is the “data controller” of such data – see Section 10 below). Note that if you do contact us, we may share your communications with our customer and its account users; and that we may also share the contact details of the account administrator with individuals who sent us such a request or query relating to this account.
10. Data Controller/Processor
Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Siro is the “data processor” of Customer Data, which we process on behalf of our customer (who is the “data controller” of such data; and our Service Providers who process such Customer Data on our behalf are the “sub-processors” of such data.
Siro is both a “data controller” and “data processor” of Siro User Data. Such data is processed by Siro for its own purposes (as described in Section 2 above), as an independent ‘controller’; whilst those certain portions of it which are included in Customer Data will be processed by us on our customer’s behalf, as a ‘processor’.
Accordingly, Siro processes Customer Data strictly in accordance with such customer’s reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such customer. The customer, as controller of such data, will be responsible for meeting any legal requirements applicable to data controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
For the avoidance of doubt, each customer is solely responsible for providing adequate notice to their account users and customers whose data may be contained in Customer Data – including sufficient reference to the processing of their Personal Data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.
11. Additional Notices
Our Services are not designed to attract children under the age of 16: We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Sites, Platform and/or Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at [email protected]
Effective Date: February 10, 2021