Privacy Policy

Last Updated: January 9, 2024

We appreciate your trust in providing us with your information. Protection of that information is our top priority because we want to keep your trust.

We design all of our products and services with data protection in mind. We have dedicated teams who work hard to keep your information safe and secure. We constantly update our security practices and invest in our security efforts to enhance your privacy.

This Privacy Policy explains how we collect, disclose, use, and protect information when you visit any of the websites or use any online service or other service operated or offered by SRS Acquiom Inc. and its affiliates (“SRS Acquiom Group”), including any online service or application that we own and/or operate that link to this Privacy Policy.

As you review this Privacy Policy, here are a few general principles to keep in mind:

• Our services are not intended for children under 18. We do not knowingly collect personal data from children under 18.
• To the extent you are deemed under applicable law to have an individual consumer financial product or service with us, we will use and disclose personal data that we collect from or about you in accordance with our SRS Acquiom Consumer Privacy Notice provided at the end of this policy.
• If you reside outside the United States, you understand that your personal data may be processed in countries (including the United States) where laws regarding processing of personal data may be less stringent than the laws in your country.
• If you have questions after reviewing this policy, please call us at 1-800-331-5842 or email us at Privacy@SRSAcquiom.com.

Please read this Privacy Policy carefully. 

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SERVICES.

1. Who we are

SRS Acquiom is responsible for your information under this Privacy Policy and the SRS Acquiom Group includes the following legal entities: SRS Acquiom Inc., SRS Acquiom Holdings LLC, Acquiom Clearinghouse LLC, Acquiom Financial LLC, SRS Acquiom Workspaces LLC, Shareholder Representative Services LLC, Acquiom Agency Services LLC, SRS Acquiom Holdings UK Limited and Acquiom Financial UK Limited. This Privacy Policy is issued on behalf of the SRS Acquiom Group so when we mention "SRS Acquiom", "we", "us" or "our" in this Privacy Policy we are referring to the relevant company in the SRS Acquiom Group responsible for processing your personal data as the controller (which will depend on your relationship and interaction with us). SRS Acquiom Inc. is the controller responsible for this website. In the provision of our services, certain SRS Acquiom Group entities also act as joint or independent controllers of your personal data and have arrangements in place which designate appropriate roles and responsibilities between the entities involved.

2. Where This Privacy Policy Applies

This Privacy Policy describes the information that SRS Acquiom collects both directly and indirectly when you use the srsacquiom.com website, any srsacquiom.com or acquiom.com subdomain, and/or any other SRS Acquiom-owned website (the “Website”), use our products or services or otherwise interact with us. It explains why we collect such information, and what we do with the information we collect. This Privacy Policy applies to you when you visit the Website, use any of the services or tools accessible from the Website, including SRS Acquiom Clearinghouse®, SRS Acquiom ComPort® (Shareholder Representative Portal), SRS Acquiom MarketStandard®, SRS Acquiom Deal Dashboard, SRS Acquiom Workspaces, SRS Acquiom Virtual Data Room, SRS Acquiom Private Client Portal, use or access any such services or tools (including any white labelled version) from a third party custom domain, communicate with us offline, such as by mail, email, or telephone for customer support or otherwise engage with us.

In respect of personal data that is uploaded to the SRS Acquiom Virtual Data Room or Private Client Portal services by an End User (each as defined in the SRS Acquiom Workspaces Terms of Use for such services) forming part of the Workspace Content (as defined below), we are a “processor” or “service provider” of such personal data as we do not control such data. With respect to such personal data, the End User and/or the Customer (each as defined in the SRS Acquiom Workspaces Terms of Use) is responsible for individual notification of purposes for which such personal data is collected and for obtaining appropriate consent (if required) when they collect such personal data. Personal data that is transferred to us by End Users to be processed shall be deemed to have been lawfully collected. SRS Acquiom assumes no responsibility for obtaining or validating that appropriate consent has been obtained with respect to such data provided by End Users.

This Privacy Policy does not apply to information that is collected by any third-party website or service that you access through our services. 

In this Privacy Policy, to “process” information means to perform any operation on the information, whether or not by automated means, such as collection, recording, organizing, storing, adapting, use, disclosure, combining, erasing or destroying.

3. Information We Collect

Personal Data

The types of personal data we collect depends on the product or service you use. Some information may be provided by you directly, while other information may be provided to us by third parties involved in a transaction in which you have an interest and that utilizes one or more of our products or services. When you provide us information to receive a product or service from us, such information is collected by us in order for us to perform the related contract for you to receive such product or service.

The personal data we may process could include but is not limited to your name, email address, mailing address, telephone number(s), investment information, employment information, security holdings, and tax information. We may also collect bank account information, social security numbers, employer identification numbers, and driver’s license or passport information (or comparable) where we believe it is reasonably required for ordinary business purposes in order for us to perform the related contract for you to receive a product or service from us.

If you give us permission through your device’s operating system settings, we may also collect your approximate location through your mobile network service provider. The collection of your approximate geolocation may occur in the background even when you aren’t using our services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.

Virtual Data Room Service & Private Client Portal: Workspace Content

One of the core aspects of the SRS Acquiom Virtual Data Room and Private Client Portal services (each, a “File Sharing Solution”) is that you can upload any information, data, content or material (“Workspace Content”). You (and anyone who can interact with your use of the applicable File Sharing Solution) ultimately control(s) the nature of the Workspace Content, and our collection, use, and disclosure practices with respect to Workspace Content are separate from those with respect to other sorts of information we collect. As explained in detail below, we may also upload Workspace Content automatically with your authorization from third-party service providers (such as from your Google Drive).

Certain aspects of the File Sharing Solution allow you to link or integrate third-party products and services to enable certain features and functionalities with the applicable File Sharing Solution. For example, you can connect your Google Drive account so as to generate End User Files (as defined in the SRS Acquiom Workspaces Terms of Use) in the File Sharing Solution contained therein from information and data contained in your Google Drive. If you choose to use these features or functionalities, you may be asked to create an account with a third-party service provider or link your existing account with that service provider (and, by doing so, acknowledge the privacy policy and/or agree to the terms and conditions of that third-party). You may also be asked to authorize SRS Acquiom to collect information from the third-party service provider on your behalf. We will then collect information (such as your username or user ID associated with that third-party service) from you and/or that third-party service provider as necessary to enable the File Sharing Solution to access your data and content stored with that third-party service provider. Once the authentication is complete, we have the ability to access information you provided to us or was otherwise collected by the third-party service in accordance with the privacy practices of that third-party service. We will store the information and data we collect and associate it with your SRS Acquiom Workspaces account, and we will only use that information and data to enable the integration of the applicable File Sharing Solution with the third-party service provider and to perform actions requested or initiated by you, or that are reasonably necessary to carry out instructions provided by you.

Usage and Other Information

When you visit our websites or use our online services, we may collect and aggregate usage information to help us understand how people view the website so that we can improve its usefulness and value over time. When you use our online services, we may collect information to better provide the services to you and optimize your user experience. We may also collect data that helps us monitor network traffic and identify unauthorized or unusual activity.

The specific information we may collect includes: the name of the domain and host used to access the Internet (e.g., gmail.com); internet protocol (IP) address of the host server; referring page; name and version of the Web browser; date, time and country of site access; internet address of any site viewer used to link to our site; page views and length of time on each page.

If you request materials or send an inquiry, we may collect your name, email address, company name and title, and any other information that you send to us in such communication.

Additional Sources of Information

We may also collect information about you from additional sources, including without limitation, third party sources such as our business clients, government agencies, consumer reporting agencies, and other commercially available suppliers of information.  We may combine this information with the personal and other information we have collected about you. When the combined information directly or indirectly identifies an individual, we treat it as personal data.

4. How We Use Information

We use the information we collect in a number of ways, depending on what we collect and what services you use (or features of such services). These purposes may include:

• Processing and servicing accounts and transactions;
• Verifying your identity;
• Preventing fraud and enhancing the security of your account or our online services;
• Responding to your requests and communicating with you;
• Managing your preferences;
• Performing analytics concerning your use of our online services, including your responses to our emails and the pages you view;
• For marketing purposes, such as to send marketing communications by email affiliates (our marketing emails tell you how to “opt-out”; if you opt out, we may still send you non-marketing emails, such as emails about your accounts and our business dealings with you); and to show you tailored content regarding our products and/or services on other websites;
• Operating, evaluating and improving our business: including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing and other internal functions;
• Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies;
• For any other purposes that we may specifically disclose at the time you provide, or we collect your information; and
• For any other purpose with your consent.

We may also use data that we collect on an aggregate basis, such that it does not identify any individual customers, for various business purposes at our discretion.

If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your personal data.

Notwithstanding anything else in this Privacy Policy to the contrary, in respect of a File Sharing Solution, we will not use or access Workspace Content except in the following cases: for providing the applicable File Sharing Solution service to you; where you explicitly approve access (e.g., during a customer support inquiry); where compelled to do so in response to lawful requests by law enforcement or government regulators; where necessary to ensure the stability and security of the service and our systems (e.g., where we have reason to believe specific Workspace Content is degrading server stability); and where necessary to protect the rights, privacy, safety, or property of you, us, or others. We may also monitor your use of the File Sharing Solution and/or analyze metadata related to Workspace Content (such as total number of records, file size, access logs, etc.) to improve the service and enforce the terms of the associated SRS Acquiom service agreement.

To process your personal data as described in this Privacy Policy, we rely on the following legal bases:

• Legitimate interests: We may use your information where we have legitimate interests to do so. For example, we analyze our users’ behavior to improve the services, to prevent and detect fraud and misuse, and to market new products and services that we think will interest you
• Performance of a contract: We may use your information in order to perform services for you.
• Consent: From time to time, we may ask for your consent to use your information. Subject to applicable law, you may withdraw your consent at any time by contacting us at Privacy@SRSAcquiom.com. With respect to the placement of cookies for which your consent is the legal basis for processing, you may withdraw your consent by modifying your Cookie preferences.
• Processing is necessary for compliance with any legal obligation to which the controller is subject.

5. How We Disclose Information

We may disclose the information we collect from and about you with our related affiliates and other third parties.  For example, we may disclose your information to:

• Our third-party service providers who process your personal data on our behalf, such as IT and cloud hosting providers, customer service solutions providers, HR and administration services providers, advertising and marketing providers, when you are a payee who we are engaged to pay, the depository bank where funds are processed;
• Our affiliated businesses (including SRS Acquiom Group companies) in an effort to bring you improved service and offerings across our family of products and services, when permissible under relevant laws and regulations;
• Other companies to bring you co-branded services, products or programs, or the offerings of such other companies that may be of interest to you, when permissible under relevant laws and regulations;
• Professional advisers including lawyers, bankers, auditors, accountants and insurers;
• Public authorities and regulators that regulate how we operate;
  Third parties or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of our businesses;
• If you are a user of one of our File Sharing Solutions, with other File Sharing Solution users, at your direction and in accordance with the permissioning designated within such File Sharing Solution website; and
• If we process payments to you, with the party engaging us to process your payments (and any person authorized by such party to access SRS Acquiom Deal Dashboard with respect to your transaction).

Applicable law may require SRS Acquiom to disclose your personal data if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant) or other legal requirements; (ii) necessary to protect legal rights of SRS Acquiom users, customers, business partners, or other interested parties; (iii) necessary for the prevention or detection of crime. For residents of the United Kingdom (“UK”) or European Economic Area (“EEA”), SRS Acquiom will disclose personal data only when permitted to do so under applicable European, UK and EU Member States’ national data protection laws and regulations.

6. Understanding Client-Side Storage Tracking Technologies

Client-side storage comprises pieces of information stored directly on the computer you are using.  We or our third-party service providers may place cookies, user data, or other objects on your hard drive for security purposes, to facilitate site navigation and to personalize your experience.

For more information regarding our use of cookies and your ability to manage your cookie preferences, please refer to SRS Acquiom’s Cookie Notice here: https://www.srsacquiom.com/privacy/cookies/

By using the services and tools provided through SRS Acquiom Clearinghouse®, SRS Acquiom ComPort® (Shareholder Representative Portal), SRS Acquiom MarketStandard®, SRS Acquiom Deal Dashboard, SRS Acquiom Workspaces, SRS Acquiom Virtual Data Room or SRS Acquiom Private Client Portal (including any white labelled version thereof used or accessed via a third party custom domain) you acknowledge that the cookies that are placed in connection with your use of such services and tools and are intentionally directing SRS Acquiom or its affiliates to make your cookie data available to our third party partners to optimize your experience and support the functionality of such services and tools, consistent with your expectations under applicable privacy and data protection laws. These cookies are critical to the performance and proper functioning of such services and tools and accordingly, are considered Necessary Cookies. As such, you cannot opt out of the placement of such cookies. You further acknowledge that we have a legitimate interest in placing such cookies in connection with your use of such services and tools.

Our Policy On “Do Not Track (‘DNT’)” Signals and Global Privacy Control Signals

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain personal data about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including SRS Acquiom Inc., do not respond to DNT signals. We do, however, recognize and honor Global Privacy Control (GPC) signals. For more information about GPC, please visit Global Privacy Control.

7. How We Protect and Retain Information

We use physical, technical and organizational measures designed to protect your information against unauthorized access, theft and loss. We restrict access to your information to those employees who need to know that information to perform their job functions.

Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure. We expect that you will use appropriate security measures to protect the personal data you transmit to us.

You are responsible for maintaining the security of your account and the information in your account. We may suspend your use of all or part of our services without notice if we suspect or detect any breach of security. You understand and agree that we may deliver electronic notifications about breaches of security to the email address on record on your account.

If you believe that your account or information is no longer secure, please notify us immediately at Privacy@SRSAcquiom.com.

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include but are not limited to:

• The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the services);
• In the case of Workspace Content, if you have directed the deletion thereof;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).

8. Cross Border Data Transfers

International transfers of information we collect

Our sharing of personal information as part of providing our services sometimes involves cross-border data transfers to or from the United States of America and other jurisdictions. For example, when our services are available to users in the United Kingdom ("UK") and European Economic Area (“EEA”), their personal data may be transferred to our affiliates, as well as other third parties, in the United States.  Where we transfer the personal data of UK and EEA individuals outside of the UK and EEA, we take steps to ensure personal data remains protected, including by: (i) relying on applicable adequacy decisions / regulations which are granted by the European Commission and UK Government (respectively); (ii) implementing appropriate safeguards, such as approved standard contractual clauses and data transfer addendums; (iii) or relying on applicable derogations, such as:  where the data transfer is necessary to perform a contract with you or a contract in your interest. We apply safeguards intended to protect the privacy and security of your personal data and to use your data consistently with your relationship with us and the practices described in this Privacy Policy.

International transfers within the SRS Acquiom companies

To facilitate our global operations, we transfer information globally and allow access to that information from countries in which the SRS Acquiom owned or operated companies have operations for the purposes described in this policy. These countries may not have equivalent privacy and data protection laws to the laws of many of the countries where our customers and users are based. When we disclose information about you within and among SRS Acquiom corporate affiliates, we make use of the Data Privacy Framework to receive personal data transfers from the European Union, the UK or Switzerland to the U.S., to safeguard the transfer of information we collect from the EEA, the UK and Switzerland. 

Data Privacy Framework Notice

SRS Acquiom and its US subsidiaries (SRS Acquiom Holdings LLC, Acquiom Clearinghouse LLC, Acquiom Financial LLC, SRS Acquiom Workspaces LLC, Acquiom Agency Services LLC and Shareholder Representative Services LLC) adhere to the Data Privacy Framework Principles regarding the collection, use, and retention of personal data that is transferred from the European Union, UK (and Gibraltar) and Switzerland to the U.S. 

SRS Acquiom complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF (“UK Extension”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. SRS Acquiom has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension. SRS Acquiom has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (together with the EU-U.S. Data Privacy Framework Principles, the “DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles will govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. SRS Acquiom’s compliance with the EU-U.S. DPF, UK Extension, and Swiss-U.S. DPF is subject to the investigatory and enforcement powers of the Federal Trade Commission.

SRS Acquiom complies with the DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.

SRS Acquiom commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF should first contact SRS Acquiom at privacy@srsacquiom.com.

SRS Acquiom also commits to referring unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you. 

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found in Annex 1 of the DPF Principles.

9. Your Choices About Your Information And Your Rights

Device permissions. Mobile Device operating systems have permission systems for specific types of device data, such as location services, and so-called push notifications. You can change your settings on your Device to allow or decline the collection of data or the display of the notifications, but certain services may lose full functionality when you do. You also can stop all information collection by our mobile application by uninstalling it from your Device.

If you are a UK or EEA individual you have the right, under certain circumstances, to request access, correction or erasure of your personal data, restrict or object to our processing of your personal data or receive an electronic copy of your personal data for purposes of transmitting it to another company or have it directly transmitted to another company. You also have the right to withdraw your consent (where we rely on consent as our lawful basis). If you would like to exercise any of these rights, please contact us using the contact information below.

In your request, please make clear to us the personal data to which your request relates and the actions you would like us to take. For your protection, we will verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we often need to retain certain data for recordkeeping purposes and our databases and other records may have residual data that we will not remove. We also may not allow you to review or delete certain data for legal, security or other reasons.

We do not undertake solely automated decision-making which has a legal or similarly significant effect on you.

If at any time you believe that the services have not adhered to this Privacy Policy, please let us know by contacting Privacy@SRSAcquiom.com. We will use good faith efforts to determine and correct the problem. 

If you are a UK or EEA individual, you have the right to lodge a complaint with a data protection authority about how we process your personal data.

10. Your California Privacy Rights 

California Shine the Light

If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to Privacy@SRSAcquiom.com. Please allow up to 30 days for a response.

California Privacy Rights Act

The California Privacy Rights Act (“CPRA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing (for cross-contextual behavioral advertising) of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CPRA defines “Personal Information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CPRA will vary based on our relationship or interaction with that individual. Certain information we collect may be exempt from the CPRA because it is covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act. For example, this California Privacy Rights Act disclosure does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes. For more information about how we collect, disclose, and secure information relating to these customers, please refer to the section below entitled SRS Acquiom Privacy Notice.

To the extent that we collect Personal Information that is subject to the CPRA, that information, our practices, and your rights are described below.

Personal Information We Collect

Within the last twelve months we have collected the following types of Personal Information from consumers and disclosed certain types of personal information with third parties for a business purpose:

We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.

We do not use or disclose sensitive personal information for purposes other than those specified in California Civil Code section 1798.121.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

All of the above categories of information about you or third parties (other than Internet/Electronic Network Activity and Geolocation Data) may be contained in Workspace Content that is uploaded by a user of a File Sharing Solution. Workspace Content is collected by us at the user’s behest. We will not use or access Workspace Content except in the following cases: for providing the applicable File Sharing Solution service to you; where you explicitly approve access (e.g., during a customer support inquiry); where compelled to do so in response to lawful requests by law enforcement or government regulators; where necessary to ensure the stability and security of the service and our systems (e.g., where we have reason to believe specific Workspace Content is degrading server stability); and where necessary to protect the rights, privacy, safety, or property of you, us, or others. We may also analyze metadata related to Workspace Content (such as total number of records, file size, access logs, etc.) to improve the service and enforce the terms of the associated SRS Acquiom service agreement. We may disclose such Workspace Content (including any Personal Information contained therein) to our affiliates and service providers in order to provide the applicable File Sharing Solution, and with other File Sharing Solution users, at your direction and in accordance with the permissioning designated within such File Sharing Solution website.

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include but is not limited to:

• The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the services);
• In the case of Workspace Content, if you have directed the deletion thereof;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).

SRS Acquiom and its affiliates do not sell and have not in the preceding 12 months sold Personal Information to which the CPRA applies, within the meaning of the CPRA.

The Right to Opt Out of Sharing (for cross-context behavioral advertising)

You may direct us to not share your personal information by clicking here. Our use of online tracking technologies with respect to California consumers may be considered “sharing” under applicable law. In addition, California visitors to our website can opt out of being tracked by these third parties by clicking the “Cookie Settings” link contained in our Cookie Notice and selecting their preferences, or by clicking here:

In addition, SRS Acquiom participates in a service called the Global Privacy Control (GPC) that lets California residents set a “Do Not Sell or Share” preference at the browser level. In order to do this, you will need a GPC-enabled browser or browser extension. Next, you will activate or turn on the GPC setting in the browser. When you visit a website, your browser will automatically send the site a “Do Not Sell or Share” signal and participating websites, like ours, will honor your preference Please note that not all browsers and extensions offer a GPC setting. To download a GPC-enabled browser, go to the Global Privacy Control website. When we are detecting your active GPC signal, we won’t allow you to opt back into the sharing of your personal information.

Categories of personal information disclosed that may be considered “sharing”: Identifiers (e.g., name, email address), Internet /Electronic Network Activity, Geolocation Data, and Commercial Information.

Categories of third parties to whom personal information was disclosed that may be considered “sharing” include advertisers and marketing partners, data analytics providers, and social media networks.

SRS Acquiom does not have actual knowledge that it Shares (for Cross-Context Behavioral Advertising) the Personal Information of Minors Under the Age of 18.

Right to Know & Access

You may request access to the Personal Information that we have collected and maintained about you (along with the categories of Personal Information, the categories of sources from which such information is collected, the business or commercial purpose for collecting or sharing such information, the categories of third parties to whom we disclose Personal Information and the specific pieces of Personal Information we have collected about you). You may only make such requests twice (2) per every twelve (12) months. Once your request is verified and we have determined that we are required to provide you with such information in accordance with applicable law, we will provide you with access to such information.

Deletion

You have the right to request that we delete Personal Information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your personal information accordingly. Your request to delete your Personal Information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CPRA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.

Correction
You have the right to request that we correct Personal Information collected and maintained about you. Once your request is verified and we have determined that we are required to correct that information in accordance with applicable law, we will correct your Personal Information accordingly. Please note that a record of your correction request may be kept pursuant to our legal obligations.

Exercising Rights:

To exercise the access, deletion or correction rights described above, please submit a request to us by either:

• Privacy@SRSAcquiom.com or
• call us at 1-800-331-5842.

Verification Procedures:

Only you, or a person that you authorize to act on your behalf, may make a request related to your Personal Information. You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. In the case of access and deletion, your request must be verifiable before we can fulfill such request.

Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected Personal Information or a person authorized to act on your behalf (e.g., previous transactions of person to whom request relates).

We will only use the Personal Information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority.

Please allow up to 45 days for a response once we have received your request. Please note that Consumers have a right to not receive discriminatory treatment for the exercise of their rights under the CPRA. Should you have any questions or concerns about our Privacy Policy and information practices, please contact us at Privacy@SRSAcquiom.com.

11. Links to Other Websites and Services

The services may include links to third-party websites and services that are not operated by us. When you click on these links, you will be directed away from the services. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours. This Privacy Policy does not apply to any personal data that you provide to these other websites and services.

12. Changes to this Privacy Policy

The Effective Date of this Privacy Policy is set forth at the top of this webpage. As we add new features to our services, we may amend this Privacy Policy. If we make a material change to this Privacy Policy that reduces your privacy rights, we will notify you in advance through our services. Your continued use of the services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions.

13. Questions?

If you have any questions about this privacy policy, the practices of this site, or your dealings with this website, please contact our privacy officer at Privacy@SRSAcquiom.com.

SRS Acquiom Consumer Privacy Notice