Privacy Policy

Introduction

Welcome to Sirius Investors, accessible from siriusinvestors.com. At Sirius Investors, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy outlines the types of information we collect, how we use it, and the steps we take to safeguard your data.

By accessing or using our website and services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with any part of this policy, please do not use our website or services.

Legal Compliance

This policy is designed to comply with various data protection laws, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other applicable privacy regulations worldwide. It informs you of your privacy rights and explains how the law protects you.

Information We Collect

We collect various types of information to provide and improve our services:

Personal Data

While using our website, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. This may include:

• Email address
• First name and last name
• Phone number
• Address, state, province, ZIP/postal code, city
• Payment information (processed securely through our payment processors)
• Investment preferences and financial goals

Usage Data

We automatically collect information on how our website is accessed and used. This Usage Data may include:

• Your device's Internet Protocol address (IP address)
• Browser type and version
• Pages of our website that you visit
• Time and date of your visit
• Time spent on those pages
• Unique device identifiers
• Diagnostic data

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our website and hold certain information. Cookies are files with a small amount of data that may include an anonymous unique identifier. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

How We Use Your Information

Sirius Investors uses the collected data for various purposes:

• To provide and maintain our services
• To personalize your experience and deliver investment insights relevant to your interests
• To notify you about changes to our services
• To allow you to participate in interactive features when you choose to do so
• To provide customer support and respond to your inquiries
• To gather analytics to improve our services
• To monitor usage of our services
• To detect, prevent, and address technical issues
• To comply with legal obligations
• To protect against fraud and potential legal liability

Legal Basis for Processing

We process your personal data on the following legal grounds:

• Contract fulfillment: Processing necessary for the performance of our contract with you to provide investment research services
• Legitimate interests: Processing necessary for our legitimate interests, provided these interests don't override your fundamental rights
• Legal compliance: Processing necessary for compliance with a legal obligation
• Consent: Processing based on your specific and informed consent

Data Retention

Sirius Investors will retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, and as required to comply with our legal obligations, resolve disputes, and enforce our agreements. When we no longer need to retain your data, we will securely delete or anonymize it.

Data Transfer

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or governmental jurisdiction where data protection laws may differ from those of your jurisdiction.

When we transfer your data internationally, we take all necessary steps to ensure your data is treated securely and in accordance with this Privacy Policy. These steps may include:

• Using approved standard contractual clauses
• Working with processors certified under privacy frameworks like the EU-US Data Privacy Framework
• Implementing appropriate technical and organizational measures to protect your data

Disclosure of Data

We may disclose your personal information in the following situations:

• Service Providers: To trusted third parties who assist us in operating our website and conducting our business (these providers have access to your personal information only to perform these tasks on our behalf)
• Business Transfers: In connection with a merger, acquisition, or sale of assets, where your data may be transferred as part of the business assets
• Legal Obligations: To comply with legal obligations, such as responding to lawful requests from public authorities
• Protection of Rights: To protect and defend the rights or property of Sirius Investors
• Safety: To protect the personal safety of users of the service or the public
• With Your Consent: In any other case where we have your explicit consent

Your Data Protection Rights

Depending on your location, you may have certain rights regarding your personal data:

• Right to Access: The right to request copies of your personal data
• Right to Rectification: The right to request correction of inaccurate information
• Right to Erasure: The right to request deletion of your personal data
• Right to Restrict Processing: The right to request restriction of processing your personal data
• Right to Data Portability: The right to request transfer of your data to another organization
• Right to Object: The right to object to processing of your personal data
• Rights Related to Automated Decision-Making: The right not to be subject to decisions based solely on automated processing

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section below. We will respond to your request within the timeframe required by applicable law.

Data Security

The security of your data is important to us. We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security.

Third-Party Websites

Our website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children's Privacy

Our services are not intended for use by individuals under the age of 18. We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

• Business Name: Sirius Investors
• Email: contact@siriusinvestors.com
• Address: Amsterdam, Netherlands
• Chamber of Commerce Number: 94496048
• VAT Number: NL005087747B73