DCirrus

Privacy Policy

Last updated: September 28, 2026

DCirrus Americas Inc. ("DCirrus", "we", "us", or "our") operates DCirrus (the "Platform"). This Privacy Policy explains how we collect, use, disclose and safeguard personal information when you visit our website or use our Platform.

How This Policy Applies to Customer Data

DCirrus is a business-to-business platform. Documents and data room content that a customer uploads to the Platform as part of a paid engagement remain that customer's confidential information and are handled as described in the confidentiality and data-handling terms of that customer's signed agreement with DCirrus.

This Privacy Policy addresses the personal information of website visitors, prospective customers, and individuals who use the Platform (including account holders, data room participants, and similar authorized users) - such as names, email addresses and usage data - rather than the substantive business or deal content stored within a data room.

Information We Collect

We collect information you provide directly to us, information collected automatically when you use the Platform or visit our website, and information provided to us in connection with a customer relationship. This may include:

  • Account information: name, email address, company name and password when you register.
  • Data room and platform content: documents, files and related metadata you upload to or share through the Platform, subject to the confidentiality terms described above.
  • Usage data: information about how you interact with the Platform, including features used, documents accessed and login activity.
  • Billing and contract information: company and billing details we collect to invoice and administer your service agreement.
  • Device and log data: IP address, browser type, operating system, referring URLs and access timestamps.

How We Collect Personal Information

We collect personal information from you directly when you provide it, automatically through your use of the website or Platform, and in connection with customer or business relationships. We may also receive information from authorized customer administrators or service providers acting on our behalf.

How We Use Your Information

We use the information we collect to:

  • Provide, maintain, secure and improve the Platform and its features.
  • Process transactions and send related information, including purchase confirmations and invoices.
  • Send technical notices, updates, security alerts and support messages.
  • Respond to comments, questions and customer service requests.
  • Monitor and analyze usage trends to improve user experience and Platform performance.
  • Detect, investigate and prevent fraudulent transactions, security incidents and other illegal activities.
  • Comply with applicable legal obligations and enforce our agreements and rights.

Data Sharing and Disclosure

We do not sell your personal information. We use reputable third-party vendors for hosting, infrastructure, billing, analytics and other services necessary to operate the Platform. These providers may process personal information on our behalf and are subject to contractual or confidentiality obligations as applicable.

Beyond these service relationships, we may disclose personal information in the following circumstances:

  • Legal requirements: when required by law, regulation or legal process, or to protect our rights, privacy, safety or property.
  • Business transfers: in connection with a merger, acquisition, financing, reorganization or sale of assets, where personal information may be transferred as part of that transaction.
  • With your consent or at your direction: when you have authorized or requested the disclosure.
  • To professional advisers and other recipients where reasonably necessary to provide the Platform, protect our rights, or comply with legal obligations.

Data Security

We implement administrative, technical and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure or destruction, including access controls, encryption in transit and activity logging. We may engage reputable third-party infrastructure and service providers (sub-processors) to help operate the Platform; those providers are only permitted to process data as needed to deliver the Platform and are bound by confidentiality obligations.

California Privacy Rights

If you are a California resident and the California Consumer Privacy Act, as amended (the "CCPA"), applies to DCirrus, you may have rights regarding your personal information, subject to statutory exceptions and verification requirements. These may include:

  • Right to know: request information about the categories and specific pieces of personal information we collect, the sources of that information, the purposes for which we use it, and the categories of third parties to whom it is disclosed.
  • Right to delete: request deletion of personal information we have collected about you, subject to applicable exceptions.
  • Right to correct: request correction of inaccurate personal information.
  • Right to opt out of sale or sharing: request that we stop selling or sharing personal information where those activities are subject to the CCPA. We do not sell personal information.
  • Right to limit: where applicable, limit certain uses or disclosures of sensitive personal information.
  • Right to non-discrimination: exercise applicable privacy rights without unlawful discriminatory treatment.

Where required by applicable law, DCirrus will honor valid opt-out preference signals, including Global Privacy Control (GPC), for applicable requests.

To submit a California privacy request, contact support@dcirrus.com. We may need to verify your identity before completing certain requests. You may use an authorized agent where permitted by law, subject to applicable verification and authorization requirements. We will respond within the time periods required by applicable law.

Notice at Collection

The categories of personal information we may collect include identifiers and contact information; professional or employment-related information; commercial and contract information; internet or other electronic network activity information; account and authentication information; device and log information; and documents or other content provided through the Platform. We collect and use these categories for the business and commercial purposes described in this Policy, including providing and securing the Platform, administering accounts and contracts, supporting customers, analytics and product improvement, preventing fraud and complying with law.

Your Other Privacy Rights

Depending on your location and applicable law, you may also have rights to access, correct or delete personal information, object to or restrict certain processing, request portability of personal information in a structured, machine-readable format, and withdraw consent where processing is based on consent. To exercise these rights, contact us at support@dcirrus.com.

Cookies

We use cookies and similar tracking technologies to collect information about browsing activity. These include essential cookies required for the Platform to function and analytics cookies to understand usage patterns. Analytics cookies are only set if you opt in, where applicable, and you can change your choice through our cookie controls.

Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, to provide the Platform and services, maintain business and contractual records, comply with legal obligations, resolve disputes, enforce agreements, and protect our rights. Customer data retention and deletion following termination of a paid engagement are governed by the applicable customer agreement.

Third-Party Services

The Platform may contain links to third-party websites or integrate with third-party services. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing personal information.

Children's Privacy

The Platform is intended for business users and is not directed to individuals under 18. We do not knowingly collect personal information from children under 13 through the Platform.

Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the State of California, without regard to its conflict-of-law principles. Any disputes arising under or relating to this Policy shall be subject to the exclusive jurisdiction of the state and federal courts located in California, unless applicable law requires otherwise.

Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. If required by applicable law, we will provide additional notice of material changes. We encourage you to review this Policy periodically.

Contact Us

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

Email: support@dcirrus.com

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