Privacy Notice

Last Updated: May 2024

This Website Privacy Notice (“Privacy Notice”) sets forth the privacy practices of SRS Investment Management, LLC (“SRS,” “we,” “our” or “us”) to explain how we collect, use, disclose, and protect personal information from and about you through your interactions with us, including your interactions with our Website. Please note that if you are an investor in one of our funds, you should review the privacy notice(s) provided with your investment documents for additional information on our data collection and use.

If you are a California resident please review Additional Information for California Residents for additional disclosures, our Notice at Collection, and a description of your rights with regard to your personal information.

Collection of Your Information & Sources of Information

We may collect information, including personal information, when you communicate or otherwise interact with us, and automatically from your use of the Website. We may also collect certain information from other sources including your transactions with us, our service providers, and our affiliates. When we use the term “personal information,” we mean any information about an individual from which that person can be identified.

Depending on how you interact with us, you may provide us or our service providers personal information, including identifiers such as (i) your name; (ii) contact information such as your email address; (iii) online identifiers such as your IP address; and (iv) correspondence and communications such as information in the comments or questions you send to us.

How We Process Your Information

We may process the personal information we collect from you for our everyday business purposes, including, for example: (i) provide our products and services; (ii) communicate with you; (iii) manage, operate, and improve our Website and services; (iv) to process a transaction for your account and (v) to comply with and enforce applicable legal requirements.

How We Protect Personal Information

SRS will maintain appropriate technical and organizational measures designed to protect your personal information against loss or accidental, unlawful, or unauthorized, alteration, access, disclosure, or use. Unfortunately, no data transmission or storage system can be guaranteed 100% secure.

How Long We Keep Your Information

We will store your personal information only for as long as necessary for the purposes of providing access to our Website and related services to you, as required by law, and for the exercise or defense of legal claims.

Sharing of Your Information

We may share your personal information with certain third parties in different circumstances, including with:

• Our affiliates.
• Our service provider who hosts the website.

Where We Process Your Information

We are based in the U.S. When you provide personal information to us from outside of the U.S., please be aware that we will receive and process it in the U.S. and that U.S. data protection laws may be different from those of your country of residence.

Your Rights

You may have certain rights with regard to your personal information, including to review the information we have about you and correct or update any inaccurate information. You can also manage your receipt of certain marketing and non-transactional communications.

If you wish to exercise these rights or have any questions, please contact us using the information below in Contact Us.

Additional Information for California Residents & Notice at Collection

The California Consumer Privacy Act (CCPA) requires us to provide additional disclosures with regard to our collection, use, and disclosure of personal information and your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.

Notice at Collection and Use of Personal Information. Depending on how you interact with us, we may collect the categories of personal information listed above in Collection of Your Information & Sources of Information. We may use this personal information for the business or commercial purposes described in How We Process Your Information. We do not sell or share your personal information (as defined under the CCPA). For more information on our privacy practices, please review our entire Privacy Notice.

Our Collection, Use, & Disclosure of Personal Information and Sensitive Personal Information. In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information from all or some of the sources listed in Collection of Your Information & Sources of Information. We may use this personal information for the business or commercial purposes described in How We Process Your Information. We do not sell or share personal information, including not selling the personal information of minors under 16. In the preceding 12 months, we may have disclosed the categories of personal information identified in Collection of Your Information & Sources of Information to the following categories of third parties: (i) analytics providers; and (ii) technical service providers. We do not collect sensitive personal information (as defined under the CCPA) from our website visitors.

Rights Under the CCPA. The CCPA provides a California consumer certain rights, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected, and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Request to Delete”); (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); (v) opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not); (vi) limit the use and disclosure of sensitive personal information where required by the CCPA (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit); (vii) correct inaccurate personal information (“Request to Correct”); and (viii) request that we disclose to you the personal information we have collected, used, and disclosed about you during the past 12 months (“Request to Know”).

How to Submit a Request Under the CCPA. You can submit a Request to Know, Request to Correct, or a Request to Delete (“Consumer Rights Request”) as described above, by calling 212-520-7900 or emailing us at [email protected] with “CCPA Rights Request” in the subject line. We are only required to respond to verifiable Consumer Rights Requests made by you or your authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request such as your name and email address. Any information gathered as part of the verification will be used for verification purposes only. If you would like to use an authorized agent to submit a request, we may request proof that that they are authorized to act on your behalf or have a power of attorney. We may deny requests from authorized agents who do not submit such proof.

Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals.

Changes to Our Privacy Notice

We may update this Privacy Notice from time to time and to reflect changes in our personal information practices. We encourage you to review the most current Privacy Notice posted on our Website.