Effective Date 5/25/18

Last Updated: 4/1/19

What does this policy cover?

This policy describes how Trinity (referred to here as “Trinity”, “we” or “us”) uses your data where you interact with our websites or where you contact us with a query.  Trinity is committed to respecting your privacy and protecting your personal data.

It also describes data protection rights which may apply to you, including a right to object to some of the processing which Trinity carries out. More information about your rights, and how to exercise them, is set out in the “What rights do you have?” section.

Key points

  • Trinity uses your personal data to allow you to use our websites and any features in our content, to handle and respond to any contact you may make, and to comply with its legal obligations.
  • We share data with our service providers and advisors, who help us in processing your personal data. We may also use your data in countries outside of your country of residence, particularly if you are not located in the United States.  
  • Wherever you provide us with your consent, for example where you consent to our processing of your data in connection with cookies, you can withdraw this consent.
  • Our privacy policy sets out more details of this processing, including details of your data protection rights, including your right to object to certain processing.
  • Trinity does not knowingly collect or process any information from any child under the age of 13 without explicit permission from their parent or legal guardian.

What information do we collect?

We collect and process personal data about you when you interact with our websites or when you contact us. We process the information you provide to us – for example, when you provide information through a form on our website or by email.     

We may also receive information about you through our use of cookies, as described in our “Cookies and similar technologies” sections below. We make use of Google’s DoubleClick and Analytics cookies in particular.

Please note that Trinity does not knowingly collect or process any information from any child under the age of 13 without explicit permission from their parent or legal guardian.

How do we use this information, and what is the legal basis for this use?

We process this personal data for the following purposes:

  • As required by Trinity to conduct our business and pursue our legitimate interests, in particular:
    • we will use your information to respond to any questions comments or complaints you may send us;
    • we will, where appropriate and permitted, send you direct marketing, including electronic marketing, about our services.
    • we monitor use of our websites and online services, and use your information to help us monitor, improve and protect our content, services and websites, both online and offline;
    • we will use information you provide through our websites to personalize our websites or services for you;
    • we use information you provide to investigate any complaints received from you or from others, about our websites or services; and
    • we will use information in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
  • Where you give us your consent:
    • we place cookies and use similar technologies, in accordance with our section on Cookies and similar technologies below; and
    • on other occasions where we ask you for consent, for example where we required consent to send you marketing, we will use the data for the purpose which we explain at that time.
  • For purposes which are required by law, for example compliance with laws requiring us to maintain specific records.

Relying on our legitimate interests

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests.  You have an absolute right to opt-out of any direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

Cookies and similar technologies

Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page.  Other tracking technologies are also used which are similar to cookies. This can include pixel tags and tracking URLs. All these technologies are together referred to in this Policy as “Cookies”.

The types of Cookies that we may use on our website, and the purposes for which they are used, are set out below:

  • Strictly necessary cookies: These cookies are essential in order to enable you to move around our website and use its features, such as accessing secure areas of our website. Without these cookies, any services on our Site you wish to access cannot be provided.
  • Analytical/performance cookies: These cookies collect information about how you and other visitors use our website, for instance which pages you go to most often, and if you get error messages from web pages. We use data from these cookies to help test designs and to ensure a consistent look and feel is maintained on your visit to the website.  All information these cookies collect is aggregated. It is only used to improve how a website works. We use Google Analytics, for example, to anonymously track website usage and activity.
  • Functionality cookies: These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise.  The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
  • Targeting cookies: These cookies are used to deliver adverts more relevant to you and your interests. We, for example, make use of the cookie Doubleclick. These cookies are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
  • Social media cookies: These cookies allow you to share what you’ve been doing on our website on social media such as Facebook and Twitter. These cookies are not within our control.  Please refer to the respective privacy policies for how their cookies work.
  • Pixel tags: Also known as a clear GIF or web beacon. These are invisible tags placed on certain pages of our website but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, registering when a particular device visits a particular page. They are used to, among other things, track the actions of users of our services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of our services and response rates. If you turn off cookies, the pixel tag will simply detect an anonymous website visit.

If you do not want to allow Cookies at all, or only want to allow use of certain Cookies, please refer to your browser settings. You can also use your browser settings to withdraw your consent to our use of Cookies at any time and delete Cookies that have already been set. Please note that by deleting our cookies or disabling future Cookies you may not be able to access certain areas or features of our website.

To find out more about cookies please visit: www.allaboutcookies.org or see www.youronlinechoices.eu which contains further information about behavioural advertising and online privacy.

Who will we share this data with, where and when?

Personal data may be shared with government authorities, supervisory authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

Personal data will also be shared with third party service providers, who will process it on behalf of Trinity for the purposes identified above. In particular, we use third party providers of website hosting services.

In the event that the business is sold or integrated with another business, your details will be disclosed to Trinity’s advisers and any prospective purchaser’s advisers and will be passed to the new owners of the business.

We will process the data in our location. Where you are resident outside of the United States, this may involve the use of your data outside the country of your residence.

What rights do you have?

You may, depending on your location, have the right to ask us for a copy of your personal data; to correct it, erase it or restrict (stop any active) processing of your personal data; and to ask us to transfer some of this information to other organizations in a structured, machine readable format.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited in some situations, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in applicable national legislation. We will inform you of relevant exemptions we rely upon when responding to any request you make. In some instances, this may mean we are able to retain data even if you withdraw your consent.

Where we require personal data to comply with legal obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to meet obligations placed on us.  In all other cases, provision of requested personal data is optional

We hope that we can satisfy queries you may have about the way we process your data.  To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to a data protection authority where you live, work, or where you believe a breach may have occurred.

How do I get in touch with you?

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at _Compliance@trinitypartners.com or by writing to Compliance Officer Trinity 230 Third Ave, Waltham, MA 02451.

How long will you retain my data?

Where we process your information in relation to your use of Trinity websites, we keep this data for up to 2 years, unless we are required to keep your information by law or to meet contractual requirements or to keep copies of any correspondence with you. Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

Where we are required to process your data to meet legal requirements, we will hold information for as long as necessary for these purposes or as required by these laws, and will ensure your data is reviewed over time to ensure it is not held where no longer necessary.