Effective Date 5/25/18
Last Updated: 2/12/25

What does this policy cover?

This Privacy Policy (the “Policy”) describes how Trinity Partners, LLC.  (referred to here as “Trinity,” “we” or “us”) uses your data in instances in which you interact with our websites or in which you contact us with a query. Trinity is committed to respecting your privacy and protecting your personal data.

The Policy also describes data protection rights which may apply to you, including a right to object to some of the processing carried out by Trinity. More information about your rights and how to exercise them is set out in the “What rights do you have?” section.  Additional information about our collection practices and your rights as pertains to California Residents can be found in the supplemental Notice at Collection for California Residents.

Key points

• Trinity uses your personal data to allow you to use and interact with our websites, 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 our 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.

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 personal data to respond to any questions, comments or complaints you may send us;
  • we will, as appropriate and permitted, send you direct marketing, including electronic marketing, about our products and services.
  • we monitor use of our websites and online services, and we use your personal data to help us monitor, improve and protect our content, services and websites, both online and offline;
  • to personalize our websites or services for you;
  • to investigate any complaints received from you or from others about our websites, products or services; and
  • we will use personal data 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 upon which we ask you for consent, for example where we require consent to send you marketing, we will use the personal data for the purpose that 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 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 personal data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, in instances in which we rely on our legitimate interests. You have an absolute right at any time to opt out of any direct marketing or profiling we carry out for direct marketing. You can do this by following the instructions in the communication in instances in which this is an electronic message, or by contacting us using the details set out below in the “How do I get in touch with you?” section.

Use of Anonymized Personal Data

We may collect and use anonymized personal data for various purposes, including but not limited to improving our services, conducting research, and analyzing trends. Anonymized data is data that has been stripped of any information that could be used to identify an individual. This means that once data is anonymized, it is no longer personal data and is not subject to applicable data privacy laws.

Purposes of Anonymized Data Collection:

• To enhance user experience by understanding how our services are used.
• To conduct research and analysis to improve our products and services.
• To compile statistical reports and insights for internal and external use.

Data Security: We take the security of your data seriously. Anonymized data is stored securely and is only accessible to authorized personnel. We implement appropriate technical and organizational measures to protect anonymized data from unauthorized access, disclosure, alteration, or destruction.

Your Rights: Since anonymized data cannot be linked back to you, it is not subject to the same rights and protections as personal data under data protection laws. However, we are committed to maintaining the highest standards of data privacy and security.

Cookies and similar technologies

Cookies are small pieces of information sent by a web server to a web browser that allow the server to uniquely identify the browser on each page. Other tracking technologies similar to cookies are also used. 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 in our Trinity Cookie Policy.

If you do not want to allow cookies at all, or if you 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 to 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.

With whom will we share this data, 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.

Will there be any international transfers of my personal data?

Your personal data may be transferred, processed and/or stored in a country other than the one in which your personal data is collected, including but not limited to the United States and India.  Trinity has implemented procedures to ensure that appropriate safeguards are in place to protect the personal data regardless of where it is being transferred to. Where we transfer your data internationally, we will do so on the basis of: (i) an adequacy decision; (ii) your consent; (iii) model contractual clauses; or (iv) another valid transfer mechanism.  For information on the safeguards applied to such transfers, please contact us at Compliance@trinitypartners.com.   

How long will you retain my data?

Where we process your information in relation to your use of Trinity websites, we retain this personal data for as long as there is a legitimate business purpose, unless we are required to keep your information by law or to meet contractual requirements.  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 request). We also keep indefinitely a record of the fact that you have asked us not to send you direct marketing or to process your data, so that we can respect your request in future.

In situations in which 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 when it is no longer necessary.

How We Protect Personal Data:

We maintain appropriate technical and organizational security safeguards designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. We update and test our security technology on an ongoing basis. We limit access to your personal data to those employees who need access to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your personal data.

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 or some active) processing of your personal data; and to ask us to transfer some of this information 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, in situations in which those rights would infringe upon the rights of a third party (including our rights), or if you ask us to delete information that we are required by law to keep or that we have compelling legitimate interests in keeping. Relevant exemptions are included in the GDPR, CCPA, and applicable national legislation. We will inform you of relevant exemptions upon which we rely 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 or 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 if you would like to exercise your data subject rights , you can get in touch at Compliance@trinitylifesciences.com or by writing to Compliance Officer, Trinity, 230 Third Ave., Waltham, MA 02451.

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Notice at Collection for California Residents

Additional information for residents of California:

To the extent that you are a resident of California, this CCPA Notice at Collection supplements the above Privacy Policy with respect to specific obligations and rights granted under the California Consumer Privacy Act of 2018 (the “CCPA”) as amended and expanded by the California Privacy Rights Act of 2020 (CPRA) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA.

Categories of Personal Data We Collect and Disclose For a Business Purpose:

Within the last twelve (12) months we have collected the following categories of personal data from California residents and we have disclosed each of these categories of personal data with third-party service providers as set forth in “With whom will we share this data, and when?” in this Privacy Policy.

Category of Information	Categories of External Recipients	Disclosed for a Business Purpose as defined in the CCPA
Personal Identifiers.	• Service Providers	Yes
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	• Service Providers	Yes
Protected classification characteristics under California or federal law.	• Service Providers	Yes
Internet or other similar network activity.	• Service Providers	Yes
Professional or employment-related information.	• Service Providers	Yes

In addition to the categories of external recipients identified above, during the 12-month period prior to the last updated date of this Privacy Notice, we may have disclosed personal information about you to governmental agencies, regulators, and other third parties for the purposes set forth in “With whom will we share this data, and when?” in this Privacy Policy.

Sensitive Personal Information:

Subject to the relevant jurisdictional regulatory requirements, we may process sensitive personal information. We will only use and disclose sensitive personal information for a purpose for which it was originally collected. Unless we request it, we ask that you not send us, or disclose, any sensitive personal information.  

Within the last twelve (12) months, Trinity has not collected and processed sensitive personal data as defined under the CCPA. 

Purposes for Collecting Personal Data:

We collect personal data for business or commercial purposes set forth in “How do we use this information, and what is the legal basis for this use?”, respectively, in the Privacy Policy above.

Trinity does not sell your personal data or share your personal data for the purpose of cross context behavioral advertising, as defined by the California Privacy Rights Act (CPRA) of 2020.

Retention:

We retain the categories of personal data set forth above in the “Categories of Personal Data We Collect and Disclose For a Business Purpose section of this Supplemental California Notice at Collection for those business or commercial purposes described in “How do we use this information, and what is the legal basis for this use? in this Supplemental California Notice at Collection and as set forth in “How long will you retain my data?” section in the main Privacy Policy above, except as may be required under applicable law, court order or government regulations.

California Privacy Rights Under The CCPA: 

You have certain rights under the CCPA in respect of the personal data we hold and which you may exercise. These rights are:

Deletion rights: You have the right to request that we delete any of your personal data that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.

Disclosure and access rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal data specific to you over the last twelve (12) months. Such information includes:

• The categories of personal data we collected about you;
• The categories of sources from which the personal data is collected;
• Our business or commercial purpose for collecting such personal data;
• Categories of third parties or persons with whom we share the personal data;
• The specific pieces of personal data we have collected about you; and
• Whether we disclosed your personal data to a third party, and if so, the categories of personal data that each recipient obtained.

CCPA also provides you the right to receive information about any financial incentives (i.e., compensation payments) that we may offer in connection with use of your personal data for participating in certain of our Activities (as that term is defined in “About Trinity” in our Main Privacy Policy).

Additional rights: Under CCPA, you also have the right to:

• Request the correction of any inaccurate personal data maintained by us about you.
• Request that we limit the use and disclosure of your sensitive personal data. Currently, however, we do not use or disclose your sensitive personal data other than for the purpose(s) for which it was collected.
• Choose to opt-out of the sale of personal data or the sharing of personal data for cross-context behavioral advertising. Currently, however, we do not sell or share personal data as defined under the CCPA. 

Your rights will in each case be subject to the restrictions set out in the CCPA. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your personal data, can be obtained by contacting us.

Non-Discrimination for Exercising Your Rights:

We follow the requirements of California Civil Code §1798.125 and will not discriminate against any consumer who exercises the rights set forth in this Privacy Policy.

We will not penalize or otherwise subject you to discriminatory treatment for exercising any of your California Privacy Rights.

Exercising Your California Privacy Rights:

To exercise any of your rights under the CCPA, please contact us by any of the methods below:

By mail:
Trinity
230 Third Avenue
5th Floor
Waltham, MA 02451-7528

By email:  Compliance@trinitypartners.com 

By phone: 1-855-566-2229

Verifying Your Identity:

If you choose to contact us with a request, you will need to provide us with identifying information that matches the personal data we currently have about you.

Authorized Agent:

You have the right to appoint an authorized agent to exercise your rights on your behalf. If you would like to do so, please contact Compliance@trinitypartners.com

Accessibility Information:

For individuals with disabilities who need to access to this policy in an alternative format, please contact us at Compliance@trinitypartners.com

Updates To This Supplementary Notice of Collection:

We may reserve the right to periodically update this Supplemental California Notice at Collection. Please reference the “LAST UPDATED” note below for the effective date of the most recent updates.

This Supplemental California Notice at Collection was last updated on 2/12/25