Effective Date 5/25/18
Last Updated: 3/4/22
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 depending on your location. This may include 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 “Non-US Residents: What rights do you have?” and “Personal Data Rights For California Residents” sections.
- 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.
- In specific instances where you provide us with your consent, for example where you consent to being further contacted, you can withdraw this consent.
- 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, in certain instances, collect resumes, CVs, and additional information about your professional and education history.
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 will, where appropriate and permitted, use information you provide through our website to evaluate job candidates
- 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 rely on legitimate interests as the legal basis for the processing of personal data. You can obtain more information 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
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.
Trinity does not and will not sell your personal data.
How long will you retain my data?
Where we process your information in relation to your use of Trinity websites, we only retain this data for as long as necessary for the given business purpose, contract, or legal requirement. 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.
Protection of Your Personal Data
We maintain physical, electronic, and procedural security measures that comply with applicable legal and regulatory standards to safeguard your personal data. Access to such information is restricted to those employees who are trained in the proper handling of personal information and have a legitimate business need to access that information. We follow generally accepted standards to protect the personal data you submit to us, whether that information is in transit or at rest. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
International Transfers of Personal Data
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. When transferring your personal data to the US or other countries, we have implemented procedures to ensure that appropriate safeguards are in place to protect the personal data regardless of where it is being transferred to.
Trinity may transfer personal data to a non-equivalent country (a country or territory other than (i) a member state of the EEA or the UK; or (ii) a country or territory which has at the relevant time been decided by the European Commission in accordance with EU law to ensure an adequate level of protection for personal data), in order to fulfill the purposes described in this Privacy Notice and in accordance with applicable law, rule or regulation, including where such transfer is a matter of contractual necessity to enter into, perform and administer agreements, and to implement requested pre-contractual measures. For information on the safeguards applied to such transfers, please contact us at Compliance@trinitypartners.com.
Non-US residents: 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 EU and UK 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, 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.
Personal data Rights for California Residents
The California Consumer Privacy Act (“CCPA”) requires us to make certain additional disclosures and provides California residents with the ability to request additional information about their personal data. If you are a California resident and it is determined that the CCPA applies to you, this section details those rights, how you may exercise them, and what Trinity will do in response.
Please note that the rights under the CCPA do not apply to PII collected, processed, sold or disclosed pursuant to Gramm-Leach-Bliley Act (Public Law 106-102) and Fair Credit Reporting Act (12 CFR 1022).
If you are an individual who resides in California and whose personal data is collected and processed by Trinity, you may have the right to:
- Request that we disclose, free of charge, the categories and specifics of the personal data we collect about California residents, the sources from which the personal data was collected (and/or, if applicable, sell or otherwise disclose to a third party), and the business purpose for collecting personal data).
- Choose to opt-out of the sale of personal data. Currently, however, Trinity does not sell personal data.
- Request that we delete the personal data we have collected. Following our verification of the request, we will comply with the request and delete any or all the personal data in our possession that we collected from the California resident and/or any or all such personal data in the possession of our service providers, unless otherwise restricted by law or regulation.
Non-Discrimination for Exercising Your PII Rights
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, by writing to Compliance Officer Trinity 230 Third Ave, Waltham, MA 02451, or calling us at 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 PII we currently have about you.
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 us at Compliance@trinitypartners.com. You can also contact us by writing to Compliance Officer Trinity 230 Third Ave, Waltham, MA 02451 or by calling us at 855-566-2229.
For consumers with disabilities who need to access this policy in an alternative format, please contact us at Compliance@trinitypartners.com, write to Compliance Officer Trinity 230 Third Ave, Waltham, MA 02451, or call us at 855-566-2229.
Changes to this Privacy Notice
From time to time we may update this privacy notice. If revisions are made to the privacy notice, we will update the statement with a new revision date.