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Privacy Policy

  1. What is this document and why should you read it?

    This fair processing website privacy policy explains how and why Trilantic Capital Management GP Limited (also referred to as “the Company”, “Trilantic Europe”, “we”, “our” and “us”) uses personal data about those individuals who visit our website at www.trilanticeurope.com (the “Website”), our Investor Portal (https://icx.efrontcloud.com/trilanticeurope/login.aspx) (the “Portal”) or otherwise communicate or engage with us (referred to as “you”).

    You should read this policy, so that you know what we are doing with your personal data. Please also read any other privacy policies that we give to you, that might apply to our use of your personal data in specific circumstances in the future.

  2. Trilantic’s data protection responsibilities

    Personal data” is any information that relates to an identifiable natural person. Your name, address and contact details are all examples of your personal data, if they identify you.

    The term “process” is a legal term and means any activity relating to personal data, including, by way of example, collection, storage, use, consultation and transmission.

    Trilantic is a so-called "controller" of your personal data. This is also a legal term. This means that we make decisions about how and why we process your personal data and, because of this, we are responsible for making sure it is used in accordance with data protection laws.

    In relation to personal data processed through your use of the Website and our Portal, the relevant controller will be Trilantic Capital Management GP Limited. Any references in this Policy to processing of your personal data via the Website will be to the processing activities of Trilantic Capital Management GP Limited.

  3. What types of personal data do we collect and where do we get it from?

    We collect different types of personal data about you when you visit our Website and Portal, or otherwise communicate or engage with us. We also obtain some personal data from other sources, and create some personal data ourselves.

    If any of the personal data we hold about you changes, such as your contact details, please inform us without delay by contacting us by email at info@trilanticeurope.com.

    We collect your personal information from various sources. The table below sets out the different types of personal information that we collect and the sources we collect it from.

  4. What do we do with your personal data and why?

    We process your personal data for particular purposes in connection with your use of the Website and Portal, the provision of services from us to you (or vice versa), your communication or other engagement with us and the management and administration of our business.

    We are required by law to always have a so-called “lawful basis” (i.e. a reason or justification) for processing your personal data. The table below sets out the purposes for which we process your personal data and the relevant lawful basis on which we rely for that processing.

    Please note that where we have indicated in the table that our processing of your personal data is either:

    1. necessary for us to comply with a legal obligation; or

    2. necessary for us to take steps, at your request, to potentially enter into a contract with you, or to perform it,

    and you choose not to provide the relevant personal data to us, we may not be able to enter into or continue our contract or engagement with you.

    Contact Information

    We may also convert your personal data into statistical or aggregated form to better protect your privacy, or so that you are not identified or identifiable from it. Anonymised data cannot be linked back to you. We may use it to conduct research and analysis, including to produce statistical research and reports. For example, to help us understand and improve the use of our Website and Portal.

  5. Who do we share your personal data with, and why?

    Sometimes we need to disclose your personal data to other people.

    Inside Trilantic Europe’s Group:

    We are part of the Trilantic Europe group of companies, and this includes our companies in Guernsey and Luxembourg. This means that, in limited circumstances, we will need to share your personal data with other companies in our group, affiliates, employees or partners for our general business management purposes and, in some cases, to meet our investor needs where providing services across branches/locations and/or for authorisations/approvals with relevant decision makers, reporting and where systems and services are provided on a shared basis.

    Access rights between members of the Trilantic Europe group are limited and granted only on a need to know basis, depending on job functions and roles.

    Where any Trilantic Europe group companies process your personal data on our behalf (as our processor), we will make sure that they have appropriate security standards in place to make sure your personal data is protected.

    Outside Trilantic Europe’s Group:

    From time to time we may ask third parties to carry out certain business functions for us, such as for IT support and maintenance of our Website and Portal. These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties so that they can perform those functions. Before we disclose your personal data to these third parties, we will seek to ensure that they have appropriate security standards in place to protect your personal data.

    In certain circumstances, we will also disclose your personal data to third parties who will receive it as controllers of your personal data in their own right for the purposes set out above, where the relevant disclosure is in relation to:

    1. services provided to you or us by a third party acting independently to Trilantic Europe but which has a relationship with Trilantic Europe, for example certain payment and fraud checking services;

    2. the expansion or reduction of our business, which may involve the sale and/or the transfer of control of all or part of our business; and

    3. the disclosure of your personal data in order to comply with a regulator or law enforcement request, legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, customers or others.

    We have set out below a list of the categories of recipients with whom we are likely to share your personal data:

    1. IT support, Website and data hosting providers and administrators;

    2. Service providers in relation to fund and entity administration services to Trilantic Europe;

    3. consultants and professional advisors including legal advisors and accountants;

    4. courts, court-appointed persons/entities, receivers and liquidators;

    5. business partners and joint ventures;

    6. insurers; and

    7. governmental departments, statutory and regulatory bodies.

  6. Where in the world is your personal data transferred to?

    As part of an international organisation, Trilantic Europe may transfer your personal data to recipients (either internally or externally, as set out above) that are established in jurisdictions other than your own. Please be aware that the data protection laws in some jurisdictions may not provide the same level of protection to your personal data as is provided to it under the laws in your jurisdiction.

    If any disclosures of personal data referred to above require your personal data to be transferred from within to outside the European Economic Area, we will seek to ensure that it is adequate protected by way of safeguards, including the use of EU Standard Contractual Clauses, reliance on an adequacy decision of the European Commission in relation to the relevant recipient jurisdiction or reliance on a US recipient being certified under the EU/US Privacy Shield framework.

    For more information about what appropriate safeguards we use and how to obtain a copy of them or to find out where they have been made available, please contact us using the details below.

  7. How do we keep your personal data secure?

    We will take specific steps (as required by applicable data protection laws) to ensure we take appropriate security measures to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.

  8. How long do we keep your personal data for?

    We will only retain your personal data for a limited period of time and for no longer than is necessary for the purposes for which we are processing it for. This will depend on a number of factors, including:

    1. any laws or regulations that we are required to follow;

    2. whether we are in a legal or other type of dispute with each other or any third party;

    3. the type of information that we hold about you; and

    4. whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.

  9. How do we communicate with you?

    1. in relation to any transactions you perform with us;

    2. to administer our relationship with you; and

    3. to respond to any questions or complaints that you may have; and

  10. Cookies

    When you visit the Website and Portal, one or more “cookies” are generated and deployed with your consent (if required).

    If you do not agree to our use of cookies, you should set your browser settings accordingly or not use the Website and Portal. Please be aware that if you disable the cookies that we use, this may impact your user experience while using the Website and Portal.

    The table below summarizes the different types of cookie we use on the Website and Portal, together with their respective purpose and duration (i.e. how long each cookie will remain on your device).

    Two types of cookies may be used on the Website and Portal - "session cookies" and "persistent cookies". Session cookies are temporary cookies that remain on your device until you leave the Website and Portal. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or "lifetime" of the specific cookie and your browser settings).

    Cookies used on the Website and Portal:

    What are Cookies?

    Cookies are files or pieces of information that may be stored on your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit the Website and Portal. A cookie will usually contain the name of the website from which the cookie has come from, the "lifetime" of the cookie (i.e. how long it will remain on your device) and a value, which is usually a randomly generated unique number.

    We use cookies to make the Website and Portal easier to use and to better tailor our web presence and products to your interests and needs. Cookies may also be used to help speed up your future activities and experience on the Website and Portal. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our web properties and to help us improve web structure and content. We cannot identify you personally from this information.

    Most internet browsers are initially set up to automatically accept cookies. You can change the settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings.

    If you disable the cookies that we use, this may impact your experience while on the Website and Portal. For example, you may not be able to visit certain areas of the Website and Portal.

    If you use different devices to view and access the Website and Portal (e.g. your computer, smartphone, tablet etc.), you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.

    If you would like more information about cookies, Trilantic Europe can recommend www.aboutcookies.org and www.allaboutcookies.org as helpful resources. Both websites also provide instructions on how to reject cookies if you would like to do so.

  11. What are your rights in relation to your personal data and how can you exercise them?

    Where our processing of your personal data is based on your consent (please see the tables above), you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know.

    Where our processing of your personal data is based on the legitimate interests (please see the tables above), you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.

    You have the right to (subject to applicable laws and certain limitations):

    1. access your personal data and to be provided with certain information in relation to it, such as the purpose for which it is processed, the persons to whom it is disclosed and the period for which it will be stored;

    2. require us to correct any inaccuracies in your personal data without undue delay;

    3. require us to erase your personal data;

    4. require us to restrict processing of your personal data;

    5. receive the personal data which you have provided to us, in a machine readable format, where we are processing it on the basis of your consent or because it is necessary for your contract with us (please see the tables above) and where the processing is automated; and

    6. object to a decision that we make which is based solely on automated processing of your personal data (however, we do not currently conduct any such decision making).

    You also have the right to lodge a complaint with the relevant Supervisory Authority (in the UK this would be the Information Commissioner’s Office, for example.

  12. Updates to this policy

    We may update this policy from time to time to reflect changes to the type of personal data that we process and/or the way in which it is processed. We will update you on material changes to this policy. We also encourage you to check this policy on a regular basis.

  13. Where can you find out more?

    If you want more information about any of the subjects covered in this privacy policy or if you would like to discuss any issues or concerns with us, you can contact us by email at info@trilanticeurope.com.

Contact

Trilantic Europe

London

35 Portman Square, London W1H 6LR, United Kingdom

Guernsey

Le Marchant Street, St Peter Port, Guernsey GY1 4HY

Luxembourg

26 Bd Royal, L-2449 Luxembourg, Luxembourg