Trilogy Global Advisors International, LLP
WHAT IS THE PURPOSE OF THIS NOTICE?
Trilogy Global Advisors (“Trilogy”, "We" or “Us”) is committed to protecting and respecting your privacy. You can contact us at email@example.com in relation to this notice.
This privacy notice describes how we collect and use your personal data in accordance with the General Data Protection Regulation ("GDPR") and other applicable laws.
We are a "data controller". This means that we are responsible for deciding how and why we hold and use your personal data. We are required by data protection legislation to notify you of the information contained in this privacy notice.
This notice may apply to you in relation to your client engagement with Trilogy and/or use of the Trilogy website (“Site”).
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing your personal data, so that you are aware of how and why we are using your personal data.
DATA PROTECTION PRINCIPLES
We will comply with data protection law in relation to your personal data. The law says that the personal data we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
THE TYPES OF PERSONAL DATA WE MAY HOLD ABOUT YOU
Personal data means any information about an individual from which that person can be identified. It does not include data where your identity has been removed (i.e. anonymous data).
When a you engage Trilogy to manage your assets, Trilogy may collect the following public
Information from you:
· Information provided by you. This could include name, address, telephone number, social security or tax identification number, client, bank or brokerage account number, and other information required to facilitate the management of your assets.
· Information about transactions entered by Trilogy on your behalf, transactions with Trilogy affiliates and transactions with the entities Trilogy has hired to provide services to you. This would include information about the shares bought and sold for your account, and the deposits and withdrawals made by you. From time to time Trilogy may hire a service provider such as a broker-dealer or a proxy service who will then in turn also have information about the transactions conducted through them on your behalf Trilogy will also have access to the information generated when the service provider conducts those services relating to transactions in your account.
· Information we collect about you. We may collect information as a result of your visiting the Site. This may include technical information (such as the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform), information about your visit (including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time)), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page and any phone number used to call our customer service number.
· Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. We may also receive information about your as part of our KYC, anti-money laundering, sanctions and other client checks (“Client Checks”).
HOW WE WILL USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
1. Where we need to perform a contract we have with you. We may also disclose your personal data to our business partners, suppliers and sub-contractors in order where necessary for us to do so.
2. Where we need to comply with a legal obligation, including to provide “know your customer”, sanctions or a member of the Trilogy Group and other Client Checks.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. These interests may include:
· managing our relationship and performing our agreement with you;
· managing the Trilogy Group;
· providing you with information about other goods and services we offer that are similar to those that you have already purchased and telling you about our other products and services;
· preventing and detecting crime, including fraud, money laundering and identify theft;
· enforcing our rights and protecting ourselves against harm and allowing members of the Trilogy Group to do the same;
· where we enter into discussions to, sell all or a part of our business;
· anti-money laundering, sanctions and other client checks, including using reference agencies;
· notifying you about changes to our services;
· processing necessary to administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to improve the Site to ensure that content is presented in the most effective manner for you and for your computer and to allow you to participate in interactive features of our service when you choose to do so;
· ensuring that content from our Site is presented in the most effective manner for you and for your computer;
· the use of analytics and search engine providers that assist us in the improvement and optimisation of our Site;
· keeping the Site safe and secure;
· measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
4. Where you give your consent to processing.
We may also use your personal data in the following situations:
5. Where we need to protect your interests (or someone else's interests).
6. Where it is needed in the public interest.
We may use CCTV in and around our premises for security. These systems may monitor and
collect images or recordings of you.
Where you must provide personal data to us in relation to a contract we may not be able to perform this agreement without such data.
We may use your personal data to undertake searches against sanction lists maintained by United Kingdom, United States or other governments, including those lists maintained by the United Kingdom Treasury and the United States Office of Foreign Assets Control as considered appropriate by us.
"Special categories" (information about ethnicity, health, religious or political belief, trade union membership or offences) of personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process such special categories of personal information about you in the following circumstances:
1. with your explicit written consent;
2. where we need to carry out our legal obligations; and
3. where it is needed in the public interest, such as for equal opportunities monitoring in line with this data protection notice.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.
We may share your personal data with third parties, including third-party service providers and other entities in our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006) (the "Target Group") where this is in our legitimate interests.
We require third parties to respect the security of your personal data and to treat it in accordance with the law.
DISCLOSURE OF YOUR PERSONAL DATA
We may disclose your personal data to:
· other members of the Trilogy Group (who will apply a similar standard of protection to such data);
· service providers to and agents of the Trilogy Group (on appropriate terms that apply an adequate level of protection);
· law enforcement, regulatory and other authorities;
· your advisers and others acting for you (including payment recipients, beneficiaries, account nominees, intermediaries, correspondent and agent banks, clearing houses and clearing or settlement systems);
· anyone you authorise to give instructions or to use services on your behalf;
· other financial institutions;
· fraud prevention agencies, credit reference agencies and debt recovery agents;
· trade associations; and
· third parties in connection with a reorganisation, sale or acquisition of any part of the Trilogy Group business.
WHAT DOES TRILOGY DO TO PROTECT YOUR PERSONAL DATA?
Trilogy restricts access to your personal data to the people who need to know that information in order to perform their jobs, comply with law, rules or regulations or to provide services related to the management of the client account with Trilogy. To ensure that Trilogy is complying with the laws governing the securities business, Trilogy maintains physical, electronic, and procedural safeguards to keep your personal data confidential.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
FOR HOW LONG WILL RETAIN YOUR PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a customer we will retain and securely destroy your personal information in accordance with this policy and applicable law.
In order for us to be able to achieve these processing purposes within the Trilogy Group we may transfer your personal data to our service providers and other members of its Group to enable the global organization to work together and to support reporting relationships across the Trilogy Group. Trilogy will provide an adequate level of data protection should your personal data be transferred to service providers or Trilogy Group companies in countries outside the European Economic Area, including by use of the EU Model Clauses, where appropriate.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
If you have any questions about this privacy notice or how we handle your personal data, please contact firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. You can find out more about your rights in relation to your personal data at www.ico.org.uk.
Please note that you have rights to obtain a copy of your personal data and in certain situations to obtain correction, erasure and restriction of processing of your personal data. You have a right of data portability.
Where processing is based on your consent you have a right to withdraw this at any time.
You have the right to ask us not to process your personal data for marketing purposes or for purposes that are in our legitimate interests. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes.
You can also exercise any of your rights at any time by contacting us at email@example.com.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Trilogy Privacy Notice June 2018
079900 - 011035