PRIVACY POLICY

Introduction

Trillium Capital Ltd is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.

It is the intention of this privacy statement to explain to you the information practices of Trillium Capital Ltd in relation to the information we collect about you.

For the purposes of the GDPR the data controller is:
• Trillium Capital Ltd
• Contact details of Trillium Capital Ltd
• When we refer to ‘we’ it is Trillium Capital Ltd

Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Who are we?

• Trillium Capital Ltd is an independent fund with a global outlook, based in Ireland. Our skills are in building and managing a portfolio whilst using a holistic approach to investing.

Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:

• James Garza
• jgarza@trilliumcapital.ie
• 01 495 9950

Purpose for processing your data

• Meeting legal and regulatory obligations.both for GDPR and for Central Bank of Ireland regulations
To comply with these requirements we collect some of your personal information, verify it, keep it up to date through regular checks and delete it once we no longer require it.

Why we are processing your data?

In order for us to provide you with investment services Trillium Capital Ltd need to collect personal data for verification of identity. Our reason (lawful reason) for processing your data under the GDPR is:

• Legal basis – Trillium Capital Ltd needs to process your data as this is necessary in relation to an investment in our fund or to provide you with information on our fund if you have requested such information.

In any event, Trillium Capital Ltd are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

How will Trillium Capital Ltd use the personal data it collects about me?

Trillium Capital Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary.

Special Categories of personal data
If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classified as special categories of personal data) – we will ensure the following

• we will obtain your explicit consent

Who are we sharing your data with?

We may pass your personal data on to third-party service providers contracted to Trillium Capital Ltd in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Trillium Capital Ltd procedures.

If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent, unless we are legally required to do otherwise.
The third parties that we pass your personal data to are:

Interactive Brokers Ltd

Trillium Financial Services Ltd

We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questions

If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.

Data Subjects Rights:
Trillium Capital Ltd facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why.
All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.

Additional information we are providing you with to ensure we are transparent and fair with our processing

Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Trillium Capital Ltd will process personal data in accordance with our retention schedule. This retention schedule has been governed by our internal governance.

Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Trillium Capital Ltd or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Organisation Name’s data protection representatives Data Protection Officer / GDPR Owner

Failure to provide further information

If we are collecting your data for a contract and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.
Profiling – automatic decision making

a) Risk Profiling
To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customers attitude to various levels of risk having answered a series of questions.

b) Profiling for marketing purposes.
When we seek to contact you about other services, as outlined above we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.

Additional Processing
If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information prior to processing this data.

Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 01 492 9950 or email jgarza@trilliumcapital.ie

Privacy policy statement changes
Trillium Capital Ltd may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services you agree to this privacy policy.

This privacy policy was last reviewed in May 2018

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Privacy Policy