Privacy Notice
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of our website or otherwise when you communicate or interact with us in the course of business.
This version of our privacy notice was last updated on 20 November 2022.
Controller
Trinetra Investment Management LLP is the data controller of your personal data. We are responsible for its security and for ensuring that we use it only for the purposes outlined in this Privacy Notice.
If you have any questions about this privacy notice or about your rights, please contact us.
Contact details
We are: Trinetra Investment Management LLP of 7 Stratford Place, London W1C 1AY.
If you need to get hold of us for any reason in connection with your personal data, please email us through our website contact page or call us on +44 20 3908 8900.
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns about data protection before you approach the ICO so please contact us in the first instance.
2. The data we collect about you
Personal data” means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal data does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
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Contact Data includes name, role at business, email address, phone number.
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Correspondence Data includes email correspondence, minutes of meetings, notes of conversations, recorded conversations.
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Usage Data includes information about how you use our website.
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Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
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Direct interactions. We collect the majority of your data when you choose to give this to us on our website, by email, over the phone, in person at meetings or otherwise. Because of the nature of our business, by law, we are required to record some of our telephone conversations.
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Automated technologies or interactions. As you interact with our website, we may automatically collect and be provided with Usage Data and Technical Data about your browsing actions and patterns. If you don’t want us to do this, you can set your browser to refuse the Google Analytics cookie by following this link: https://tools.google.com/dlpage/gaoptout.
4. How we 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:
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where it is necessary for our legitimate interests (or those of a third party) in the operation of our business and we have made an objective assessment that your interests and fundamental rights do not override those interests (for example to manage our relationship with you and to improve the service that we offer);
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in anticipation of or accordance with an agreement that we have with you; or
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where we need to comply with a legal or regulatory obligation.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
5. Disclosures of your personal data
We will need to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
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Financial regulatory bodies where we need to submit certain information to them.
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Fund structures in the course of business.
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Our service providers who provide us with IT management and system administration services.
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Website analytics providers.
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Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same ways as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
A number of our IT management and system administration service companies that process personal data on our behalf have servers based in the US or elsewhere outside the UK so their processing of your personal data may involve a transfer of data outside the UK.
Our service providers are required to ensure a similar degree of protection is afforded to your personal data by ensuring that either:
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there are UK ‘adequacy regulations’ about the country or territory where the receiver is located or a sector which covers the receiver; or
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we are putting in place one of the ‘appropriate safeguards’ referred to in the UK GDPR, such as the IDTA or Binding Corporate Rules; or
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having carried out a risk assessment, we are satisfied that for the data subjects of the transferred data, the relevant protections under the UK data protection regime will not be undermined; or
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an exception provided for in the UK GDPR applies, such as for contractual reasons for the conclusion or performance of a contract or to carry out pre-contractual measures or where we are required to submit certain information to financial regulatory bodies.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
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. By law we have to keep your Contact and Correspondence Data for seven years after we stop working together. In some circumstances you can ask us to delete your data: (see below for further information).
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under UK GDPR, individuals have the following rights
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The right to be informed about the collection and use of their personal data. This is a key transparency requirement under the UK GDPR.
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The right of access (a "data subject access request").
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The right to rectification of the personal data that we hold about you.
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The right to erasure of your personal data.
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The right to restrict processing of your personal data.
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The right to data portability.
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The right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
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Rights in relation to automated decision making and profiling.
For more information on these rights and when they apply is available here:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.