EU And UK Website Privacy Policy
Your privacy is important to Truelink Capital and its affiliates
(together, “Truelink,” “our,” “us,” “we” or “company”). To better protect your
privacy, we are providing information explaining our online information
practices.
This EU and UK Website Privacy Policy describes how we gather
and use information for visitors of this website, or investors who use our
online investor portal, in each case, that are from the EU or UK. Please read
this EU and UK Website Privacy Policy carefully.
For the purposes of applicable EU and UK laws, Truelink and its
affiliated general partners and managing members will each be a data controller
of any personal data collected by us. If you have any questions regarding our
use of your personal data, or this EU and UK Website Privacy Policy, please
contact Truelink’s Compliance Officer at compliance@truelinkcap.com.
We rely on various legal bases under applicable data protection
legislation in order to process your personal information (e.g., name,
title, address, email, marital status, date of birth, IP address, financial
data, username, password, etc.), including our legitimate interests,
contractual necessity and as required by law. We use the personal information
we collect to operate our business and provide you with the services and
products we offer and perform essential business operations. We do not collect
any special categories of personal information about you (this includes details
about your race or ethnicity, religious or philosophical beliefs, sex life,
sexual orientation, political opinions, trade union membership, information
about your health and genetic and biometric data). Nor do we collect any
information about criminal convictions and offences.
If we require your personal information due to a legal
requirement or obligation or in order to perform a contract with you, we will
make you aware of this at the time we collect your personal data, and the
possible consequences of you failing to provide this personal data. Failure to
provide this information means that we cannot provide our services or products
to you). In this case, we may have to cancel a product or service you have with
us but we will notify you if this is the case at the time.
Further information about the legal bases under which we process
your personal information is included in the section headed “Why we use your
personal information.”
You do not need to take any action as a result of this EU and UK
Website Privacy Policy, but you do have certain rights as described below in
the section headed “Your rights.”
HOW WE OBTAIN YOUR PERSONAL INFORMATION
Information you provide to us
We collect your personal information when you decide to interact
with us and we only collect the information necessary to carry out our business
for the purposes set out below. You can provide us with personal information
via online form, email, post, telephone and this website.
Information provided by third parties or publicly available
sources
We also process information in relation to companies that we are
evaluating in connection with a potential investment in or purchase of such
companies. In this situation, your personal data will be provided to us by
third parties involved in that potential transaction (including the target of
any investment).
WHY WE USE YOUR PERSONAL INFORMATION
We will only use your personal data when the law allows us to.
Most commonly, we will use your personal data: (i) where we need to perform the
contract we are about to enter into or have entered into with you; (ii) where
it is necessary for our legitimate interests (or those of a third party) and
your interest and fundamental rights do not override those interests; and (iii)
where we need to comply with a legal obligation. To the extent that you provide
us with any personal information, through or in connection with this website (i.e.,
via online form, telephone, email or post) or the investor online portal, we
may use such information for the following purposes:
Purpose |
Legal Basis |
To
provide you with the services or products you have requested. |
Contractual
necessity |
To
keep a record of your relationship with us. |
Legitimate
interest |
To
verify your identity. |
Legal
requirement |
To
conduct due diligence activities in connection with an actual or prospective
corporate transaction or investment with respect to which we are party to. |
Legitimate
interest |
Fraud
and abuse prevention. |
Legitimate
interest |
Litigation
management and conducting internal audits and investigations. |
Legitimate
interest |
To
administer and protect our business and this website. |
Legitimate
interest |
To
make suggestions and recommendations to you about goods or services that may
be of interest to you. |
Legitimate
interest |
No automated decision-making, including profiling, is used when
processing your personal information.
MARKETING
We may send you direct marketing communications to keep you
informed of our products and services in which you might be interested either
where we have obtained your prior consent or based on our legitimate business
interests where we have an existing relationship with you and we wish to
contact you about similar products or services in which you may be interested.
You may opt-in to certain kinds of marketing, and all forms of marketing at any
time, by emailing Truelink’s Compliance Officer at compliance@truelinkcap.com.
You can also click on the “opt-out”/unsubscribe link provided in our marketing
emails, if applicable, or by contacting Truelink’s Compliance Officer at compliance@truelinkcap.com.
DISCLOSURE AND TRANSFER OF PERSONAL INFORMATION
Unfortunately, the transmission of information and data via the
Internet is not completely secure. Although we do our best to protect your
personal data, we cannot guarantee the security of any information or data
transmitted to or through this website; any transmission of information or data
by you to or through this website is at your sole risk.
Your personal information will be shared with and processed by
our affiliates and certain service providers as necessary to fulfil the
purposes set out in this policy, including Strategic Consultants and other
consultants, recruitment firms, placement agents and data hosting providers. 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. We seek to ensure that anyone who provides a service to, or for
us, involving personal data enters into an agreement with us and meets our
standards for data security. To the extent your personal information is
transferred to countries outside of the EEA or UK, such transfers will only be
made in accordance with applicable data privacy laws. For further information
about the safeguards/derogations used, please contact Truelink’s Compliance
Officer at compliance@truelinkcap.com.
We reserve the right to disclose your personal information as
required by law, or when we believe that disclosure is necessary to protect our
rights and/or comply with a judicial proceeding, court order, request from a
regulator, national security, for the purposes of public importance or any
other legal or investigatory process involving us. Should we, or any of our
affiliated entities, be the subject of a takeover, divestment or acquisition,
we may disclose your personal information to the new owner of the relevant
business and their advisors on the basis of our legitimate interest.
SECURITY AND RETENTION OF PERSONAL INFORMATION
We are committed to protecting the personal information you
entrust to us. We adopt robust and appropriate technologies and policies, so
the information we have about you is protected to the extent possible from
unauthorized access and improper use. In addition, we limit access to your
personal information 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 information breach and will notify you and any applicable regulator of
a breach where we are legally required to do so.
We will keep your personal information only for as long as is
reasonably necessary for the purposes set out in this EU and UK Website Privacy
Policy, unless a longer retention period is required by law. We will not keep
more information than we need for those purposes. For further information about
how long we will keep your personal information, please contact Truelink’s
Compliance Officer at compliance@truelinkcap.com.
CAPACITY
This website is only intended for individuals who are at least
18 years of age. We do not knowingly encourage or solicit visitors to this
website who are under the age of 18 or knowingly collect personal information
from anyone under the age of 18 without parental consent. If we learn we have
collected or received personal information from an individual under the age of
18, we will delete that information.
COOKIES
Information regarding how you access this website (e.g.,
browser type, access times and Internet Protocol (IP) address) and your
hardware and software is automatically collected through the use of cookies (a
small text file placed on your hard drive) or other technologies or tools. This
information is used to improve website performance and for our business
purposes. Where cookies are not necessary for us to provide the products or
services you have requested or for the functioning of this website, we will ask
you to consent to their use. You may opt-in to accept cookies automatically by
changing the settings on your browser. If you opt-out of certain cookies, you
may not be able to access certain parts of this website. You may wish to visit
www.aboutcookies.org, which contains comprehensive information about types of
cookies, how they are used and how you manage your cookie preferences.
YOUR RIGHTS
You have the right to access the personal information we hold
about you, and there are a number of ways you can control the way in which and
what information we store and process about you. To exercise these rights and
controls, please contact Truelink’s Compliance Officer at compliance@truelinkcap.com.
- Access:
You have the right to ask for a copy of the personal information that we
hold about you free of charge; however, we may charge a “reasonable fee,”
if we think that your request is excessive, to help us cover the costs of
locating the information you have requested.
- Correction:
You may notify us of changes to your personal information if it is
inaccurate or it needs to be updated.
- Deletion:
If you think that we should not be holding or processing your personal
information any more, you may request that we delete it. Please note that
this may not always be possible due to legal obligations.
- Restrictions
on use: You may request that we stop
processing your personal information (other than storing it), if: (i) you
contest the accuracy of it (until the accuracy is verified); (ii) you
believe the processing is against the law; (iii) you believe that we no
longer need your data for the purposes for which it was collected, but you
still need your data to establish or defend a legal claim; or (iv) you
object to the processing, and we are verifying whether our legitimate
grounds to process your personal information override your own rights.
- Object:
You have the right to object to processing, including: (i) for direct
marketing; (ii) for research or statistical purposes; or (iii) where
processing is based on legitimate interests.
- Portability:
If you wish to transfer your personal information to another organization
(and certain conditions are satisfied), you may ask us to do so, and we
will send it directly if we have the technical means.
- Withdrawal
of consent: If you previously gave us
your consent (by a clear affirmative action) to allow us to process your
personal information for a particular purpose, but you no longer wish to
consent to us doing so, you can contact us to let us know that you
withdraw that consent.
We may need to request specific information from you to help us
confirm your identity and ensure your right to access your personal information
(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.
NOTIFICATION OF CHANGES
We reserve the right to amend this EU and UK Website Privacy
Policy from time to time by updating this EU and UK Website Privacy Policy. If
we decide to change our EU and UK Website Privacy Policy, we will post those
changes so our users are always aware of what information we collect, how we
use it and under what circumstances, if any, we disclose it. If at any point we
decide to collect personal information or use any collected information in a
manner different from that stated at the time it was collected, we will notify
applicable users. We will use information only in accordance with this EU and
UK Website Privacy Policy under which the information was collected.
CONTACT US
If you have any questions or concerns about this EU and UK Website
Privacy Policy, please contact Truelink’s Compliance Officer at compliance@truelinkcap.com.
COMPLAINTS
Should you wish to lodge a complaint with regards to how your
personal information has been processed by us, please contact your local
supervisory authority. In the UK, this is the Information Commissioner’s Office
– https://ico.org.uk/global/contact-us.