Privacy Policy For UK/EU
TRIMONT PRIVACY POLICY
This privacy policy applies to individuals who engage with our operations in the United Kingdom or Ireland.
Trimont Europe Limited, Nominee Limited and Trimont Europe Limited (“Trimont”, “we” or “us”) are committed to protecting your personal data. This Privacy Policy will inform you how we use your personal data and tells you about your rights under data protection law.
Please make sure you read this Privacy Policy carefully. In particular please note that the details of the types of personal data that we process and the processing activities we undertake will differ depending on our relationship with you, so please ensure you are reading the section that applies to you.
Section Table
- Who we are
- Who we collect personal data about
- How we collect personal data
- The types of personal data we collect
- Purposes for which we process personal data
- Who we share your personal data with
- How long do we keep your personal data for
- International Transfers
- How we keep your personal data secure
- Marketing
- Your rights
- How to contact us
- Questions and complaints
- Updates to this Privacy Policy
WHO WE ARE
Trimont is the data controller in respect of any personal data which you provide to us or which we hold about you and any personal data which is processed in connection with the services we provide. You will be advised of the exact company which is acting as data controller based on our relationship with you.
Where you provide personal data to us about other people (for example, staff members), you should share a copy of this Privacy Policy with them before providing us with their personal data.
WHO WE COLLECT PERSONAL DATA ABOUT
We collect and use personal data about various different categories of individuals. The most common categories of individuals are as follows:
- Current and prospective clients (including their staff members)
- Current and prospective business partners such as contractors, consultants and agents
- Tenants and owners of properties connected with the services we provide to our clients and property managers
- Users of our website
HOW WE COLLECT PERSONAL DATA
We use different methods to collect personal data from and about you.
Personal data we collect from you
You may provide us with personal data directly when you:
- Complete our online forms
- Correspond with us for example via telephone calls and email
- Meet with us via face to face meetings
Personal data we collect from third parties or publicly available sources
We may collect personal data about you from various third parties and publicly available sources, including via:
- Our employees, contractors, consultant and agents
- Parties to whom we provide services
- Referrals from clients or partners (e.g. Our legal advisers)
- Law enforcement bodies
- Banks and credit providers
- Know Your Client (KYC) service providers
THE TYPES OF PERSONAL DATA WE COLLECT
Depending on our relationship with you, we may collect and process different types of personal data. For simplicity, we have grouped these together, as set out below.
- Identity Data includes title, first name, surname, date of birth, country of birth, nationality, gender, employment status and family status.
- ID Numbers includes driving licence number, passport number, national insurance or personal public service number, tax and other government identifier numbers.
- Contact Data includes home address, country of domicile, business address, home phone number, business phone number, e-mail address, LinkedIn Profile link.
- Financial Data includes bank account details, payment details, aggregated financial reporting information, tax information, reference checks, transactions data, credit information and insurance information.
- Employment Data includes qualifications and skills, employment history, education history and employer and position.
- Property Data includes, rent amounts and purchase prices of properties that form part of our clients assets.
- Technical Data includes the location from which you have come to our website and the pages you have visited, your IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system, page clicks, time spent and other automatically collected meta-data.
- Service Data includes details about your use of our products and services, details of enquiries or complaints that you make with us and conversations and correspondence made or received with you.
Criminal Offence Data
If you are a current or prospective business partner (such as a contractor, consultant or agent) we may collect additional data as part of our due diligence process.
This may include information about criminal convictions and offences (including information relating to any offences or alleged offences committed or any court sentences which you are subject to) (“Criminal Offence Data”), regulatory offences and any related information which is passed to us by third parties, notified to us by you or is in the public domain.
PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
We may process personal data for a number of different purposes. For each purpose we must have a “lawful basis” for this processing. We will rely on the lawful bases set out below when we process your personal data.
In addition, when a purpose involves the processing of Criminal Offence Data we must also have an additional “processing condition”. Where required this is also set out below.
How we process your personal data may also differ depending on our relationship with you.
We have set out below the personal data which we expect to process in the ordinary course of our activities and which of the lawful bases and processing conditions (where applicable) we rely on to do so.
Current and prospective clients
| Purpose/Activity | Type of data | Lawful basis |
| To facilitate the placement, marketing and promotion of our products and services. | Identity DataContact DataService Data | Legitimate Interest:Our legitimate business interest to keep our clients up to date with changes to our products or services.Performance of our contract with you.Consent. |
| Management and administration of our products and services. | Identity DataContact DataID NumbersFinancial DataService Data | Legitimate Interest:Our legitimate interest to provide our clients with our products and services.Performance of our contract with you. |
| Ongoing loan monitoring as required under credit documents entered into between commercial owners/borrowers and guarantors, and lenders in accordance with credit documents. | Identity DataContact DataFinancial DataID Numbers | Legitimate Interest:Our legitimate interest to provide loan monitoring services.Performance of our contract with you. |
| For due diligence purposes (including Anti Money Laundering/Know Your Customer). | Identity DataContact DataFinancial DataID Numbers | Processing is necessary in order for us to comply with our legal obligations. |
| To comply with our legal and regulatory obligations. | Identity DataContact Data | Processing is necessary in order for us to comply with our legal obligations. |
| To manage our relationship with you and communicate with you. | Correspondence DataContact DataService Data | Legitimate interest: Our legitimate business interest to communicate with you about the service we provide.Performance of our contract with you. |
Current and prospective business partners (including contractors, consultants and agents)
| Purpose/Activity | Type of data | Lawful basis | Additional processing condition (where required) |
| To assess your suitability for engagement. | Identity DataContact DataEmployment DataCriminal Offence Data | Legitimate Interest:Our legitimate business interest to assess the suitability of the business partners we engage in assisting us to provide our products and services. | Explicit Consent.Regulatory requirements.Personal data is in the public domain.Employment, social security and social protection (if authorised by law). |
| To engage you in assisting us to provide our products and services. | Identity DataContact DataFinancial Data | Legitimate Interest:Our legitimate business interest to engage contractors, consultants and agents to provide our services.Performance of our contract with you. | N/A |
| To comply with our legal and regulatory obligations. | Identity DataContact Data | Processing is necessary in order for us to comply with our legal obligations. | N/A |
| To manage our relationship with you and communicate with you. | Correspondence DataContact Data | Legitimate interest:Our legitimate business interest to communicate with you about the services you provide to us. | N/A |
Tenants and owners of properties connected with the services we provide to our clients and property managers
| Purpose/Activity | Type of data | Lawful basis |
| Collection of rent rolls and leasing reports in commercial rental properties to be provided to lenders as required under loandocuments. | Identity DataProperty Data | Legitimate interest:Our legitimate business interest of providing this information as required to provide our services to our clients. |
| Collection of basic information concerning owners of properties or comparable assets that form part of the collateral underlying a loan in order to administer such loan. | Identity DataProperty Data | Legitimate interest:Our legitimate business interest of providing this information as required to provide our services to our clients. |
| For due diligence purposes (including Anti Money Laundering/Know Your Customer). | Identity DataContact DataFinancial DataID Numbers | Processing is necessary in order for us to comply with our legal obligations. |
Private individuals with an interest or in a position of control in an entity belonging to a client to which we provide services
| For due diligence purposes (including Anti Money Laundering/Know Your Customer). | Identity DataContact DataFinancial DataID Numbers | Processing is necessary in order for us to comply with our legal obligations. |
Private individuals that have provided a personal guarantee in any of the transactions that Trimont administers
| For due diligence purposes (including Anti Money Laundering/Know Your Customer). | Identity DataContact DataFinancial DataID Numbers | Processing is necessary in order for us to comply with our legal obligations. |
Users of our website
| Purpose/Activity | Type of data | Lawful basis |
| In order to maintain and improve our website and undertake website analytics. | Technical data | Legitimate business interest:Our legitimate business interest of maintaining and improving our website.Consent. |
| To communicate with you about any enquiries or complaints. | Correspondence data | Legitimate business interest:Our legitimate business interest to communicate with you about your enquiries and complaints. |
WHO WE SHARE YOUR PERSONAL DATA WITH
During the ordinary course of providing our services, your personal data may be provided to the recipients or categories of recipients set out below for the purposes set out above.
| Recipient | Category of Individual and Type of Data |
| Our business partners | Current and prospective clients:Identity Data and Contact Data |
| Tenants and owners of properties connected with our clients’ assets and property managers:Identity Data and Property Data | |
| Government bodies including: HMRC, the ICO and other authorities based in the United Kingdom and the Revenue Commissioners, the DPC and other authorities based in Ireland | All categories of individuals:Identity Data and Contact Data |
| Emergency service providers and law enforcement agencies | All categories of individuals:Identity Data and Contact Data |
| Professional advisers including lawyers, bankers, auditors and insurers | All categories of individuals:Identity Data and Contact DataPotentially any other category of data (depending on the circumstances) |
| Our related entity Trimont LLC | Current and prospective clients:Identity Data, Contact Data, Financial Data and ID Numbers |
| Current and prospective contractors, consultants and agents:Identity Data, Contact Data, Employment Data, Criminal Offence Data and Correspondence Data | |
| Prospective employees:Identity Data, Contact Data, Employment Data, Criminal Offence Data and Correspondence Data | |
| Tenants and owners of properties connected with the services we provide our clients and property managers:Identity Data and Property Data | |
| Service Providers acting as processors such as chartered surveyors or appraisers | Tenants and owners of properties connected with the services we provide our clients and property managers:Identity Data and Property Data |
HOW LONG WE KEEP YOUR PERSONAL DATA FOR
We will only retain your personal data for as long as necessary to fulfil the purposes that it was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the 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 applicable legal requirements. By way of example, we retain asset documents for either 7 years from the date of final inactivation of the asset (and related assets), or 7 years after expiration of a legal hold. For further information regarding our retention periods please contact us using the details set out below.
In some circumstances we may anonymise your personal data (so that it can no longer identify/be associated with you) for research or statistical purposes.
INTERNATIONAL TRANSFERS
We (or third parties acting on our behalf) may store or process information that we collect about you in countries outside of the UK and/or the European Economic Area (“EEA”). Where we make a transfer of your personal data outside of the UK and/or the EEA we will take the required steps to ensure that your personal data is protected. Such steps may include placing the party we are transferring information to under contractual obligations to protect your personal data to adequate standards.
We transfer your personal data to Trimont LLC (USA).
We ensure that any personal data transferred out of the UK or EEA is protected by putting in place appropriate measures to ensure such personal data is protected and that the third party and any subsidiaries comply with applicable data protection law, including using “Standard Contractual Clauses” which are clauses approved by the European Commission and the Information Commissioner’s Office.
HOW WE KEEP YOUR PERSONAL DATA SECURE
We implement physical, administrative and technical safeguards designed to protect your personal data from unauthorised access, use, or disclosure. Some of these processes and systems include using security cards or access codes to access areas that contain personal data, using secure servers, and using unique usernames, passwords and other protections. We also contractually require that our suppliers protect such information from unauthorised access, use, and disclosure.
Trimont has an overall security program based on widely accepted industry standards which provides a comprehensive set of controls comprising best practices in information security. Trimont also participates in an annual audits which includes a review of physical, network, and logical security and covers the security trust principle. To protect our systems and data, we employ, among other things, firewalls, an intrusion detection system, secured remote connectivity and encryption.
MARKETING
Trimont is selective about marketing which is sent to you, to ensure that it is relevant to you. Trimont may use personal data to form a view on what you may want, need, or what may be of interest to you. In order to send such marketing Trimont either relies on such marketing being sent to you in connection with your interactions with us or based on consent received from you for marketing.
You can ask Trimont to stop sending you marketing messages by clicking on the link in the marketing email or at any time by emailing: legaldepartment@trimont.com.
YOUR RIGHTS
Under data protection law you have the following rights in relation to your personal data:
- The right to be informed – you have the right to be informed about how we process your personal data. This information is provided to you via this Privacy Policy;
- The right of access – you have the right to access your personal data (commonly known as a “data subject access request”);
- The right to rectification – you have the right to request that we correct any personal data that we hold about you that you believe is incorrect or incomplete;
- The right to erasure – you have the right to request that we erase your personal data, under certain conditions;
- The right to object – you have the right to object to our processing of your personal data in certain circumstances;
- The right to restrict processing – you have the right to request restriction on our processing of your personal data, under certain conditions;
- The right to data portability – you have the right to request that we transfer your personal data to you or to a third party where this is technically feasible;
- The right to withdraw consent at any time where we are relying on consent to process your personal data; and
- You also have the right to obtain an explanation of any automated decision making or challenge and object to the processing of personal data for the purposes of automated decision making.
It is usually free of charge to exercise your data subject rights.
Please note, we may not always be able to do what you have asked. This is because your rights will not always apply (e.g. if it would impact the duties we owe to others, or if the law allows us to deal with the request in a different way).
Where we need to collect personal data by law or under the terms of the agreement we have with you and you fail to provide that data or exercise a certain right (such as the right to erasure or withdrawal of consent), we may no longer be able to provide our services to you.
If you wish to exercise any of the rights set out above, please email: legaldepartment@trimont.com
HOW TO CONTACT US
For further information on how your personal data is used and your rights in relation to your personal data please contact us by:
- Postal address: Trimont Europe Limited, Welbeck Works, 33 Welbeck Street, United Kingdom W1G 8EX or
- Email address: legaldepartment@trimont.com
QUESTIONS AND COMPLAINTS
If you have you have any questions about this policy or how we handle your personal data, please contact us using the details set out in the “how to contact us” section and we will do our best to resolve any issues.
If you’re not happy with the way we’re handling your personal data, you have a right to make a complaint with your local data protection supervisory authority at any time. In the UK this is the Information Commissioner’s Office (ICO). You can contact the ICO on +44 0303 123 1113. In Ireland this is the Data Protection Commission (DPC). You can contact the DPC on +353 01 7650 100.
UPDATES TO THIS PRIVACY POLICY
We will keep this policy under review and will update it from time to time to reflect developments in data protection law, regulation or new technologies. Any changes we makes to this policy will be published in an updated version on this website and we will bring any key changes to your attention.
This Privacy Policy was last updated on: 7 April 2023