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General Privacy Notice

The Trimont group of companies is committed to protecting your privacy.  This General Privacy Notice (“Notice”) describes how we collect, use, process and disclose personal data, i.e., information that can be used to identify an individual (e.g., name, address, date of birth, personal identification numbers).  Additional information on our personal data practices may be provided in supplemental privacy statements or notices provided prior to or at the time of data collection.

Privacy notice information for specific jurisdictions may be found at:

Australia
California
United Kingdom/EU

What kinds of personal data we collect and why

Personal data we collect may include:

  • business and personal contact information (e.g., name, postal/email address, telephone number),
  • information needed to perform AML/KYC (e.g., beneficial ownership interests, residency),
  • government issued identifiers to confirm identify,
  • CCTV footage at our offices as a protection for our employees, visitors, facilities and property,
  • account information including login credentials at our website,
  • human resource-related information about prospective and current employees and contractors (e.g., employment and educational history, professional designations, pay and performance information),
  • financial information from individual guarantors for transactions that we administer.

The personal data we may collect differs, depending on the nature of our interaction with you. We may use your personal data for the purposes of operating our business, including fulfilling contractual or legal requirements, delivering, supporting, improving, and customizing our website and products and services, sending communications related to our business, responding to inquiries and complaints, managing applications for employment, record keeping, improving your online experience and for other purposes permitted by applicable law.

How we collect personal data

We may collect personal data about you as you use our website, products or services, or interact with us including through telephone calls, and from third parties such as our employees, contractors, consultants and agents, parties to whom we provide services, your current and previous employers, and government bodies, in accordance with applicable law and where required, upon obtaining your consent.  We may combine the information we collect from you over time with information obtained from other sources. This helps us improve overall accuracy and completeness.

We do  not knowingly collect personal data of users under 18 years of age.  If you become aware of any data that we have collected from users under the age of 18, please contact us using the contact information provided below.  We do not disclose personal data to non-affiliated third parties for their direct marketing purposes.

Our website may use automatic data collection tools, such as cookies, embedded web links, and web beacons, upon obtaining your consent where required under applicable law. These tools collect certain standard information that your browser sends to our website such as:

  • browser type and the address of the website from which you arrived at our website,
  • internet Protocol (IP) address, a number automatically assigned to your computer or device whenever you connect to the Internet, which, among other things, allows web servers to locate and identify your device,
  • clickstream behavior, which includes, for example, the pages you view, time spent and the links you click. 

This information is used to better understand and improve the usability, performance, and effectiveness of our website and to help tailor content. These tools help make your visit to our website easier, more efficient, and more valuable by providing you with a customized experience and recognizing you when you return. If you wish to obtain more information about how we use automatic data collection tools, such as cookies and widgets, please contact us using the contact information provided below.

We may provide links to other third-party websites and services that are outside our control and not covered by this Notice. We encourage you to review the privacy statements posted on those websites. We disclaim any obligation to review the security or content at such websites.

With whom we share personal data

We may share your personal data within our organization, to our affiliates, and to third parties such as contractors, business partners, government bodies, external auditors and insurance providers for the purposes of operating our business, delivering, supporting, improving, and customizing our website, products or services, sending communications related to our business, and for other purposes permitted by applicable law. We may also disclose information about you if we are required to do so by law or legal process, to law enforcement authorities, regulators and/or other government entities and/or other competent authorities based on a lawful disclosure request, or when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.  We may also disclose personal data to business partners, service vendors, authorized third-party agents, or contractors to provide a requested solution in aggregated, anonymized, and/or de-identified form which cannot reasonably be used to identify you, and if we otherwise notify you and you consent to the disclosure.  We do not and will not sell or rent personal data.

We may transfer your personal data to affiliates or to third parties located outside of your country of residence.  By using our website, products or services or providing personal data to us, where applicable law permits, you consent to the transfer, processing, and storage of such data outside of your country of residence where data protection standards may be different.  The transfer of personal data is however restricted in certain countries such as the United Kingdom and the countries located in the European Economic Area unless proper data safeguards are in place in the receiving country, including the United States of America. Prior to transferring your personal data, we take reasonable measures to ensure that proper safeguards and contractual arrangements are in place to satisfy the legal requirements allowing such data transfers to occur.

How we keep personal data secure

  • We intend to protect your personal data and treat it securely. We implement physical, administrative, and technical safeguards designed to protect your personal data from unauthorized access, use, modification, disclosure or destruction including using security cards or access codes to access areas that contain personal data, secure servers to store personal data, and unique usernames, passwords and other protections on systems that can access personal data. We generally hold personal data in paper files stored securely at our premises and electronically, in computer systems and databases either operated by us or our external service providers. This means not everyone within our organization will or should have access to such data so that the risk of data leakage is actively managed. User access to such data is limited in accordance with job description, seniority, and location. We also contractually require that our suppliers protect such information from unauthorized access, use, and disclosure. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any personal data you provide to us.
  • We maintain data, including personal data, on servers, which may be located in data centers in multiple jurisdictions. Such data centers are run by operators required to maintain industry best practices and adhere to applicable law. Physical access to data servers and related equipment is controlled and monitored 24/7. Logical access is protected through encryption of data in transfer and during storage. We follow a detailed data security plan and industry best practices and monitor such operators through annual critical vendor reviews.

How long we retain personal data

We will retain your personal data as needed to fulfill the purposes for which it was collected. Unless applicable law requires otherwise, we will retain and use your personal data as necessary to comply with our business requirements, retention policies, and legal obligations, and to resolve disputes, protect our business and our assets, and enforce our agreements, subject to applicable law.  

How to request correction or deletion of personal data

You have the right to request that we correct or delete any of your personal data that we have collected and retained, subject to certain exceptions.  Following a request, we must first verify your identity. We will take commercially reasonable steps to verify your identity, which may include requiring you to provide us with a copy of state-issued identification and, in some cases, an affidavit. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you.  We will only use personal data provided in connection with a verifiable request to verify the requestor’s identity or authority to make the request.  Making a verifiable request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal data associated with that specific account.

We endeavor to respond to a verifiable request within a reasonable time but not longer than the time period allowed under applicable law. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If the personal data we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date, unless an exception applies.  We will take reasonable steps to destroy or de-identify personal data if that information is no longer needed for the purposes for which we are authorized to use it.  If you want to use a pseudonym or remain anonymous when dealing with us, you should notify us and we will try to accommodate your request, subject to our ability to interact with you without having your personal data and always subject to any applicable law and/or regulation (including, but not limited to, applicable “know your customer” or anti-money laundering requirements).

We may deny a request to correct or delete personal data if the request is unreasonable or retaining the information in its current form is necessary for us or our service providers to:

  • complete the transaction for which we collected the personal data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract involving you,
  • detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities,
  • debug products to identify and repair errors that impair existing intended functionality.
  • exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law,
  • comply with applicable law,
  • enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us,
  • make other internal and lawful uses of that information, which are compatible with the context in which it was provided.

In addition, we may deny access to personal data if the request is unreasonable, providing access would have an unreasonable impact on the privacy of another person or would pose a serious and imminent threat to the life or health of any person; or if there are other legal grounds to deny the request. 

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

If you need help for any reason accessing, correcting, or deleting your personal data, withdrawing your consent where our collection and processing of your personal data is based on such consent, or exercising your right to nominate any individual who will exercise your rights in case of your death or incapacity where such right is available to you under applicable law, please contact us directly.

How to submit a request for access, portability, correction or deletion of personal data

Please submit a verifiable request to us by either:

Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your personal data. You may also make a verifiable request on behalf of your minor child. The request must also contain sufficient detail that allows us to properly understand, evaluate, and respond to it. 

Communication Preferences

You can manage your communication preferences by sending us a message by mail to Trimont LLC, Legal Department, Two Alliance Center, 3560 Lenox Road NE, Suite 2200, Atlanta, Georgia 30326, USA, or by emailing us at: legaldepartment@trimont.com.

These choices do not apply to service notifications or other required communications related to products and services, which you may receive periodically unless you stop using or cancel the applicable products or services in accordance with their terms and conditions.

By using our website, products or services, or otherwise providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use. For example, if we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our website by sending an email, or otherwise contacting you.

How to File a Complaint

If you would like to file a complaint, then you must first make the complaint in writing, using the contact details below. We will have a reasonable time to respond to the complaint.  If the privacy issue cannot be resolved, you may take your complaint to:

  • UK and EU residents, the Information Commissioner’s Office
  • Australian residents,  the Office of the Australian Information Commissioner.
  • United States residents, state attorney general’s office or Federal Trade Commission

How to Contact Us

United States of America

Trimont LLC
Two Alliance Center
3560 Lenox Road NE, Suite 2200
Atlanta, Georgia 30326 USA

Attn: Legal Department

Email: legaldepartment@trimont.com

United Kingdom / EU

Trimont Europe Limited
33 Welbeck Street
London W1G 8EX
United Kingdom
Attn: Legal Department
Email: legaldepartment@trimont.com

Australia

Trimont AU Pty Ltd
Suite 8.02 Level 8, 4-6 Bligh Street
Sydney NSW 2000
Australia
Attn: Legal Department
Email: legaldepartment@trimont.com