Privacy Policy

We consider privacy to be fundamental to our relationships with our clients and investors. In the course of serving your account, we collect personal information about you (“Personal Information”). We are committed to maintaining confidentiality, integrity and security of our clients and investors’ personal information. It is our policy to respect the privacy of our current and former clients and investors and to protect the personal information entrusted to us. This privacy policy (“Privacy Policy”) describes the standards followed by TriLinc Global Advisors, LLC and its affiliated advisers and investment funds (collectively “TriLinc”) for handling your personal information and how we use the information we collect about you.

Information We May Collect

We may collect Personal Information about you from the following sources:

Information on applications, subscription agreements or other forms which may include your name, address, e-mail address, telephone number, social security number, tax identification number, date of birth, marital status, driver’s license number, citizenship, assets, income, employment history, beneficiary information, personal bank account information, broker/dealer, financial advisor, IRA custodian, account joint owners and similar parties.
Information about your transactions with us, our affiliates, and others, such as the types of products you purchase, your account balances and transactional history.
If you visit our Web site, information we collect via web server, often referred to as “cookies.” Cookies may include information about the specific device you are using, such as the hardware model, operating system version, web-browser software, and your Internet Protocol (IP) address/MAC address/device identifier. We may record this information on our server logs from your browser, including how you came to and used our Web site; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (country or city-level location) and other technical data collected through cookies, pixel tags, and other similar technologies that uniquely identify your browser. We may also collect information about how your device has interacted with our Web site, including pages accessed and links clicked. We may use identifiers to recognize you when you arrive at our Web site via an external link, such as a link appearing on a third-party site.
Do Not Track (DNT): Most internet browsers have incorporated “Do Not Track” (DNT) features. These features, when turned on, send a signal to the sites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret DNT signals, nor a common definition of “tracking”, we do not currently respond to DNT signals.
Sensitive Information: Generally, we do not collect sensitive information about you unless required by law or where you consent for us to do so (and in any event only where it is relevant). We will not collect sensitive information about you where this is expressly prohibited by law. Sensitive information includes information relating to: race; political or religious beliefs; sexual orientation and sexual life; criminal convictions; membership of professional or trade associations or unions; biometric and health information; or information about your affiliation with certain organizations, such as professional associations.

Why We Collect Personal Information

We collect information from and about you:

in order to identify you as a client and investor;
in order to establish and maintain your client and investor accounts;
in order to complete your client and investor transactions;
in order to communicate and share information with your broker/dealer, financial advisor, IRA custodian, joint owners and other similar parties acting at your request and on your behalf; and
in order to meet our obligations under the laws and regulations that govern us.

Use and Disclosure of Information

We may disclose Personal Information we collect about you as described above to the following types of third parties:

Our Affiliated Companies. We believe that by sharing information about you and your accounts among our companies, we are better able to serve your investment needs. We may share your Personal Information with our affiliates for the purposes listed above.
Other Nonaffiliated Third Parties. Except as outlined below, we do not share your Personal Information with nonaffiliated third parties. However, we may disclose your Personal Information to the extent permitted, or as required, by law. For example, to:
– correct technical problems and malfunctions in how we provide our products and services to you and to technically process your information;
– protect the security and integrity of our records and web site;
– protect our rights and property and the rights and property of others;
– take precautions against liability;
– respond to claims that your information violates the rights and interests of third parties;
– take actions required by law or to respond to judicial process;
– assist with detection, investigation or reporting of actual or potential fraud, misrepresentation or criminal activity; and
– provide personal information to law enforcement agencies or for an investigation on a matter related to public safety to the extent permitted under other provisions of law.

Procedures

Protecting Your Information

Our employees are required to follow the procedures we have developed to protect the integrity of your information. These procedures include:

Restricting physical and other access to your Personal Information to persons with a legitimate business need to know the information in order to service your account;
Contractually obligating third parties doing business with us to keep your Personal Information confidential and secure and to use it only as authorized by us;
Providing information to you only after we have used reasonable efforts to assure ourselves of your identity by asking for and receiving from you information only you should know;
Maintaining reasonably adequate physical, electronic, and procedural safeguards to protect your information; and
Disposing of personal information in a secure manner.

Your Rights Regarding Your Personal Information

Subject to local law, you may have certain rights regarding personal information we have collected about you. Such rights might include the right to (a) know what personal information we have collected about you, (b) update or correct such information if you believe there is an error, (c) restrict the processing of your personal information, (d) request deletion of your personal information, (e) object to our use of your personal information, or (f) request transmission of your personal information to another data controller. If you wish to exercise any of these rights, please email info@trilincglobal.com.

If you would like to make a complaint about how we have handled your personal information, or make a complaint about a breach of data protection laws, please email us. Complaints will be investigated and the outcome of the investigation will be communicated to you after the complaint is made in accordance with applicable law. You may also have a right in some locations to file a complaint with your local data protection authority.

California Residents’ Rights

We may disclose personal data to our affiliates, who may use this information for purposes outlined in this Privacy Policy. Under California law, separate legal entities are considered “third parties” and certain communications with our affiliates might be viewed as promoting our services. Therefore, we provide the following information for California residents who have provided us with their personal information.

California residents may request information about our disclosures of certain categories of personal data to third parties for such third parties’ direct marketing purpose. This request may be made no more than once per calendar year by emailing info@trilincglobal.com. In response, we will provide a list of the categories of personal information disclosed to third parties for direct marketing purposes during the immediately preceding calendar year, along with their names and addresses.

Children

Our products and services are not directed towards anyone under the age of 18 nor do we knowingly contact or engage with anyone under the age of 18. If a parent or guardian becomes aware that his/her child has provided us with personal information, please contact us at info@trilincglobal.com and we will delete any of the child’s personal information we may have collected.

CAN-SPAM Act of 2003

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to deliver important updates and communication about our products and services.

To be in accordance with CAN-SPAM we agree to do the following:

NOT use false, or misleading subjects or email addresses
Identify the message as an advertisement in some reasonable way
Include the physical address of our business or site headquarters
Honor opt-out/unsubscribe requests quickly
Allow users to unsubscribe by using the link at the bottom of each email

If you would like to stop receiving our emails, please follow the instructions at the bottom of each email to unsubscribe.

Keeping You Informed

If at any point we decide to use or disclose your Personal Information in a manner different from that stated at the time it was collected, we will notify you in writing, which may be by email. If you object to the change to our Privacy Policy, then you must contact us using the information provided in the notice. We will otherwise use and disclose a client and investor’s Personal Information in accordance with the Privacy Policy.

Data Retention

We retain Personal Information pursuant to our records retention program, for as long as is necessary for the purposes described under “Use and Disclosure of Information” above, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights. The criteria used to determine the period for which your Personal Information will be stored varies depending on the legal basis under which we process such personal data:

Questions about our Privacy Policy

If you have any questions about our Privacy Policy, please contact us via telephone at (310) 997-0580 or email Sarah Pikover, Director of Compliance, at info@trilincglobal.com.