Privacy policy

This policy is issued by Trinova Real Estate LLP and its subsidiaries (“Trinova”), a company incorporated in England and Wales under number OC394174, its registered office being 12 Finsbury Square, Finsbury, EC2A 1AS, London. Trinova is registered with the Information Commissioner’s Officer under reference ZA292558.

This policy summarises how Trinova use, share and store the data collected from you when you visit Trinova’s website or associated fund website, when you become an investor in a fund managed by Trinova, when you become a tenant in a property owned by one of our funds or when you apply for a job with Trinova. This privacy policy applies to Trinova’s site and all products and services offered by Trinova and by entering our site you are agreeing to the policies described herein.

Trinova is committed to safeguarding the personal information which you may provide to us and to the extent that Trinova collects any personal information, Trinova will hold it in confidence in accordance with the Data Protection Act 1998 and the General Data Protection Regulation (GDPR) (EU) 2016/679 which came into force on 25 May 2018.

Information you share with us

You may be asked to voluntarily provide certain personal information details about you such as your name, address, telephone number, email address and other information in connection with Trinova’s customer or tenant registration procedures and job application process. Trinova will use this information for the administration and servicing of your investments, performing its obligations under lease contracts, evaluating job applications and other related activities and to ensure compliance with its obligations under the UK regulatory regime. Trinova may disclose the information to its agents and service providers.

Please note that by submitting personal information you are consenting to such information being processed for the purposes referred to above. You agree that Trinova has the right to use and store such data on its internal systems and to transfer it to its associated companies, third-party agents and service providers where applicable.

Information we collect from you

The Trinova site collects both behavioural data (information about how you use our site); and technical data
(information about the device you use to access our site). Trinova uses the Google Analytics service provided by Google
Inc. (Google) to collect this data.

Examples of behavioural data collected:

• Terms entered via our search facility
• Pages visited
• Length of time spent on each page
• The referring site from which you visited

Examples of technical data collected:

• Your web browser type and version
• Your device type and operating system

The site does not collect any data that makes you personally identifiable. The information obtained via Google Analytics
is anonymised and cannot be attributed to any one individual. Google Analytics is set to retain data for a duration of
38 months.

Google provides a method to opt out of their Google Analytics service completely. Opting out will prevent Google
Analytics from collecting your data from any site that uses their service.

Why we collect this information

This information provides us with a better understanding of how our site is being used. This understanding informs any
improvements we undertake and ensures that the site and its content continue to best serve the needs of our visitors.

How we keep data safe

Trinova adheres to the following practices to help keep the data that we process safe:

• We encrypt and protect the transmission of information using Secure Sockets Layer (SSL).
• We host our site and its contents with Amazon Web Services (AWS) on a secure server within the European Economic
  Area (EEA).
• We limit server access by Internet Protocol (IP) address to only those that require it.
• We have a server firewall in place that permits only standard inbound internet traffic HTTP, HTTPS & SSH
  (restricted by IP).
• We control and regulate access to our Trinova data files and email accounts.
• We enforce strong passwords and 2 factor authentication (2FA) wherever possible.

Provision of Information to Third Parties

A Data Processor is a third party with which we are required to share personal detail in the provision of investment and
property management services. Trinova will only share personal information in the following circumstances:

• where the transfer is necessary to fulfil the requirements of the contract or operation for which the
  information was provided, and the third party is a Data Processor;
• as required by a court order or any other legal or regulatory requirement.

Trinova does not collect or compile personal data or information obtained through the Website for dissemination or sale
to outside parties.

We may share your personal information with third party organisations:

• Professional firms, agents and advisers who we use to help run your accounts and services, collect what you owe,
  administer funds, manage properties and explore new ways of doing business;
• HM Revenue & Customs, regulators and other authorities;
• Third parties as required through Trinova’s regulatory requirements arising from the provision of investment
  services;
• Fraud prevention agencies;
• Companies we have a joint venture or agreement to co-operate with;
• Companies within the Swiss Life group
• Organisations that introduce you to us;
• Independent Financial Advisors, or other regulated entities or parties involved in the management of your
  relationship with Trinova; or
• Companies you ask us to share your data with.

We require all third parties with whom we share your personal information to respect the security of your data and to
treat it in accordance with the law. We do not allow such third parties to use your personal data for their own
purposes. We only permit them to process your personal data for specified purposes and in accordance with our
instructions.

Your Rights and Your Personal Data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of your personal data which Trinova holds about you;
• The right to request that Trinova corrects any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary for Trinova to retain such
  data;
• The right to withdraw your consent to the processing at any time;
• The right to request that Trinova provide the data subject with his/her personal data and where possible, to
  transmit that data directly to another data controller, (known as the right to data portability);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request
  a restriction is placed on further processing;
• The right to object to the processing of personal data;
• The right to lodge a complaint with the Information Commissioners Office.

How long we keep your Data

We are required under the Markets in Financial Instruments Directive II (MIFID II) rules to retain all client related
information for up to 7 years, after which time it will be destroyed. Personal information that we use for marketing
purposes will be kept with us until you notify us that you no longer wish to receive this information. After you stop
being a client, we may keep your data for up to 7 years for one of these reasons:

• To respond to any questions or complaints;
• To show that we treated you fairly; or
• To maintain records according to rules that apply to us.

CVs in respect of unsuccessful applicants are deleted promptly following completion of the job application process.

Marketing

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk
about marketing.
The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we
decide which products, services and offers may be relevant for you. We can only use your personal information to send
you marketing messages if we have either your consent or a legitimate interest. That is when we have a business or
commercial reason to use your information. It must not unfairly go against what is right and best for you. You can ask
us to stop sending you marketing messages by contacting us at any time. If at any point you believe the information we
process on you is incorrect you can request to see this information and have it corrected or deleted. If you wish to
raise a complaint on how we have handled your personal data, you can contact us on the details below to have the matter
investigated.

Privacy policy changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for
other operational, legal or regulatory reasons. For clarity, we shall include the date of the most recent revision at
the bottom of the page. The amended privacy policy shall be effective as from that date. We therefore recommend that you
refer back to this periodically.

Your rights

If you are a client you have the right to access information we hold about you and request your information to be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Data controller

For the purpose of the Data Protection Act (1998) and the General Data Protection Regulations (GDPR) (EU) 2016/679 the
Data Controller is Trinova Real Estate LLP.

Contact us

Trinova is not required to appoint a Data Protection Officer. For more information about our privacy policies or if you
have any questions, we welcome your comments.

Please contact us at info@trinovare.com, by telephone 020 7776 5000 or by mail:
Trinova Real Estate LLP
The Aspect 12 Finsbury Square, London, England, EC2A 1AS

Last updated: 1 August 2023
Trinova Real Estate LLP, 12 Finsbury Square, Finsbury, EC2A 1AS, London.