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Privacy Policy

This Privacy Policy sets out details of the personal information that we may collect from you and how we may use that information. Trinity Group Partners are the Data Controllers of your personal data and we are committed to complying with the EU General Data Protection Regulation 2016/679 (the “GDPR”).

We are committed to ensuring that your data and privacy are protected and the information that we hold is secure and in line with internationally recognised standards.

Please take your time to read this Privacy Policy carefully. Where you are providing us with personal data concerning another person, you should provide them with a copy of this Privacy Policy.

Who we are and how to contact us

In this Privacy Policy references to “we” or “us” or “Trinity” are references to Trinity Group Partners of 1009, International Business Tower, Business Bay, Dubai, P.O.Box 58562, U.A.E. “Trinity Group Partners” means the group of companies, partnerships, subsidiaries and other entities carrying on business under the name “Trinity” (or such other names as may be adopted from time to time).

You can contact us by:

Post: 1009, International Business Tower, Business Bay, Dubai, P.O.Box 58562, U.A.E

Telephone: +971 4 447 8931

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

This Privacy Policy describes what personal information we may collect from you and about you and describes how and why we use your personal information.

Purpose of processing your data

Sometimes we request and hold personal information because we need it for our own purposes (for example to satisfy our regulatory anti-money laundering requirements), we will be the “data controller” of that personal information. Other times we process personal information on behalf of our clients (for example where we maintain a register of members for a company), we will be the “data processor” of that personal information. As a data controller, we must provide information to you about what we do with your personal information.

We have appointed a data protection officer to oversee our handling of personal information. If you have any questions about how we collect, store or use your information, you may contact our data protection officer at the address above.

How we collect your data

The following non-exhaustive list includes the types of personal data that we may collect about you in number of ways, for example:

  • From the information you provide to us when you meet us;
  • From information about you provided to us by your company or an intermediary;
  • When you communicate with us by telephone, fax, email or other forms of electronic communication.

In this respect, we may monitor, record and store any such communication;

  • When you complete (or we complete on your behalf) client on-boarding or application or other forms;
  • From other companies in the Trinity Group;
  • From your agents, advisers, intermediaries, and custodians of your assets;
  • From publicly available sources or from third parties, most commonly where we need to conduct background checks about you.

The categories of personal data we collect

We may collect the following categories of personal data about you:

  • Your name and contact information such as your home or business address, email address and telephone number;
  • Biographical information which may confirm your identity including your date of birth, tax identification number and your passport number or national identity card details, country of domicile and/or your nationality;
  • Information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details;
  • Information about your knowledge and experience in the investment field;
  • An understanding of your goals and objectives in procuring our services;
  • Information about your employment, education, family or personal circumstances, and interests, where relevant; and
  • Information to assess whether you may represent a politically exposed person or money laundering risk.

Legitimate interests

We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person. In this respect, we use your personal data for the following:

  • For marketing to you. In this respect, see the separate section on Marketing below;
  • Training our staff or monitoring their performance;
  • For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis;
  • Seeking advice on our rights and obligations, such as where we require our own legal advice.

Legal obligations

We also process your personal data for our compliance with a legal obligation which we are under. In this respect, we will use your personal data for the following:

  • To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws.
  • As required by tax authorities or any competent court or legal authority.

In this respect, we will share your personal data with the following:

  • Our advisers where it is necessary for us to obtain their advice or assistance;
  • Registered agents, government authorities, other associated registries;
  • Our auditors where it is necessary as part of their auditing functions;
  • With third parties who assist us in conducting background checks;
  • With relevant regulators or law enforcement agencies where we are required to do so.

Marketing

We will send you marketing about similar services we provide, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you.

We will communicate this to you in a number of ways including by post, telephone, email, SMS or other digital channels. If you object to receiving marketing from us at any time, kindly contact our Privacy and Data Compliance Officer.

Transfer and processing of your personal data outside the European Union

When sharing your personal data with third parties as set out in this Privacy Notice, as we are located in the U.A.E. it will have been transferred outside of the European Union. However, if your personal data is originally collected from inside the EU it will only be transferred on one of the following bases:

  • the country that we send the personal data to is approved by the European Commission as providing an adequate level of protection for personal data;
  • the transfer is to a recipient in the United States of America who has registered under the EU/US Privacy Shield;
  • the recipient has entered into European Commission standard contractual clauses with us; or 5 4164-6846-4402.2
  • you have explicitly consented to the same. To find out more about transfers by us of your personal data outside the UAE or E.U. kindly contact our Privacy and Data Compliance Officer.

Your rights

  • to be informed about how we use your personal data
  • to access your data
  • to have your data rectified promptly if it is inaccurate or incomplete
  • to have your data erased in specific circumstances
  • to restrict processing
  • to object to processing of your data
  • to portability of your data so that you can obtain and reuse your data
  • to prevent automated decision making and profiling

Withdrawing Consent

Should you wish to withdraw your consent to process data you can do so in writing however such a withdrawal may affect the way in which we deal with you and/or any related entities.

Please note that we are contractually obliged to retain certain information in accordance with legislation.

Retention of your data

We will only retain your personal data in accordance with jurisdictional legislation.

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The material on our website is intended to provide only general information and comment to our clients and the public. Although we make our best efforts to ensure that the information found on our website is accurate and timely, we cannot, and do not, guarantee that the information is either.
Trinity Group Office 1009, 10th Floor, International Business Tower, Business Bay P.O. Box 58562, Dubai, UAE