SCOPE

This Privacy Policy (“Policy”) describes how Trillium Management, LLC and its controlled affiliates treat personal Information on our websites where the Policy is located (the “Platform”).

“Information” should be understood as personal identifying information collected and defined under US data privacy laws and personal data collected and defined under General Data Protection Regulation, (“GDPR”).

TYPES OF INFORMATION WE COLLECT

We collect Information from you and about you. Here are some examples of the Information we may collect:

• Contact Information. For example, we may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.
• Information You Submit. We may collect Information when you send us a message through the “Contact Us” page or similar features on our Platform.
• Device Information. For example, we may collect the type of device you use to access our Platform. We may also collect your device identifier, IP address or operating system.
• Employment Information. For example, we may collect your resume, employment history and references.
• Social Media Information. For example, we may collect your profile Information and Information you post to your, or our, social media accounts.
• Commercial Information. We may collect personal Information that could identify you and relates to the services in which you are interested or have considered. We may also collect personal Information about your consuming history or tendencies.
• Account Information. Certain portions of the Platform allow you to create a user account. In connection with that account, we may collect your username and password.
• Other Information. If you use our website, we may collect information about the browser you are using. We might look at what site you came from, or what site you visit when you leave us.

HOW WE COLLECT YOUR INFORMATION

We collect your Information in different ways. Below are some examples of how we may collect your Information.

• Directly From You. For example, when you register for an account, submit an inquiry to us or interact with our social media pages.
• Passively. For example, when you visit and navigate our Platform on any device. We may also collect Information about users over time and across different websites and devices when you use the Platform.
• From Third Parties. We may receive Information about you from other sources. For example, this may include receiving Information from our business partners, including but not limited to analytics vendors.
• By Combining Information. For example, we may combine Information that we collect offline with Information we collect through our Platform. We may also combine Information we collect about you from the different devices you use to access our Platform.
• By Using Cookies and Electronic Tools. We may place, view, or use “cookies”, web server logs, web beacons, pixel tags or other electronic tools to collect statistical and other Information about your use of our websites and other websites.
• By Web Advertising. We and our designated service providers, or third parties such as advertisers or their advertising servers, may place or recognize unique cookies on your computer or use other electronic tools in order to help display advertisements that you see on our websites or on other websites.
• Ways of Collecting Your Information: We may collect your Information in a multitude of ways, including, but not limited to, phone calls, customer service contacts, mobile apps, websites and other sources.

HOW WE USE YOUR INFORMATION

Examples of how we may use your Information include:

• To Run and Improve Our Platform and Business. We may use your Information to make our Platform and business better. We may also use your Information to provide you with Information about our business.
•  To Respond to Your Requests or Questions. This may include responding to your feedback.
• To Communicate With You. We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Platform terms and conditions.
• For Marketing Purposes. We may provide you with Information about our company and our business initiatives, e.g., we may provide you with marketing information, special offers and promotions via various means including e-mail, in accordance with applicable law. Where we have obtained your consent to send these marketing communications to you, we therefore process your personal Information for these purposes on the basis of your consent. However, where permitted by applicable law we may lawfully use your personal Information to send you such marketing communications (including via email) without your consent. Where permitted by applicable law we may also process your personal Information for these marketing purposes where necessary for our legitimate interests, which include promoting our products and services, special offers and promotions which may be of interest to you. For more information about your choices related to these communications, see the Choices section below.
• For Security Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform.
• For Normal Course of Business, if necessary. We may also process your personal Information and other Information if such processing is necessary:

1. to comply with the law or in response to a subpoena, court order, law enforcement request, or other legal process;
2. to protect the interests, rights, safety, or property of us or others;
3. to enforce any terms of service on our websites or the terms and conditions of our activity;
4. to provide you and others with the services or products requested by you or your designated representative, and to perform other activities related to such services and products, including billing and collection;
5. to provide you with special offers or promotions from us that may be of interest to you, where permitted;
6. as part of a business transaction where all or some of our assets are bought, sold, or otherwise transferred by act of law or contract; or
7. to operate our systems properly.

• As Otherwise Permitted By Law or As We May Notify You.
•  As Requested or Directed By You.

HOW WE SHARE YOUR INFORMATION

We may share your Information in the following ways:

• Internally. We may share your Information with our parent, subsidiary and affiliate entities.
• With Our Service Providers. We may share your Information with third parties who perform services on our behalf. For example, this may include companies that send emails on our behalf or help us run our Platform.
• With Our Business Partners. For example, we may also share personal Information with social media sites, advertisers, media buying agencies, advertising networks and advertising service providers for the purposes described in this Policy. We may also share personal Information with companies that help us learn more about our customers.
• With Any Successors to All or Part of Our Business. For example, if we merge with, are acquired by, or sell part of our business to another entity. This may include an asset sale, corporate reorganization, or other change of control.
• To Comply With the Law or To Protect Ourselves. For example, this could include responding to a court order or subpoena. It could also include sharing Information if a government agency or investigatory body requests. We might share Information when we are investigating a potential fraud.
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• For Other Reasons We May Describe to You with proper notice.

• As Requested or Directed By You.

CHILDREN UNDER 13

The Platform where this Policy is located is meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 13 and strive to comply with the provisions of COPPA (The Children’s Online Privacy Protection Act) and the GDPR. If you are a parent or legal guardian and think your child under 13 has provided us with Information, please contact us at privacypolicy@TRLM.com. You can also write to us at the address listed at the end of this website Policy. Please mark your inquiries “COPPA/GDPR Information Request.”

CHOICES REGARDING YOUR INFORMATION

You have certain choices about how we use your Information. Certain choices you make are browser and device specific.

Marketing Communications:

You can opt out of receiving our marketing communications. Note that you will still receive transactional messages from us, including Information about your account and responses to your inquiries.

Cookies & Other Tracking Technologies:

• Cookies: You can adjust your browser to control cookies to require your affirmative acceptance for new cookies, automatically reject cookies and/or delete or disable existing cookies. How you do so depend on the type of cookie and the browser that you are using. For more Information on how to control browser cookies, click here. If Information about your browser is not available through this page, please search your browser for instructions about how to opt-out of cookie collection.
• Google Analytics: We may use Google Analytics on our Platform to help us understand how you use our Platform. You can learn about how to opt-out of Google Analytics here.
• Facebook: We may use Facebook cookies to target ads to you. You can learn about how to opt-out of receiving targeted advertisements from Facebook here.
• Email Tools: You can also change your email settings to block the automatic download of images in email messages, as such images may contain technologies that help us understand how you interact with the message.
• Note that deleting or blocking cookies may impact your experience on our website, as some features may not be available. Certain options you select are browser and device specific.

Our Do Not Track Policy:

• Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.  If you block cookies, certain features on our sites may not work.  If you block or reject cookies, not all of the tracking described here will stop.
•  Options you select are browser and device specific.

EU CITIZENS AND RESIDENTS

EU residents or citizens have certain rights under the General Data Protection Regulation (“GDPR”), which include:

•   Requesting rectification of your personal Information.
•   Objecting to the processing of your personal Information for direct marketing purposes.
•   Objecting to the processing of your personal Information (including profiling) where our legal basis for processing your personal Information is our legitimate interests.
•   Requesting erasure of your personal Information.
•   Requesting restriction of your personal Information.
•   Exercise your right to data portability.
•   Objecting to automated decision making (including profiling).

In addition, where we process your personal Information on the basis of your consent as mentioned in this Policy, you can withdraw that consent at any time.

We may retain your personal Information as is necessary to fulfill the purposes for which the personal Information was collected. We may also retain this personal Information as required by law or contract, in order to fulfill our legal obligations and protect our legal rights. However, once the purpose for the collection is no longer valid, and there is no legal reason for us to retain your personal Information, you may request us to delete your personal Information.

You can make a request to us to exercise any of these rights by contacting Us at the at the details set out in “Contact Us” section below.

SECURITY

The internet is not 100% secure. We cannot promise that your use of our Platform will be completely safe. We encourage you to use caution when using the Internet. We use reasonable means to safeguard personal Information under our control, and more specifically:

(a) to safeguard personal Information against loss, theft, unauthorized use, disclosure, or modification;

(b) to ensure the integrity of your personal Information.

 A user id and a password are needed to access certain areas of our Platform. It is your responsibility to protect your username and password.

STORAGE OF INFORMATION

Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal Information to the United States.

This Platform is intended for use in the United States and the EU and is subject to the laws of the United States and the EU, which may not provide the same level of protections as those in your own country.

LINKS

Our Platform may contain links to other third-party sites that are not governed by this Policy. If you click on a link to a third-party site, you will be taken to a site we do not control.  We are not responsible for the privacy practices used by third-party sites or any Information you may provide while on such sites. We suggest that you read the privacy policies of those sites carefully, before providing applicable third parties with your Information. We are not responsible for these third-party sites.

HOW TO CONTACT US

If you have any questions, comments, or concerns with respect to our privacy practices or this Policy or wish to update your Information, please feel free to contact us at privacypolicy@TRLM.com.

CHANGES IN POLICY

From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law, prior to the effective change. We will also post an updated copy on our Platform. Please check our Platform periodically for updates.