Regulators, including the U.S. Securities and Exchange Commission, have regulations outlining the obligations of financial institutions to protect the privacy of non-public personal information. Trimer Capital Management (“Trimer” or the “Firm”) takes our investors’ privacy seriously. This notice explains how we collect, share, and protect your personal information. We do not disclose non-public personal information about past, current, or prospective investors to third parties other than as described below unless with prior authorization.

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Personal information we collect. We collect personal information about you in connection with our providing advisory services to you. This information may include your mother's maiden name, passport information, marital status, social security number, and other information such as your assets, investment experience, transaction history, income, bank or brokerage account information, and wire transfer instructions.

How we collect this information. We collect this information from you through various means such as when you give us your contact information, enter into an investment advisory contract with us, buy securities (including interests in a fund) from us, tell us where to send money, make a wire transfer, or use our Investor Portal.

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How we use this information. We use the personal information we collect from you for our everyday business purposes. These purposes may include, for example, providing advisory services to you, opening accounts for you, processing transactions for your account, marketing products and services to you, and responding to court orders, regulatory requests, and legal investigations.

Disclosure to others. We may provide your personal information to our affiliates or firms that assist us in servicing your account and have a need for such information, such a broker or fund administrator. We may also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements (i.e., a formal agreement between nonaffiliated financial companies that together market financial products or services to you, such as placement agents). We require third party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that the Federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with nonaffiliates for them to market to you).

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How we protect your personal information. To protect your personal information from unauthorized access and use, we use security measures that comply with Federal law. These measures include computer safeguards and secured files and buildings.

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Whom to contact with questions. If you have any questions regarding this Privacy Notice, please contact us at ir@trimercap.com.

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European Union and United Kingdom Privacy Notice

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The European Union ("EU") General Data Protection Regulation 2016/679 (“EU GDPR”) and the EU GDPR as it forms part of the law of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018 (the “UK GDPR”) as supplemented by the Data Protection Act 2018 (together the “Applicable Data Protection Laws”) govern the use of personal data by investment funds managed by Trimer. Trimer recognizes the importance of protecting the privacy of investors in its funds and, in accordance with the Applicable Data Protection Laws, asks that you please read this Privacy Notice carefully to understand how we collect, share, and protect the personal information of investors in our funds.

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Personal information we collect and how it is collected. We, our service providers, and affiliates may process the following types of personal data in connection with our providing advisory services to you: personal data provided by you to us including your name, address, contact information, birthdate, gender, nationality, photograph, signature, occupational history, job title, income, assets, other financial information, bank and brokerage details, investment experience, tax residency, and tax identification information; personal data collected or generated by us in the course of business including information related to emails and related data, correspondence, call recordings, and website usage data; and personal data obtained by us from other sources including know your client ("KYC") or client due diligence procedures such as anti-money laundering (“AML”), counter-terrorist financing (“CTF”), proliferation financing, sanctions, or politically exposed persons reports, tax purposes (United States Foreign Account Tax Compliance Act (“FATCA”), OECD Common Reporting Standard (“CRS”), future regulatory, securities, and tax requirements, information from public websites, public sources of information, and information received from your advisors or intermediaries.

How we use this information. We use the personal information we collect from you for our everyday business purposes. For example, regarding performance of a contract such as a subscription for interests in a fund, your personal data will be processed in accordance with our internal investor assessment procedures to determine whether we may permit you to invest and whether your subscription documents are acceptable. Such processing may be undertaken prior to entering into a contract. If we accept your subscription documents to invest in a fund and you provide to the appropriate parties all required documentation, your personal data will be entered into the books of the fund and your personal data will be processed accordingly. If you are an investor in a fund, processing your personal data is necessary for managing and administering your holdings in that fund and any related account, as well as for distributing payments or circulating periodic reports in relation as required by relevant agreements or regulations.
 
For compliance with a legal obligation, including where it is necessary to comply with any applicable current or future legal, regulatory, or tax requirements imposed on a fund, we and/or any third party service provider, prior to your investment in a fund, during your investment in a fund, or after you have exited any or part of your investment in a fund, will process your personal data in accordance with legal obligations under company law, tax law, AML, and CTF legislation. AML / CTF or Ultimate Beneficial Ownership legislation and regulations may require us to identify prospective, existing, or previous investors in a fund and, as such, certain information will be required at the time of application as set out in relevant agreements, which will be processed accordingly. FATCA / CRS regulations may require us to collect certain information about each prospective, existing, and/or previous investor’s tax arrangements. For FATCA / CRS reporting purposes, please note that in certain circumstances we may be legally required to share such information and other financial information with respect to an investor’s interests in a fund with relevant tax authorities, and we may be legally restricted from disclosing to you that such processing is undertaken.
 
We may use your data for legitimate business interests such as carrying out ordinary business activities (including marketing activities) or other activities previously disclosed to our investors or referred to in this Privacy Notice; ensuring compliance with all legal and regulatory obligations and industry standards and preventing fraud; disclosing information to third-parties as provided for in this Privacy Notice; and recording, maintaining, and storing written correspondence, emails, facsimiles, and/or telephone calls that you make to and receive from us, any third party service provider, and their delegates or duly appointed agents and any of their respective, related, associated, or affiliated companies for processing and verification of instructions, management, and administration of your account(s), as well as any other matters related to investment in a fund, dispute resolution, record keeping, security, and/or training purposes.
 
We may disclose your personal data to affiliates and third-party service providers who are engaged in connection with the investment management, oversight, legal obligations, administration, distribution, operation of a fund and its assets or for purposes of providing services to us. These third parties will be subject to confidentiality requirements and will only use your personal data as described in this Privacy Notice and may include a fund's professional advisors, bankers and brokers, auditors, information technology consultants, other service providers, and competent authorities (including tax authorities), regulators, courts, law enforcement agencies, and other regulatory entities as required by applicable law, or as requested by such entities, our affiliates, or third party service providers for internal investigation and reporting purposes or in order to establish, exercise, or defend our legal rights.

 

Some of these parties will process your personal data in accordance with our instructions and others will themselves be responsible for their use of your personal data. These parties may be permitted to further disclose the personal data to other parties.

 

International Transfers. Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection of personal data as under the Applicable Data Protection Laws. Where a personal data transfer is made to a jurisdiction that provides a level of data protection lower than that prescribed by the Applicable Data Protection Laws, we will take steps to ensure the security and confidentiality of your personal data in accordance with the Applicable Data Protection Laws. You can obtain more details of the protection given to your personal data when it is transferred to different jurisdictions, including a copy of any standard data protection clauses entered into with recipients of your personal data by contacting us at ir@trimercap.com.

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Personal Data Security. We will ensure that appropriate technical and organizational measures are implemented to safeguard against unauthorized or unlawful processing of your personal data and against the accidental loss, destruction, or damage of your personal data.

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Personal Data Retention. How long we hold your personal data for will vary. The retention period will be determined by various criteria, including the purposes for which we are using it. In general, it will be kept for as long as is necessary for any of those purposes and legal obligations (as laws or regulations may set a minimum period for which we must keep your personal data).

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Data Subject Rights. You have a number of legal rights in relation to the personal data that we hold about you. These rights include the right to obtain information regarding the processing of your personal data and access to the personal data that we hold about you; in some circumstances, the right to receive certain personal data and the right to request that we transmit that data to a third party; the right to request that we rectify your personal data if it is inaccurate or incomplete; the right to request that we erase your personal data in certain circumstances provided that we are not legally entitled to retain it; the right to object to or request that the we restrict our processing of your personal data in certain circumstances provided that we are not legally entitled to continue processing your personal data or to refuse that request; and the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can find out more information about your rights under UK data protection laws by contacting the UK’s Information Commissioner’s Office, or by searching their website at ico.org.uk (or, if you are based in the EU, the relevant EU supervisory authority, details of which are available on request).

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If you would like further information on the collection, use, disclosure, transfer, or processing of your personal data or to exercise any of the rights listed above, please email ir@trimercap.com.