Translink Capital (“Translink”, “we”, “our” or “us”) is committed to protecting the privacy of those who entrust us with their personal information. “Personal information” means any information pertaining to an identified or identifiable individual and may include, for example, email addresses, contact details and any similar information provided to us in the course of our business operations. Personal information that is de-identified or anonymized is not considered personal information. This Privacy Policy details our commitment to your privacy.
This Privacy Policy applies to our website, and other online and mobile services (the “Services”), and explains how we collect, use, and disclose information through the Services.
By using or visiting the Services or otherwise interacting with us, you are accepting the practices described in this Privacy Policy. We recommend that you review this Privacy Policy periodically, as it may be updated from time-to-time.
This Privacy Policy does not address our privacy practices with respect to any personal information we may collect from an investor in funds that we sponsor or manage. We address these practices in separate notices to investors as required by law.
We explain here what categories of personal information we collect, where we get it from, and with whom we share it:
Category of Personal Information Collected
Contact and other personal information: such as name, address, email address, and phone number. We may collect personal information about you from your discussions with us, from legal documents, from information you supply about your investments or portfolio, from your incoming wire transfers or invoice payments, and from applications and other forms completed by you or provided to us by your authorized representatives and other fiduciaries. We may also collect personal information from email correspondence, telephone calls, paper communications, social media, our own websites and online platforms, visiting our offices, inquiring about or buying products or services from us, providing products or services to us and trade events such as conferences or exhibition.
Browsing information: such as your IP address, MAC address or other device identifier, your device type or mobile carrier, standard server log information, the kind of browser or computer you use, pages and content that you visit on our Services, what you click on, the state and country from which you access the Services, date and time of your visit, and web pages you linked to our Services from.
Recruitment and Job Application information: such as name, address, and phone number, or information on a resume or a curriculum vitae.
Source
Contact and other personal information: Users of our Services.
Browsing information: Our Services and your interactions with the Services, including through the use of cookies and other tracking technologies explained further below.
Recruitment and Job Application information: Visitors of our Services or job applicants.
Purpose for Collection
Contact and other personal information: To allow our users to access various aspects of our Services, to communicate with and respond to our users about our Services, or to meet legal obligations, and provide you with the products, promotions, services, newsletters, and information you request.
Browsing information: To evaluate usage of the Services and improve performance; to protect the security and integrity of the Services and our business, such as preventing fraud, hacking, and other criminal activity or to meet legal obligations.
Recruitment and Job Application information: To consider you for an employment position or to respond to an employment inquiry.
Categories of Recipients
Contact and other personal information: We may share this information with our affiliates, select marketing or other service providers and partners that perform services for us (such as for hosting the Services, or providing other customer service functions).
Browsing information: Our service providers who help us with fraud protection and service analytics.
Recruitment and Job Application information: Our service providers who help us with employee matters or job fulfillment.
Translink will only use personal information for the purposes identified in this Privacy Policy. In some jurisdictions, individuals may have the right to withdraw consent from certain uses. If you reside in such jurisdictions, you may have additional rights that are detailed in sections 8 and 9. We may use service providers to provide some of our services. In all cases, any service providers will be contractually limited in the way they may use personal information maintained by Translink, including requirements that such information be maintained in a confidential and secure manner.
In Connection with Business Transfers: In the event that a division, a service, or all of Translink is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.
To Comply with Laws: Translink may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose personal information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our clients, our clients’ customers or employees or others, in accordance with or as authorized by law.
The Services use certain technologies such as cookies, beacons, tags and scripts. A cookie is a small piece of information that a website, online application, or email may save to your browser or your computer’s hard drive for use in subsequent visits to the website or online application. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies or how to disable cookies altogether. If you reject cookies, you may not be able to participate in certain activities or receive a promotion tailored to you. Translink does not control and does not guarantee the effectiveness of browser-based tools for managing cookies.
Translink may use Google Analytics or other analytics providers to evaluate use of the Services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.
Any and all personal information collected on the Services will be kept strictly confidential and will not be sold, reused, rented, disclosed, or loaned to third parties, except as otherwise described in this Privacy Policy.
Do Not Track (DNT): This is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium, or W3C, has not yet established universal standards for recognizable DNT signals, and therefore Translink and the Services do not recognize DNT.
Where applicable, Translink uses industry-standard technology in connection with the Services to help protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise authorized or required by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or de-identified.
Translink may, subject to applicable laws, use personal information from users of our Services to contact them about our Services or services, including to provide them with information on additional products or services from Translink that may be of interest to them. You may exercise choices regarding these communications as follows:
Our Services is not directed toward children and we do not knowingly solicit or collect personal information online from children under the age of 13 without prior verifiable parental consent. If Translink learns that a child under the age of 13 has submitted personal information online without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from children under age 13 without verifiable parental consent, please contact us using the information detailed in the Contacting Us section below.
In certain jurisdictions, you may have the right to obtain confirmation as to whether your personal information is being processed, information about the purposes of that processing, and information about the recipients to whom your personal data have been or will be disclosed. You may also have the right to receive a copy of the personal data you have provided and/or request its deletion.
California law permits our customers who are California residents to request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year.
To make such a request, please write to us at the following address:
TransLink Capital
530 Lytton Avenue, Suite 300
Palo Alto, CA 94301
If you are a California resident, California law provides you with the following rights with respect to your personal information:
When you exercise these rights and submit a request to us, we will verify your identity (or the identity and authorization of your agent) by asking you for your email address, telephone number, information about your company’s contract with Translink, or the last four digits of a credit or debit card used with Translink. We also may use a third party verification provider to verify your identity.
Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.
For the 12-month period prior to the date of this Privacy Policy, Translink has not sold any personal information about its clients or their employees or about the customers of our clients; nor does it have any plans to do so in the future.
Please note: if you are a customer of one of our clients, you should contact them first concerning your California privacy rights.
In some cases, personal information that we process of users located in various countries, including in Canada, the EU and Switzerland or relative to queries or visitors to the Services may be transferred to the United States or other countries that may not have data privacy laws that provide the same protection as the countries where you reside. You understand and expressly agree that your personal information may therefore be transferred, processed and stored outside of your country of residence, and therefore may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions.
We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or in the United States. For information on how you can file a privacy complaint with the Federal Trade Commission, please visit: https://www.ftccomplaintassistant.gov/.
Translink will review and update its Privacy Policy as required to keep current with rules and regulations, new technologies and security standards. We will post those changes on the Services and/or update the Privacy Policy modification date below. In certain cases and if the changes are material, we will provide written notice to users directly by email or otherwise.
This policy is effective November 12, 2020.
If there are any questions regarding this Privacy Policy or to request a copy of this Privacy Policy in another format you may contact us using the information below.
530 Lytton Avenue, Suite 300, Palo Alto, CA 94301
T (650) 330-7353
info@translinkcapital.com