Trinary Capital is Proud to Be a Veteran Owned Business
Welcome to Trinary Capital! An important part of the relationship we have with our members is the information you choose to share with us. As a registered investment adviser firm, we’d like you to know how we treat your private information. The following Privacy Policy outlines the type of personal information that Trinary Capital, LLC collects, including through Trinary Capital’s website at https://trinarycapital.com (the “Site”), and through our mobile applications for iOS and Android devices. In using our services, you can expect that we will take the steps outlined below to keep the information we have about our members confidential and secure.
Privacy and confidentiality are important to us. Trinary Capital will never rent or sell your personal information to anyone. Our policy is to keep this information strictly safeguarded, and to use or disclose it only as needed to provide our services to you, or as permitted or required by law.
If you have any questions or if you believe that Trinary Capital has not adhered to this Privacy Policy, please contact us at rudyklapper@trinarycapital.com.
Information Trinary Capital Collects and Why
The non-public personal information Trinary Capital collects includes what you give us when you open an account or communicate with us. We may be required by law to collect certain information to provide you with investment advice.
This personal information could include:
Trinary Capital also collects various types of anonymous information about visitors to the Site and its apps, such as device-related information (including type of computer, browser type and IP address) and server log information (including the date and time of day of your visit, average time spent on the Site, browsing activity, etc.). We may collect various types of personal information based on your interaction with Trinary Capital – for example, by contacting our team directly, or otherwise giving it to us (via an email, phone call, or chat communication).
We use your non-public personal information and other collected information to better understand our members and our business, communicate with members, process payments, personalize the user experience, improve customer service, facilitate Site services, and enhance the overall Trinary Capital experience. We continually strive to improve our offerings based on the information and feedback we receive from you.
Processing of payments is not conducted through the Site. Payments are securely processed through your client account with our affiliate broker-dealer pursuant to the terms of your Client Advisory Contract, if any. However, you may be required to provide your payment details upon account sign-up on the Site, and will receive confirmation of any payments made to Trinary Capital through the contact information you provide to us through the Site.
Additionally, we may use your personal information to contact you regarding our own services, resources, or job openings that we think may be of interest. If you no longer wish to receive such communications, you may unsubscribe by using the “unsubscribe” link on any Trinary Capital emails. Please note that if you are a member, you cannot opt out of certain communications related to account administration, such as billing statements.
Security and Safeguards
Trinary Capital has procedures in place that we believe are reasonably designed to protect the security and confidentiality of your information. These include password-protected user access to our computer files and strict confidentiality policies that apply to all Trinary Capital personnel. We have adopted appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on the Site.
Non-public personal information about our customers and members is secured such as to prevent any employees from providing non-public personal information to unauthorized individuals who may seek to obtain such information through fraudulent means. While we cannot guarantee that non-public personal information may never be inadvertently disclosed or compromised, Trinary Capital has systems in place to take action in the event we suspect or detect that unauthorized individuals may have gained access to non-public personal information.
Sensitive and private data exchanges between the Site and its members happen over an SSL-secured communication channel that is encrypted and protected with digital signatures. At our physical office, we physically restrict access to non-public personal information to unauthorized individuals. Trinary Capital may segregate duties of personnel based on their responsibilities necessitating access to non-public personal information.
Trinary Capital regularly reviews, revises, and updates our information security procedures to account for changes in technology.
Information We Disclose
Trinary Capital does not sell, rent, or trade your personal information to anyone. Trinary Capital does not share non-public personal information with affiliates, i.e., companies related by common ownership or control, and does not participate in joint marketing arrangements.
Trinary Capital may disclose non-public personal affirmation to non-affiliated third parties for the purpose of conducting our investment advisory business on your behalf. For example, such disclosures may include, among other things, information related to billing and investment transactions for your investment account. Other non-affiliated third-party disclosures may include disclosures to third party service providers who supply us with computer-related services including data maintenance and document processing and delivery. Trinary Capital will not share your non-public personal information with non-affiliated third parties to market to you.
From time to time, we must give information about our business to legal or regulatory authorities or where required by law, rules, or regulations. This may include personal information about you. For example, we may disclose personal information in response to service of legal process, such as a court order, summons, subpoena, or as permitted or required by law when we reasonably believe it is necessary or appropriate to investigate or take action regarding illegal activities, potential fraud, or suspected violations of our Client Advisory Contract or Terms of Use.
Notice to Clients
Trinary Capital will send a copy of this Privacy Policy annually to its members. This policy may be periodically revised, and Trinary Capital will provide members with a revised policy if the changes materially alter the previous policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described herein unless we first notify you and provide you with an opportunity to prevent such information sharing.
Former Members and Customers
Trinary Capital will disclose non-public personal information about former members and customers only as permitted and/or required by law or legal process, or with the former member’s or customer’s consent. Trinary Capital treats former members’ and customers’ information with the same care as we do our current customers.
Access to and Retention of Your Personal Information
Once you have registered with Trinary Capital (either through the Site or on a mobile app), you can access your profile, review the information that you have provided, and revise that information as you see fit. Non-public personal information about you will be maintained during the time you are a member, and for any required time thereafter that such records are required to be maintained by federal and state securities laws. After this required period of record retention, all such information will be destroyed.
Accepting this Privacy Policy
By using and continuing to use the Site and Trinary Capital’s mobile apps, and/or our services, or otherwise providing us with personal information (such as an email address), you agree to the terms and conditions of this Privacy Policy and any updates thereto. As noted above, this policy may change from time to time, and will be provided to all members when materially amended and on an annual basis. This is our entire and exclusive Privacy Policy and supersedes any earlier version.
Anyone may request a copy of this Privacy Policy by contacting our Chief Compliance Officer, at rudyklapper@trinarycapital.com.