PRIVACY STATEMENT

Last updated: December 2020

This statement describes how we, Transtrend B.V., process your personal data.

‘Personal data’ means any information relating to an identified or identifiable individual. It includes, for example, your name, your contact information, your date of birth, details from your passport, photographic or video images, communication records and any other information about you.

We treat your personal data with care and in accordance with the applicable legislation, including the EU General Data Protection Regulation (GDPR). Keeping personal data secure is an important responsibility of us. We maintain physical, technical, electronic, procedural and organizational safeguards and security measures to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure or access. Our employees are bound by internal policies that require confidential treatment of personal data.

Section A of this statement describes the use of our website and the use of cookies, including related processing of personal data. Section B provides more information about the processing of your personal data other than through the use of our website. It includes information for and/or about (potential) clients, other contacts, KYC data, webinar attendees, job applicants, communication records, visiting our premises, transfer of data to third parties and transfer of data out of the European Economic Area (EEA). Section C provides information about the rights you have in relation to your personal data we process. In section D you can find our contact details.

This privacy statement may be amended from time to time without us notifying you. Use of our services (including use of our website) or your continued provision of personal data to us signifies acceptance of such revised statement.

A. USE OF OUR WEBSITE

When you use our website, various data is registered. For example, the type of connection, the browser used, your computer's operating system, your IP address and, when relevant, your e-mail address when you sign up for our mailing list. Some of this data may contain personal data, as described in more detail below.

1. IP address

When you visit our website, your IP address is saved automatically. Based on your IP address, information about the location from which the website is being visited can be obtained. If for example you visit our website from your place of work, then your employer’s IP address will be identified. If you visit our website from your home computer, this will be the IP address of your home computer.

Our website is maintained by an external service provider. This service provider has access to your IP address. We can obtain your IP address from the service provider upon our request. We will only submit such request in case of a (security) incident. We have entered into a data processing agreement with the service provider. In case you wish to receive more information about this provider, please contact us.

Our website is hosted at an external cloud provider. This cloud provider has access to your IP address. We have entered into a data processing agreement with the cloud provider. If you wish to receive more information about the cloud provider, please contact us.

The use of our website is monitored and analyzed. Your IP address is used to distinguish unique users and include an indication of your location in the analysis. The analysis is available to us on an aggregated and/or anonymous basis only. For this analysis, Google's “Analytics” and Hotjar’s services are used. This means Google and Hotjar may also have access to this data. Please refer to paragraph 3.2 ‘analytical cookies’ for more information about these services.

YouTube may have access to your IP address if you visit a page on our website in which the YouTube plug-in is integrated. LinkedIn and Twitter may also have access to your IP address if you click on the buttons of these parties on our website. Please refer to paragraph 3.3 ‘Third party cookies and hyperlinks’ for more information about this plug-in and these buttons.

2. Subscribing to our mailing list

If you sign up for our mailing list by submitting your e-mail address in the designated field on our website and your confirmation of the subscription hereafter, we process your personal data for this purpose. You will receive monthly as well as incidental updates on our firm, our services and performance. You have the right to withdraw your consent and you can unsubscribe from our mailing list at any time by contacting us, or by making use of the ‘opt-out’ possibility at the bottom of each mailing. We will store your data until you withdraw your consent or as long as relevant to stay in contact with you.

3. Use of cookies

A cookie is a file that is sent from a website and is saved by your browser to your computer's hard drive. Cookies are used by us to store data linked to the use of our website. This data can be read and written by us when you visit our website. You will find further information regarding how to switch cookies on or off or delete them by using your browser's ‘Help’ function.

Our website uses the following cookies.

3.1 Functional cookies

Functional cookies are used to ensure that a website works properly. Our website uses both session cookies and permanent cookies. Permanent cookies are saved for a longer period of time. Session cookies are deleted when you close your browser. Cookies enable us to recognize you when you return to our website. This enables the website to tailor the user experience to your preferences. For instance, cookies may be used to record that you gave your permission for the placement of cookies and to record your language preference. You may delete the cookies via your browser settings.

3.2 Analytical cookies

Analytical cookies allow us to analyze the use of our website. This allows us to improve the website so your visit is more enjoyable and you can access the information you are looking for more easily. These cookies are used to collect data on, for example, the number of visitors or the popular pages and subjects. Google's “Analytics” service and Hotjar are used for this purpose.

Google Analytics

A Google cookie is placed via our website as part of Google's “Analytics” service. We use this service to monitor how users use the website and to generate relevant reports. Google may share this data with third parties if it is legally required to do so, or insofar this data is processed by third parties on behalf of Google. We do not have any influence on this process. We have not permitted Google to use the analytics data obtained for other Google services.

The data collected by Google is anonymized as far as possible before it is processed by Google and provided to us. Your IP address is partially masked and is not processed in its entirety. Google may save data on its servers in the United States. We have entered into a data processing agreement that incorporates EU Standard Contractual Clauses and that guarantees an appropriate level of protection to the processing of any personal data. We do not use any other Google services in combination with the “Analytics” cookies.

Hotjar

Through our website, a cookie of Hotjar, a website service analysis tool, may be placed. We use Hotjar’s service to gain insights into how our website is used. The data collected by Hotjar is anonymized as far as possible before it is processed by Hotjar and provided to us. Your IP address is not stored by Hotjar. Hotjar may share data with third parties insofar as it is legally required to do so. We have signed a data processing agreement with Hotjar. Data is only stored within the EEA.

3.3 Third party cookies and hyperlinks

Our website includes buttons for sharing web pages on social networks, such as LinkedIn and Twitter. These buttons contain hyperlinks to these social networks and do not place cookies when you visit our website. Please refer to the privacy or cookie statements of LinkedIn and Twitter (which may be amended frequently) for further information on how LinkedIn and Twitter use cookies and process your data when you visit their websites.

Our website may contain hyperlinks to websites of third parties. By clicking on a hyperlink, you will be directed to an external website. Such external website may use cookies. Please refer to the privacy or cookie statement of such website to find out more about its use of cookies and the processing of any personal data.

Our website includes YouTube plug-ins. These plug-ins work by using code originating from YouTube itself. This code does not place cookies.

B. PROCESSING OF PERSONAL DATA

The paragraphs below describe the processing of your personal data by us, other than through the use of our website. It includes information for and/or about (1) (potential) clients, (2) other contacts, (3) KYC data, (4) webinar attendees, (5) job applicants, (6) recordings of communication, (7) visiting our premises, (8) the transfer of data to third parties and (9) transfers of data to parties outside the EEA. Please refer to the relevant paragraph(s).

1. Clients and potential clients

We process personal data of our clients and potential clients, including personal data of employees, directors, representatives and other associated persons of our (potential) institutional clients.

If you are a (potential) investor in MultiTrend or in one of the OmniTrend sub-funds of Transtrend Fund Alliance (TFA), please refer to TFA’s privacy statement for more information. If you are a (potential) investor in RoTrend Diversified Fund, please refer to RoTrend Diversified Fund’s privacy statement for more information.

We may process your personal details, such as your name, gender, (business) contact details, title or position, and any other information you have provided to us during our conversations, meetings, by e-mail or by any other means. Personal data may also be included in any materials and documents provided to us or entered into with us, such as promotional material, authorized signatories lists, contracts and related documents. We may also process data of you in the context of our customer due diligence; please refer to paragraph 3 below for more detail. We process this data to maintain contact with you, to provide you with our services, to maintain and optimize the quality of our services and our relationship with you, to provide you with relevant information about your investment(s), to provide you with updates about us, our services and performance, to provide you with other information that may be of interest to you and to record and be able to verify any agreements made with you or your company.

We process your personal data because this is necessary for compliance with legal obligations to which we are subject, to enter into and/or perform a contract with you, or for the purposes of a legitimate interest we have, each as described above. When we provide you with updates, this may be based on your consent. You have the right to withdraw your consent and you can unsubscribe from our mailing list at any time by contacting us, or by making use of the ‘opt-out’ possibility at the bottom of each mailing.

We will store your personal data as long as relevant within the context of our relationship. Contracts and related documents will be kept on file as long as necessary to exercise or defend actual or potential legal claims. Any data may be archived or backed up.

2. Other contacts

We may process personal data of our (potential) service providers, service providers of our clients, suppliers, other contacts and, where applicable, any of their representatives and employees. Personal details may include your name, gender, contact details, title or position, and any other information you have provided to us during our conversations, meetings, by e-mail or by any other means. Personal data may also be included in any materials and documents provided to us or entered into with us, such as contracts and authorized signatories lists. We may also process data of you in the context of our service provider due diligence; please refer to paragraph 3 below for more detail. We process this data to maintain contact with you, for example in order to use your services or purchase your products, to service clients, to conduct due diligence, for relationship management purposes and to record and be able to verify any agreements made with you or your company. Upon your request, we may also use your contact details to provide you with updates about us and our services.

We process your personal data because this is necessary for compliance with legal obligations to which we are subject, to enter into and/or perform a contract with you, or for the purposes of a legitimate interest we have, each as described above. When we send you updates this may be based on your consent. You have the right to withdraw your consent and you can unsubscribe from our mailing list at any time by contacting us, or by making use of the ‘opt-out’ possibility at the bottom of each mailing.

We will store your personal data as long as relevant within the context of our relationship. Contracts and related documents will be kept on file as long as necessary to exercise or defend actual or potential legal claims. Any data may be archived or backed up.

3. KYC data

Pursuant to applicable anti-money laundering and counter terrorist financing legislation, we have to conduct due diligence before we provide services to our clients or obtain certain services from our service providers. We have to finalize the due diligence satisfactorily prior to entering into a contract and repeat it periodically during the relationship with our clients and service providers. Pursuant to the due diligence we collect data from our (potential) clients and service providers, which may include data of employees, directors, representatives, shareholders, ultimate beneficial owners and other associated persons (“KYC data”). The KYC data we process may include personal data, such as your full name, place and date of birth, nationality, home address, country of residence, a copy of your passport, information about your regulatory listings, information about investigations or sanctions you are or may have been subject to and information in relation to the source of your funds and wealth. Personal data may also be included in promotional material, authorized signatory lists, contracts, certificates and any other related information we obtain from you.

We collect data from our clients or service providers directly or through a world-check database, sanction lists, or publicly accessible sources. In case we collect KYC data from our institutional clients or service providers, personal data of employees, directors, representatives, shareholders, ultimate beneficial owners and other associated persons may not be provided to us by those persons themselves, but by other representatives of the client or service provider. In case you are providing someone else’s personal data to us, you are requested to inform such person of the provision of their data to us and refer them to this privacy statement for more information about our processing of their personal data and the rights they have in this regard. Failure to provide certain requested data to us may result in the impossibility to invest or stay invested with us or to provide or keep providing services to us.

We process KYC data because this is necessary for compliance with legal obligations to which we are subject and because this is necessary to enter into and/or perform a contract with you.

KYC data will be kept on file for at least five years after the termination of our relationship. If retention is necessary for the effective implementation of internal measures for the prevention or detection of money laundering or terrorist financing, the files will be kept on file for up to an additional five years. Any data may be archived or backed up.

4. Webinar attendees

If you attend one of our webinars, we will process your personal data that you entered in the registration form, including your name, e-mail address, country, organization, job title and any information you entered in the questions and comments field. We process this data to provide you access to the webinar and for compliance purposes, including compliance with applicable marketing restrictions. We may also use your details to contact you to communicate with you about the webinar and our services, for relationship management purposes and to optimize the quality of the webinar and our services. Without providing the details in the required fields, you will not be able to attend the webinar. We process your personal data because this is necessary for compliance with legal obligations to which we are subject and for legitimate interest we have, as described above. We may store your personal data as long as relevant within the context of our relationship. Any data may be archived or backed up.

Webinars are hosted at an external webinar software provider, LogMeIn, that processes your personal data on behalf of us and has access to the personal data you entered in the registration form. LogMeIn may store data on servers that are located in the United States. We have entered into a data processing agreement that is based on the EU Standard Contractual Clauses. This means that an appropriate level of protection is applied to the processing of personal data.

5. Job applicants

Personal data of job applicants are processed in accordance with our privacy statement for job applicants, which is available in the Dutch language.

6. Recording of communications

We may record communications, including telephone conversations, chat messages, or communications by any other means. We record several of our telephone lines, including those of our Trading and Electronic Trading teams, our Investor Relations team, our head of Finance, our head of IT and certain conference call telephones.

We record communications to comply with legal obligations and for the purposes of legitimate interests, as it may serve as proof of transactions or related matters in the event of disagreement, for verification of agreements or instructions, and for investigation and fraud prevention purposes.

Communication records will be retained for a period of five years or, upon request of a regulator, for a period of seven years starting from the date of the recording. Communication records other than telephone recordings may be archived or backed up.

7. Visiting our premises

Video images are obtained from visitors of our premises by security cameras. We process this data with the legitimate interest to secure our premises and the safety of our employees and visitors. Access cannot be granted without processing this data.

Recordings of security cameras will be kept either for a maximum of four weeks after the recording or until after an identified incident has received adequate follow-up.

8. Transfer of data to third parties

We may process data through the use of, and store data on the servers of, a cloud service provider. We have entered into a data processing agreement with our cloud service provider which guarantees an adequate level of data protection. Data is only stored within the EEA. We may also make use of IT or other supporting service providers that process personal data on behalf of us. In such case, we will enter into a data processing agreement with such party that guarantees the protection of personal data. If you wish to receive more information about the cloud service provider or our other service providers and the related processing of data, please contact us.

In addition to what is described above in relation to specific data transfers, we may also share data with our affiliates, professional advisors and auditors to the extent required. Any such party will be subject to obligations of confidentiality. Where possible and appropriate, any personal data will be anonymized. We may also have to transfer data to any court, governmental or supervisory authorities, at the (authorized) request of a regulator, when this may be required pursuant to applicable regulations or pursuant to a court order. Should this be the case, we will use reasonable endeavors to notify you of such transfer, to the extent we are allowed to do so.

9. Transfer of data outside the EEA

We may need to transfer personal data to parties that are located in countries outside of the EEA that are not recognized to provide an adequate level of data protection according to EEA standards. Regulations with respect to the protection of personal data can be less strict in such countries, as a result of which personal data may be less adequately protected. In such case, where necessary or appropriate, we will adopt safeguards to ensure an appropriate level of protection of your personal data. In particular, we may transfer personal data to affiliates with offices around the world. For this purpose, we have entered into an inter-affiliate data transfer agreement in which we have included standard clauses regarding the protection of personal data. If you wish to receive more information, please contact us.

C. YOUR RIGHTS
1. Requests related to personal data

You can contact us if you have any of the following requests:

- Access to your personal data: you can request us to provide you with an overview of your personal data processed by us.

- Rectification: you can request us to rectify any inaccurate personal data that we hold of you.

- Erasure: you can request us to erase any personal data that we hold of you.

- Restriction of processing: in certain circumstances, you may request us to restrict the processing of your personal data.

- Data portability: in certain circumstances, you can request us to provide you, in a structured, commonly used and machine-readable format, with the personal data that you provided to us earlier, and transmit this data to another party.

- Objection: where processing of your personal data is based on a legitimate interest of us, you have the right to object to such processing.

We will endeavor to meet any of the above requests. There may however be circumstances in which we will not be able to do so. For example, we are not allowed to erase any information which we are legally required to retain. There may also be residual information that will remain within our databases and other records, which cannot be removed.

If you have any of the abovementioned requests, please contact us at info@transtrend.com or +31 10 453 6510. We will respond to your request as soon as possible, but at least within one month.

To prevent abuse, we may ask you to adequately identify yourself. If your request concerns personal data linked to a cookie, please send us a copy of this cookie. Cookies can be found via your browser settings.

2. Complaints

If you have a complaint about our processing of your personal data, please do not hesitate to share this complaint with us. You also have the right to lodge a complaint with the competent authority of your home EU member state. In the Netherlands, you can lodge a complaint with the Autoriteit Persoonsgegevens. Please refer to www.autoriteitpersoonsgegevens.nl.

D. CONTACT DETAILS

Transtrend’s mail address is:

Transtrend B.V. | P.O. Box 444 | 3000 AK Rotterdam | The Netherlands


Transtrend’s visitors address is:

Transtrend B.V. | Weena 723, unit C5.070 | 3013 AM Rotterdam | The Netherlands


If you have any questions about this privacy statement, please contact us as at info@transtrend.com or +31 10 453 6510. Of course, you may also contact us through your usual contact person.