Last Updated: November 1, 2021

We at Trident Management LLC (“Trident,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared.  This Privacy Policy relates to the information collection and use practices of Trident in connection with our website located at www.trident.co (the “Website”) and our proprietary online investment platform accessible through our Website (the “Platform”). Both the Platform and Website are operated in the United States and intended for use by individuals who are located in the United States.

By browsing, accessing or using our Website or our Platform, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use (the “Terms”) found at www.trident.co/privacy-policy and/or the Supplemental Platform Agreement(s) as applicable. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in the Terms.

The Information We Collect and How We Use It

In the course of operating the Website and the Platform, Trident collects (and/or receives) the following types of information.

Member Information

When you sign up as either an investor or sponsor on our Platform (collectively referred to as a “Member”), you will be asked to provide certain information to establish an account.  Members may be asked for their:

• full name,
• email,
• phone number,
• postal code,
• LinkedIn profile link (optional),
• firm type, firm name, and firm address, and
• account information (e.g., username and password).

Sponsors may be asked for background on their firm including typical investment targets, track record, and professional background. The information is used for account creation, to provide account access authentication, and to analyze your use of the Platform.  We also use this information to further improve your user experience with respect to the Platform, including providing periodic updates on existing investments and new deals. 

This information may be used for the purposes of direct marketing or email campaigns – see Communication Preferences below.  All information we collect under this section is collectively called “Member Information”

Contact Information

When you contact us, connect with us through LinkedIn or a social media page, or email us directly, you may be asked to provide certain contact information (“Contact Information”), which may include your first name, last name, job title, name of organization, professional address, email address, and phone number.

This information is used to establish or strengthen our business relationships, such as by servicing prospective and existing Members, providing requested information, and directly marketing our services to you.

Transaction Information

As a Member, depending on your intended use of the Platform (as a sponsor or as an investor), you will also be required to provide us with additional information in connection with one or more potential transaction(s) (the “Transaction Information”).  Transaction Information is only collected once you have been approved for registration and have registered as a Member to the Platform, and our use, collection, disclosure, and processing thereof is governed by the applicable Supplemental Platform Agreement.

Other Information

In addition to the Member Information, Transaction Information and Contact Information, we may collect additional information (collectively, “Other Information”).  Such Other Information may include:

• Usage Information. We collect certain information regarding the activity of Visitors to our Website and Members of our Platform. This information includes IP addresses, user name, device type, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website or Platform you visit, and similar information concerning your use of the Website and the Platform.
• Third-Party Analytics. We use third-party analytics provider(s) on the Platform and/or the Website, as the case may be. These provides evaluate your use of the Website and the Platform, respectively, compile reports on activity (utilizing IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, date and time, city, country, region, time zone, advertising account attributes, media company, media company access token, amount of time spent on particular pages, display width, display height, email, and other application usage data), and analyze performance metrics (collectively, “Analytics Data”). 
• Other. We may also collect any other information that you provide or submit to us.

How We Use Information

You authorize us to use the Contact Information, Member Information and Other Information (collectively, “Information”) to provide the Platform and the Website and our services and to improve the same; to solicit your feedback; and to inform you about our products and services.

You also authorize us to use Information as described below.

• We will access and use the Information as required to provide our services to you and to address your questions or requests regarding our Platform, the Website services, and/or support.
• We may communicate with you about your account or our relationship. This may include providing you with information or documents through the Platform. We may also contact you about this Policy or our Platform or Website terms and conditions.

• We may employ other companies and individuals to perform functions on our behalf.  Examples may include providing technical assistance, analytics, customer service, marketing assistance, investment fund administration, hosting services, data storage, email management, and error tracking. 
• We may use Information for security purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform or Website.
• In an ongoing effort to better understand our customers, our Platform and Website, we may analyze certain Information in anonymized and/or aggregate form in order to operate, maintain, manage, and improve the Platform, the Website and services. This anonymous information does not identify you personally.  We may use anonymous and/or aggregate information, and share and/or license it with and to our affiliates, agents, business and promotional partners, and other third parties. 
• For other reasons we may describe to you.
• As requested or directed by you.

How We Share Information

We may share Information in the following ways:

• We may share Information with third parties who perform services on our behalf, as discussed above. These other companies will have access to the Information only as necessary to perform their functions and/or to the extent permitted by law.

• We may share some or all of your Information with any of our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control with us.
• As we develop our business, we might sell or buy businesses or assets.  In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
• To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of Trident or others.
• We may also disclose anonymous and/or aggregate user statistics in order to describe our services and business to current and prospective business partners and to other third parties for other lawful purposes.

• For other reasons we may describe to you.
• As requested or directed by you.

Communication Preferences

Members may access, remove, review, and/or make changes to Member Information by following the instructions found on the Platform.

In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Trident marketing e-mail or by contacting us directly at [email protected].  You cannot opt out of receiving transactional emails related to your account or transactions made through your account. We will use commercially reasonable efforts to process such requests in a timely manner.

Retention of Personal Information

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized, or as allowed under applicable law.

How We Protect Your Information

Trident takes very seriously the security and privacy of the personal information that it collects pursuant to this Privacy Policy. Accordingly, we will implement commercially reasonable security measures to protect your personal information.

However, the Internet is not 100% secure. We cannot promise that your use of our Platform or Website will be completely safe. We encourage you to use caution when using the Internet. 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.

Children

We do not knowingly collect personal information from children under the age of 13 through the Platform or the Website. If you are under 13, please do not give us any personal information.  We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission.  If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at [email protected] and we will endeavor to delete that information from our databases.

Important Notice to All Non-US Residents

Our Platform and servers are located in the U.S. Please be aware that your Information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.  If you are located outside of the U.S. and choose to use the Website or the Platform, you hereby consent to such transfer to, and processing and use in, the U.S.

Cookies & Other Tracking Technologies

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

• 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 depends 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.
  • You may also be able to control our use of cookies on the Website and Platform by using the cookie consent management tool found in the banner on our Website and Platform.
• Google Analytics: We may use Google Analytics on our Website and Platform to help us understand how you use our Website and Platform. You can learn about how to opt out of Google Analytics here.
• Hotjar: We may use Hotjar cookies on our Website and Platform to help us understand how you use our Website and Platform. You can learn how to opt out of Hotjar here.
• Intercom: We may use Intercom cookies on our Website and Platform to help us understand how you use our Website and Platform. You can learn how to opt out of Intercom 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.

Do Not Track

Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. Trident does not respond to “Do Not Track” settings or other related mechanisms at this time.

Links to External Websites

The Platform and the Website may contain links to third-party websites (“External Sites”). Trident has no control over the privacy practices or the content of any such External Sites.  As such, we are not responsible for the content or the privacy policies of such External Sites.  You should check the applicable privacy policy and terms of use when visiting any such External Sites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy.  We may change this Privacy Policy from time to time with or without notice to you. By accessing the Platform or the Website after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, our use of information from or about Members and Visitors or as otherwise described above is governed by this Privacy Policy, in effect at the time we collect such information.  Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at [email protected] with “Privacy Policy” in the subject line.

Copyright 2021 Trident Management LLC, Inc. All rights reserved.