Privacy Policy

We collect, and have collected over the last twelve (12) months, the following information from the following categories of individuals.

1.1 Website Visitors

Depending on how you choose to use the Site, we may need you to provide the following information:

• to contact us - name, address, e-mail address, telephone number, and other contact details along with any other information you choose to provide;
• to login to our client/investor portal - username and password (if applicable); and
• to subscribe to certain communications - email address and country of residence (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication).

For information on technology and cookies used on the Site, see the section entitled “Use of Technology and Cookies” below.

1.2 Office Visitors and Callers

When you visit Truenorth Capital Advisors offices or telephone certain Truenorth Capital Advisors employees, we may collect certain personal information such as:

• name, organization, and other contact details;
• video images of you in certain areas of the buildings in which our offices are located from CCTV footage;
• date and time of your visit to Truenorth Capital Advisors offices; and
• voiceprints and telephone numbers

1.3 Third-Party Service Providers, Vendors, and Suppliers

In the process of engaging third-party service providers, vendors, and suppliers, Truenorth Capital Advisors may collect certain personal information about them and/or about their individual representatives and associates including:

• name, job title, telephone number, email address, and other contact details;
• the name of the third-party service provider, vendor, or supplier with whom you are associated and its address; and
• information required to process payments, such as a tax ID number and wire instruction details.

We may also collect personal information about you from companies who maintain anti-money laundering and terrorism sanction screening and know your customer databases.

1.4 Recruitment (if applicable)

When you submit a job application through our Site or a third-party website for an open job position, we will process your personal information for purposes of recruitment.

1.5 Business Contacts, Prospective Clients, and Investors (if applicable)

Truenorth Capital Advisors may collect personal information about individuals or representatives of organizations with whom Truenorth Capital Advisors has a business relationship (or with whom Truenorth Capital Advisors seeks to establish a business relationship), as well as prospective clients and investors. Such information may include:

• name, address, telephone number, email address, and other contact details;
• organization name and address, job title; and
• investor type, strategy, product, and communication preferences (if you choose to receive marketing communications, you will have the option to opt out of receiving such communications at any time by contacting us or unsubscribing via a link in the particular communication).

Your personal information will be processed: (i) in order to comply with our legal and regulatory obligations; (ii) because we need the information for reasons of substantial public interests; (iii) in order to comply with our obligations under contract; and/or (iv) because we have a legitimate business interest in processing it, including for the following purposes (as applicable):

• to respond to your questions and handle and resolve complaints;
• to perform research with respect to the usage of the Site (applicable to Site visitors);
• to personalize and enhance your experience on our Site (applicable to Site visitors);
• to fill open job positions as part of a recruiting process (if applicable);
• to maintain the security of our premises, personnel, assets, systems, and intellectual property, and to manage access to our premises and our disaster recovery procedures (applicable to office visitors);
• to pay you for your services (applicable to third-party service providers, vendors, and suppliers);
• in order to comply with our obligations in connection with record-keeping requirements and applicable anti-money laundering, anti-corruption and bribery, terrorism financing rules, sanctions, and the prevention and detection of crime or other applicable laws or regulations of jurisdictions in which Truenorth Capital Advisors conducts business (applicable to office callers, third-party service providers, vendors, and suppliers);
• to maintain and provide appropriate management of our relationship with you;
• to exchange mail correspondence or documentation which may involve providing your contact details to couriers and service providers in charge of the delivery service;
• to engage your services in the future (applicable to third-party service providers, vendors, suppliers, and business contacts);
• to contact you to set up meetings and/or phone calls between you and your Truenorth Capital Advisors business contact(s); and
• to process your subscription requests and to send marketing communications about Truenorth Capital Advisors to you (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication) (applicable to Site visitors, business contacts, prospective clients, and investors).

Where required by applicable law, we will obtain your prior consent before sending you direct marketing communications. For information on how we use and process technology and cookies on the Site, see the section entitled “Use of Technology and Cookies” below. Where Truenorth Capital Advisors is relying on its legitimate interests as the ground for processing your personal information, we must carry out an assessment to ensure our interests do not override any rights you may have.

We may share, and have shared over the last twelve (12) months, the personal information we receive about you with the following categories of recipients:

• Truenorth Capital Advisors affiliated entities;
• third-party service providers, vendors, contractors, and agents of Truenorth Capital Advisors as part of normal business operations, including providers:
  • engaged to assist in know your customer and identity verification and anti-money laundering and terrorism screening (applicable to third-party service providers, vendors, and suppliers);
  • of accounting, banking, and other data processing services;
  • of information technology services and platforms/applications;
  • of courier services or other package delivery services;
  • of call recording and storage services (applicable to office callers);
• third-party outsourcing providers;
• building security personnel (applicable to office visitors);
• third parties acting on your behalf such as consultants and other agents;
• governmental authorities and/or law enforcement officials where required;
• financial institutions to wire payments to you (applicable to third-party service providers, vendors, and suppliers);
• advisors who provide audit, financial and legal advice to Truenorth Capital Advisors; and
• other parties to a merger, acquisition, reorganization, funding/investment round or similar transaction or proceeding involving Truenorth Capital Advisors, or steps in contemplation of such activities.

Truenorth Capital Advisors may also disclose your personal information to particular parties pursuant to your express consent, to fulfill your instructions, to comply with applicable laws and regulations or to fulfill other applicable requirements.

Personnel employed by service providers generally may have access to your personal information for the purpose of performing duties for Truenorth Capital Advisors but are prohibited from using such information for other purposes.

Your personal information may be transferred to or shared with entities in countries where data protection laws might not exist or be of a lower standard than in the United States. This includes the transfer of personal information among Truenorth Capital Advisors affiliated entities and the jurisdictions in which they operate. As of the date of this notice, Truenorth Capital Advisors has affiliates within the United States and the Cayman Islands. In addition, we may transfer or share your personal information with non-affiliated parties located in the same jurisdictions as Truenorth Capital Advisors entities as well as other jurisdictions and information may be stored and processed manually and electronically through global systems and tools for the purposes outlined in this Privacy Policy.

We do not, and will not, sell personal information collected about you.

Truenorth Capital Advisors maintains established internal policies and procedures, as well as physical and electronic safeguards that comply with applicable standards to safeguard access to personal information in our possession from accidental or unlawful destruction, loss, alteration, unauthorised use, or disclosure. We endeavor to limit access to personal information about you to those employees, agents, and other authorized parties who need to know the information to enable Truenorth Capital Advisors to provide products or services to you. Please note that such safeguards, however, do not guarantee that personal information transmitted via the Internet or stored in our systems or is otherwise under Truenorth Capital Advisors’s care will be absolutely safe from unauthorised use or intrusion from third parties due to the inherent nature of the Internet.

We will retain your personal information only for as long as we consider necessary in connection with the purposes set out in this Privacy Policy, unless applicable law or regulations require or permit a longer retention period, as described further in our document-retention policies. In addition, we may retain your personal information for the duration of any period necessary to establish, exercise, or defend any legal rights.

The rights described in this paragraph are applicable to you only if you reside in a jurisdiction where the provision of such rights is required by the data protection, privacy laws, and regulations of the governing regulatory authority. As such, where required by applicable law or regulation, you may ask Truenorth Capital Advisors for a copy of your personal information, to correct it, to erase it or to transfer it to other organizations. You may also have rights to object to some processing and, where we have asked for your consent to process your personal information, to withdraw this consent. In particular, you have rights to object to direct marketing at any time.

You should also be aware that these rights may be limited (for example, access to personal information may be denied if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information). In addition, Truenorth Capital Advisors may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process your personal information. Where we must collect and process personal information in order to comply with applicable law or enter into and perform services under an agreement with you, if you do not provide the personal information we may not be able to enter into the agreement or provide services as contemplated by any agreement we have in place. Where we are not able to fulfill a request you make because your rights are limited, we will inform you of the reasons as to why when responding.

Depending on the type of personal information processing described in this Privacy Policy, we may be operating as a sole or joint controller. If operating as joint controllers, the entities jointly determine the means and purposes of the processing of your personal information. However this has no impact on your rights and how you can exercise them against either of the joint controllers by contacting us as set out below.

Should you have any questions or requests in relation to your rights, please contact us via the website contact page. We will attempt to deal with all requests at the earliest opportunity. In addition, if you have unresolved concerns you have the right to complain, where permitted, to competent data protection authorities.

Where applicable, if you are a citizen of the United Kingdom you have the Right to Know/Access:

• You have the right to request that we disclose certain information to you about our collection and use of certain personal information about you as described below:
  • the specific pieces of personal information collected.
  • the categories of personal information collected.
  • the categories of personal information collected.
  • the purpose for collecting the personal information; and
  • the categories of third parties with whom we have shared the personal information.
• Right to Delete: You have the right to request that we delete your personal information. To do so, please submit a request to us by using the contact us page on the website
• Freedom from Discrimination: You have the right to be free from unlawful discrimination for exercising any of the rights above. We will need to verify your identity prior to addressing your request.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to personal information collected about you. To designate an authorised agent, the authorised agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

7.1 Technology

When you visit our Site or open our emails, we may collect certain information by automated means (such as by cookies, web-server logs, web beacons and JavaScript). The information we may collect in this manner includes your IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our Site, and dates and times of Site visits. We also may use these and similar technology in emails we send you to collect certain information, such as whether you opened or clicked on links in our email.

We may use third-party web analytics services on our Site. These service providers help us analyze how visitors use the Site. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers.

The providers of third-party plugins and widgets on our Site, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Site and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.

7.2 Cookies

Truenorth Capital Advisors may collect certain information about you through the use of cookies. Cookies are pieces of information or files placed on your device’s disk that provide information including how and when pages on the site are accessed by users.

We use the following types of cookies on our Site (note that some cookies may fall into multiple categories):

• Test Cookies: These cookies are simply to test whether or not your browser supports cookies. It stores a simple “True” or “False” value. If True, then the below cookies are applied.
• Tracking Cookies: These cookies are used to track anonymous user movement throughout the site for statistical purposes. For example, it may track the duration of a user’s visit to a certain page or for example, to allow Truenorth Capital Advisors to determine the number of users that visited a given page of the Site, or that read a certain press release.
• Required Cookies: These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for, such as remembering your login details, cannot be provided.
• Analytics Cookies: These cookies remember choices you make, such as the duration of your session. These can then be used to provide you with an experience more appropriate to your selections, and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized (such as the IP address through which you visit the Site) and they cannot track your browsing activity on other websites. Truenorth Capital Advisors uses a Google Analytics cookie to collect this information; you have the right to opt-out of having the Google Analytics cookie placed on your browser.

When visiting the site, you may receive a pop-up banner informing you of our use of cookies.

You may also be asked to agree to allow us to use particular analytics cookies while you browse the Site. If you receive our cookie consent banner, you may click “Cookie Consent Tool” to see which cookies we have on our Site and choose whether to accept or opt-out of certain cookies while on the Site. Should you choose not to give your consent for us to use some or all of the analytics cookies on our Site, these cookies will not be placed on your browser while you browse the Site.

You may configure your browser to set preferences regarding cookies such that you can have your computer warn you each time a cookie is sent. Note that you may decline placement of cookies if your internet browser permits, though this may impact your experience of using the Site, and certain portions of the Site may be inaccessible to you if you choose to do so. You may at any time delete any cookies from your hard drive. Aggregated data gathered from cookies is used by Truenorth Capital Advisors to help maintain and improve the information provided on this Site for users. Truenorth Capital Advisors may also employ other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We take seriously the protection of your personal information and have contracts in place with these authorized third parties to protect your personal information. We may also use these technical methods in HTML e-mails that we send Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. Truenorth Capital Advisors may collect the information from use of these technical methods in a form that is personally identifiable.

During some Site visits, Truenorth Capital Advisors may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page. Truenorth Capital Advisors may use this information to measure Site activity, to develop ideas for improving the Site and for any other purpose to the extent permitted by applicable law.

It is always your choice to decide what cookies are stored on your device and whether you choose to delete them. By accepting cookies that are stored on your computer when you visit our Site, we infer that you have accepted the use of cookies as explained in this Privacy Policy. Please note that while you are free to decline cookies, certain features of this site may be difficult or impossible to use and offerings will not be personalized.

You can manage cookies using various means:

• Test Cookies: These cookies are simply to test whether or not your browser supports cookies. It stores a simple “True” or “False” value. If True, then the below cookies are applied.
  • Apple Safari
  • Google Chrome
  • Microsoft Internet Explorer
  • Microsoft Edge
  • Mozilla Firefox
• Browser Setting: Your browser likely supports a variety of settings to control the cookies that are set on your computer or device and to delete cookies. These settings are typically found under the “Tools”, “Settings”, or “Options” menus. You can also check the “Help” menu of your browser to learn how to change the cookie preferences through your browser settings. Note that you will need to manage the settings for each browser and device you use. Further information from several popular browsers can be found at the following sites:
• Online Tools: Some third parties allow you to manage cookies through online tools If you choose to do so, you will not necessarily see fewer ads. However, the ads you see may be less relevant to your interests.
• Browser Extensions: Some third parties have created software that can be added to your web browser to manage their or third-party cookies.

Do Not Track

We do not track visitors of the Site over time and across third-party websites to provide targeted advertising and therefore the Site does not respond to Do Not Track (“DNT”) signals. However, some third-party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

The site may contain links to third-party websites which, in some cases, may be integrated into and appear to be part of the site. Truenorth Capital Advisors encourages you to read the privacy policies of other websites you link to from this Site and disclaims any responsibility for the privacy policies and procedures of any third-party websites that you reach via a hyperlink contained on this Site. Such hyperlinks are provided for your convenience only, and you access them at your own risk.

The site is not intended for or targeted towards, and we do not knowingly collect personal information via the site from, children under 13 years of age. If we learn we have collected or received personal information via the site about a child under 13, we will delete that information.

Truenorth Capital Advisors reserves the right in its sole discretion to modify or amend this Privacy Policy in any way at any time. Any such changes are effective upon posting and we will indicate in the Privacy Policy when it was most recently updated. You should review this Privacy Policy periodically for changes applicable to you. Additionally, note that by accessing this Site subsequent to any modification, you are deemed to have agreed to all terms of this Privacy Policy as modified or amended.

Please direct any questions regarding Truenorth Capital Advisors’s Privacy Policy by filling out form on the contact us page

Truenorth Capital Advisors Limited,

Devonshire House,

First Floor,

One Mayfair Place,

London,

W1J 8AJ