Privacy Policy

References in this privacy policy to "we", "us" and "our" means Trovant Capital Limited (“Trovant”), a company registered in England and Wales under company number 11986820 and registered office at 11 Rosemont Road, London, England, NW3 6NG. We respect your privacy and are committed to protecting your personal data in accordance with the applicable data protection laws, including the General Data Protection Regulation and the Data Protection Act 2018. This privacy policy explains how and why we collect personal data about you and how we use it.

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In this privacy policy references to "CRM" meaning the client relationship management software managed by Trovant in the course of doing business. This privacy policy also applies to the visitors to our website at www.trovant.co.uk ("Website"). References to "you" and "your" mean references to any person logged within our CRM, including those that have opted to receive marketing (“Members”), their authorised representatives and any personnel nominated to interact with us on a Members' behalf), any visitors to our Website, any other recipient of our services or our business contact.

 

1. Our role

 

Our CRM is used solely to facilitate our core business efficiently, that is, to match our Member’s property acquisition requirements with properties that we have access to acquire via our vendor network. Our CRM allows us to shortlist Members, based on information they have provided to us, who may be interested in properties that we are seeking to dispose of on behalf of our vendors. This shortlisting reduces the amount of marketing every other client receives and ensures what is received is targeted and relevant to each client’s requirements. Trovant does not have any other commercial interest in your data and does not provide any information about our clients to any other party for commercial purposes.

 

2. Personal Information we collect

 

2.1 If you are a Member, we may collect information about you which will include the following:

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(a) Profile data: This will include information you provide to us by completing the registration process and other forms on the Website, or information which we may receive from professional adviser in order to create your account and your profile. This could include (but is not limited to) your name, date of birth, postal address, phone number, email address, certain tax information, property requirements and any other salient information about property requirements that have come about from conversations with us. We only request and collect profile data that is necessary for us to process in order to operate our CRM.

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(b) Transaction data: Details about investment activities you have conduct with us.

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(c) Personal information provided by third parties: Occasionally we may receive information about you from other sources (such as information provided by a solicitor during the course of a transaction), which we will add to the information we already hold about you in order to help us better operate our CRM. We may also receive certain personal information about you from your professional adviser (if applicable). In certain circumstances we may be required to carry out enhanced due diligence checks to comply with our obligations under the Money Laundering Regulations 2017. These enhanced checks may reveal information about criminal convictions or information about an individual’s political opinions and associations and/or other sensitive personal data. We will only collect and process such information to the extent necessary to comply with our regulatory obligations and in accordance with the applicable data protection laws.

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2.2 Contact data: if you contact us via any our Website, by telephone or by email, we will collect information necessary to identify you and respond to your query.

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2.3 Marketing and Communications data includes your preferences in receiving marketing from us (mail, email or telephone) for your communication preferences.

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2.4 Business contact data: If you are not a Member but we are in contact with you in relation to our offering or we have come into contact with you in the course of our business, we may collect your personal data, such as information printed on your business card or other information you give us, in order to stay in touch with you.

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2.5 Other than information that we may receive as a result of enhanced due diligence checks, we do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union Membership, information about your health or genetic or biometric data), or data relating to criminal convictions and offences.

 

3. How we use your personal information

 

3.1 We may collect, store and use your personal information for the following purposes:

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(a) to provide you with details of upcoming property transactions relevant to your preferences;

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(b) to create and manage your CRM profile and update the records we hold about you from time to time;

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(c) to manage the investment process, including payments, fees and charges;

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(d) to provide and administer our CRM, our Website and related services;

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(e) to contact you in relation to the use of our CRM, including to provide you reminders on important usage issues;

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(f) to respond to your queries;

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(g) to detect and prevent fraud;

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(h) to conduct "know your customer" checks;

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(i) to administer our contract with you;

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(j) to develop and improve our services and products;

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(k) to notify you about changes to our service, our terms and conditions and this privacy policy;

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(l) to manage our business, including for accounting and auditing purposes;

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(m) to maintain our IT systems and manage hosting of our data;

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(n) to collect and recover money owed to us;

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(o) to deal with legal disputes involving you, any relevant manager, professional adviser or our suppliers;

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(p) to provide you with information, services that you request from us or which we feel may interest you, when you have consented to be contacted for such purposes; and

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(q) to verify your identity in order to prevent and detect crime and money laundering.

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3.2 We do not sell your data. From time to time, we may send emails containing information about new features and other news about Trovant Capital, such as suggestions and recommendations about similar services we offer, which we think may be of interest to you. This is considered direct marketing. You have the right to stop us from contacting you for these purposes. We will always inform you if we intend to use your personal data for such purposes. You can object to our processing of your personal data for such purposes at any time by contacting us at info@trovant.co.uk.

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3.3 Some of the above purposes for processing will overlap and there may be several grounds which justify our use of your personal information.

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3.4 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

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3.5 Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

4. Lawful processing

 

4.1 We are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:

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(a)Legitimate interest: Where applicable law allows us to collect and use personal information for our legitimate interests, and the use of your personal information is fair, balanced and does not unduly impact your rights. We may rely on this ground to process your personal information when we believe that it is more practical or appropriate than asking for your consent. For instance, we rely on the legitimate interest ground to process your personal information in order to protect the security of our networks e.g. when we receive external emails we will scan such emails for any threats. We will also rely on the legitimate interest ground to communicate with you in most instances and if we need to process your personal data to conduct our business in an efficient, compliant and profitable manner. It may also be necessary to process your personal data for legitimate interest of a third party, such as your solicitor or professional adviser.

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(b) Contractual relationship: Where it is necessary for us to process your personal information in order to perform a contract to which you are a party (or to take steps at your request prior to entering a contract).

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(c) Legal obligation: Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject. This may be the case for example when we process personal data collected by us in order to comply with our obligations under the Money Laundering Regulations 2017.

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(d) Consent: Where we ask for your consent for our use of your personal information for a specific purpose. You always have the right to withdraw your consent.

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4.2 Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your personal information. Please contact us if you need details about the specific legal grounds we are relying on to process your personal information where more than one ground has been set out in the table above.

 

5. Will we disclose your personal data to anyone?

 

5.1 We may need to share your personal information with third parties such as: our vendors, our vendor’s solicitors and professional advisers, any relevant investment manager or financial adviser, our regulators, including the Financial Conduct Authority, law enforcement agencies in connection with any investigation to help prevent unlawful activity, and in the context of the possible sale or restructuring of our business.

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5.2 We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information.

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5.3 We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

6. Keeping your personal data secure

 

6.1 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

 

6.2 While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us (see ‘How can you contact us?’ below).

 

6.3 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.