4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to.

Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you or as someone associated with our corporate or institutional client.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time.  If you wish to withdraw consent, please Contact Us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

In no event does Triland sell or trade your personal data.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact Us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

To comply with our legal and regulatory obligations, including:

• The rules and regulations of the Financial Conduct Authority (FCA) and other regulatory bodies pursuant to which we:
  • carry out KYC and due diligence
  • assess suitability for particular products and services
  • implement measures in order to prevent market abuse and fraud
  • detect transactions which deviate from normal patterns
  • monitor and report transactions and associated risks
  • record phone calls, chats and emails, where required
  • maintain records in connection with services and transactions
  • cooperate with regulators and official enquiries or requests
• Prevention of money-laundering and terrorist financing
• Compliance with sanctions legislation and embargoes
• Prevention of tax fraud, tax evasion or its facilitation and compliance with tax controls
• Preventing any other types of financial crime and/or breaches of applicable law
  

Type of data:

• Identity
• Contact
• Transaction

Key activities:

• Account-opening 
• Account review
• Account, relationship, order and transaction handling and management
• Regulatory risk management activity, including financial crime; AML review, tax notification, identity screening and verification
• Monitoring orders and transactions
• Reporting transactions or positions to regulators, exchanges, trade repositories or similar entities

To perform a contract with you or your organisation, including:

• Providing you with information regarding our products and services
• Assisting you with enquiries and requests
• Entering into transactions with you
• Receiving and accepting orders from you
  • Assess suitability for particular products and services and under what other conditions, including:
  • setting up users for our trading applications and online services

Type of data:

• Identity

• Contact

• Transaction

• Technical

• Profile

• Usage

Key activities:

• Account, relationship, order and transaction handling and management

• Product offerings and service setup, e.g. Tri-X, Tri-O

• Education and training events, seminars and workshops

To fulfil our legitimate interest, including:

• Preventing crime, money laundering, fraud, financial crime and/or other breaches of applicable law
• To keep our records updated and to run our business administration
  • Safeguarding against loss, theft, unauthorised processing and misuse
• Improving and developing our products or services
  • Statistical analyses for business growth and marketing strategy; improving our services and creating new product offerings
  • Personalising our services to your organisation and better understand you and your organisation’s interests
  • Inviting you to participate in surveys and provide feedback to us
• IT and IT infrastructure development and management
  • IT security, business continuity and disaster recovery
• Delivering relevant website content and using data analytics
  • Developing advertisements and measuring the effectiveness of marketing activities and user experience
• Exercising and defending our legal rights
  • Proof of transactions, debt recovery
  • Proof of evidence of authority of persons acting on behalf of our counterparties
  • Copyright and trademark infringement

Type of data:

• Identity

• Contact

• Transaction

• Technical

• Profile

• Usage

• Marketing and Communication

Key activities:

• Administration and operation of our business

• Keeping our website updated and relevant, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

• Staff training

• Contacting you about our services and product offerings (with your prior consent where required by applicable law) Monitoring and review

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you have any questions or comments please Contact Us.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or received services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any company outside the Triland group of companies for marketing purposes.

You can ask us or third parties to stop sending you marketing messages; please Contact Us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service, warranty registration, product/service experience or other transactions.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy on our website.

We will only use your personal data 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact Us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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