This statement describes how Transtrend B.V. (“Transtrend” or “we”) process your personal data.
‘Personal data’ means any information relating to an identified or identifiable individual, such as your name, contact details, date of birth, passport details, photographs or videos, communication records, and any other information about you.
Transtrend treats your personal data with care and in accordance with the applicable legislation, including the EU General Data Protection Regulation (GDPR). Protecting personal data is an important responsibility for us. We maintain physical, technical, electronic, procedural, and organizational safeguards to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access. Our employees are bound by internal policies requiring confidential treatment of personal data.
This statement contains the following chapters:
This privacy statement may be amended from time to time without notice. Continued use of our services or continued provision of personal data to us signifies acceptance of such revised statement.
When you use our website, various data is registered, for example, connection type, browser used, operating system, IP address and, when relevant, your e-mail address if you sign up for our mailing list. Some of this data may be personal data, as described below.
When you visit our website, your IP address is automatically saved. Based on your IP address, information about your approximate location can be obtained. For example, if you visit our website from work, your employer’s IP address is identified; if from home, your home computer’s IP address is used.
Our website is maintained by an external service provider who has access to your IP address. Transtrend can request your IP address from this service provider in case of a (security) incident. A data processing agreement has been entered into with the service provider.
Our website is hosted on external cloud provider, who also has access to your IP address. A data processing agreement is in place.
Website usage is monitored and analyzed. Your IP address is used to distinguish unique users and indicate location in the analysis. Reports are available to only us on an aggregated and/or anonymous basis. Google's “Analytics” service is used for this service. Please refer to paragraph 3.2 ‘analytical cookies’ for more information.
If you visit a page with the YouTube plug-in, YouTube may access your IP address. LinkedIn and X may also access to your IP address if you click their buttons on our website. Please refer to paragraph 3.3 ‘Third party cookies and hyperlinks’ for more information.
2.1 Mailing list
When you sign up for our mailing list and confirm your subscription, we process your personal data for this purpose. You will receive monthly and occasional updates about our firm, services and performance.
You have the right to withdraw your consent at any time and you can unsubscribe by contacting us, or using the ‘opt-out’ possibility at the bottom of each mailing. Your data is stored until you withdraw your consent or as long as relevant to stay in contact with you.
2.2 Forms
When you submit personal details in a (contact) form on our website, this data is processed for the intended purpose, such as registering for an event. Details may be used to contact you and for relationship management purposes. For more information, see the paragraphs ‘clients’ or ‘other contacts’.
We process your personal data based on our legitimate interests (e.g. organizing an event, contacting you). Data may be stored as long as relevant to our relationship. Data may be archived or backed up.
A cookie is a file sent from a website and saved by your browser to your computer's hard drive. We use cookies to store data related to use of our website. This data can be read and written by us when you visit our website. Further information about managing cookies is available via your browser's ‘Help’ function.
Our website uses the following types of cookies.
3.1 Functional cookies
Functional cookies ensure the website works properly. We use both session and permanent cookies. Session cookies are deleted when your browser is closed, while permanent cookies are saved longer.
Cookies help us recognize you when you return to our website, tailoring the user experience to your preferences. For example, cookies may record your permission for cookie placement and your language preference.
3.2 Analytical cookies
Analytical cookies allow us to analyze website usage and improve the site. These cookies collect data on visitors numbers, popular pages, and topics. Google's “Analytics” service is used for this purpose.
A Google cookie is placed via our website as part of Google's “Analytics” service. We use this service to monitor website usage and generate reports. Google may share data with third parties if legally required, or if processed on Google’s behalf. We do not have control over this. We have not permitted Google to use analytics data for other services.
Google anonymizes data as much as possible before processing. Your IP address is partially masked and not fully processed. Data may be stored on Google servers in the United States. Google participates in the EU-U.S. Data Privacy Framework, guaranteeing an appropriate level of protection of personal data. We do not use other Google services in combination with the “Analytics” cookies.
3.3 Third party cookies and hyperlinks
Our website does not use third party cookies.
The site does include buttons to share pages on LinkedIn and X. These buttons are hyperlinks and do not place cookies. For details on how LinkedIn and X process data, see their respective privacy and cookie statements.
Our website may contain hyperlinks to third party-sites. Clicking a link directs you to an external website, which may use cookies. Please refer to the privacy or cookie statement of the external site for details.
The website includes YouTube plug-ins, which use YouTube’s own code. These do not place cookies.
The following paragraphs describe how Transtrend process personal data outside website usage. This includes:
Please refer to the paragraph(s) relevant for you.
We process personal data of clients and potential clients, including 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. If you are a (potential) investor in RoTrend Diversified Fund, please refer to RoTrend Diversified Fund’s privacy statement.
Personal data we process may include your name, gender, (business) contact details, title/position, and other information provided during interactions. Personal data may also appear in materials and documents, 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 for more detail.
Data is processed to maintain contact, provide services, optimize service quality, update you about your investment(s) and about us, our services and performance, to provide you with other information that may be of interest, and to record agreements.
Data processing is necessary for compliance with legal obligations, to enter into and/or perform a contract with you, or our legitimate interests, as described above. Updates may be sent based on your consent, which can be withdrawn at any time by contacting us, or by making use of the ‘opt-out’ possibility at the bottom of each mailing.
Your personal data is stored as long as relevant for our relationship. Contracts and related documents remain on file as needed to exercise or defend legal claims. Data may be archived or backed up.
We process personal data of (potential) service providers, service providers of our clients, suppliers, other contacts, and their representatives and employees. Personal data may include name, gender, contact details, title/position, and other information you have provided during interactions. Personal data may also be included in materials and documents, such as promotional material, authorized signatories lists, contracts, and related documents. We may also process data of you in the context of our service provider due diligence; please refer to paragraph 3 for more detail.
Data is processed to maintain contact, for example to use your services or purchase your products, to service clients, to conduct due diligence, for relationship management purposes and to record agreements. Upon your request, we may also use your contact details to provide you with updates about us and our services.
Data processing is necessary for compliance with legal obligations, to enter into and/or perform a contract with you, or our legitimate interest, as described above. Updates may be sent based on your consent, which can be withdrawn at any time by contacting us, or by making use of the ‘opt-out’ possibility at the bottom of each mailing.
Personal data is stored as long as relevant for our relationship. Contracts and related documents remain on file as long as needed to exercise or defend legal claims. Data may be archived or backed up.
In accordance with anti-money laundering and counter terrorist financing legislation, we conduct due diligence before providing services to our clients or obtaining services from service providers. Due diligence must be completed before entering into a contract and repeated periodically.
We collect data from (potential) clients and service providers directly or through databases, sanction lists, or publicly accessible sources. KYC data may include personal details of employees, directors, representatives, shareholders, ultimate beneficial owners, and other associated persons, such as full name, place and date of birth, nationality, home address, country of residence, passport copy, information about regulatory listings, investigations or sanctions, and information on source of your funds and wealth. Personal data may also be included in documents such as promotional material, authorized signatory lists, contracts, and certificates.
If you provide someone else’s personal data, please inform them and refer them to this privacy statement.
KYC data is processed for compliance with legal obligations and to enter into and/or perform a contract with you. Failure to provide certain requested data may result in an inability to invest or to provide services.
KYC data is stored for at least five years after ending of our relationship, after which personal data is deleted and/or destroyed. Data may be archived or backed up.
Personal data of job applicants is processed in accordance with our privacy statement for job applicants, available in Dutch.
We may record communications, including phone calls, chat messages, and other communications. Several telephone lines are recorded, including those of our Trading and Electronic Trading teams.
Recordings are made to comply with legal obligations and based on our legitimate interests, serving as proof of transactions, agreements, instructions, and for fraud prevention.
Communication records are retained for five years, or seven years if required by a regulator, from the date of the recording. Communication records other than telephone recordings may be archived or backed up.
Security cameras record video of visitors to our premises for our legitimate interest to secure our premises and the safety of our employees and visitors. Access cannot be granted without processing this data.
Recordings are kept for a maximum of four weeks or until after an identified incident has been properly followed up.
We may process and store data with a cloud service provider. A data processing agreement guarantees an adequate level of data protection, with data stored within the EEA. We may also use other (IT, cloud or other) service providers that process personal data on behalf of us, with agreements in place to protect personal data.
We may also share data with affiliates, professional advisors, and auditors to the extent required. All parties are subject to confidentiality obligations. Where possible and appropriate, personal data is anonymized. Data may also be transferred to courts, governments, or supervisory authorities, if required by applicable regulations or court order, with notification to you where possible.
We may transfer personal data to parties outside the EEA, where data protection laws may be less. In such cases, where necessary or appropriate, we adopt safeguards to ensure an appropriate level of protection of your personal data.
You may contact us for:
Transtrend will endeavor to meet requests but may be unable to do so in certain circumstances (e.g., legal requirement to retain data). Residual information may remain in databases and records.
For requests, please contact us at info@transtrend.com or +31 10 453 6510. We will respond to your request as soon as possible.
To prevent abuse, we may ask you to adequately identify yourself. If your request concerns cookie-linked data, please send a copy of this cookie (found via browser settings).
For complaints regarding personal data processing, please contact us. You also have the right to lodge a complaint with your home EU member state’s authority. In the Netherlands, contact the Autoriteit Persoonsgegevens (www.autoriteitpersoonsgegevens.nl).
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. You may also contact your usual contact person.