Regulatory Disclosures & Website Privacy Policy
About This Page
Published August 3, 2020; Last updated December 12, 2022
As of June 2020, the Securities and Exchange Commission (SEC) implemented a requirement for broker-dealers to provide investors with two new disclosure documents: Regulation Best Interest (Reg Bl) and a Client Relationship Summary known as the "Form CRS." A primary goal of these two documents is to help investors gain greater insight into investor risks and elevate investor awareness of broker-dealers' compensation and potential conflicts of interest. TPEG Securities, LLC, an affiliate of Trinity Investors, encourages you to review our new disclosure documents.
Form CRS: The Form CRS is provided to help our potential customers make informed decisions about the services TPEG Securities offers. Its primarily focus is on conflicts of interest and compensation. The Form CRS includes important information about the risks involved in private equity investing. The SEC requires broker-dealers to provide the Form CRS to a retail investor prior to or at the time of a recommendation.
Reg Bl Disclosure: The Reg Bl Disclosure expands on the Form CRS and provides valuable supplemental information for your consideration. The SEC requires a broker-dealer to provide the Reg Bl disclosure to a retail investor prior to or at the time of a recommendation.
Customer Privacy Policy: The Privacy Policy lists the type of personal information collected when investing with Trinity. This information is not sold or given to any outside parties and is shared only on a need-to-know basis within the firm. Information is shared within the firm for the sole purpose of providing efficient financial services.
Customer Significant Business Disruption Disclosure: The Significant Business Disruption (SBD) disclosure details the procedures and contact details for TPEG Securities/Trinity Investors should a significant business disruption occur. Significant business disruptions can include extreme weather, terrorist actions, or loss of power or telecommunications.
Additional Disclosures: The Investor Education and Protection, Customer Complaint Disclosure, and SIPC Disclosure list contact details for FINRA, TPEG Securities, and SIPC. These disclosures also detail the procedure should an investor want to access BrokerCheck or file a complaint.
We encourage you to contact your Financial Professional or the firm's compliance officer, Pat Swanson, with any questions you may have at telephone number 713.204.6313.
TPEG Securities, LLC Relationship Summary Disclosure
Published June 30, 2020; Last updated December 12, 2022
Introduction
TPEG Securities, LLC (TPEG) is a broker-dealer registered with the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA). Brokerage and investment advisory services and fees differ, and it is important for you to understand these differences. Free and simple tools are available for you to research firms and financial professionals at https://www.investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisors, and investing.
We offer brokerage services, but only present and effect securities transactions in private placement securities. Further, the majority of private placements we present to our customers are managed by our affiliated entities. We believe this benefits our customers by facilitating access to the management teams and investment-related information. With our focus on alternative investing, we do not assess whether there are similar investments being offered in the marketplace or if those investments would be better suited for any particular customer. In compliance with key regulatory requirements, TPEG does not act as custodian for funds or securities. To that end, private placements can be held in retirement accounts, where investments will be held with the custodian of the account. We do not introduce accounts to a clearing firm and do not offer the option to hold cash in either money markets or an FDIC insured account. We do not monitor your brokerage account. You make the ultimate decision regarding the purchase of investments. However, because the investments are private placements, liquidity is highly restricted by applicable securities laws. These laws and the terms of the corporate operating agreements that pertain to your particular investment(s) are explained to you in the form of a private placement memorandum (PPM). The PPM details the minimum investment size and related terms, and is provided each time you invest in a new private placement. It is your responsibility to notify TPEG Securities promptly when changes to your financial situation, objectives, or other personal information occur.
→Conversation Starters:
-
Given my financial situation, should I choose a brokerage service? Why or why not?
-
How will you choose the investments you recommend to me?
-
What is your relevant experience including your licenses, education and other qualifications? What do these qualifications mean and how do the benefit me?
What investment services and advice can you provide me?
TPEG and its affiliates receive fees and expenses from your investments, including commissions and underwriting fees, as detailed in the private placement memorandum (PPM) for each investment. Importantly, these fees and expenses do not reduce the value assigned to your principal investment. Thus, if you invest $100,000, that amount would be used for the purpose of calculating any interest or preferred returns due to you and would be the amount used for the purpose of distributions.
The fees and expenses paid to TPEG and its affiliates (and any other costs described in the PPMs) will absolutely reduce the amount of your invested dollars that go to the subject project(s) associated with your investment. Among the fees that will reduce the amount available to the project entity are the underwriting fees paid to TPEG at closing, which are shared with your financial professional, and the ongoing project management fees paid to a TPEG affiliate. It is common that TPEG receives underwriting fees equal to 7%-8% of the amount you invest, which are then partially shared with your financial professional. These underwriting fees are paid from the total amount invested in conjunction with the invested funds provided to the project entity. Further, the TPEG affiliate serving as the manager of the entity in which you invest will receive an ongoing project management fee. Upon liquidation, TPEG financial professionals can receive additional compensation in the form of carried interest, which does not have value until investors have received their preferred return and 100% of their original investment. Thus, these fees and expenses detailed in the subject PPMs represent a conflict for TPEG and its financial professionals.
Additional Information: TPEG and its affiliates will receive compensation in the form of fees and expenses whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investment over time. Please make sure you understand what fees and costs you are paying. See additional information about your fees and costs at https://www.trinityinvestors.com/disclosures.
→Conversation Starter: Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will apply to fees and costs, and how much will be invested for me?
What fees will I pay?
When we provide you with a recommendation, we must act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates conflicts with your interests. You should understand and ask us about these conflicts because they can affect the recommendation we provide you. Here is an example to help you understand what this means.
Proprietary Products: TPEG and its financial professionals almost always introduce investments that are sponsored or managed by an affiliate of TPEG. Thus, TPEG Securities and its affiliates stand to receive compensation and other benefits when you invest in products that a TPEG affiliate is sponsoring or managing. TPEG, affiliates and employees have conflicts resulting from the affiliate relationship. Benefits received include underwriting compensation, selling compensation, management fees, carried interest, and ownership interest sales resulting from a TPEG Securities offering. We do not assess whether the compensation and benefits are greater than investments in other products not affiliated with TPEG. However, it is likely that TPEG Securities and its affiliates, including your representative, stand to receive more compensation and benefits if you invest in products sponsored and/or managed by a TPEG affiliate rather than in some third-party products that could otherwise be used to construct your portfolio.
Again, given our business model, TPEG and its financial professionals do not assess whether there are similar investments being offered in the marketplace or if those investments would be better suited for any particular customer.
→Conversation Starter: How might conflicts of interest affect me, and how will you address them?
What are your legal obligations to me
when providing recommendations? How else does your firm make money and what conflicts do you have?
We pay our financial professionals commissions, which can vary based on the type of investment purchased and the dollar value invested. The commission compensation to our financial professionals is between 2%-4% of your investment amount. Additional compensation could include carried interest.
How do your financial professionals make money?
Yes, visit https://www.investor.gov/CRS for a free and simple search tool to research us and our financial professionals.
→Conversation Starter: As a financial professional, do you have any disciplinary history? For what type of conduct?
Do you or your financial professionals have legal or disciplinary history?
Additional Information
Additional Information: For additional information about our broker-dealer services, or services offered by our affiliates and their Form CRS, please visit https://www.trinityinvestorscom/disclosures. You can request up to date information and a copy of the Customer Relationship Summary by contacting Pat Swanson at pat@trinityinvestors.com or call 713.204.6313.
→Conversation Starter: Who is my primary contact person? Is he or she a financial professional of an investment advisor or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?
About Us
Trinity Investors creates alternative investments to traditional stocks and bonds to present compelling risk- adjusted returns by working with partners who share and align with our core values. Trinity Investors combines this approach with exhaustive due diligence and an active and direct investing style that differs from many pooled investment vehicles and REITs. Serving as the affiliated broker-dealer for investments sponsored by Trinity Investors, TPEG Securities, LLC (“TPEG Securities,” collectively “Trinity”), is registered with the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA).
Trinity’s Core Values
-
We build long-term business partnerships, grounded in trust and respect.
-
We align with our investors, co-investing in every investment opportunity
-
We persevere on every investment, with steadfast attention from beginning to end.
-
We commit to complete transparency and putting our investors’ interests first.
About this Document
This document is meant to provide additional information and disclosures regarding TPEG Securities pursuant to Regulation Best Interest. Brokerage and investment advisory services and fees differ, and it is important for you to understand these differences. Free and simple tools are available to research firms and financial professionals at https://www.investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisors, and investing.
Scope of Services
TPEG Securities offers brokerage services limited to private placement securities. Further, the majority of private placements we present to our customers are managed by our affiliated entities. We believe this benefits our customers by facilitating access to the management teams and investment-related information. With our focus on alternative investing, we do not assess whether there are similar investments being offered in the marketplace or if those investments would be better suited for any particular customer. In compliance with key regulatory requirements, TPEG Securities does not act as custodian and therefore does not hold customer funds or securities. Private placements can be held in a retirement account, in which case investments will be held with the custodian of the retirement account. We do not introduce accounts to a clearing firm and do not offer the option to hold cash in either money markets or an FDIC insured account. We do not monitor your brokerage account. You make the ultimate decision regarding the purchase of investments. However, because the investments are private placements, liquidity is highly restricted by applicable securities laws. These laws and the terms of the corporate operating agreements that pertain to your particular investment(s) are explained to you in the form of a private placement memorandum (PPM). The PPM details minimum investment size and related terms, and is provided each time you invest in a new private placement.
Our registered representatives provide services related to investments in private placements, including taking customer orders and providing general information regarding your investments. Our financial professionals do not make investment decisions for you or manage your investments on a discretionary basis. Because our financial professionals do not have discretionary investment authority, this means we cannot purchase your investments without first obtaining your consent. Our financial professionals may recommend investments to you, but you are responsible for making the decision whether to purchase or sell investments, and we will purchase only when specifically directed by you.
When we act in our capacity as a broker-dealer, we are subject to the Securities Act of 1933, the Securities Exchange Act of 1934, as amended, the rules of self-regulatory organizations, such as the Financial Industry Regulatory Authority, Inc. (FINRA), and applicable state laws.
Material Limitations
TPEG Securities does not provide tax, legal or accounting advice. Accordingly, we encourage our customers to consult their own personal tax, legal and/or accounting advisers in order to understand the potential consequences associated with a particular investment strategy.
You should understand there are material limitations to the recommendations your financial professional provides. TPEG Securities approves and offers only investments in private placements. There may be additional account types, products, and securities that could benefit you and your portfolio but are not offered by TPEG Securities. In addition, various versions of the products that we offer could be available at a lower cost through another firm but will not include the same unique project assets.
Additionally, all the financial professionals associated with TPEG Securities are licensed to offer you private placement. You can check to see the licenses your financial professional holds, by visiting www.brokercheck.finra.org.
Requirements for You to Invest with Us
Our private placement offerings include minimum investment size and related terms detailed in each respective private placement memorandum.
Trinity’s Investment Approach
We cater to high net worth and sophisticated investors with varying investment profiles.
If a TPEG Securities financial professional recommends an investment to you, we require they have a reasonable basis to believe that each recommendation made is in your best interest and does not place the interest of your financial professional or TPEG Securities ahead of your interest. In forming such a reasonable basis, the financial professionals are required to take into account the potential risks, rewards, and costs associated with each recommendation.
Further, your financial professional is required to consider your individual investment profile. The information in your investment profile includes, but is not limited to, your age, other investments, financial situation and needs, tax status, investment objectives, investment experience, investment time horizon, liquidity needs, risk tolerance, and other information that you disclose to us or your financial professional in connection with a recommendation. It is your responsibility to notify TPEG Securities promptly when changes to your financial situation, objectives, or other personal information occur.
Material Fees, Costs, and Associated Conflicts
Fees and Costs
TPEG Securities and its affiliates receive fees and expenses from your investments, including commissions and underwriting fees, as detailed in the private placement memorandum for each investment. Importantly, these fees and expenses do not reduce the value assigned to your principal investment. Thus, if you invest $100,000, that amount would be used for the purpose of calculating any interest or preferred returns due to you and would be the amount used for the purpose of distributions. However, the fees and expenses paid to Trinity and its affiliates (and any other costs described in the PPMs) will reduce the amount of your invested dollars that go to the subject project(s) associated with your investment. Among the fees that will reduce the amount available to the project entity are the underwriting fees paid to Trinity at closing, which are shared with your financial professional, and the ongoing project management fees paid to a Trinity affiliate. It is common that Trinity receives underwriting fees equal to 7%-8% of the amount you invest, which are then partially shared with your financial professional as detailed below. These underwriting fees are paid from the total amount invested in conjunction with the invested funds provided to the project entity. Further, the TPEG Securities affiliate serving as the manager of the entity in which you invest will receive an ongoing project management fee. Upon liquidation, TPEG Securities’ financial professionals can receive additional compensation in the form of carried interest, which does not have value and is not paid until investors have received their preferred return and 100% of their original investment. Thus, these fees and expenses detailed in the subject PPMs represent a conflict of interest for TPEG Securities and its financial professionals.
Compensation
The fees and expenses detailed in the subject PPMs represent a conflict of interest for TPEG Securities and its financial professionals. We pay our financial professionals commissions, which can vary based on the type of investment purchased and the dollar value invested. The commission compensation paid to our financial professionals is between 2%-4% of your investment amount. Upon liquidation, Trinity financial professionals can receive additional compensation in the form of a carried interest that does not have value and is not paid until investors have received their preferred return and 100% of their original investment.
Conflicts of Interest
When we provide you with a recommendation, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates conflicts with your interests. You should understand and ask us about these conflicts because they can affect the recommendation we provide you.
Below are several examples to help you understand what this means:
-
Proprietary Products: TPEG Securities and its financial professionals almost always introduce investments that are sponsored or managed by an affiliate. Thus, TPEG Securities and its affiliates stand to receive compensation and other benefits when you invest in products that a TPEG affiliate is sponsoring or managing. We do not assess whether the compensation and benefits are greater than investments in other products not affiliated with Trinity. However, it is likely that TPEG Securities and its affiliates, including your representative, stand to receive more compensation and benefits if you invest in products sponsored and/or managed by a Trinity affiliate rather than in some third-party products that could otherwise be used to construct your portfolio. Thus, these fees and expenses detailed in the subject PPMs represent a conflict for TPEG Securities and its financial professionals because they create an incentive to encourage you to make additional investments. Given our business model, TPEG Securities and its financial professionals do not assess whether there are similar investments being offered in the marketplace or if those investments would be better suited for any particular customer. To see detailed information regarding the investment, selling compensation, and other fees which will be charged by the issuer, you should review the relevant private placement memorandum.
-
Affiliated Parties: TPEG principals and affiliates have previously contributed land, pre-development costs, and other forms of consideration to TPEG Securities offerings and have made loans to TPEG Securities projects. Further, TPEG principals, affiliates, or employees have existing ownership interests in properties, property management companies and sponsors. If a TPEG securities offering will involve an acquisition or other agreement involving such entities or assets, the relevant TPEG person(s) would likely receive proceeds directly as a result of a TPEG securities offering closing. These activities represent a conflict for TPEG Securities and its financial professionals. In addition, affiliates of TPEG Securities serve as the managers of the entities in which customers invest. The managers’ ability to exercise control over the investment entity represents a conflict with TPEG Securities customers, because, for example, the managers have the ability to grant or withhold consent to a customer’s redemption of an investment.
-
Non-Cash Compensation: TPEG Securities, TPEG Securities employees and financial professionals receive non-cash compensation from TPEG affiliates and project vendors that is not in connection with any particular customer or investment. Compensation includes such items as gifts, an occasional dinner, or ticket to a sporting event.
-
Financial Professional’s Outside Business Activities: Financial professionals are permitted to engage in certain TPEG Securities-approved business activities other than the provision of brokerage through TPEG Securities. If you engage with a financial professional for services separate from TPEG Securities, you may wish to discuss with him/her any questions you have about the compensation he/she receives from the engagement. Additional information about your financial professional’s outside business activities is available on FINRA’s website at www.brokercheck.finra.org.
-
Political and Charitable Contributions: Financial professionals and other associates can make political and charitable contributions creating the perception that the financial advisor, the associate, or the firm is seeking a quid pro quo arrangement.
-
Supervision Conflicts: When a manager is also a financial professional serving customers, he/she can be incentivized to spend more time on revenue generating activities than supervision activities.
Understanding Risk
Investing in private placements involves risk of loss that customers should be prepared to bear. Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment or investment strategy will be profitable for a customer’s investment portfolio. Past performance is not indicative of future results. A customer should not assume that the future performance of any specific investment, investment strategy, or product will be profitable or equal to past or current performance levels. We cannot assure that the investment objectives of any customer will be realized. The following is a non-exhaustive list of risks associated with investing in private placements. For additional product-specific risks, customers should review the relevant private placement memorandum.
-
Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while private placements are not. Private placements offered through TPEG Securities have not been registered under any federal or state securities laws and are being sold in reliance on exemptions from registration under the Securities Act of 1933 and the provisions of applicable state securities laws. As a result, the operating documents of the entities in which you invest typically restrict the transfer of the interests. Among other things, these operating agreements provide that, except for certain permitted estate planning transfers, investors cannot transfer or encumber their interests without the prior written consent of the issuer’s manager. Thus, holders of the membership interests may not be able to liquidate their investment in such securities in the event of an emergency or for any other reason.
-
Possible Future Dilution Risk: Projects may need to raise additional funds from time to time through equity or convertible debt financings in order to meet operating and capital needs that would not be met by traditional borrowing through lending institutions. In such instances, existing investors will have preemptive rights to purchase such securities. If existing investors do not participate in these issuances of equity and convertible debt securities, pursuant to their preemptive rights or otherwise, such investors could suffer significant dilution in their percentage ownership of the holding company. Further, the companies in which you invest through TPEG Securities can generally issue new equity or debt with rights, preferences, and privileges senior to persons who invest pursuant to this offering. Investors should carefully review the company agreement of your investment closely to understand the details of such additional fund-raising avenues and the rights thereunder.
-
Leverage Risk: Excessive borrowing to finance a business’ operations or investments increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations can result in bankruptcy and/or a declining market value of securities. The projects associated with investments available through TPEG Securities typically utilize leverage to fund their operations.
-
Debt Refinancing Risk: Projects associated with investments made through TPEG Securities may need additional capital and may not be able to refinance or sell a project. It is possible that a project will need to raise additional capital to refinance or otherwise carry out its business plans. It is possible that the company might be unable to sell or refinance the project for a profit or even upon commercially reasonable terms at the maturity of the senior debt financing. In such an event, the project would be forced to seek replacement financing, additional capital, or a combination of both to maintain the project’s goal. The project may not be able to obtain such additional financing
-
Interest-rate Risk: Fluctuations in interest rates will cause investment prices to fluctuate. For example, when interest rates rise, yields on existing fixed-income oriented investments become less attractive, causing their market values to decline. In addition, an increase in interest rates can increase borrowing costs for a project.
-
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year because purchasing power is eroding at the rate of inflation.
-
Business Risk: These risks are associated with an industry, geographic location, asset class, or a particular project.
-
Other Risks: Other risks should be reviewed in each private placement memorandum for your investment. It is important to note that any of the factors disclosed above can change over time. In order to receive specific and the most up-to-date information, customers should review each respective private placement memorandum. Customers should discuss any questions or issues with their financial professional.
Published August 3, 2020; Last updated December 12, 2022
TPEG Securities, LLC Regulation Best Interest Disclosures Supplement
Customer Significant Business Disruption (SBD) Disclosure
Published June 29, 2020
In accordance with regulatory requirements and professional business practices, our firm has developed procedures in the event of a SBD. We provide these to you for your information.
A significant business disruption (SBD) is a situation which may cause stress to our customers as we provide our customers with financial services in the areas of transaction order receipt and order entry.
SBDs may take the following forms as a result of weather events, fire, or terrorist actions. They may affect our firm and our customers in varying degrees: a firm-only business disruption, a disruption to a single building, a disruption to a business district, a citywide business disruption, and a regional disruption.
It is our intention to be in a position to continue to serve our customer's needs in any of these SBD events.
The two most serious challenges we will overcome is a regional loss of power and telecommunications.
To accomplish the goal of continuing to provide service to our customers in the event that we experience a SBD, we have developed and installed a Business Continuity Plan (BCP) which we feel will provide a seamless relocation of our office to an alternate location.
In a SBD situation:
1. Your primary contact method will remain our main telephone number (817) 310-2900. In the event of a significant event, calls will be forwarded to cell phones with voice mail capabilities.
2. In the event that our office and cellular telephone services are unavailable, you may directly contact the company you invested with at the number listed in the Private Placement Memorandum.
We are committed to providing every customer with updates to this disclosure should we add improvements or make any changes to our Business Continuity Plan for possible significant business disruptions.
While it is highly recommended that each customer maintain all statements and investment documents, our firm and associated firms with which we conduct business have established similar Business Continuity Plans that contain alternate business locations and back up of all client records.
TPEG Securities, LLC
Member SIPC/FINRA
2102 E State Hwy 114, Suite 300
Southlake, Texas 76092
In Accordance with the Gramm Leach Bliley Act of 1999, we are providing you with our firm's Annual Customer Privacy Policy. This notice is given to all our existing clients and all new clients. All our clients will also receive our Customer Privacy Policy Notice annually. Should our Customer Privacy Policy change at any time regarding the treatment of your information you will receive our New Customer Privacy Policy Notice in advance and be given the opportunity to "opt out" of any new disclosure.
What information is collected: In compliance with the Federal and State Regulations and to provide you with financial services, we are required to collect personal non-public information on you and your family such as your name, address, social security number, credit reference, telephone number & email address, age, investment objective, investment experience, date of birth, tax bracket, bank accounts,
annual income, net worth, value of your residence if owned, liquid net worth, affiliations with corporations or insurance companies or banks, your employment or occupation and marital status and other personal, non-public information.
Use of this information: The information is used to allow us to provide financial services to you. Your information is not sold by us to any outside party. Your information is not shared in joint marketing arrangements with other financial institutions by us.
Access to information: Your personal information is shared on a limited need to know basis in order to allow us to provide you with financial services. Personal or financial information may be shared with affiliates (such as your adviser representative) and with third parties, again solely to allow us to be efficient and to provide you with financial services. Your information is also shared with other investment advisers and broker dealers holding your investments. You will receive a Customer Privacy Policy Notice from these financial firms as well. Other service providers include TPEG Securities’ accountants and attorneys. Other third parties include governmental agencies such as the Securities and Exchange Commission, FINRA and the Texas State Securities Board.
Opt-Out Notice: In the future, if we arrange a joint marketing arrangement with another financial institution or non-affiliated third parties we will notify you in writing and allow you to Opt-Out of the sharing of your personal, non-public financial information. If you decide to Opt-Out your request may be made in writing addressed and mailed to TPEG Securities, LLC, 2102 E State Hwy 114, Suite 300, Southlake, Texas 76092, or you may call our office and request our Opt-Out Request Form (817-310-2900).
Customer Investment Protections Disclosure
Published June 29, 2020; Last updated December 12, 2022
INVESTOR EDUCATION AND PROTECTION (FINRA Rule 2267)
Pursuant to "FINRA Rule 2267: Investor Education and Protection", TPEG Securities LLC would like to remind customers that they may obtain information regarding FINRA BrokerCheck and FINRA itself at the following contact details:
FINRA Website: https://www.finra.org/
FINRA BrokerCheck: https://brokercheck.finra.org/
FINRA BrokerCheck online informational website: https://www.finra.org/investors/learn-to-invest/choosing-investment-professional/about-brokercheck
For further questions regarding FINRA BrokerCheck, please do not hesitate to call the BrokerCheck telephone hotline number at (800) 289-9999.
CUSTOMER COMPLAINT DISCLOSURE (Securities Exchange Act Rule 17a-3(a)(18)
In the event a customer would like to register a complaint regarding TPEG Securities LLC, please contact us at the following address:
TPEG Securities, LLC
2102 E State Hwy 114, Suite 300
Southlake, Texas 76092
Attention: Chief Compliance Officer
Telephone: 817-310-2900
Email Address: Pat@trinityinvestors.com
SIPC DISCLOSURE (FINRA Rule 2266)
SIPC protects customers of brokerage firms that are closed due to bankruptcy or other financial difficulty. Each customer may be protected up to $500,000, including up to $250,000 in cash held in the account. SIPC will cover any missing customer securities when the brokerage fails, whether the securities are missing due to conversion, theft, unauthorized trading or other reasons. SIPC does not protect against ordinary market loss. Not every investment is protected by SIPC and some customers may be ineligible to have their claims satisfied with SIPC funds.
Pursuant to "FINRA Rule 2266: SIPC Information to Customers", TPEG Securities LLC would like to remind customers that they may obtain information about the Securities Investor Protection Corporation ("SIPC"), including the SIPC brochure, by contacting SIPC at the following contact information:
SIPC Website: https://www.sipc.org/
SIPC Brochures: https://www.sipc.org/news-and-media/brochures
SIPC Mailing Address:
Securities Investor Protection Corporation (SIPC)
1667 K St. N.W., Suite 1000
Washington, D.C. 20006-1620
Telephone: (202) 371-8300
Fax: (202) 223-1679
Email: asksipc@sipc.org
WEBSITE PRIVACY POLICY
Last updated: May 11, 2023
This Privacy Policy describes Trinity Investors’ (referred to as either “Trinity,” “Trinity Investors,” "the Company", "We", "Us" or "Our" in this Agreement) policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
-
Account means a unique account created for You to access our Service or parts of our Service.
-
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
-
Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
-
CCPA and/or CPRA refers to California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").
-
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Trinity Investors, 2102 E State Hwy 114, Suite 300 Southlake, Texas 76092.
-
Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
-
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
-
Country refers to: Texas, United States
-
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
-
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
-
Personal Data is any information that relates to an identified or identifiable individual. For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
-
Service refers to the Website.
-
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
-
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
-
Website refers to Trinity Investors, accessible from https://www.trinityinvestors.com/
-
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
-
Email address
-
First name and last name
-
Phone number
-
Address, State, Province, ZIP/Postal code, City
-
Usage Data
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
-
Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
-
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies on TermsFeed website article.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
-
To provide and maintain our Service, including to monitor the usage of our Service.
-
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
-
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
-
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
-
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
-
To manage Your requests: To attend and manage Your requests to Us.
-
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
-
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
-
With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
-
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
-
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
-
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
-
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
-
With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Service may give You the ability to delete certain information about You from within the Service.
You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
-
Comply with a legal obligation
-
Protect and defend the rights or property of the Company
-
Prevent or investigate possible wrongdoing in connection with the Service
-
Protect the personal safety of Users of the Service or the public
-
Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
Analytics
We may use third-party Service providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
CCPA/CPRA Privacy Notice
This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.
Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
Collected: Yes.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collected: Yes.
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: Yes.
Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: No.
Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.
Category F: Internet or other similar network activity.
Examples: Interaction with our Service or advertisement.
Collected: Yes.
Category G: Geolocation data.
Examples: Approximate physical location.
Collected: No.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: No.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: No.
Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
Category L: Sensitive personal information.
Examples: Account login and password information, geolocation data.
Collected: Yes.
Under CCPA/CPRA, personal information does not include:
-
Publicly available information from government records
-
Deidentified or aggregated consumer information
-
Information excluded from the CCPA/CPRA's scope, such as:
-
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
-
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
-
Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service.
-
Indirectly from You. For example, from observing Your activity on our Service.
-
Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
-
From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, or other third-party vendors that We use to provide the Service to You.
Use of Personal Information
We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:
-
To operate our Service and provide You with Our Service.
-
To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
-
To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry.
-
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
-
As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
-
For internal administrative and auditing purposes.
-
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
-
Other one-time uses.
-
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.
If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.
Disclosure of Personal Information
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
-
Category A: Identifiers
-
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
-
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Share of Personal Information
We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:
-
Service Providers
-
Our affiliates
-
Our business partners
-
Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You
Sale of Personal Information
As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.
We may sell and may have sold in the last twelve (12) months the following categories of personal information:
-
Category A: Identifiers
-
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
-
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
Sale of Personal Information of Minors Under 16 Years of Age
We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.
We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.
If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.
Your Rights under the CCPA/CPRA
The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
-
The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
-
The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
-
The categories of personal information We collected about You
-
The categories of sources for the personal information We collected about You
-
Our business or commercial purposes for collecting or selling that personal information
-
The categories of third parties with whom We share that personal information
-
The specific pieces of personal information We collected about You
-
If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
-
The categories of personal information categories sold
-
The categories of personal information categories disclosed
-
-
The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request, please see the "Do Not Sell My Personal Information" section or contact Us.
-
The right to correct Personal Data. You have the right to correct or rectify any any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) Your personal information, unless an exception applies.
-
The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact Us.
-
The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
-
Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
-
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
-
Debug products to identify and repair errors that impair existing intended functionality.
-
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
-
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
-
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
-
Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
-
Comply with a legal obligation.
-
Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
-
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
-
Denying goods or services to You
-
Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
-
Providing a different level or quality of goods or services to You
-
Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services
Exercising Your CCPA/CPRA Data Protection Rights
Please see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.
Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:
By email: pat@trinityinvestors.com or info@trinityinvestors.com
By phone number: 817-310-2900
Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:
-
Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
-
Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it
We cannot respond to Your request or provide You with the required information if We cannot:
-
Verify Your identity or authority to make the request
-
And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.
Do Not Sell My Personal Information
As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.
You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.
The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.
Website
If applicable, click "Privacy Preferences", "Update Privacy Preferences" or "Do Not Sell My Personal Information" buttons listed on the Service to review your privacy preferences and opt out of cookies and other technologies that We may use. Please note that You will need to opt out from each browser that You use to access the Service.
Additionally, You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
-
The NAI's opt-out platform: http://www.networkadvertising.org/choices/
-
The EDAA's opt-out platform http://www.youronlinechoices.com/
-
The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.
Mobile Devices
Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:
-
"Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
-
"Limit Ad Tracking" on iOS devices
-
You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.
Limit the Use or Disclosure of My Sensitive Personal Information
If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.
We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the "Use of Your Personal Data" section or contact us.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Children's Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us:
By email: pat@trinityinvestors.com or info@trinityinvestors.com
By phone number: 817-310-2900