1. Privacy Policy


We consider unitholder privacy to be fundamental to our relationships with our unitholders. In the course of serving your account, we collect personal information about you (“Nonpublic Personal Information”). We are committed to maintaining confidentiality, integrity and security of our unitholders’ personal information. It is our policy to respect the privacy of our current and former unitholders and to protect the personal information entrusted to us. This privacy policy (“Privacy Policy”) describes the standards we follow for handling your personal information and how we use the information we collect about you.


Information We May Collect

We may collect Nonpublic Personal Information about you from the following sources:

  • Information on applications, subscription agreements or other forms which may include your name, address, e-mail address, telephone number, tax identification number, date of birth, marital status, driver’s license number, citizenship, assets, income, employment history, beneficiary information, personal bank account information, broker/dealer, financial advisor, IRA custodian, account joint owners and similar parties;
  • Information about your transactions with us, our affiliates and others, such as the types of products you purchase, your account balances and transactional history; and
  • If you visit our Web site, information we collect via web server, often referred to as “cookies.” Cookies indicate where a site visitor has been online and what has been viewed.

Why We Collect Nonpublic Personal Information

We collect information from and about you:

  • in order to identify you as a unitholder;
  • in order to establish and maintain your unitholder accounts;
  • in order to complete your unitholder transactions;
  • in order to communicate and share information with your broker/dealer, financial advisor, IRA custodian, joint owners and other similar parties acting at your request and on your behalf; and
  • in order to meet our obligations under the laws and regulations that govern us.

Use and Disclosure of Information

We may disclose Nonpublic Personal Information we collect about you as described above to the following types of third parties:

  • Our Affiliated Companies. We believe that by sharing information about you and your accounts among our companies, we are better able to serve your investment needs. We may share your Nonpublic Personal Information with our affiliates for the purposes listed above, as well as to suggest educational materials that may be of interest to you.
  • Other Nonaffiliated Third Parties. Except as outlined below, we do not share your Nonpublic Personal Information with nonaffiliated third parties. However, we may disclose your Nonpublic Personal Information to the extent permitted, or as required, by law. For example, to:
    -     correct technical problems and malfunctions in how we provide our products and services to you and to technically process your information
    -     protect the security and integrity of our records, Web Site and unitholder service center;
    -     protect our rights and property and the rights and property of others;
    -     take precautions against liability;
    -     respond to claims that your information violates the rights and interests of third parties;
    -     take actions required by law or to respond to judicial process;
    -     assist with detection, investigation or reporting of actual or potential fraud, misrepresentation or criminal activity; and
    -     provide personal information to law enforcement agencies or for an investigation on a matter related to public safety to the extent permitted under other provisions of law.

Additional Information Regarding California Residents

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Nonpublic Personal Information about California residents that we have collected or disclosed within the preceding 12 months:

(1) We collected the following categories of Nonpublic Personal Information:

  1. Identifiers, such as name, contact information, online identifiers and Social Security numbers and other government-issued ID numbers;
  2. Personal information, as defined in the California customer records law, such as name, contact information, signature and financial information;
  3. Characteristics of protected classifications under California or federal law, such as sex, national origin, citizenship, immigration status and marital status;
  4. Commercial information, such as transaction information, financial details and financial account information;
  5. Internet or network activity information, such as browsing history, online behavior, interest data, and interactions with our and other websites and systems;
  6. Geolocation data, such as device location and IP location;
  7. Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities; and
  8. Professional or employment-related information, such as employer or the entity with which you are affiliated.

We collect this Nonpublic Personal Information from you and from other categories of sources: entities with which we do business that have a relationship with you, joint marketing partners and social media platforms.

We share this Nonpublic Personal Information with our affiliates, our service providers and entities with which we do business that have a relationship with you and other business partners.

We may use this Nonpublic Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Nonpublic Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

(2) We disclosed the following Nonpublic Personal Information to third parties for our operational business purposes:

  1. Identifiers, such as name, contact information, online identifiers and Social Security numbers and other government-issued ID numbers;
  2. Personal information, as defined in the California customer records law, such as name, contact information, signature and financial information;
  3. Characteristics of protected classifications under California or federal law, such as sex, national origin, citizenship, immigration status and marital status;
  4. Commercial information, such as transaction information, financial details and financial account information;
  5. Internet or network activity information, such as browsing history, online behavior, interest data, and interactions with our and other websites and systems;
  6. Geolocation data, such as device location and IP location;
  7. Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities; and
  8. Professional or employment-related information, such as employer or the entity with which you are affiliated.

(3) We have not “sold” Nonpublic Personal Information for purposes of the CCPA.

For purposes of this Privacy Policy, “sold” or “sale” means the disclosure of Nonpublic Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Nonpublic Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

If you are a California resident, you may request that we:

(1) Disclose to you the following information covering the 12 months preceding your request:

  • The categories of Nonpublic Personal Information we collected about you and the categories of sources from which we collected such Nonpublic Personal Information;
  • The specific pieces of Nonpublic Personal Information we collected about you;
  • The business or commercial purpose for collecting Nonpublic Personal Information about you; and
  • The categories of Nonpublic Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Nonpublic Personal Information (if applicable).

(2) Delete Nonpublic Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us at 800-358-8951 or trilincglobalimpactfund.com. In some instances, we may decline to honor your request where the law does not apply or where an exception applies. We will respond to your request consistent with applicable law. Nonetheless, you have the right to be free from unlawful discrimination for exercising your rights under the CCPA.


Additional Information Regarding Nevada Residents

We do not sell Covered Information as defined under Nevada law.  If you would like to make a further inquiry regarding the selling of your Covered Information, as defined under Nevada law, please contact nvprivacy@trilincglobal.com.

2. Procedures


Protecting Your Information

Our employees are required to follow the procedures we have developed to protect the integrity of your information. These procedures include:

  • Restricting physical and other access to your Nonpublic Personal Information to persons with a legitimate business need to know the information in order to service your account;
  • Contractually obligating third parties doing business with us to keep your Nonpublic Personal Information confidential and secure and to use it only as authorized by us;
  • Providing information to you only after we have used reasonable efforts to assure ourselves of your identity by asking for and receiving from you information only you should know; and
  • Maintaining reasonably adequate physical, electronic and procedural safeguards to protect your information.

Former Unitholders

We treat information concerning our former unitholders the same way we treat information about our current unitholders.


Keeping You Informed

If we decide to change our Privacy Policy, we will post those changes on our Website so our unitholders are always aware of what information we collect, use and disclose. If at any point we decide to use or disclose your Nonpublic Personal Information in a manner different from that stated at the time it was collected, we will notify you in writing, which may be by email. If you object to the change to our Privacy Policy, then you must contact us using the information provided in the notice. We will otherwise use and disclose a unitholder’s Nonpublic Personal Information in accordance with the Privacy Policy.


Questions About Our Privacy Policy

If you have any questions about our Privacy Policy, please contact us via telephone at 310.997.0580 or email Sarah Pikover, Director of Compliance, at info@trilincglobal.com.

Residents of some states may have additional privacy rights. We adhere to all applicable state laws.