Trinitas Foundation (“we”, “our”, “us”) is committed to protecting and respecting your privacy.
We invest in the development, rigorous testing, and scaling of innovations targeted at improving the lives of the grassroots. We use personal information in the course of our grant funding or investment (whether through grant funding or investment into a company or project). This includes information about the senior leadership team of a prospective or current investee (a company or organisation), key individuals (for example, experts) involved in a particular project, and even beneficiaries of our grant funding or investment. We refer to these individuals as TF People.
The purpose of this notice is to give TF People information about:
- what personal information we collect.
- sources of personal information.
- how we use your personal information (and the legal grounds for our use).
- who we share your personal information with.
- when and where we transfer your personal information internationally.
- how we keep your personal information safe.
- how long we keep your personal information.
- your rights in respect of your personal information and how to get in touch.
This notice sets out the basis on which we will process your personal information. Please read this notice carefully so that you understand your rights in relation to your personal information.
This notice may be updated from time to time. We will post any revised notice on our website. It is important you read this notice so that you are aware of how and why we are using your personal information. For information on how to get in touch with us, see section 8 at the end of this notice.
1. What personal information we collect
When we use the phrase personal information in this notice, we mean any information that relates to you or could be used to identify you. At its simplest, this could be your name and your occupation. Personal information will also include any information provided in background checks that we run on you, as well as any feedback about you that we receive in relation to a grant funding or investment.
As part of the assessment process, the personal information we collect includes (but is not restricted to):
- Personal details: name, contact details (address, email addresses, phone numbers), gender, and passports (if we run a background check – see below for more information about these checks).
- Relevant expertise: records of education and experience which are relevant to the investment.
- Relationship with the applicant: role or job title at the applicant, contract (if an independent contractor), years of service with the applicant, salary information (if relevant to the investment).
- Information from background checks: information provided by third party agencies who run background checks in relation to fraud, sanctions and politically exposed people. We run these checks depending on the circumstances, but can be run on key shareholders or funders, directors or trustees, key partners, and senior leadership staff of applicants.
- Opinions and findings of external assessors: opinions from external experts we use to assess the potential for applicants.
- Information provided by applicants: applicants may provide additional information in support of their case for the potential grant funding or investment.
During the administration of our grant funding or investment, the personal information that we collect and use includes (but is not restricted to):
- The personal information identified in the paragraph above in relation to successful applicants.
- Reports from TF People: any personal information provided in reports from TF People, for example, an update about the staffing for a particular project tied to an investment.
- Information about any incidents: In the rare case of an incident arising with an investment (for example, allegations of fraud or other misconduct), the TF People may provide us with information that includes the personal information of those individuals involved.
- Promotional material: any personal information (for example, photographs and testimonials from beneficiaries) provided by an investee to Trinitas Foundation.
Please note that the provision of certain personal information to us is necessary for us to assess whether or not we will make or continue to make an investment. If an applicant does not provide us with this personal information, we may not be able to proceed with the grant funding or investment.
2. Sources of personal information
Because of the nature of our grant funding or investment, we will collect personal information directly from the TF People during our assessment of potential grant funding or investment, and the administration of successful grant funding or investment. Other personal information we collect and use will also come from third party sources, which we have listed below:
- Publicly available sources: for example, we may review the Twitter and LinkedIn accounts of members of the senior leadership of potential TF People.
- Background check services: as part of the due diligence process in our assessment of potential TF People.
- Providers of sanctions and “politically exposed persons” screening lists.
3. How we use your personal information
We will only use personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, Trinitas Foundation has a legitimate interest in processing personal information to assess the prospects of success for proposed grant funding or investment projects.
- where it is necessary to comply with a legal obligation on us (for example, fraud reporting obligations and reports to the Economic and Financial Crimes Commission (EFCC)).
- Assessing potential grant funding or investment: we have a multi-stage assessment process that involves due diligence, internal analysis of the prospective TF People and external expert input. For more about the application process, see our website.
- Administration of our grant funding or investment: this includes monitoring the performance of the TF People (whether through reports provided by the beneficiaries or audits), addressing any incidents which arise in relation to payment or ending of the grant funding or investment.
- Operations: this includes allocating charity resources, strategic planning, project management, business continuity, a compilation of audit trails and other reporting tools, maintaining records relating to our activities, budgeting, financial management and reporting and communications and IT systems.
- Reporting to stakeholders: Trinitas Foundation is funded by a number of donors and we have reporting obligations about our use of resources, use of donor funds and the impact made by the use of donor funds.
- Compliance: Complying with legal and other requirements, such as record-keeping and reporting obligations, conducting audits, compliance with government inspections and other requests from government or other public authorities, responding to legal process such as subpoenas, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims, conducting investigations and complying with internal policies and procedures.
- Promotion of Trinitas Foundation/Trinitas Investment Programme (TIP): this includes promotion of our grant funding or investment through case studies on our website, press releases and other public releases of information, interviews with media organisations and other promotions of Trinitas Foundation and TIP. This also includes fundraising undertaken by TF People, for example in the development and presentation of funding proposals to potential donors (where possible, the information included in our funding proposals is anonymised).
There may be more than one purpose for which we wish to use your personal information in any particular circumstance. For example, if you are a member of the senior leadership team of an applicant we may use your personal information to assess the investment, and then we may continue to use your personal information in order to then administer that investment.
We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purposes. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
4. Who we share your personal information with
We share personal information within our group where necessary for the purposes set out above in section 3.
We also share personal information with the relevant in our TF People (or prospective beneficiary) where appropriate. For example, when we provide feedback as part of the assessment process.
We share your information with selected unaffiliated recipients. These categories of recipients include:
- Partners: these include co-investors, who might also support an applicant project;
- Reviewers/Assessors: experts who help us to assess the investment application and the prospects of success;
- Professional Advisors: accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors in all of the countries in which Trinitas Foundation operates;
- Service Providers: companies that provide products and services to Trinitas Foundation, such as IT infrastructure providers and contractors we use to support our operations;
- Background check agencies: for example, credit reference agencies or Know Your Customer agencies;
- Stakeholders: our donors, that provide Trinitas Foundation/TIP funding for the purposes of grant or investment.
- Public and Governmental Authorities: Entities that regulate or have jurisdiction over Trinitas Foundation such as regulatory authorities, public bodies, and judicial bodies, including to meet national security or law enforcement requirements; and
- Third Parties in Corporate Transactions: In connection with any proposed or actual reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Trinitas Foundation’s organisation (including in connection with any bankruptcy or similar proceedings).
5. How we keep your personal information safe
Trinitas Foundation takes reasonable technical and organisational measures to safeguard your personal information against loss, theft and unauthorised use, access or modification.
We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.
6. How long do we keep your personal information?
We will keep your personal information for as long as required in connection with the purposes for which it was collected and/or is used.
7. Your rights
When we use your personal information you have the right to:
- Ask that we correct any personal information that we hold about you which you believe to be inaccurate.
- Ask for the processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate use.
If you have any questions about how we process your personal information, please feel free to get in touch via firstname.lastname@example.org.