Privacy Policy

Triatomic Management LP (“Triatomic”) respects your right to privacy.  This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.  This Privacy Notice only applies to personal information that we collect through our website at Triatomic Capital (“Website”). If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice. Triatomic is a is an investment partnership, headquartered in the United States.  For more information about Triatomic, please see the “About” section of our Website at Triatomic Capital.

What personal information does Triatomic collect and why?

The personal information that we may collect about you generally falls into the following categories:

• personal details such as names, dates of birth, address, business and/or personal email address, and business and/or personal telephone phone numbers, positions and places of work, nationality and/or citizenship, country of residence, country of tax residence, photographs and signatures
• information from third party sources
• government issued identifiers including passports, national insurance numbers, taxpayer identification numbers and other government-issued IDs
• other identifying documentation, such as utility bills and proof of address
• financial information such as subscription and bank and brokerage account information, including routing and account numbers
• tax identification number(s) and related tax forms
• technical information such as internet protocol address, cookies, information about the device you use to interact with us and information from your use of our website.

We will only process sensitive personal data to the extent required by law and where there is a lawful basis for doing so under the data protection laws (such as, where permitted, on the basis of your express consent, defence of a legal claim, for substantial public interest). If you decide not to provide sensitive personal data, we may be unable to complete a proposed transaction with you or otherwise continue our business relationship.

Who does Triatomic share my personal information with?

We may disclose your personal information to the following categories of recipients:

• to our group companies, third party services providers and partners who provide data processing services to us
• your associates, advisers and representatives
• to any competent law enforcement body, regulatory, government agency, court or other third party, for example to comply with law
• lenders, our professional advisers, anti-fraud services, credit reference agencies, debt-collection agencies, and tracing agencies
• any relevant party in connection with our legal, regulatory, and compliance obligations, including identity verification, know your client (KYC), terrorist financing, anti-money laundering, and sanctions checks
• any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of the interests you may acquire from us

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.  However, we will normally collect personal information from you:

• where we need the personal information to perform a contract with you, including where you are a client, where you invest with us, or where we need to make payments to you
• comply with our legal obligations, including where we have legal and regulatory obligations, conduct our business in accordance with law, comply with requests from regulatory agencies, or prevent and detect criminal activity
• where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, including managing our business, conduct credit and financial due diligence, communicate with you, address complaints or concerns, manage our legal obligations, comply with our accounting and other requirements, seek professional advice, or protect the security of our systems

From time to time, we may need to process personal data, including possibly special category personal data, on other legal bases. Depending on the nature of the processing and the type of personal data, other legal bases may include:

• your express consent to the processing
• the exercise or defence of a legal claim
• if it is necessary to protect the vital interests of other data subjects
• if it is necessary for reasons of substantial public interest.

Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. We use necessary cookies (such as those that enable basic functions on our website), statistical cookies (such as those that help us understand how visitors interact with our website), and marketing cookies.

How does Triatomic keep my personal information secure?

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you.  The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.  

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident.  These countries may have data protection laws that are different to the laws of your country. Specifically, our group companies and service providers and partners operate around the world.  This means that when we collect your personal information we may process it in any of these countries. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your data protection rights

If you are a resident of the United Kingdom or the European Economic Area, you have the following data protection rights:

• to request confirmation of whether we process personal data relating to you and, if so, to request a copy of that personal data
• to request that we rectify or update your personal data that is inaccurate, incomplete, or outdated
• to request that we erase your personal data in certain circumstances
• to request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted (for example, a request that we update your personal data)
• where you have given us your consent to process your personal data, to withdraw your consent
• to request that we provide a copy of your personal data to you or a third party in a structured, commonly used, and machine-readable format in certain circumstances
• to object to certain of our processing of your personal data.

You have the right to complain to a data protection authority about our collection and use of your personal information.  For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here. If you want to contact us, please use the contact details below. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact us using the following details:

Triatomic Management LP
505 Hamilton Ave, STE 330
Palo Alto, CA 94301

The data controller of your personal information is Triatomic Management LP

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