Last updated: March 23, 2021
Introduction
TresVista Financial Services Private Limited, (its holding entity and all affiliates and subsidiaries, both foreign and domestic, collectively, “TresVista,” or “we,” “us,” “our”) respect your concerns about personal data protection and value our relationship with you, (“user” or “you”, “your”).
TresVista is committed to complying with the applicable data privacy and security requirements in the countries in which it operates. TresVista complies with internationally recognized standards of privacy protection, and with various privacy laws globally including, but not limited to, the EU General Data Protection Regulation 2016/679 (GDPR), California Consumer Privacy Act AB-375 (CCPA) . This Policy applies when providing valuation, research, financial modeling, portfolio management, business development, data analytics, real estate advisory, or other services (the “Services”) to its clients or collection and use of personal information you may supply to us through your conduct on the Website.
Collecting Data
Data will be collected by TresVista. TresVista collects personal data to offer and administer our Services and products. TresVista collects the following categories of personal data:
We also collect the following:
Cookies
Our Website may use “Cookies” to identify the areas of our Website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We may use Cookies to personalize the content that you see on our Website. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our Website correctly or at all.
Log Information
We may automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered our Website, if any, as well as the name of the website to which you’re headed when you leave our Website. This information also includes the IP address of your computer/proxy server that you use to access the internet, your internet website provider name, web browser type, type of mobile device, and computer operating system. We may use all this information to analyze trends among our users to help improve our Website.
Clients and other third parties who provide personal information to TresVista must do so in compliance with applicable data privacy regulations.
Cookie Policy (“Cookie Policy”)
A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We may use Cookies to personalize the content that you see on our Website.
Types of cookies TresVista uses include:
Essential Cookies
These cookies enable the Website to function. Certain functional cookies also allow us to respond to service or other inquiries received through a form.
Functional Cookies
These cookies enable the Website to function. Certain functional cookies also allow us to respond to service or other inquiries received through a form.
Analytics Cookies
Analytics cookies track aggregate Website performance, web speed, traffic sources, video plays and other aggregate data across the Website. These cookies allow us to personalize web experience by type of visitor and, upon certain circumstances, by individual user. Individual user information is recognized through form completions or response to certain email marketing campaigns.
Advertising Cookies
Upon occasion, TresVista may advertise on certain media sites. In order to track ad performance, we may place third party cookies from the ad partners. The ad partners may track anonymous site usage behavior on the Website and link it to other information they have associated with your IP address.
In addition to cookies, some information may automatically be collected as you browse our Website, such as type of browser, operating system, domain name or IP address.
Processing of Personal Data
TresVista follows the following principles with respect to the processing of personal data:
If TresVista engages in the processing of personal data for purposes other than those specified in this Policy, TresVista will provide notice of these changes, the purposes for which the personal data will be used, and the recipients of personal data.
The data you provide to us will be processed in accordance with the purposes specified in this Policy, namely:
Whenever we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You have the right to object to this processing, if you may prefer.
How data is processed
Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and in compliance with current regulations. We permit only authorized TresVista employees and authorized representatives to have access to your information. Such employees and representatives are appropriately designated and trained to process data only in accordance with the instructions we provide them.
Accuracy
It is your responsibility to provide TresVista with accurate personal data. Except as otherwise set forth in this Policy, TresVista shall only use personal data in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, TresVista shall take reasonable steps to ensure that personal data is accurate, complete, current and relevant to its intended use.
Storage of Personal Data
TresVista will retain personal data for a reasonable period, taking into account legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with state, local, federal regulations, or country specific regulations and requirements, and in accordance with TresVista’s document retention policy.
Disclosure/Sharing of Personal Data
We only share your personal data with your consent or in accordance with this Policy. We will not otherwise share, sell or distribute any of the information you provide to us except as described in this Policy.
We share personal data among TresVista entities who act for TresVista for the purposes set out in this Policy.
TresVista may share your information with its representatives and other service providers who are performing certain services on behalf of TresVista. Such third parties have access to personal data solely for the purposes of performing the services specified in the applicable service contract, and not for any other purpose. TresVista requires these third parties to undertake security measures consistent with the protections specified in this Policy.
TresVista may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
If TresVista’s business enters into a joint venture with or is merged with another business entity, your information may be disclosed to our new business partners.
Cross-Border Transfers of Personal Data
TresVista is a global firm with operations in several countries. Personal information may be transferred, accessed and stored globally as necessary for the uses stated above in accordance with this Policy, and in compliance with local regulations.
Personal Data may be transferred to or processed in locations outside of the European Economic Area (EEA), some of which have not been determined by the European Commission to have an adequate level of data protection. In that case, for personal data subject to European data protection laws, we take measures designed to provide the level of data protection required in the EU, including ensuring transfers governed by the requirements of the Standard Contractual Clauses adopted by the European Commission, or another adequate transfer mechanism.
Where we receive requests to disclose personal data from law enforcement or regulators, we carefully validate these requests, including reviewing the legality of any order and challenging the order if there are grounds under the law to do so, before any personal data is disclosed.
Your Rights
Depending on the laws of the jurisdiction governing the processing of your personal data, you may have certain rights under applicable data protection laws including:
Please contact us to request access, rectification, or erasure, or to restrict processing, to object to processing, to request data portability. Subject to legal considerations or certain exemptions, we may not always be able to address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way. Please contact us by email to ensure your request is received in a timely manner.
Automated Decision Making
Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.
TresVista does not make automated decisions using personal data. If automated decisions are to be made, affected persons will be given an opportunity to express their views on the automated decision in question and object to it.
Providing Information to TresVista
If you choose not to provide certain personal information, it may be an impediment to the exchange of information necessary for the execution of the contract or provision of Services, and we may not be able to provide you with some services and you may not be able to participate in some of the activities on our Website.
User Registration and Password
Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. To ensure effectiveness of your password, we recommend that you do not disclose your user identification or password to anyone. Please be careful and responsible whenever you are online.
Third Party Websites or Other Services
We are not responsible for the privacy practices of any non-TresVista operated websites, mobile apps or other digital services, including those that may be linked through our Website or services, and we encourage you to review the privacy policies or notices published thereon.
Miscellaneous Privacy Issues
Tresvista is committed to protecting the privacy of children. Our policy is that we do not knowingly collect, use or disclose personal data about visitors that we know are under 13 years of age. This Website is not directed in any respect to children under the age of 13.
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 in the European Economic Area (EEA).
Service Providers
We employ third party companies and individuals to facilitate our Website (“Service Providers”), to provide our Website on our behalf, to perform Website-related services or to assist us in analyzing how our Website is used. These third-parties may have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
California Consumer Privacy Act (CCPA)
TresVista may collect and use consumer personal information for its business purposes and related operational purposes. With respect to these activities, TresVista may have direct responsibilities as a business subject to the CCPA. For example, for certain activities related to interacting with prospective/current clients, marketing, website and web application use, engaging vendors, and interacting with visitors/users of our Website. In these cases, this Policy is applicable.
TresVista also collects information in its capacity as a service provider to our clients, providing Services. In that case, TresVista receives personal information from our clients where we have no direct relationship with the individuals whose personal information we process, and information is provided to us solely for the business purpose of providing those Services. If you are a customer or other user associated with one of our clients on whose behalf we have collected or processed your information, this Policy does not apply to you, and if you have questions or wish to exercise your rights relating to your personal information (such as information, access or deletion), please contact that client directly.
Information We Collect
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 (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
| Category | Examples | Collected |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | 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. | YES |
| C. Protected classification characteristics under California or federal law. | 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). | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information. | 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. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | NO |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
| 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)). | 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. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business 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.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers
Category B: California Customer Records personal information categories
Category C: Protected classification characteristics under California or federal law
Category I: Professional or employment-related information
We disclose your personal information for a business purpose to the following categories of third parties:
IN THE PRECEDING TWELVE (12) MONTHS, WE HAVE NOT SOLD ANY PERSONAL INFORMATION.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer 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:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please contact us.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Compliance
TresVista will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.
If you believe that your personal data/personal information has been processed or disclosed in violation of this Policy, TresVista encourages you to raise any concerns using the contact information provided in this Policy. TresVista will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of your personal data/personal information.
Changes to this Policy
This Policy may be amended from time to time, consistent with the requirements of applicable law. A notice will be posted by TresVista on this Website when this Policy is changed.
Contact Us
Please contact us at TresVista with questions, concerns, or complaints.
