Privacy Policy

Ormonde Partners Ltd, Ormonde Europe Limited, Ormonde Advisory Limited, Ormonde Capital Management SARL and Ormonde USA LLC, (“Ormonde” and each an “Ormonde Affiliate”, together the “Ormonde Group”, “we” and “us”) are committed to protecting the privacy of those with whom we interact and we recognise the need to respect and protect information that is collected or disclosed to us (called “Personal Data”, explained below).

We respect your privacy and we are committed to protecting your Personal Data. This privacy policy will inform you as to how we look after your Personal Data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy applies to devices, products, website or applications that refer or link to the privacy policy (collectively, our “Services”) and will apply whether you access our Services using a computer, mobile phone, tablet, TV or other device.

Please see below for further information on our privacy practices:

1.              IMPORTANT INFORMATION AND WHO WE ARE

2.              THE DATA WE COLLECT ABOUT YOU

3.              HOW IS YOUR PERSONAL DATA COLLECTED?

4.              HOW WE USE YOUR PERSONAL DATA

5.              DISCLOSURES OF YOUR PERSONAL DATA

6.              INTERNATIONAL TRANSFERS

7.              DATA SECURITY

8.              DATA RETENTION

9.              YOUR LEGAL RIGHTS

10.            GLOSSARY

1.              Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how the Ormonde Group collects and processes your Personal Data through your use of this website, including any data you may provide through this website when you use our website.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

The Ormonde Group is made up of different legal entities, details of which can be found above. This privacy policy is issued on behalf of the Ormonde Group so when we mention “Ormonde”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Ormonde Group responsible for processing your data. Ormonde Advisory Limited is the controller and responsible for this website.

We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data protection manager using the details set out below.

Our full details are: Ormonde Advisory Limited

Data protection manager:  Christopher Winn, Chief Executive Officer

Email address: legal@ormondepartners.com

Postal address: Berkeley Square House, Berkeley Square, London, W1J 6BD, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.              The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified (“Personal Data”). It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

·       Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.

·       Contact Data includes address, email address and telephone numbers.

·       Financial Data includes information about investments and pension assets.

·       Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

·       Usage Data includes information about how you use our website, products and services.

·       Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3.              How is your personal data collected?

Ormonde collects information through its website and other Ormonde products, applications, platforms, services and events (our “Products”). We use different methods to collect data from and about you including:

3.1           Direct interactions

You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

·       apply for our products or services;

·       subscribe to our service or publications;

·       set-up portfolios, preferences, and notifications/alerts connected to our Products.

·       request marketing to be sent to you.

3.2           Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

3.3           Third parties or publicly available sources. 

We will receive Personal Data about you from various third parties and public sources as set out below:

a)    Technical Data by using tracking and analytics tools, such as pixel tags, action tags, web beacons and JavaScript amongst others to collect and analyse information on behaviour and engagement with our Products.

b)    Identity and Contact Data from publicly available sources such as Companies House or the FCA.

4.              How we use your personal data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

·       Provide our Services: to deliver our Products, as well as to administer systems and accounts;

·       Customised Content: to provide customised content and layout of our Products and Services;

·       Analysis Purposes: for assessment and analysis of our market, customers, products, and other Services, and to create sales, marketing and promotional plans and programs;

·       Service Improvement: to enhance our Products and the user experience and to develop new products and services;

·       Customer Support Services: to provide customer support services, product training and education to users;

·       Crime Prevention: for the prevention or detection of fraud or crime;

·       Business Purposes: for business monitoring and internal record keeping;

·       Legal Obligations: to comply with our legal obligations;

·       Training: for staff training and quality assurance purposes, particularly in relation to our customer support representatives; and

·       Updates: to communicate with you, including communicating with you about your account, profiles or transactions with us, giving you important information about your products or other Services, sending you notices about any material changes to our privacy policy, and, where permitted by you and applicable laws, marketing, sending you offers and promotions for our Services.

Marketing 

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. When we process your Personal Data for marketing purposes, we do so on the basis that it is in our Legitimate Interests to do so, or in the case of our email notification service, that it is necessary to perform our contract with you.

We may also use your Personal Data to personalise and to target more effectively our marketing communications to ensure, to the extent possible, that any marketing-related correspondence is relevant to you.

To opt out of receiving marketing-related correspondence from us, please contact us or click “Unsubscribe” from any marketing or promotional email you receive from us.

Third-party marketing 

We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your Personal Data 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 purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.              Disclosures of your personal data

We will only use your Personal Data for our internal business purposes, some of which are mentioned above. However, we may disclose your information with the following entities:

5.1           Ormonde Affiliates

We may need to transfer your Personal Data to other Ormonde Affiliates to provide the Services you require or any other services/assistance you request. All Ormonde Affiliates are required to follow the privacy practices set forth in this privacy policy, or such other privacy policy that they may notify to you.

5.2           Service Providers

We use third party service providers to help us to administer certain activities and services on our behalf, such as analysing usage of our Services, email support services, and tracking effectiveness of our marketing campaigns. We may share Personal Data about you with such third-party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions. Here are examples of third-party service providers we use:

(a)        Email Support Services — support services to assist us in ensuring our email service functions so as to provide you with our Services;

(b)        Analytics Service Providers — analytics providers are used to assist us in understanding the usage of our products/devices and other Services, to enable us to improve our Services. For further information see our Cookie Policy.

5.3           Third parties when required by Law or to Protect our Services

We will disclose your Personal Data to comply with applicable law or respond to valid legal process, including from our regulators, law enforcement or other government agencies; to protect our customers (e.g. to prevent spam or attempts to defraud users of our Services); to operate and maintain the security of our Services (e.g. to prevent or stop an attack on our systems or networks); or to protect the rights or property of Ormonde, including enforcing any terms or agreements governing the use of our Services.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

5.4           Other Parties at Your Direction

We may share Personal Data about you with third parties when you request to such sharing, including fund administrators, financial adviser, broker, actuary, solicitor or accountant.

6.              International transfers

Many of our external third parties are based outside the EEA so their processing of your Personal Data may involve a transfer of data outside the EEA.  Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

·       We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.

·       Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

7.              Data security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.              Data retention

How long will you use my personal data for?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.              Your legal rights

We will collect, store and process your Personal Data in accordance with your rights under any applicable data protection laws. Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. Please click on the links below to find out more about these rights:

9.1           Subject Access — you have the right to request details of the Personal Data which we hold about you and copies of such Personal Data.

9.2           Right to Withdraw Consent — where you have consented to our processing of your Personal Data, you have the right to withdraw such consent at any time. In the event you wish to withdraw your consent to processing, please contact us using the details provided in section 13 below.

9.3           Data Portability — you may, in certain circumstances, request us to port (i.e. transmit) your Personal Data directly to another organisation.

9.4           Rectification — we want to ensure that the Personal Data about you that we hold is accurate and up to date. If you think that any information, we have about you is incorrect or incomplete, please let us know. To the extent required by applicable laws, we will rectify or update any incorrect or inaccurate Personal Data about you.

9.5           (“right to be forgotten”) — you have the right to have your Personal Data “erased” in certain specified situations.

9.6           Restriction of processing — you have the right in certain specified situations to require us to stop processing your Personal Data and to only store such Personal Data.

9.7           Object to processing — you have the right to object to specific types of processing of your Personal Data, such as, where we are processing your Personal Data for the purposes of direct marketing.

9.8           Prevent automated decision-taking — in certain circumstances, you have the right not to be subject to decisions being taken solely on the basis of automated processing.

Enforcing your rights

If you wish to exercise any of the rights set out above, please contact us at info@ormondepartners.com.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.           Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do 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 can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Ormonde Group acting as joint controllers or processors and who are based France or the United Kingdom and provide IT and system administration services and undertake leadership reporting.

External Third Parties

·       Service providers acting as processors based in the United Kingdom who provide IT and system administration services.

·       Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom, Ireland, and France who provide consultancy, banking, legal, insurance, regulatory and accounting services.

·       HM Revenue & Customs, Financial Conduct Authority, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:

·       If you want us to establish the data’s accuracy.

·       Where our use of the data is unlawful but you do not want us to erase it.

·       Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

·       You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.