ORI is committed to processing personal information (“PI”), including sensitive personal information (“SPI”)1, in line with all applicable privacy and data protection laws. “ORI”, “we”, “us” or “our” means ORI Capital Limited, and each of the ORI Group companies (the “ORI Group”).

References to “you” or “your” refers to individuals whose PI is processed by ORI, including clients with direct or indirect relationships (such as those who invest through an intermediary); employees, contingent workers, officers, agents (together “Representatives”); and beneficial owners of an organization or entity in connection with:

• the provision of services to potential and actual clients;
• transactions to which we are party (including those which we effect on behalf of clients); or
• services provided to us by a third-party vendor.

This Privacy Notice sets out the purposes for which we collect, use and disclose (collectively “processing”) PI and how it is protected. It also sets outs individuals’ rights in relation to the processing of their PI.

There may be additional terms, conditions and commitments that also govern how we collect, use and disclose your PI, which should be read in conjunction with this Privacy Notice.

PI we collect about you

PI is information relating to an individual, which can be used either alone or with other sources of information to identify that individual. PI does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous. SPI is a sub-category of PI that includes PI relating to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.

The nature of the information that we may collect will depend on the services we provide and our relationship with you. We categorize PI we process as follows (the PI listed for each category are non-exhaustive examples):

• Identification data

Full name, title, gender, marital status, date of birth, passport number, driving licence number, national identification number, signature

• Contact data

Personal address, telephone number, email address

• Electronic Monitoring data

To the extent permitted by law, we may record and monitor your electronic communications with us

• Financial data

Bank account number; credit card number

• Marketing and Communications data

Marketing and communication preferences; tracking data relating to whether you have read marketing communications from us

• Professional Information data

Position/job title, work address; telephone number; email address

• Profile data

Username and password for our online services that you have access to; investments made by you; services requested; marketing communications responded to; survey responses

• Services data

Payment details to and from you; details of services you have provided to us or we have provided to you

• Technical data

Your use of and interaction with our online services; your IP address; browser type and version; browser plug in types and versions; operating system

• SPI

In limited circumstances, and where allowed by law, we may collect information about criminal convictions and offences, when legally required; dietary requirements if we are arranging catering; disability so that we can make reasonable accommodations for you in our buildings; sexual orientation if you provide details of your spouse or partner; political affiliations for us to determine whether you are a politically exposed person.

We may collect PI in relation to you in a number of ways, including:

• when you provide it to us in connection with an ORI product or service, such as a completed investment application form
• if you are Representative of an organization or entity that is a client or vendor of ORI and that organization or entity provides us with your PI
• throughout the course of our relationship with you, including where you change your details, provide additional PI, or where the services we are providing to you change
• from public sources where you have manifestly chosen to make your PI public, including via public profiles on social media
• from third parties such as credit reference agencies
• from visits to our websites or through logging into any of our online services

We may also create or derive PI such as creating records of your interactions with us, subject to applicable law.

Unless we otherwise indicate that the provision of specific PI is optional, any PI we request is necessary for us to provide you or your organization or entity with the products and services requested. If you do not provide the PI requested, we may not be able to provide those products and services.

To whom we may disclose your PI

We may disclose PI in any jurisdiction to:

• other members of the ORI Group;
• professional advisors, third parties, agents or independent contractors that provide services to any member of the ORI Group (such as IT systems providers, platform providers, financial advisors, brokers, consultants (including lawyers and accountants);
• goods and services providers (such as providers of marketing services where we are permitted to disclose your personal information to them); intermediaries, brokers, and other individuals and entities that partner with us;
• competent authorities (including any national and/or international regulatory or enforcement body, agency, court or other form of tribunal or tax authority) or their agents where ORI is required or allowed to do so under applicable law or regulation;
• a potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of ORI’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it;
• credit reference agencies or other organizations that help us to conduct anti-money laundering and anti-terrorist financing checks and to detect fraud and other potential criminal activity; or
• any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument.

Third-party marketing/sale of PI

We do not share or sell your PI to third parties for the third party to use for their own marketing or other purposes.

PI retention

We will process your PI for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defense of legal claims.

PI security

The security of data transmitted over the internet (including by e-mail) cannot be guaranteed and carries the risk of access and interception. You should not send us any PI by open/unsecure channels over the internet. We endeavour to protect personal information but cannot guarantee the security of data transmitted to us or by us.

Contacting us

If you wish to exercise any of your rights regarding your PI or SPI, or have questions concerning this notice, please contact us by email at info@ori-capital.com

Complaints

If you have any concerns or complaints about the way your PI is processed, please contact us at info@ori-capital.com.

Linked websites

This Privacy Notice is not applicable to third party websites that we do not own or control, or to any third-party website where ORI advertisements are displayed.

Changes to this Privacy Notice

We may modify or amend this Privacy Notice from time to time and you are advised to visit our website regularly to check for any amendments. Any material changes will be communicated to you through an appropriate channel, depending on how we normally communicate with you.