Privacy Policy

1. Introduction

Orvex Capital Limited ("Orvex Capital", "we", "us", or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your data when you visit our website, engage our services, or interact with us in any capacity.

This policy applies to all personal data processing activities conducted by Orvex Capital in connection with our venture capital, development capital, and fund management activities in Canada and the United Kingdom.

2. Data Controller

The data controller responsible for your personal information is:

Orvex Capital Limited
Email: privacy@orvex.capital

3. Information We Collect

3.1 Information You Provide

• Contact details (name, email address, phone number, postal address)
• Company or organisation information
• Identity verification documents (passport, driver's licence, corporate registration)
• Financial information (source of funds, bank details, investment history)
• Communications and correspondence with us
• Information submitted through our contact forms

3.2 Information Collected Automatically

• IP address and browser type
• Device information and operating system
• Pages visited and time spent on our website
• Referring website addresses
• Cookies and similar tracking technologies (see Section 9)

4. How We Use Your Information

We use your personal information for the following purposes:

• To provide and manage our venture capital and fund management services
• To conduct customer due diligence and comply with AML/KYC requirements
• To process investment applications and manage fund participations
• To communicate with you regarding our services and your enquiries
• To comply with legal and regulatory obligations in Canada and the UK
• To improve our website and services
• To protect against fraud and unauthorised access

5. Legal Basis for Processing

We process your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our services agreement with you
• Legal obligation: Processing required to comply with AML, KYC, and other regulatory requirements
• Legitimate interests: Processing necessary for our business operations, fraud prevention, and service improvement
• Consent: Where you have given explicit consent for specific processing activities

6. Data Sharing and Disclosure

We may share your personal information with:

• Regulatory authorities (FINTRAC, FCA, NCA, and other competent bodies) as required by law
• Professional advisers (legal, audit, compliance) bound by confidentiality obligations
• Service providers who assist in our operations (IT, cloud hosting, identity verification)
• Fund administrators and custodians in connection with fund management activities
• Counterparties in investment transactions, subject to confidentiality agreements

We do not sell your personal information to third parties.

7. International Data Transfers

As Orvex Capital operates in both Canada and the United Kingdom, your personal data may be transferred between these jurisdictions. We ensure that all international transfers are conducted with appropriate safeguards, including standard contractual clauses and adequacy decisions where applicable.

8. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. AML/KYC records are retained for a minimum of five (5) years after the termination of the business relationship.

9. Cookies

Our website uses essential cookies necessary for website functionality. We may also use analytics cookies to understand how visitors interact with our site. You can control cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.

10. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you
• Rectification: Request correction of inaccurate or incomplete data
• Erasure: Request deletion of your data (subject to legal retention requirements)
• Restriction: Request limitation of processing in certain circumstances
• Portability: Request transfer of your data to another service provider
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Withdraw consent where processing is consent-based

To exercise any of these rights, please contact us at privacy@orvex.capital.

11. Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, secure data storage, and regular security assessments.

12. Children's Privacy

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal information from minors.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.

14. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact:

Data Protection Officer
Orvex Capital Limited
Email: privacy@orvex.capital

You also have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction (Office of the Privacy Commissioner of Canada or the Information Commissioner's Office in the UK).