This Privacy Notice describes how Ormonde Investment Management, LLC ("OIM," "we," "us," or "our") collects, uses, shares, retains, and protects information when you visit our website, contact us, or are a client or prospective client receiving investment advisory services from us. It also explains the privacy rights available to you and how to exercise them.
OIM provides this Notice pursuant to Title V of the Gramm-Leach-Bliley Act (GLBA) and the U.S. Securities and Exchange Commission's Regulation S-P (17 CFR Part 248), and, with respect to general website visitors and applicable state law, as a broader website privacy notice. We do not sell your personal information. We do not use your personal information for marketing by nonaffiliated third parties.
OIM is a Delaware limited liability company registered as an investment adviser with the U.S. Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940. Our principal office is at 4100 Alpha Road, Suite 500, Dallas, TX 75244. OIM was formerly known as Ormonde USA LLC.
We provide discretionary and non-discretionary investment management services to a limited number of institutional and high-net-worth clients. We are an investment adviser only — we are not a broker-dealer, do not execute securities transactions on a principal basis, and do not maintain custody of client assets. Client assets are held by qualified custodians selected by the client or by OIM with the client's consent.
Our affiliates include Ormonde Benefits Administration LLC ("OBA"), a Texas-licensed third-party administrator, and Paydhealth LLC, which provides operational and technology support services to OIM; we share information with these affiliates to facilitate service delivery to clients. Ormonde Advisory Limited ("OAL") is our United Kingdom affiliate; it provides group support services. References in this Notice to "affiliates" include these entities and others under common control with OIM.
This Notice applies to information OIM collects: when you visit our website at ormondeinvestments.com or any subdomain we operate; when you contact us by email, phone, or mail; when you are a client or prospective client and provide information to us in connection with our investment advisory services; and when we receive information about you from custodians, service providers, affiliates, or regulators in connection with those services. Where GLBA and Regulation S-P apply, they govern our handling of the information described in this Notice for our clients and prospective clients. This Notice also describes our practices with respect to general website visitors who do not have and are not seeking an advisory relationship with us.
We collect nonpublic personal information about you that is necessary to open and maintain your advisory relationship, to manage your account, and to meet our legal and regulatory obligations. The categories below summarize the information we collect, examples, and sources.
| Category | Examples | Sources |
|---|---|---|
| Identification and contact data | Legal name, date of birth, residential and mailing address, email address, telephone number, government-issued identification, Social Security number or taxpayer identification number. | Provided by you on account-opening documents and through subsequent communications. |
| Financial profile | Net worth, annual income, source of funds, source of wealth, liquidity needs, investment experience, risk tolerance, and investment objectives. | Provided by you on the client questionnaire and investment policy statement; updated through periodic reviews. |
| Account and transaction data | Custody account numbers, account balances, holdings, transaction history, contributions and withdrawals, performance information, and tax-lot data. | Provided by your qualified custodian, executing broker-dealers, and our portfolio management systems. |
| Tax information | Taxpayer identification number, tax residency, IRS Form W-9 or W-8 series, and tax-lot accounting elections. | Provided by you on account-opening documents. |
| KYC and AML information | Information collected to satisfy our customer identification, beneficial ownership, sanctions screening, and anti-money-laundering obligations, including for entity clients the names and identification of authorized signatories and beneficial owners. | Provided by you and verified against independent data sources and government sanctions lists. |
| Communications data | Records of your communications with us (calls, emails, meeting notes, instructions). | Generated when you contact us or we contact you. |
| Technical data | IP address, device identifiers, and log data when you use our online services. | Collected automatically when you interact with our online services. |
We collect the minimum information reasonably necessary to provide our services and to meet our legal obligations. We do not collect health information, biometric identifiers, precise geolocation data, or information about your race, religion, or political opinions.
We use your nonpublic personal information only for the following purposes: investment management (constructing, implementing, and monitoring portfolios in accordance with your objectives, guidelines, and risk tolerance); account administration (opening and maintaining your account, processing contributions and withdrawals, coordinating with your custodian); reporting and communications (client reports, performance statements, required regulatory disclosures, responding to inquiries); KYC, AML, and sanctions compliance; regulatory compliance and recordkeeping (books and records under Rule 204-2, responding to examinations and lawful regulatory requests); tax reporting; risk management and supervision (supervising trading and advice, monitoring suitability and conflicts, operating our compliance program under Rule 206(4)-7); and information security and fraud prevention.
We do not sell your personal information. We do not share your personal information with nonaffiliated third parties for their own marketing purposes. We do not use your personal information for cross-context behavioral or targeted advertising.
We share your nonpublic personal information only as necessary to provide our services, as you have directed, or as permitted or required by law. Our disclosures fall within the exceptions set out in Regulation S-P §§ 248.13, 248.14, and 248.15, which permit disclosure to service providers, in connection with servicing or processing transactions you have requested, and as otherwise required or permitted by law.
We share information with the qualified custodian that holds your assets as needed to open and maintain your custody account, place trades, and reconcile holdings; and trade-instruction and account information with broker-dealers that execute securities transactions for your account, as needed to route, execute, and settle those transactions.
We engage service providers — including portfolio management and order-management systems, performance and reporting providers, IT and cloud-hosting providers, secure document and email providers, and KYC/AML verification providers — to support our operations. Service providers act on our instructions, are contractually required to protect your information to standards equivalent to those described in this Notice (including breach-notification obligations to us), and are not authorized to use your information for their own purposes.
We may share information, where strictly necessary, with our auditors, legal counsel, tax advisors, and compliance consultants, all of whom are subject to professional confidentiality obligations.
We may disclose information to the SEC, FinCEN, the IRS, state securities regulators (including the Texas State Securities Board), state attorneys general, and other regulators where required by law, in response to lawful requests, audits, or examinations; and in response to valid subpoenas, court orders, or other lawful legal process, to investigate or prevent suspected fraud or security incidents, or to protect the rights, property, and safety of OIM, our clients, or others. We disclose only what is required.
We share information with persons you authorize — for example, your tax advisor, attorney, family office, or other adviser — when you instruct us to do so in writing.
We may share information with our affiliates (Ormonde Benefits Administration LLC and Paydhealth LLC) and with Ormonde Advisory Limited for group support services — only as needed to provide our services, manage shared infrastructure, and meet group-wide regulatory obligations. We do not share creditworthiness or marketing information with affiliates that would trigger an opt-out right under the Fair Credit Reporting Act, because we do not collect or share that type of information.
If OIM is involved in a merger, acquisition, financing, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will require any successor to honor the privacy commitments described in this Notice or to provide an equivalent notice.
We do not sell your nonpublic personal information for money or other valuable consideration, and we do not share it with nonaffiliated third parties for cross-context behavioral or targeted advertising.
Categories we collect: identification and contact data, financial profile, account and transaction data, tax information, KYC and AML information, communications data, and technical data (Section 3). Categories we disclose: any of the categories described in Section 3, but only to the categories of recipients described in Section 5 and only for the purposes described in Section 4. Categories of recipients: our affiliates (Ormonde Benefits Administration LLC, Paydhealth LLC, and Ormonde Advisory Limited) and the nonaffiliated categories described in Section 5 — qualified custodians, executing broker-dealers, service providers, professional advisors, regulators and government authorities, and persons you authorize. Joint marketing: we do not disclose nonpublic personal information to nonaffiliated third parties for joint marketing. Opt-out rights: because our disclosures fall within the exceptions in §§ 248.13, 248.14, and 248.15, no opt-out right under § 248.10 applies; if we ever propose to share outside those exceptions, we will provide a revised notice and an opportunity to opt out first. Former clients: we continue to apply these protections to former clients' information for as long as we retain it.
OIM maintains a written information security program designed to protect nonpublic personal information from unauthorized access, disclosure, alteration, and destruction, consistent with Regulation S-P Rule 248.30 (as amended in 2024), applicable state law, and recognized industry frameworks. Our safeguards include:
No method of transmission or storage is perfectly secure. If you believe your information has been compromised, please contact us at the address provided in Section 16.
| Information type | Minimum retention period | Basis |
|---|---|---|
| Investment advisory records (account opening documents, advisory agreements, communications, trade records, performance records) | 5 years from the end of the fiscal year, first 2 years easily accessible | Investment Advisers Act, Rule 204-2 |
| Books and records concerning recommendations, advice, and performance information | 5 years from the end of the fiscal year | Rule 204-2(a) |
| Safeguards-rule compliance records | 6 years | Regulation S-P § 248.30(a)(6) (as amended) |
| Tax and IRS records | Generally 7 years | Internal Revenue Code recordkeeping |
| AML and customer identification records | 5 years after the account is closed | FinCEN customer identification rules |
| Privacy rights request records | Generally 3 years | Applicable state privacy laws |
When the applicable retention period expires, we securely destroy or de-identify the information in accordance with our record retention and disposal policy. Where retention periods required by different laws differ, we retain the information for the longer of the applicable periods.
Depending on the law that applies to you, you may have rights of access, correction, deletion (subject to legal exceptions, including books-and-records, AML, and tax retention obligations), portability, opt-out of sale, sharing, or targeted advertising (we do not engage in these activities, but we honor opt-out requests), limitation of sensitive-information use, opt-out of profiling for significant decisions (we do not engage in such profiling), complaint and non-retaliation, and appeal of a denied request. These rights derive from GLBA / Regulation S-P and, where applicable, state privacy laws including the CCPA/CPRA (California), TDPSA (Texas), CPA (Colorado), CTDPA (Connecticut), and VCDPA (Virginia). We honor the rights that apply to you.
Submit a privacy rights request by email (privacy@ormondeinvestments.com) or mail (OIM Privacy Office, 4100 Alpha Road, Suite 500, Dallas, TX 75244). We will verify your identity by matching your request against information already in our records; we do not require in-person verification. We respond within the timeframe required by the law that applies to you — typically 45 days for state privacy law requests, with extensions as permitted by law and notice to you. The first request in a 12-month period is free; we may charge a reasonable, cost-based fee for additional requests, and will tell you in advance. If we deny your request in whole or in part, we will explain why and how to appeal; you may also complain to the SEC, your state securities regulator, or your state attorney general. We will not retaliate against you for exercising your rights. Where state law permits, you may use an authorized agent, subject to written authorization and verification.
Our website does not use cookies. We use a privacy-preserving third-party analytics service (currently Fathom Analytics) to understand aggregate site usage. Fathom does not use cookies, does not fingerprint visitors, does not track individuals across sites or sessions, and does not collect personal information. The analytics service processes information on our behalf under contractual confidentiality obligations and collects only aggregate signals such as page views, referring source, browser type, and country (derived from IP address, which the service does not retain). We do not use cookies, similar technologies, or profiling for cross-context behavioral or targeted advertising.
Our services are intended for adults and institutional clients and are not directed to children. We do not knowingly collect personal information from children under the age of 13, and we are not subject to the Children's Online Privacy Protection Act. If we receive personal information about a minor in connection with an account (for example, a beneficiary), we treat that information with the same protections described in this Notice and use it only for the purposes described here.
Personal information we process in connection with our investment advisory activities is generally exempt from state consumer-privacy laws under the GLBA exemption, but is covered by GLBA and Regulation S-P. Where the GLBA exemption does not apply, the rights described in Section 9 apply.
Our website may contain links to, or be integrated with, third-party websites and services that we do not own or control, including OpenStreetMap, Google Maps, Apple Maps, and external partner sites. This Notice does not apply to those third-party services. We encourage you to review their privacy notices before providing information to them.
OIM operates from the United States. If you access our website from outside the United States, you understand that your information may be transferred to, stored in, and processed in the United States, where data protection laws may differ from those of your country.
We may update this Notice from time to time to reflect changes in our practices or in applicable law. The effective date shown at the top of this document identifies the current version. Because we share nonpublic personal information only as described in this Notice and as permitted by law, and no opt-out right applies, no annual notice is required to clients unless our practices change; we will provide a revised notice before any material change takes effect, and where required by law we will obtain your consent before applying a material change to information we have already collected. Material changes will be communicated by posting the updated notice on this page and, for clients, by email or mail.
If you have questions about this Notice, want to exercise your privacy rights, or want to make a complaint, contact us by email (privacy@ormondeinvestments.com), mail (OIM Privacy Office, 4100 Alpha Road, Suite 500, Dallas, TX 75244), or phone (+1 833 689 6003). You may also file a complaint about our privacy practices with the U.S. Securities and Exchange Commission (www.sec.gov, phone 1-800-SEC-0330), your state securities regulator, or your state attorney general. We will not retaliate against you for exercising your rights or filing a complaint.