ORAMAN PRIVATE CAPITAL

3. Information Collection and Use

Oraman Private Capital collects and processes information to deliver, maintain, and enhance our suite of financial and investment services, to ensure compliance with all applicable regulatory and legal obligations, and to safeguard the integrity and security of our operations.

The information we collect allows us to: • Provide tailored investment, advisory, and wealth management solutions;
• Ensure the efficient and secure operation of our Services;
• Conduct risk assessments, compliance checks, and due diligence in accordance with regulatory requirements;
• Monitor and improve the quality, functionality, and user experience of our digital platforms;
• Communicate important information, updates, and offers relevant to our clients;
• Detect, prevent, and respond to fraud, cyber threats, or other unauthorized activities.
All information is handled with the highest standards of confidentiality and security, in accordance with applicable laws and Oraman’s internal data protection policies.

4. Types of Data Collected

(a) Personal Data
Oraman Private Capital may collect personally identifiable information (“Personal Data”) to provide, manage, and improve our services. This may include, but is not limited to:
• Full name, date of birth, nationality, and marital status;
• Contact information including email address, phone number, and residential or business address;
• Government-issued identification documents (e.g., passport, national ID);
• Financial information, investment portfolio details, and risk profile;
• Health or other sensitive personal data, only where legally required;
• Cookies and other online identifiers as described in this Privacy Policy;
All Personal Data is collected and processed in accordance with applicable laws and with the highest standards of confidentiality.
(b) Usage Data
Oraman Private Capital may also collect information automatically generated through your use of our Services (“Usage Data”), including:
• IP address and geographic location;
• Device type, operating system, and browser type;
• Pages visited, time spent on the platform, access times, and navigation patterns;
• Unique device or session identifiers and diagnostic data for security and performance monitoring.
Usage Data is collected to enhance the security, functionality, and user experience of our Services, and to support compliance, risk management, and analytical purposes.

5. Use of Data

• Oraman Private Capital utilizes the personal and usage data we collect for purposes that are essential to the delivery of our services, the safeguarding of our clients, and compliance with applicable laws and regulations. Key purposes include:
• 1. Service Delivery and Enhancement: To provide, manage, and continuously improve our investment, advisory, and wealth management services, ensuring they are tailored to the needs of our clients.
• 2. Monitoring and Security: To monitor usage, detect, prevent, and respond to fraud, cyber threats, unauthorized access, or other technical or operational issues.
• 3. Compliance and Risk Management: To conduct regulatory compliance checks, due diligence, and risk assessments in line with legal obligations and industry best practices.
• 4. Investment Solutions: To design and offer investment strategies, financial products, and services that are aligned with clients’ profiles, objectives, and risk tolerance.
• 5. Audit and Governance: To support internal audit, risk management, governance, and other operational oversight functions necessary to maintain the integrity of our business operations.
• 6. Communication: To provide clients with updates, relevant information, newsletters, invitations to events, and other communications concerning our services, products, or offerings, where permitted by law.
• 7. Legal and Regulatory Compliance: To comply with applicable laws, regulations, regulatory guidelines, and contractual obligations, including those related to anti-money laundering, counter-terrorism financing, taxation, and reporting requirements.
• All data usage is performed in strict accordance with applicable data protection laws and internal security and confidentiality policies.

6. Retention of Personal Data

Oraman Private Capital retains Personal Data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including the provision of our services, compliance with legal and regulatory obligations, and the protection of our clients and the firm.
Retention periods are determined based on business needs, contractual requirements, and applicable laws and regulations. Personal Data that is no longer required for these purposes will be securely deleted, anonymized, or destroyed in accordance with Oraman’s internal data retention and security policies.
Usage Data may be retained for a shorter period to support operational analysis, security monitoring, and performance improvements, except where longer retention is required by law or regulatory obligations.

7. Transfer of Personal Data

Oraman Private Capital may transfer, store, and process Personal Data in jurisdictions outside your country of residence where Oraman, its affiliates, or authorized service providers operate. Such transfers are conducted in full compliance with applicable data protection laws, regulatory requirements, and international standards.
We implement appropriate safeguards, including contractual, technical, and organizational measures, to ensure that your Personal Data is protected during international transfers and that its confidentiality, integrity, and security are maintained at all times.
By using our Services and providing your Personal Data, you consent to such transfers, processing, and storage in accordance with this Privacy Policy.

8. Disclosure of Personal Data

Oraman Private Capital may disclose Personal Data to authorized parties strictly for purposes consistent with this Privacy Policy, business operations, or as required by law. Such disclosures may include, but are not limited to:

• 1. Subsidiaries and Affiliates: To support integrated investment, advisory, and wealth management services within the Oraman group.
• 2. Service Providers and Data Processors: To trusted third-party providers engaged in operational, technical, administrative, or security functions, including IT services, payment processing, custodial services, analytics, and fraud prevention, strictly under contractual obligations and regulatory compliance.
• 3. Professional Advisors and Consultants: To legal, audit, tax, compliance, or other external advisors assisting Oraman in delivering services, ensuring regulatory compliance, and maintaining operational integrity.
• 4. Transaction Counterparties: To counterparties involved in investment or financial transactions, where disclosure is necessary for execution, settlement, or risk management.
• 5. Regulatory and Legal Authorities: To comply with applicable laws, regulations, government directives, or valid legal requests, including anti-money laundering, counter-terrorism financing, and tax reporting obligations.
• 6. With Your Consent: Where you have explicitly provided consent for disclosure for a specific purpose.
  All disclosures are performed in strict compliance with applicable data protection laws, regulatory requirements, and Oraman’s internal confidentiality policies to ensure the security and integrity of your Personal Data.

9. Security of Personal Data

Oraman Private Capital places the highest priority on the protection and confidentiality of all Personal Data under its control. We implement comprehensive organizational, technical, and administrative safeguards designed to prevent unauthorized access, disclosure, alteration, or destruction of Personal Data.
These measures include, but are not limited to, secure data storage, encryption, access controls, monitoring systems, and staff training in data protection best practices.
While we employ industry-leading security protocols, no electronic transmission, storage system, or method of communication over the internet can be guaranteed to be entirely secure.Consequently, we cannot guarantee absolute security of your Personal Data. Nevertheless, Oraman exercises all reasonable measures to protect your information and promptly address any actual or suspected security incidents in accordance with applicable laws and regulatory requirements.

10. Hyperlinks

Our website and digital platforms may contain links to third-party websites, applications, or services that are not operated or controlled by Oraman Private Capital. These third-party sites may have their own privacy policies and practices, which may differ from Oraman’s standards.
Oraman does not assume any responsibility or liability for the privacy practices, security measures, content, or operations of such third-party sites. We strongly encourage you to review the privacy policies of any third-party websites or services before submitting any Personal Dat.

11. Children’s Privacy

Oraman Private Capital’s Services are intended exclusively for individuals who are 18 years of age or older. We do not knowingly collect Personal Data from children or minors under the age of 18.
If Oraman becomes aware that Personal Data of a child under 18 has been collected without verifiable parental or guardian consent, we will take prompt and reasonable steps to delete such information from our records.
Parents or guardians who believe that their child’s Personal Data may have been inadvertently collected are encouraged to contact us immediately so that appropriate corrective measures can be taken.

12. Your Rights

As a client, partner, or user, you have the right to access, review, correct, update, or request the deletion of your Personal Data held by Oraman Private Capital, in accordance with applicable data protection laws.
To exercise your rights, please submit your request to our Data Protection Officer using the contact details below:
Oraman Private Capital
Attn: Data Protection Officer
Email: info@oramancapital.com
All requests will be handled promptly and in accordance with applicable regulatory requirements. Oraman reserves the right to verify your identity before processing any requests to ensure the security and confidentiality of your Personal Data.

13. Language

In the event of any inconsistency or discrepancy between different language versions of this Privacy Policy, the English version shall prevail.
This ensures clarity, legal certainty, and uniform application of the terms and obligations described herein, consistent with Oraman Private Capital’s commitment to regulatory compliance and professional standards.

14. Changes to This Privacy Policy

Oraman Private Capital may update or revise this Privacy Policy from time to time to reflect changes in legal, regulatory, operational, or business requirements.
Any updates will be effective immediately upon posting the revised Privacy Policy on our website, with the new “Effective Date” clearly indicated. Where required by law or deemed appropriate, we may also notify clients, partners, or users of material changes via email or prominent notice on our digital platforms.
We encourage all clients and users to periodically review this Privacy Policy to stay informed about how we protect and manage Personal Data. Continued use of our Services following such updates constitutes acceptance of the revised Privacy Policy.

15. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or the processing of your Personal Data, you may contact Oraman Private Capital’s Data Protection Officer:
Oraman Private Capital
Attn: Data Protection Officer
Email: info@oramancapital.com
Website: www.oramancapital.com
We are committed to addressing all inquiries promptly and in accordance with applicable data protection laws and regulatory requirements.