Privacy Policy
Last updated: 10-20-2026
1. Who we are
This Privacy Policy explains how Orvendis Capital LLC, a Delaware series limited liability company, together with its series and its manager (together, “we”, “us” or “Orvendis”), collects and uses personal data through this website and in connection with our relationship with prospective and existing investors.
Orvendis Capital LLC is the controller of your personal data.
Registered office (registered agent): 8 The Green, Ste A, Dover, Delaware 19901, USA
Privacy contact: request@orvendis.capital
2. Scope
This policy applies to visitors to our website, persons who submit a request through our website or contact us, prospective investors who go through our eligibility and verification process, and investors in any of our series, including their representatives, directors and beneficial owners. Additional information may be provided in the offering documents of a specific series.
3. Personal data we collect
Information you provide to us
Contact and request details: name, e-mail address, country of residence, investor type and status, and the content of your message.
Verification information (only if you proceed beyond an initial request): full name, date and place of birth, nationality, residential address, copies of identity documents, photographs or video for identity verification, tax identification number and tax residence, information on source of funds and source of wealth, evidence of investor eligibility, and, for entities, corporate documents and details of directors, controllers and beneficial owners.
Investment information: subscription amounts, signed documents, bank account details for payments and distributions, and correspondence with us.
Information we obtain from others
Results of identity verification, sanctions, politically exposed person and adverse media screening from our service providers.
Information from public registers and other publicly available sources.
Information from a person who introduced you to us, where applicable.
Information collected automatically
IP address, browser and device information, pages visited and the date and time of visits, collected through server logs and cookies as described in our Cookie Policy.
We do not intend to collect special category data. Where verification results reveal information about criminal convictions or sanctions, we process it only as required by law.
4. How we use your personal data and on what legal basis
Purpose / Legal basis
Responding to your request or enquiry
Our legitimate interest in responding to enquiries; steps taken at your request before entering into a contract relations
Checking your jurisdiction and eligibility before providing any information about specific opportunities
Compliance with legal obligations; our legitimate interest in complying with securities laws
Verifying identity, preventing money laundering, terrorist financing and fraud, and sanctions screening
Compliance with legal obligations
Processing subscriptions, maintaining member registers, making distributions and sending reports
Performance of a contract
Tax reporting and withholding
Compliance with legal obligations
Website security and operation
Our legitimate interest in keeping our website secure and functional
Sending news and materials to verified investors who have opted in
Your consent, which you may withdraw at any time
Establishing, exercising or defending legal claims
Our legitimate interests
5. Automated decisions
Our request form may automatically decline a request if the answers given show that the person is located in a jurisdiction where we do not offer interests or does not meet the eligibility criteria. You may contact us at request@orvendis.capital to ask for a review of such a decision by a member of our team.
6. Who we share personal data with
We do not sell personal data. We share it only as needed for the purposes above, with:
our manager and affiliated entities;
service providers acting on our instructions, including website hosting, e-mail, identity verification and screening, electronic signature, fund administration and data storage providers;
banks that hold the accounts of our series;
our legal, tax and audit advisers;
the issuer of the shares held by a series, its transfer agent or other shareholders, where disclosure is required to complete or record a share transfer;
regulators, tax authorities, law enforcement and courts, where required by law;
a successor or acquirer in a restructuring or sale of our business, subject to confidentiality obligations.
7. International transfers
We and our service providers are located in [the United States, the United Arab Emirates and other countries]. Where personal data is transferred from a country with data-transfer restrictions to a country that does not provide an equivalent level of protection, we use appropriate safeguards, such as standard contractual clauses approved by the relevant authority, or rely on another lawful transfer mechanism. You may request a copy of the relevant safeguards at request@orvendis.capital.
8. How long we keep personal data
Requests that do not lead to an investor relationship: up to 12 months after our last contact.
Verification, anti-money-laundering and sanctions records: at least 5 years after the end of our relationship with you, or longer if required by law.
Investment and tax records: for the life of the relevant series and at least 7 years after its dissolution.
Website logs: up to 12 months.
We then delete or anonymise the data.
9. Security
We use technical and organisational measures appropriate to the risks, including encryption in transit and at rest, access controls and two-factor authentication. No method of transmission or storage is completely secure. Please do not send identity documents or bank details through the website request form or by unencrypted e-mail unless we ask you to use a secure channel.
10. Your rights
Depending on the law that applies to you, you may have the right to access your personal data, have it corrected, erased or restricted, object to processing based on legitimate interests, receive it in a portable format, and withdraw consent at any time without affecting earlier processing. Some rights are limited where we must keep data to comply with anti-money-laundering, tax or other legal obligations.
To exercise your rights, contact request@orvendis.capital. We may need to verify your identity before responding. You may also lodge a complaint with the data protection authority in your country of residence [or the UAE Data Office, where applicable].
11. Children
Our website and services are not intended for anyone under 18, and we do not knowingly collect their personal data.
12. Cookies
We use strictly necessary cookies and, with your consent, analytics cookies. See our Cookie Policy for details and to change your preferences.
13. Changes to this policy
We may update this policy from time to time. The current version, with its date, is always available on this page. We will notify investors of material changes.
14. Contact
Questions about this policy or our use of personal data: request@orvendis.capital, or by post to the registered office.