Privacy Policy

At Orcana Capital Management LLC (“Orcana”), we are committed to protecting your privacy and personal identification information (“PII”). Please read on for more details about our privacy and information security program policies.

Privacy Policy Notice

Your relationship with Orcana is based on trust and confidence. To fulfill our responsibilities to you, Orcana requires that you provide certain financial and personal information. You deserve to expect that Orcana will protect the information you have provided in a manner that is reasonably safe, secure and professional. Orcana and its supervised persons are committed to protecting your privacy and to safeguarding that information.

Your Privacy

Orcana requires that you provide current and accurate financial and personal information so that we may make the best possible choices for your circumstances. We will protect the information you have provided in a manner that is safe, secure and professional.

We recognize the importance of protecting our clients’ privacy. We have policies to maintain the confidentiality and security of your non-public personal information. The following is designed to help you understand what information we collect from you and how we use that information to serve you.

Information Security

Orcana maintains an information security program to reduce the risk that your personal, private, non-public and confidential information may be breached. Orcana is committed to maintaining the confidentiality, integrity and security of our clients’ personal information that is entrusted to us.

During regular business hours, access to client records is monitored so that only those with approved entitlements may access the information. During hours in which the company is not in operation, client records are secured.

We maintain a secure office, and we use data encryption and multi-factor authentication to protect the personal information we store electronically, including information stored in the cloud.

Information We Collect

In the normal course of business, we collect non-public client data in checklists, forms, in written notations, in documentation provided to us by our clients for evaluation, planning, investing or other related consulting services, and data about client transactions with us, such as types of investments and account status. We also create internal lists of such data.

The categories of non-public information that we collect from you may include information about your personal finances and information about transactions between you and third parties. We use this information to help you plan, invest, and work towards your personal financial goals.

How We Use the Information That We Collect

Non-public personal information that we receive with respect to our clients who are natural persons is not shared with non-affiliated third parties which are not service providers to us without prior notice to, and consent of, such clients, except:

• When necessary to complete a transaction in a client account, such as with the account custodians;
• When required to maintain or service a client account;
• To resolve client disputes or inquiries;
• With persons acting in a legal fiduciary or representative capacity on behalf of the client;
• With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of the firm;
• In connection with a sale or merger of Orcana’s business;
• To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability;
• To comply with federal, state or local laws, rules and other applicable legal requirements;
• In connection with a written agreement to provide investment management or advisory services when the information is released for the sole purpose of providing the products or services covered by the agreement;
• In any circumstances with the client’s instruction or consent; or
• Pursuant to any other exceptions enumerated in the California Financial Information Privacy Act.

Additionally, we may disclose such non-public personal information as required by law (such as to respond to a subpoena) or to satisfy a request from a regulator and/or to prevent fraud. Without limiting the foregoing, we may disclose non-public personal information about you to governmental entities and others in connection with meeting our obligations to prevent money laundering including, without limitation, the disclosure that may be required by the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001 and the regulations promulgated thereunder.

In addition, if we choose to dispose of our clients’ non-public personal information that we are not legally bound to maintain, we will do so in a secure manner that reasonably protects such information from unauthorized access. The same privacy policy also applies to former clients who are natural persons.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent are excluded from all other categories of information described in this policy and will not be shared with any third parties.

Accessing or Correcting Your Information

You may access the data collected by us about you by sending a request to the address listed below. If you believe that an error has been made in the accuracy of the information collected from you, we will correct such error upon adequate verification of the error and the identity of the person seeking the correction.

Document Retention: Confidentiality, Security and Safeguarding Client Documents

We have physical, electronic, and procedural security safeguards to protect and secure the information we collect. We restrict access to non-public personal information about our clients to those employees and agents who need to know that information to provide products and services to our clients.

During regular business hours, access to client records is monitored so that only those with approved entitlements may access the files. During hours in which the company is not in operation, the client records will be secured. No individual who is not so authorized shall obtain or seek to obtain personal and financial client information. No individual with authorization to access personal and financial client information shall share that information in any manner without the specific consent of a firm principal. Failure to observe Orcana’s procedures regarding client and consumer privacy will result in disciplinary action and may lead to termination.

Notification in the Event of Data Breach

Orcana has adopted an incident response program in the event of a potential data breach. If your sensitive non-public information is breached by an unauthorized party, we will comply with applicable laws in notifying you of the breach as soon as possible, and no later than 30 days after discovery. This includes breaches at critical third parties we do business with that may affect information about you that could be used to harm you.

Updating Your Personal Information and Privacy Preferences

You have the right to access and correct or change any personal information that you provide to us at any time. You may do so by contacting your IAR, or by sending us an email or letter at the address below. Any change to the information that you have provided may affect the recommendations we make to you, the management of your account or the delivery of other services and information to you. We will respond to your request within thirty days.

Personally identifiable information (“PII”) about you will be maintained while you are a client, and for the required period thereafter that records are required to be maintained by federal and state securities laws. After that time, information will be securely destroyed.

If You Close Your Account

If you decide to close your account(s) and/or become an inactive customer, we will continue to adhere to the privacy policies and practices as described in this Policy. We reserve the right to change this Policy at any time, and we will notify you in advance of any material changes.

Opt-Out Provisions

Orcana may share clients’ non-public personal information with its affiliates as needed to provide services to clients. Orcana does not share this information with affiliates for marketing purposes, and does not share it with unaffiliated third parties except under the circumstances noted above. Since sharing under the circumstances noted above is necessary to service client accounts or is mandated by law, there are no allowances made for clients to “opt out.”

Unless you ask us not to, we may contact you via email in the future to tell you about service updates. We will provide this Privacy Notice to you annually, or as otherwise required by law.

Contact Us

Orcana Capital Management LLC
4041 MacArthur Blvd Suite 400, Newport Beach, CA 92660
Email: jesse@orcanacapital.com
Phone: 714-623-8106