Old Dominion Capital Management, Inc. (referred to as “ODCM”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, ODCM attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information. 

It is the policy of ODCM to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, social security numbers, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client. ODCM may disclose the client’s information if ODCM is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with ODCM, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by ODCM in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for ODCM (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.

ODCM may share clients’ information with its parent company, Atlantic Union Bank and its affiliates, as well as with third party vendors, for everyday business purposes. ODCM will not share clients’ information with affiliates or non-affiliates for marketing purposes. 

ODCM permits only authorized employees and affiliates who have signed a copy of ODCM’s Privacy Policy or a confidentiality agreement to have access to client information. Employees violating ODCM’s Privacy Policy will be subject to ODCM’s disciplinary process. Additionally, whenever ODCM hires other organizations to provide services to ODCM’s clients, ODCM will require them to sign confidentiality agreements and/or the Privacy Policy.

If at some future time ODCM decides to start sharing information with any affiliates or non-affiliates for purposes other than everyday business purposes, ODCM will first notify clients in writing, and clients will have an opportunity to opt out of such information sharing.

Should you have any questions regarding the above, please contact Maurée Barrett, Chief Compliance Officer.