PRIVACY POLICY

Last Updated: 1^st April 2026

Introduction

Welcome to the privacy policy of Chartwell International Limited (“we”, “us”, or “our”).

We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we look after your personal data when you visit our website (regardless of where you visit it from) or engage our services for Foreign Exchange (FX), Business Finance, or Mortgage and Property Finance solutions, and tells you about your privacy rights and how the law protects you.

Important Information and Who We Are

Controller- Chartwell International Limited is the controller and responsible for your personal data.

Contact Details

If you have any questions about this privacy policy, please contact us:

• Full name of legal entity: Chartwell International Limited
• Postal address: 8 Viceroy House, Mountbatten Business Centre, Millbrook Road East, Southampton SO15 1HY, United Kingdom
• Email address: dpc@chartwellinternational.co.uk

The Data We Collect About You

We may collect, use, store and transfer different kinds of personal data about you, including:

• Identity Data: First name, last name, username, title, date of birth
• Contact Data: Billing address, delivery address, email address, and telephone numbers
• Financial Data: Bank account details and payment card details
• Transaction Data: Details about payments to and from you and other details of products and services you have purchased from us or our partners
• Technical Data: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform
• Profile Data: Your interests, preferences, feedback and survey responses
• Usage Data: Information about how you use our website and services

Mortgage and Property Data

Where you enquire about or apply for mortgage or property finance services, we may also collect:

• Employment status and income details
• Expenditure and financial commitments
• Credit history and credit scores
• Property details and purchase information
• Deposit amounts and source of funds
• Marital status, dependents, and household information
• Identification documents (e.g. passport, driving licence, proof of address)

How We Use Your Personal Data

We will only use your personal data when the law allows us to.

Most commonly, we use your personal data in the following circumstances:

• Performance of a Contract:
  Where we need to perform the contract we are about to enter into or have entered into with you (e.g., arranging a finance facility, mortgage, or opening an FX account)
• Legitimate Interests:
  Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Legal Obligation:
  Where we need to comply with legal or regulatory obligations, including Anti-Money Laundering (AML), Know Your Customer (KYC), fraud prevention, and financial services regulation

Additional Uses (Mortgage Services)

We may also use your personal data:

• To assess your eligibility for mortgage products
• To provide mortgage advice and recommendations
• To submit applications to lenders and manage your application process
• To carry out affordability and suitability assessments
• To comply with regulatory requirements relating to mortgage services

Profiling

We may analyze your personal and financial information to assess your eligibility and suitability for financial products, including mortgages. This may involve a degree of automated processing.

Disclosures of Your Personal Data

To provide our services, we may share your personal data with:

• Foreign Exchange Partners:
  Including Sciopay Ltd (or other authorised partners) for opening trading accounts and facilitating currency transactions
• Lenders:
  A panel of third-party lenders and financial institutions for business finance and mortgage applications
• Mortgage Lenders and Providers:
  For assessing eligibility and processing mortgage applications
• Credit Reference Agencies:
  To assess your creditworthiness. These agencies may carry out “soft” or “hard” credit searches
• Fraud Prevention and Identity Verification Agencies:
  To verify your identity and prevent financial crime
• Professional Advisers:
  Including lawyers, bankers, auditors, and insurers
• Regulators:
  HM Revenue & Customs, the Financial Conduct Authority, and other authorities

International Transfers

We generally do not transfer your personal data outside the UK or the European Economic Area (EEA). However, our FX partners, lenders, or mortgage providers may operate outside these areas.

Whenever we transfer your personal data, we ensure appropriate safeguards are in place in line with UK data protection laws.

Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered or disclosed.

Access to your personal data is limited to employees, agents, contractors and other third parties who have a business need to know.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including legal, regulatory, tax, accounting, or reporting requirements.

By law, we retain customer data (including Identity, Contact, Financial and Transaction Data) for six years after the end of the client relationship.

Your Legal Rights

Under data protection laws, you have rights including:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing
• Request transfer of your personal data
• Right to withdraw consent

To exercise any of your rights, please contact us.