Privacy Policy

1. Introduction

AMBANK Asset Management Ltd ("AMBANK", "we", "us", or "our") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and protect personal information in accordance with:

• The UK General Data Protection Regulation (UK GDPR);
• The Data Protection Act 2018;
• The Privacy and Electronic Communications Regulations 2003 (PECR).

Data Controller: AMBANK Asset Management Ltd Company No. 16394677 Park Shot House, Kew Road, Richmond, England, TW9 2PR, United Kingdom

2. Personal Data We Collect

We may collect the following categories of personal data:

Identity Data — full name, title, date of birth, nationality, passport number, government-issued identification.

Contact Data — email address, telephone number, business address, country of residence.

Professional Data — company name, job title, nature of business, professional qualifications, regulatory licences held.

Financial Data — bank account details, SWIFT/IBAN codes, transaction history, AML/KYC documentation.

Technical Data — IP address, browser type and version, time zone, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Usage Data — information about how you use our website, products, and services.

Communications Data — records of your correspondence with us, including emails and telephone call logs where permitted.

3. How We Collect Personal Data

We collect personal data through:

• Direct interactions (enquiry forms, email, telephone, in-person meetings);
• Automated technologies or interactions (cookies and similar technologies — see our Cookie Policy);
• Third parties (business introducers, publicly available sources, credit reference agencies, sanctions screening services, and regulatory databases).

4. Lawful Basis for Processing

We process your personal data on the following lawful bases under Article 6 UK GDPR:

Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms. You may request details of this balancing test by contacting us.

5. Anti-Money Laundering and Regulatory Obligations

As a structured finance firm, AMBANK is subject to obligations under the Proceeds of Crime Act 2002 (POCA), the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and applicable international AML standards.

We are required by law to collect and verify identity documentation, conduct sanctions screening, and retain certain records for a minimum of five (5) years from the end of our business relationship. We may share relevant data with regulatory authorities, law enforcement agencies, or financial intelligence units where legally required or permitted.

6. International Data Transfers

AMBANK operates internationally. Personal data may be transferred to and processed in countries outside the United Kingdom, including Brazil and other jurisdictions. Where such transfers occur, we ensure appropriate safeguards are in place, including:

• UK International Data Transfer Agreements (IDTAs);
• Standard Contractual Clauses approved by the Information Commissioner's Office (ICO);
• Adequacy decisions by the Secretary of State.

7. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Typical retention periods are:

8. Your Rights Under UK GDPR

You have the following rights in relation to your personal data:

• Right of access — to request a copy of the personal data we hold about you;
• Right to rectification — to request correction of inaccurate or incomplete data;
• Right to erasure — to request deletion of your data in certain circumstances;
• Right to restriction — to request that we restrict processing of your data;
• Right to data portability — to receive your data in a structured, machine-readable format;
• Right to object — to object to processing based on legitimate interests or for direct marketing;
• Rights related to automated decision-making — to request human review of automated decisions.

To exercise any of these rights, please contact us at privacy@ambank.group. We will respond within one calendar month. Where requests are complex or numerous, we may extend this by a further two months with notice.

9. Right to Lodge a Complaint

If you believe we have processed your data unlawfully, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

ICO Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Website: www.ico.org.uk Helpline: 0303 123 1113

We encourage you to contact us first so that we may seek to resolve your concern directly.

10. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, alteration, or disclosure. These include encryption, access controls, and regular security assessments.

We cannot guarantee absolute security of data transmitted over the internet. Any transmission is at your own risk.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The current version will always be published on this page with the date of the most recent revision. Material changes will be notified to affected individuals where practicable.

12. Contact

Data Protection enquiries: AMBANK Asset Management Ltd Park Shot House, Kew Road, Richmond, England, TW9 2PR, United Kingdom Email: privacy@ambank.group