Privacy
Policy.

1. About this Policy

This Privacy Policy explains how Edwards FX Limited (“Edwards FX”, “we”) collects and uses your personal data when you visit our website, enquire about our services, or open an account with us. It applies to information we collect from you and about you in connection with our commercial services.

Where you become a client, your personal data is also processed by our regulated payment partner, The Currency Cloud Limited (“Currencycloud”), in connection with the regulated payment services they provide. Currencycloud is a separate data controller and operates under its own privacy policy.

2. Who We Are (Data Controller)

For the personal data described in this Policy, the data controller is:

Edwards FX Limited
Registered in England and Wales (Company No. 16246786)
Registered office: 167–169 Great Portland St, London W1W 5PF
Email: privacy@edwardsfx.io
Phone: 020 3375 6744

3. Personal Data We Collect

We collect different categories of data depending on how you interact with us.

From website visitors

• Information you submit through enquiry or contact forms (name, business name, role, email, phone, message content)
• Limited technical information (IP address, browser type, device type, referring URL) collected through our hosting infrastructure for security and basic operational purposes

From applicants and clients

• Identity data (full name, date of birth, nationality, identification document details)
• Contact data (residential address, business address, phone, email)
• Business data (company name and number, ownership and control structure, nature of business, expected transaction volumes)
• Financial data (bank account details, source of funds information, payment instructions)
• Trading data (trades, payments, balances and related transaction history)
• Communications data (records of phone calls, emails and other correspondence with us)

Some of this information is required by law as part of customer due diligence under the Money Laundering Regulations 2017.

4. Sources of Data

• Directly from you when you contact us, apply for an account or use our services
• From your colleagues, where they are authorised to act on behalf of your business
• From third-party identity verification, sanctions and PEP screening providers used by Currencycloud
• From public sources, including Companies House and other public registers
• From banks and payment processors involved in the settlement of transactions

5. Lawful Bases for Processing

We rely on the following lawful bases under UK GDPR:

6. How We Use Your Data

• To respond to your enquiries and provide requested information about our services
• To assess applications and onboard you as a client
• To provide, administer and improve our commercial services
• To pass information to Currencycloud so that they can carry out their regulated functions
• To comply with our legal and regulatory obligations
• To detect and prevent financial crime, fraud and abuse of our services
• To handle complaints and disputes
• To send you operational communications and, where lawful, marketing communications about our services (you can opt out of marketing at any time)

7. Who We Share Your Data With

We share your personal data with the following categories of recipients:

• The Currency Cloud Limited — our regulated payment partner, who acts as a separate data controller for the regulated payment services
• Banks and payment processors — involved in routing and settling your transactions
• Identity, sanctions and fraud-prevention providers — engaged by Currencycloud to perform regulatory checks
• Regulators and law-enforcement authorities — including the FCA, HMRC and the National Crime Agency, where required by law
• Professional advisers — including our auditors, lawyers and compliance consultants, under duties of confidentiality
• IT and infrastructure providers — including our hosting, email, CRM and communication platform providers, acting as data processors under written agreements

We do not sell your personal data to third parties for their own marketing purposes.

8. International Transfers

Some of our service providers and Currencycloud’s service providers are based outside the UK. Where personal data is transferred outside the UK, we ensure that an appropriate safeguard is in place — typically the UK International Data Transfer Agreement, the EU Standard Contractual Clauses with the UK Addendum, or transfer to a country with UK adequacy status.

9. How Long We Keep Data

We retain personal data only as long as necessary for the purposes for which it was collected, including legal, accounting and reporting obligations. In particular:

• Identity, KYB/KYC and transaction records: at least 5 years from the end of the customer relationship or the date of the transaction (as required by the Money Laundering Regulations 2017)
• Tax-related records: 6 years
• Marketing data: until you opt out or three years of inactivity
• Enquiry data: typically 24 months unless you become a client

10. Your Rights

Under UK GDPR you have a number of rights in relation to your personal data:

• Access — ask for a copy of the personal data we hold about you
• Rectification — ask us to correct inaccurate or incomplete data
• Erasure — ask us to delete data, subject to legal retention requirements
• Restriction — ask us to restrict our processing in certain circumstances
• Portability — ask for your data in a machine-readable format
• Objection — object to processing based on legitimate interests, or to direct marketing
• Withdraw consent — where processing is based on your consent, you can withdraw it at any time

To exercise any of these rights, email privacy@edwardsfx.io. We will normally respond within one calendar month. There is no fee, though we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive.

11. Automated Decision-Making

Some of our and Currencycloud’s checks — including identity verification, sanctions screening and certain transaction-monitoring rules — involve automated processing. Where automated processing has a legal or similarly significant effect on you (for example, automatically declining an application), you have the right to request human review of the decision.

12. Cookies

Our website’s use of cookies and similar technologies is described in our Cookie Notice.

13. Security

We take appropriate technical and organisational measures to protect your personal data, including encryption in transit and at rest, access controls, multi-factor authentication, secure backups and ongoing security monitoring. No system is completely secure, but we work continuously to reduce risk to a level appropriate for the data we hold.

14. Changes to this Policy

We may update this Policy from time to time. The version number and effective date at the top of this page will be updated accordingly. Material changes will be notified to clients by email or through the client portal.

15. Complaints to the ICO

If you are unhappy with how we have handled your personal data, please contact us in the first instance. You also have the right to lodge a complaint with the UK’s Information Commissioner’s Office (ICO):

Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline: 0303 123 1113
Web: ico.org.uk