Introduction

At Butler’s Capital, we are committed to protecting the information we hold about you. This Customer Privacy Notice applies to a person’s personal information held by Butler’s Capital as Data Controllers under the Data Protection Act 2020 (“the DPA”). This notice describes what information we collect about you, how we may use it, who we share it with, the circumstances under which it is shared and your rights relating to it. It further details the steps we take to ensure that, at all times, your information is kept private and secure. This notice continues to apply even after your agreement for our services ends.

Wherever we say ‘you’ or ‘your’, this means:

• You
• Any authorised person on your account
• Anyone who does your banking or deals with us for you (e.g. trustees, executors, attorneys)
• Other related people (e.g. authorised signatories, partners, members, trustees)

When we say “we”, we mean Butler’s Capital and its subsidiaries, which act as a data controller for your personal data.

What information we collect

We only collect information relevant to providing you with our services. The information may include:

• Personal details (name, date of birth, identification info)
• Contact details (address, phone number, email)
• Identity info (tax registration number, national ID, driver’s license)
• Proof of income/assets (payslips, bank statements, titles)
• Proof of employment
• Character references
• Other details you provide when applying or communicating with us

What we use your information for

We may use your information to:

• Provide, operate and maintain services
• Process and complete transactions
• Send payment reminders and updates
• Respond to enquiries and provide support
• Prevent illegal activities and fraud
• Carry out credit checks and manage risk
• Satisfy debts owed to us

Legal Basis

We process your data based on:

• Providing requested services
• Meeting legal obligations (e.g. AML checks)
• Protecting our legitimate interests
• Your consent (where applicable)

Compliance with laws

We may share your information with regulators and government bodies as required to comply with laws, prevent crime, or meet regulatory obligations.

Marketing

We may contact you with details about our products and services via email, phone, text, or social media. You may opt out anytime by contacting marketing@butlerscapital.com.

Who we might share your information with

• Payment processing providers
• Government agencies and regulators
• Debt collectors
• Auditors

How long we keep your information

We retain your information in line with our Data Retention Policy, usually up to 7 years after our relationship ends, unless required longer by law.

Your rights

You have the right to:

• Be informed
• Access your data
• Consent/withdraw consent
• Rectify data
• Object to processing
• Request data transfer
• Not be subject to automated decisions

To exercise your rights, contact compliance@butlerscapital.com.

How we keep your information secure

We use encryption and strict security measures. Staff and third parties must follow our compliance standards.

How to contact us

Butler’s Capital
Email: compliance@butlerscapital.com
Telephone:+1 (408) 991-2759

Changes to this Privacy Notice

This Privacy Notice may be updated from time to time. Last updated: October 2025.