Centenary Asset Management

Privacy Policy (GDPR-Compliant)

Centenary Asset Management Limited

Registered Office: 244 Edgware Road, London W2 1DS, United Kingdom

Tel: +44 7520 664964

Effective Date: January 1, 2025

1. Introduction

1.1 This Privacy Policy (“Policy”) explains how Centenary Asset Management Limited (“Centenary”, “we”, “us”, or “our”) collects, uses, stores, discloses, and protects personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable UK privacy laws.

1.2 This Policy applies to all personal data processed through our website, client account portal, and any related investment management services (collectively, the “Platform”).

1.3 By using the Platform or providing your personal data to Centenary, you acknowledge that you have read and understood this Policy.

2. Data Controller

Centenary Asset Management Limited acts as the Data Controller for all personal data collected from clients and users of its Platform.

If you have any questions or requests regarding data protection, please contact: Data Protection Officer (DPO)

Centenary Asset Management Limited

244 Edgware Road, London W2 1DS, United Kingdom

data@centenary.co

3. Data We Collect

Centenary may collect and process the following categories of personal data:

3.1 Identity Data

Full name, date of birth, nationality, and government-issued identification (e.g., passport, driver’s

licence).

3.2 Contact Data

Residential address, email address, and telephone number.

3.3 Financial Data

Personal financial account details, source of funds, transaction history, and investment preferences.

3.4 Account and Usage Data

3.5 Compliance Data

Anti-Money Laundering (AML) and Know Your Customer (KYC) documentation, sanctions screening, and verification records.

3.6 Marketing Preferences

Communication preferences and responses to marketing campaigns (where applicable).

4. How We Collect Data

Centenary collects personal data in the following ways:

Directly from you during account registration, fund deposits, or withdrawals.
Through our secure online client portal.
From communications between you and Centenary by email, phone, or in person.
Automatically via cookies and analytics tools when you use our website or online services.
From publicly available sources and third-party verification providers for compliance purposes.

5. Legal Basis for Processing

Centenary processes personal data on the following legal bases:
Contractual necessity – to perform our obligations under the Client Agreement.
Legal obligation – to comply with financial, AML, and regulatory requirements.
Legitimate interests – to manage client relationships, prevent fraud, and improve services.
Consent – where required, such as for marketing communications or optional data collection.

6. Purpose of Data Processing

Centenary uses personal data for the following purposes:

To open, manage, and administer investment accounts.
To verify identity and conduct AML/KYC checks.
To execute deposits, withdrawals, and investment transactions.
To provide account updates, performance reports, and statements.
To ensure compliance with applicable laws and regulations.
To improve our services and user experience.
To communicate with clients regarding Centenary’s products and services (subject to consent).

7. Data Sharing and Disclosure

7.1 Centenary may share personal data only where necessary and in accordance with applicable law.

7.2 Data may be disclosed to:

Regulatory authorities, law enforcement, or tax agencies when legally required;
Financial institutions and payment processors for transaction facilitation;
Professional service providers such as auditors, legal advisors, and compliance consultants;
IT and cloud service providers under strict confidentiality agreements.

7.3 Centenary does not sell or rent personal data to third parties.

8. International Data Transfers

8.1 Centenary stores and processes personal data primarily within the United Kingdom.

8.2 Where data is transferred outside the UK (for example, to third-party service providers), such transfers shall comply with applicable UK GDPR requirements and use appropriate safeguards, including Standard Contractual Clauses.

9. Data Retention

9.1 Centenary retains personal data for as long as necessary to fulfil contractual and legal obligations.

9.2 Typically, personal and transactional records are retained for a minimum of six (6) years after the end of the client relationship, in compliance with financial regulations.

9.3 Data no longer required will be securely deleted or anonymised.

10. Data Security

10.1 Centenary implements appropriate technical and organisational measures to safeguard personal data, including encryption, secure servers, and restricted access.

10.2 All employees and third-party service providers are bound by confidentiality obligations.

10.3 While Centenary takes all reasonable precautions, the Client acknowledges that no electronic transmission or storage system is completely secure.

11. Your Rights Under GDPR

As a data subject, you have the following rights under the UK GDPR:

Right of access: Obtain a copy of your personal data held by Centenary.
Right to rectification: Request correction of inaccurate or incomplete information.
Right to erasure (“Right to be Forgotten”): Request deletion of your personal data under certain

circumstances.

Right to restrict processing: Limit how Centenary processes your data.
Right to data portability: Receive your data in a structured, commonly used format.
Right to object: Object to processing based on legitimate interests or for direct marketing.
Right to withdraw consent: Withdraw consent at any time where processing is based on

consent.

To exercise these rights, contact Centenary’s Data Protection Officer via the contact details provided in

Section 2.

12. Cookies and Tracking

12.1 Centenary uses cookies and similar technologies to enhance user experience, analyse website traffic, and maintain security.

12.2 You can manage or disable cookies through your browser settings, though some features of the

Platform may not function properly without them.

12.3 Details of our cookie use are outlined in our Cookie Policy, available on our website.

13. Marketing Communications

13.1 Centenary may send you information about new products, services, or investment opportunities if you have consented to receive such communications.

13.2 You may opt out of marketing communications at any time by selecting the “unsubscribe” option or

contacting us directly.

14. Automated Decision-Making

Centenary does not use automated decision-making processes that produce legal or significant effects on Clients. Any profiling conducted is solely for regulatory risk assessment and service enhancement.

15. Third-Party Websites

Our Platform may contain links to external websites operated by third parties. Centenary is not responsible for the content or privacy practices of such external sites.

16. Amendments to this Policy

Centenary reserves the right to update this Policy at any time. Updates will be published on our website, and the “Effective Date” will be revised accordingly. Clients are encouraged to review this Policy periodically.

17. Complaints

If you believe Centenary has violated your data protection rights, you have the right to lodge a

complaint with the Information Commissioner’s Office (ICO) in the United Kingdom:

Information Commissioner’s Office (ICO)

Website: https://ico.org.uk

Tel: +44 303 123 1113

Centenary encourages Clients to contact us first to resolve any issues directly.

18. Contact Information

For all data protection inquiries, please contact: Centenary Asset Management Limited

Data Protection Officer

244 Edgware Road, London W2 1DS, United Kingdom

Tel: +44 7520 664964

Email: data@centenary.co

19. Acceptance

By using the Centenary Asset Management Platform or providing your personal information, you acknowledge that you have read, understood, and accepted the terms of this Privacy Policy.