Legal

Privacy Policy

Last updated: April 2026

This policy explains how EX Financial Solutions Ltd collects, uses, and protects your personal data when you use EXFI services or visit this website.

1. Who we are

This website is operated by EX Financial Solutions Ltd ("EXFI", "we", "us", "our"), a company registered in England and Wales under company number 17105188, with registered address at 128 City Road, London, EC1V 2NX, United Kingdom. Payment services are provided by Gemba Finance Ltd, registered in England and Wales (Company No. 11040011), authorised and regulated by the Financial Conduct Authority (FRN: 804853).

2. What data we collect

We may collect the following categories of personal data: • Identity data: full name, date of birth, nationality • Contact data: email address, phone number, postal address • Business data: company name, registration number, industry, ownership structure • Financial data: transaction history, account balances, payment details • Technical data: IP address, browser type, device identifiers, cookies • Usage data: pages visited, links clicked, time spent on pages • KYC/AML data: identity documents, proof of address, source of funds declarations

3. How we use your data

We use your personal data to: • Provide and manage your EXFI account • Comply with our legal and regulatory obligations (including AML, KYC, and FCA requirements) • Process payments and detect fraud • Communicate with you about your account • Improve our products and services • Send you relevant updates (where you have consented) We do not sell your personal data to third parties.

4. Legal basis for processing

We process your personal data on the following legal grounds: • Contract: processing is necessary to provide you with EXFI services • Legal obligation: processing is required to comply with FCA, HMRC, and AML regulations • Legitimate interests: to improve our services, prevent fraud, and ensure security • Consent: where you have explicitly opted in (e.g. marketing communications)

5. Data sharing

We may share your data with: • Gemba Finance Ltd (our payment services provider) • Regulatory authorities (FCA, HMRC, NCA) where required by law • Identity verification and KYC providers • Accounting integration partners (e.g. Xero) • Cloud infrastructure and hosting providers All third parties are contractually bound to protect your data in accordance with applicable data protection law.

6. International transfers

Where we transfer personal data outside the UK or EEA, we ensure appropriate safeguards are in place, including standard contractual clauses approved by the UK Information Commissioner's Office (ICO) or equivalent authorities.

7. Data retention

We retain personal data for as long as necessary to provide our services and comply with legal obligations. Financial and KYC records are typically retained for a minimum of 5 years following the end of a customer relationship, in line with the Proceeds of Crime Act 2002 and FCA requirements.

8. Your rights

Under UK GDPR, you have the right to: • Access your personal data • Rectify inaccurate data • Request erasure (where legally permissible) • Restrict or object to processing • Data portability • Withdraw consent at any time To exercise any of these rights, contact us at privacy@exfi.co. You also have the right to lodge a complaint with the ICO at ico.org.uk.

9. Cookies

We use essential cookies to operate our website and optional analytics cookies to understand usage. You can manage cookie preferences via our cookie banner or your browser settings. A full cookie policy is available on request.

10. Contact

For privacy-related enquiries: EX Financial Solutions Ltd 128 City Road, London, EC1V 2NX Email: privacy@exfi.co
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EX Financial Solutions Ltd

Trading as EXFI · Registered in England and Wales
Company number: 17105188
128 City Road, London, EC1V 2NX, UK
Incorporated: 20 March 2026

Payment services provided by

Gemba Finance Ltd · Registered in England and Wales — Company number: 11040011
Level 39, One Canada Square, Canary Wharf, London, E14 5AB
Authorised and regulated by the Financial Conduct Authority — FRN: 804853

EXFI accounts are payment accounts provided through Gemba Finance Ltd, an FCA-authorised payment institution (FRN: 804853). They are not bank accounts. Your funds are not covered by the Financial Services Compensation Scheme (FSCS). Your funds are safeguarded in accordance with the Payment Services Regulations 2017, meaning they are held in segregated accounts separate from Gemba Finance Ltd's own funds. This website is operated by EX Financial Solutions Ltd (Company No. 17105188, registered at 128 City Road, London, EC1V 2NX) as a distributor of Gemba Finance Ltd's payment services. EX Financial Solutions Ltd is not itself authorised or regulated by the Financial Conduct Authority. This website does not constitute financial advice. If you require advice on financial products, you should consult a qualified independent financial adviser.

FCA Regulated · FRN 804853

© 2026 EX Financial Solutions Ltd. All rights reserved. EXFI is a trademark of EX Financial Solutions Ltd.