Halo Financial Ltd (in Administration)

Privacy Notice relating to Halo Financial clients

A Place in the Sun Currency Limited (we/us/our) purchased a number of assets from the Special Administrators of Halo Financial Limited (Halo), a business providing foreign exchange and international payment services, on June 29th 2026.

As part of that purchase, certain personal data held by Halo has been transferred to us as a data controller.

The personal data transferred to us may include identification and contact details, business contact details, customer account and relationship information, transaction and payment information, payment instruction details, bank account information, know your client (KYC) data, anti-money-laundering (AML) compliance data and sanctions screening records, fraud prevention information, complaints and correspondence, employment-related information and other records connected with the operation, administration or transfer of Halo’s business.

We will process that personal data for the purposes of our own business, as set out in our privacy policy (Privacy Policy), which can be reviewed at https://aplaceinthesuncurrency.com/privacy-policy/, and in order to comply with our obligations to the Special Administrators in relation to the purchase.

We rely on one or more lawful bases for processing your personal data, depending on the circumstances, including performance of a contract, compliance with legal and regulatory obligations, our legitimate interests in operating our business, protecting against fraud and financial crime, and, where applicable, your consent.

We may share personal data with banks, payment service providers, correspondent banks, payment networks, KYC, AML, sanctions screening and fraud prevention providers, professional advisers, insurers, IT and hosting providers, regulators, law enforcement agencies, courts, insolvency office-holders and other third parties where this is necessary for the purposes described above or required by law.

Because Halo’s business and our own involve foreign exchange and international payments, personal data may be transferred to, accessed from or processed in countries outside the UK where this is necessary to process payments, deal with overseas banks or counterparties, carry out screening or comply with legal or regulatory requirements. We will put in place appropriate safeguards for such transfers which are required by law.

We will retain personal data for as long as necessary for the purposes described in this notice and in our Privacy Policy, including to provide services, manage the Business, comply with legal, regulatory, tax, accounting, AML and sanctions record-keeping obligations, resolve disputes and establish, exercise or defend legal claims.

Under the UK GDPR, we are required to provide you with information about who we are, how we process your personal data and for what purposes and your rights in relation to your personal data. This information is provided in the Privacy Policy and it is important that you read that information.

Please contact us at halo@aplaceinthesuncurrency.com, or by telephone on 020 8051 8555, if you have any queries about this privacy notice or our data protection practices. You can also find details of how to exercise your data protection rights in the Privacy Policy.