Privacy Policy

We would like to thank you for visiting http://www.cphcl.com (the “Website”).

Privacy assurance

We are firmly committed to protecting your privacy and we will only collect personal information about you as a visitor in line with applicable privacy laws. This Privacy Notice (“Notice”) is issued by the CPHCL Group which includes CPHCL Finance plc and other direct and indirect investments / subsidiaries of CPHCL Company Ltd that form part of this same Website domain and covers information that we collect and use in the course of our business. Subsidiaries with their own website domain will have their own Privacy Notice which may be customised accordingly.

The Data Controller for the data collected through our website is CPHCL Company Ltd, with its registered office at 22, Europa Centre, John Lopez Street, Floriana FRN 1400, Malta. Please read this Privacy Notice before using or submitting your information to us.

1. What is personal information?
   
   1.1. This section of the Notice explains what “personal information” is.
   1.2. Personal information is any information that can be used to identify you, such as your full name, address, email address, telephone/mobile number, and country (“Personal Information”).
   1.3. Other categories of Personal Information may include:
   1.3.1. Personal Details: contact information (including mobile telephone numbers), passport/national identification information, gender.
   1.3.2. Bank details: bank account details, IBAN account etc.
   1.3.3. Bondholder data: number of bonds held through CPHCL Finance plc
   1.3.4. Other information: All other information that is provided to us, on a voluntary basis, through the online free text (‘Get in Touch’) form.
   
2. Information collected
   
   2.1. This section of the Privacy Notice explains how we collect your Personal Information.
   2.2. Active information collection: We actively collect information directly from our Website visitors. Examples where we actively collect your information include when you communicate directly with us via e-mail, and/or by filling in online forms on our Website and/or filling in an application for investing in Bonds issued by CPHCL Finance plc.
   2.3. Passive information collection: In some circumstances we may process information on the basis of (i) your related interactions with us (for example, the web page from which CPHCL Privacy Notice 4 April 2026 you navigated to the Website), or (ii) Personal Information that we have received or obtained from a third party (for example, publicly available information sources). In these circumstances, your Personal Information may be said to have been passively collected (that is, gathered without you actively providing the information). We are not responsible for the privacy and data security practices and policies of third parties such as Google, Facebook, Instagram, Apple, or any social media or wireless service provider to which you may disclose Personal Information.
   2.3.1. An example of where your Personal Information may be passively collected is when you use the Website. Each time you use the Website, we will automatically collect the following information:

• details of your use of the Website including your city, country, page views, searches, downloads (file names);
• technical information, including your device model, operating system of the machine running your web browser, type and version of your web browser, IP address, date and time when you accessed the Website;
• web page download information;
• general Website usage information.

3. Purposes and use of information
   
   3.1. This section of the Notice explains why we process, collect and use your Personal Information.
   3.2. We may collect, process and otherwise use your Personal Information for purposes thatare required by applicable law, regulation or other contracts or to allow us to fulfil our business needs and legal obligations. These purposes include:

• to administer, improve and develop the Website;
• to personalise your user experience (e.g. by tailoring the content delivered to you on our Website);
• to manage our relationship with you and (if relevant) the organisation that you represent, including providing information regarding our products and services, and customer services;
• to manage our relationship with you as a bondholder, including the payment of the periodic coupon rate;
• to send you newsletters or marketing communications regarding our products or services and to advise you of promotions and/or other offers and/or other information that may be of interest to you;
• for advertising, marketing and promotional purposes directly through our online promotions or indirectly through our third-party social media networks;
• for analysing customer insights and trends;
• for legal disputes, regulatory investigations and compliance purposes.
  
  3.3. We may rely on third party service providers to help deliver our goods and services to you, including when you visit our Website. Sometimes we partner with other businesses to provide you with services, products and other offers (for example, car hire services CPHCL Privacy Notice 5 April 2026 and package offers). We may need to share your Personal Information with our business partners in order to provide you with those services.
  3.4. SMS/Text Messaging (where offered). If you opt in to receive SMS messages from us, we will use your mobile number to send service messages and, where you have opted in, promotional messages. We do not share mobile numbers with third parties or affiliates for their own marketing or promotional use. We also do not share your SMS opt-in/consent records with third parties. You can opt out at any time by replying STOP to opt out of SMS. After you opt out, we will not send you further SMS messages. Due to SMS programme rules, SMS messaging with this number may remain disabled for up to 12 months. During this period, you can still contact us via WhatsApp, email or telephone for service requests.

4. Basis for processing of information
   
   4.1. We use your personal information on the following bases:

• contractual agreement purposes – we use your personal information to provide services to you when you engage with us, or to take steps at your request prior to entering into such an agreement;
• legitimate business purposes – using your personal information helps us to operate and improve our business and minimise any disruption to the services that we may offer to you. We may also use your personal information to make our communications with you more relevant and personalised, and to make your experience of our services more efficient and effective;
• basis of consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes, such as to send you marketing communications;
• legal and regulatory obligations – such uses of your personal information may include financial reporting requirements imposed by government regulators, departments and bodies, or our auditors.

5. Cookies
   
   5.1. The Website creates “cookies” when you visit it.
   5.2. A cookie is a small piece of data that a website can send to your browser for storage (i.e. so it can later be read back from that browser). The purpose of cookies includes providing more tailored communications from websites.
   5.3. Cookies may collect information (including Personal Information), such as user preferences, general usage information, membership information and unique identifiers. Cookies may in some circumstances also remain on your device after you leave the Website.
   5.4. Your browser will return the cookie information only to the domain from where the cookie originated, i.e., the Website, and no other website can request this information. When you return to the Website, the cookie is sent back to the web server, along with your new request. CPHCL Privacy Notice 6 April 2026
   5.5. Your browser may provide settings where you can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it or reject the cookie altogether.
   5.6. The Website uses cookies to keep track of your booking cart. We also use cookies to deliver content specific to your interests. Click here for more information.
   
6. Disclosure of information
   
   6.1. In some circumstances, we may need to process or disclose your Personal Information in connection with the purposes listed in this Privacy Notice or as otherwise permitted by law.
   6.2. We may disclose your Personal Information:

• to Our affiliates in the CPHCL Group;
• to other entities falling under the umbrella of CPHCL Company Ltd;
• to our advisers and any prospective purchasers (and their advisers) should it be decided to sell off the whole or a substantial part of our business or integrate it with another business within the CPHCL Group; and
• to government authorities, law enforcement agencies and/or courts of law where we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request.
  
  6.3. Some of these disclosures may involve transfers of your Personal Information to a country outside of the European Union or the wider European Economic Area (EEA) (“International Transfers”). The EEA is comprised of the member states of the European Union, and Norway, Iceland and Liechtenstein.
  6.4. In some cases, International Transfers may be made to countries which do not have similar data protection laws to those of the European Union. In those circumstances, we will only disclose your Personal Information:
  
• where the recipient of the Personal Information is located within a country which has been assessed by the European Commission as ensuring an adequate level of protection for personal information;
• on the basis of an agreement, designed to protect your information, in the appropriate form approved for this purpose by the European Commission (or an equivalent body);
• with your explicit consent; or
• where otherwise permitted under applicable law.
  
  6.5. We will make sure that adequate safeguards are in place to protect your Personal Information where disclosure of your information requires an International Transfer. CPHCL Privacy Notice 7 April 2026

7. Links to other websites
   
   7.1. This Privacy Notice applies to the Website and Personal Information that we collect when you visit our Website which may also include a number of links or references to other websites, other agencies, local and international organisations.
   7.2. It is important for you to note that upon linking to or visiting another website, you are no longer on our Website, and you become subject to the Notice (if any) of the new website. We do not control such websites and are not responsible for their data practices. This Privacy Notice does not apply to such third-party websites.
   
8. Security
   
   8.1. We will take appropriate technical and organisational measures to keep your personal information confidential and secure and to ensure its integrity in accordance with our internal procedures covering the storage, access and disclosure of information and consistent with applicable data protection and privacy laws.
   8.2. Please note that messages you send to us by e-mail or via any internet connection may not be secure. If you choose to send any confidential information or Personal Information to us by such means you do so at your own risk with the knowledge that a third party may intercept this information. We are not responsible for the security or integrity of such information. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
   
9. Information about related persons
   
   9.1. If you provide us with Personal Information about members of your family, friends, dependents, or other third parties (e.g. for the purposes of making a reservation), it is your responsibility to inform them of their rights in connection with this Privacy Notice with respect to such information. You may, for example, provide such individuals with a copy of this Privacy Notice for these purposes.
   
10. Your rights
    
    10.1. If any of the Personal Information that you have provided to us changes, please Contact Us and let us know the correct details.
    10.2. Under applicable law, you have the right to:

• request a copy of the personal information about you that we hold;
• request correction or deletion of Personal Information about you that is inaccurate;
• withdraw any applicable consent for processing and transfer;
• object to our using your personal information for marketing purposes;
• object to profiling and automated decision making.
  
  10.3. In some circumstances, you may also have a “data portability” right to require us to transfer your personal data to you or to a new service provider. CPHCL Privacy Notice 8 April 2026
  10.4. We will ask your consent if we intend to use your data for marketing purposes or if we intend to disclose your information to any third party for marketing purposes.
  10.5. To exercise any of these rights, you may contact us at any time using the contact details set out in this Notice. Requests to exercise your rights will be handled without undue delay and, in any event, no later than one month from receipt of your request.

11. Complaints
    
    11.1. You may also raise complaints or concerns about our use or other processing of your Personal Information with the body regulating data protection in your country. In Malta, this is the Information and Data Protection Commissioner (details are available at https://idpc.gov.mt/en/Pages/Home.aspx).
    
12. Changes to this Privacy Notice
    
    12.1. If there are any changes to this Privacy Notice, we will replace this page with an updated version. The new terms may be displayed on-screen, and you may be required to acknowledge that you have read them before you continue to use the Website.
    12.2. It is therefore important that you check the “Privacy Notice” page when you access our website so as to be aware of any changes which may occur from time to time.
    
13. Contact us
    
    13.1. If you have any questions about this Privacy Notice or our data protection practices, please contact us at:
    
    +356 2551 4000
    dpo@cphcl.com
    22, Europa Centre, John Lopez Street, Floriana FRN 1400, Malta
    
    Last Updated: 14th April 2026