Privacy Policy

Privacy Policy – Summary

We respect your privacy and protect your personal data in accordance with the General Data Protection Regulation (GDPR). This summary explains the main points of how we process your personal data:

Data Controller: Our company is responsible for your personal data and has appointed a Data Protection Officer you can contact.
Purpose of Processing: We collect personal data to provide investment services, execute orders, manage portfolios, offer advice, comply with legal obligations, prevent fraud, and send marketing information if you consent.
Legal Basis: Processing is based on contracts, legal obligations, legitimate interests, or your consent.
Recipients: Your data may be shared with authorities, courts, auditors, IT service providers, and partners for the purposes described.
Data Retention: We store your personal data only as long as necessary for the purposes for which they were collected.
Your Rights: You have the right to access, correct, delete, limit processing, object, request data portability, withdraw consent, file a complaint, and claim compensation.
Marketing: With your consent, we may send you information about our products and services. You can withdraw consent at any time.

For detailed information, please read our full Privacy Policy.

With this Privacy Policy we provide basic information on the processing personal data in accordance with the General Regulation on Personal Data Protection [1]. Therefore, please read the text below carefully and please contact us in case of ambiguities or the need for additional information regarding processing of personal data.

Personal data protection officer

The Company has appointed a personal data protection officer who you can contact regarding all issues related to the processing of your personal data and the exercise of personal data protection rights.

Purpose of personal data collection and legal basis of processing

The purpose and methods of personal data processing may be determined by the Company or by one of the Company’s partners with whom the Company has a contract related to the processing of personal data or they may do so jointly.

When the Company solely determines the purpose and means of personal data processing, it is the manager of personal data processing.

When the Company, as the manager of personal data processing together with one or more partners as the manager(s) of data processing, determines the purpose and means of personal data processing, they are joint managers of personal data processing. You will be notified of this when collecting personal information.

When the Company processes data on behalf of the manager, then the Company is the executor of personal data processing and processes the data in accordance with the requirements of the manager. In that case, the processing manager determines which personal data and to what extent the Company, as the processing executor, should collect from the respondents. You will be notified of this when collecting personal information.

The main purpose of collecting personal data is to perform the following activities:

receiving and transferring orders in connection with one or more financial instruments,
execution of orders for the client’s account,
portfolio management,
investment advisory,
offer execution services, i.e. sale of financial instruments without the obligation to repurchase,
storage and administration of financial instruments for the account of clients, including custody and related services, such as money management or collateral,
consulting on capital structure, business strategies and related issues, as well as consulting and services related to mergers and acquisitions of companies,
foreign exchange services if they are related to the provision of investment services,
investment research and financial analysis, as well as other recommendations related to transactions in financial instruments,
investment services and activities and ancillary services as per applicable legislation, when those investment services and activities are linked to investment or ancillary services,
trading of crypto assets
execution of orders for virtual assets
offer execution services, i.e., sale of virtual assets
receiving and transmitting orders for virtual assets on behalf of third parties
or taking action at your request prior to entering into a contract or legal obligation of the Company (particularly obligations relating to the prevention of money laundering and terrorist financing).

The scope of personal data that we collect depends on the type of contract you intend to enter into or enter into or your request or statutory obligations of the Company. Providing your personal information is necessary to establish a business relationship and enter into and fulfill a contract, and if you do not provide the information necessary for a particular type of contract, we will not be able to provide services in this regard.

Actions at your request before concluding a contract involve checking your requirements and needs, all with the aim of providing the service.

In the event that we need certain personal information that is necessary for us to provide the requested service, we will notify you in a timely and appropriate manner.

The Company will also process your personal data for the purpose of fulfilling the Company’s legal obligations, such as (but not limited to) obligations prescribed by laws and international tax regulations (FATCA, CRS, etc.) and regulations enacted under those laws. If you do not wish to provide us with this information, we will not be able to provide you with the service.

The legal basis for the aforementioned data processing is Article 6 (1) (b) and (c) of the General Regulation on Personal Data Protection (processing is necessary for the performance of a contract to which the respondent is a party or to take action at the request of the respondent before conclusion of the contract, processing is necessary to comply with the legal obligations of the personal data processing manager).

The Company has a legitimate interest in processing personal data necessary for the purpose of preventing fraud, and the legal basis for this is Article 6, paragraph 1, item (f) of the General Regulation on Personal Data Protection (processing is necessary for the legitimate interests of the manager or third parties, except when these interests are stronger than the interests or fundamental rights and freedoms of the respondent that require the protection of personal data, especially if the respondent is a child).

If there is no purpose or basis for the processing of your personal data, we will only process your personal data if you have given your voluntary consent. The legal basis for this is Article 6 (1) (a) of the General Regulation on Personal Data Protection (the respondent has consented to the processing of his personal data for one or more specific purposes).

Recipients or categories of recipients of personal data

The Company ensures that your personal data is processed exclusively for the purposes set out in this document. The purpose of the processing of personal data will require that your personal data be disclosed and that it be processed by other companies and persons in the capacity of the processor in addition to the Company. The categories of processors by which your data will be disclosed include state and public authorities in accordance with legal obligations of the Company. Thus, your personal data may be disclosed to other recipients in order to fulfill our legal obligations, i.e. at the request of a state body (such as the Personal Data Protection Agency, the Office for the Prevention of Money Laundering and Terrorist Financing, the Financial Inspectorate, the Financial Services Supervisory Agency). Ministry of Finance, Tax Administration, State Attorney Office, etc.). Also, your personal information may be disclosed to courts, notaries, lawyers, auditors, court experts, and other persons, if necessary to make, exercise or defend legal claims, whether in court or administrative proceedings or any out-of-court proceedings. procedure. In addition, your personal data may be disclosed to IT service providers, delivery service providers, accounting service providers and other persons who are personal data processors in relation to the Company. Executors of personal data processing, with the exception of state and public authorities, process data exclusively according to the Company’s instructions, while respecting technical and organizational measures to ensure the protection of your rights.

We will provide your personal data that we process as a personal data processing executor to the personal data processing manager, in accordance with the purpose of personal data processing determined by the personal data processing manager and the rules of the personal data processing manager. This includes personal data that we collect in order to fulfill the legal obligations prescribed by the law and international tax regulations (FATCA, CRS, etc.).

Marketing

With your consent, we process your personal data for marketing purposes in terms of informing about the offers, products and services of the Company and its partners. The data we process for this purpose are: name and surname, full address (street, house number, staircase, apartment, postal code, city, country), telephone number, e-mail address and mobile phone number (if applicable), date birth. Consent also refers to the fact that your personal data is processed by one or more partners of the Company and that the partner of the Company addresses you directly, about which you will be informed in more detail before giving consent.

If you have given your consent to the processing of your personal data for the purpose of advertising and market research, you can revoke your consent at any time by notifying the Company in writing: by e-mail or by regular mail to the Company’s address. Partial revocation of consent is not possible. Revocation of consent does not affect the lawfulness of the processing of personal data which, on the basis of consent, has been carried out until the moment of revocation of consent.

If you have not given your consent or revoked it, we will not use your personal information for marketing purposes.

The legal basis for this is Article 6 (1) (a) of the General Regulation on Personal Data Protection (the respondent has consented to the processing of his personal data for one or more specific purposes).

Information on the intention to transfer personal data to the recipient in a third country or international organization and whether there is a decision on appropriateness

The Company does not intend to transfer your personal information to a recipient in a third country or international organization, unless there is a legal obligation to do so.

Period of storage of personal data and criteria for determining that period

We will store your personal data for as long as necessary to fulfill the purpose for which we process them, and the criterion for determining that time is precisely the purpose of their collection, statute of limitations required by law or a specific provision of another law that obliges us to keep your personal data. data.

Your rights in relation to personal data

In order to ensure fair and transparent processing of your personal data, we refer you to your rights:

right of access – you have the right to contact us at any time and obtain information on whether and to what extent your personal data is processed and, if such data is processed, to request access to personal data and information to which you are entitled in relation to personal data protection. The Company provides you with a copy of the personal data being processed, and for any additional copies you request, we may charge you a reasonable fee based on administrative costs, if you apply electronically, unless you request otherwise, we provide information in the usual electronic form;
right to correction – if we process your personal data that is inaccurate, you can at any time ask us to correct them, and if they are incomplete, you have the right to supplement them;
right to delete – you have the right to ask us to delete personal data relating to you if we have processed it illegally or if personal data is no longer necessary for the purpose of processing, etc. Please note that there are reasons that prevent immediate deletion, for example, for the purpose of setting, realizing or defending legal claims, about which we will inform you in detail in relation to each individual claim;
right to limit the processing – you can ask us to limit the processing of your data: if you dispute the accuracy of personal data during a period that allows us to verify the accuracy of that data; if the processing is illegal but you oppose the deletion and instead seek a restriction on the use of that data; if we no longer need the data for the purposes of processing, but are looking for them in order to set, implement and defend legal claims; if you have objected to the processing;
right to data portability – you have the right to receive your personal data provided to us, in a structured, commonly used and machine-readable format, and you have the right to transfer this data to another manager, if the processing is based on consent or contract and is carried out automatically;
right to object – you can object to the processing of your personal data at any time, if the processing is based on our legitimate interests, including the creation of profiles or if we process your data for direct marketing purposes;
right to complain – if you believe that the processing of your personal data has violated the General Regulation on Personal Data Protection or other regulations related to personal data protection, please contact our Personal Data Protection Officer to clarify contentious issues;
right to withdraw consent – when processing is based on consent, you have the right to withdraw consent at any time, provided that this does not affect the lawfulness of processing based on consent before it is withdrawn, and you can withdraw consent by notify the Company in writing: by e-mail or by mail to the Company’s address (contact details of the Company are listed at the beginning of this Privacy Policy), or notify the Personal Data Protection Officer in writing.
right to compensation – if you have suffered (non) property damage due to violation of relevant legal provisions, you are entitled to compensation for damage suffered by the Company or the processing manager if the Company is the executor of processing.

We will respond to your request within a reasonable time, and no later than one month from the date of receipt of the request, unless a longer period of time is requested for the same, in which case the same period may not exceed 2 months.

Notes

This document on the treatment of personal data is regularly updated, and its latest version is always available in our every sales office in a visible place. If significant changes occur in relation to this document in the processing of data and our handling of the same, you will be notified directly.

[1] Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC data)