AEQUITAS GROUP

Processing of personal data

Information on the processing of personal data

1. Investment group Aequitas Capital SE, Na Bělidle 997/5, 150 00 Prague 5, company ID: 17077753, registered under sp. H 2541 at the Municipal Court in Prague processes and stores Personal Data (as defined below) in accordance with this information on the processing of personal data and according to the legal regulations effective in the territory of the Czech Republic.

I. ADMINISTRATOR OF PERSONAL DATA

2. Aequitas Capital SE is also the administrator of personal data. Aequitas Capital SE can be contacted at +420 603 837 776 or at the e-mail address info@aequitascapital.eu.
3. Aequitas Capital SE, as the administrator, determines the purposes for which the personal data of persons who invest, buy shares of the SICAV fund, order bonds on the website of the fund or the issuer, or have already made a purchase of securities (hereinafter referred to as the „Client“) are processed, determines the means of processing and responds for its proper execution.

II. PERSONAL DATA PROCESSED AND THE PURPOSE FOR WHICH THEY ARE PROCESSED

Personal data of the Client means data relating to the Client, which the Client passes on to the seller, the issuer, in particular

  • name and surname
  • date of birth and age
  • permanent residence or place of permanent residence
  • contact details (especially phone number, e-mail, correspondence address, account number)
  • data on the number, numbering and total value of the subscribed bonds
  • other data resulting from the use of the website (in particular, demographic data, data on used links from the website, displayed parts of the website and the time they were viewed)
  • other data collected in connection with the fulfillment of obligations according to legal regulations

The seller, issuer processes personal data provided by the Client for the purposes of:

  • creation of a binding order form and related documentation necessary for the purchase and subsequent legal actions related to the subscribed securities, especially maintaining a list of bond owners, communication with Clients, etc.
  • fulfillment of obligations from contractual relations with Clients
  • fulfillment of obligations from legal regulations, especially towards state authorities
  • offering other securities and services, in accordance with the legitimate interest of the Issuer, the offer is implemented in the form of e-mail and mail sent to the address of the Client's residence
  • improving the appearance, functions and overall interface of the website
  • offering the Issuer's services (other than the option to purchase securities), in all forms of communication, including advertising and invitations to visit websites, intended to directly or indirectly support the Issuer's goods or services or image, the offer is implemented in in the form of an e-mail or a letter sent to the address of the Client's residence
  • offering the services of companies specified in the consent to the processing of personal data, in all forms of communication, including advertising and invitations to visit websites, intended to directly or indirectly support the goods or services or the image of the company in question, the offer is implemented in the form of e-mail or a letter sent to the address of the Client's residence
  • offering of securities issued by companies specified in the consent to the processing of personal data, the offer is implemented in the form of an e-mail or letter sent to the address of the Client's residence

The legal titles on the basis of which the seller, issuer processes Personal Data are:

  • Protection of legitimate interests of the seller, issuer (such as the fulfillment of contractual obligations towards Clients, enforcement of legal claims, offering other securities and services)
  • Fulfillment of legal obligations arising from legal regulations
  • Fulfillment of the contract (processing of personal data into the order form and other documentation associated with the order of securities)
  • Consent (possible further marketing and retention of personal data if no other legal title is given)

III. METHOD OF PROCESSING AND PERIOD FOR WHICH WE KEEP PERSONAL DATA

4. The seller's personal data is processed manually and electronically by the issuer in a database linked to the sales server, always only for the purpose for which they were obtained or for the purpose of fulfilling obligations set by law.
5. Personal data of the seller's clients, the issuer processes through its own employees. The issuer keeps the personal data provided by the seller's Client for a period of 10 years from the moment of their provision in the event that the Client does not subscribe for the securities, or 10 years after the maturity of the securities subscribed by the Client.

IV. RIGHTS OF CLIENTS AGAINST SELLER, ISSUER

6. In connection with the processing of personal data, you have rights that arise from legal regulations and which you can exercise at any time. It is about:

  • The right to withdraw consent to the processing of personal data

7. If the Client gives consent to the processing of personal data for the purposes of direct marketing, this consent can be withdrawn at any time without any consequences for other relationships between the Client and the seller, the issuer.

  • The right to access personal data, correct inaccurate and supplement incomplete personal data

8. This right means that the Client can request information from the seller, the issuer regarding the Personal Data held by the Issuer, their content, as well as their purpose of processing and the origin of this information. The client can also request the seller or issuer to make corrections to these Personal Data, or supplement them, if the Personal Data kept in the records of the seller or issuer are incomplete or incorrect.

  • The right to erasure of personal data

9.The Client may request that the seller, the issuer delete the Personal Data of the Client, the seller, the issuer will do so in the event that the personal data are not needed for the purposes for which they were collected or otherwise processed or the processing ceases to be in accordance with generally binding legal regulations. Personal data will also be deleted if the Client objects to the processing of personal data that is processed on the basis of a legitimate interest (if there are no overriding legitimate reasons for processing on the part of the Issuer), or if the Client objects to the processing of personal data for direct marketing purposes.
10. However, the Client's personal data cannot be deleted if the processing of the Personal Data is still necessary for the fulfillment of our legal obligation, the purposes of archiving in the public interest, scientific or historical research or for statistical purposes, or for the determination, exercise or defense of the seller's, issuer's legal claims.

  • The right to object to processing

11. The client has the right to object to processing that is based on the legitimate interests of the seller, the issuer, the legitimate interests of a third party or is necessary to fulfill a task carried out in the public interest or in the exercise of public authority. After raising an objection, the processing of personal data will be terminated, unless it is proven that there are serious legitimate reasons for the processing that outweigh your interests or rights and freedoms. The client is also entitled to object to the processing of personal data for direct marketing purposes.

  • The right to limit the processing of personal data

12. The client has the right to request from the seller or the issuer the restriction of the processing of Personal Data for a limited period of time, in cases where they do not request their deletion, or this deletion is not possible. The limitation of the processing of Personal Data applies to situations where the accuracy of the data is denied, the data is no longer needed by the seller, the issuer, for the original purpose, a decision is being made on the raised objection (see above).

  • Right to portability

13. The right to portability of Personal Data gives the Client the possibility to obtain the Personal Data that the Client has given to the seller, the issuer in a common and machine-readable format. The Client may subsequently transfer this data to another administrator or, if technically possible, request that the seller or issuer transfer it.

  • The right to lodge a complaint with the supervisory authority

14. In the Czech Republic, the office that supervises the area of personal data is the Office for the Protection of Personal Data.
15. The client can contact the seller, the issuer in connection with the way of processing Personal Data with written requests and questions, to which the seller, the issuer always responds within one month and states the measures taken in this connection or the reasons for not accepting them. The seller, the issuer may charge an appropriate fee in connection with the administrative burden.
16. In the event of a violation of the obligations set forth by the legal regulations for the protection of personal data, it is possible to file a complaint with the Office for Personal Data Protection or with another competent supervisory authority of a member state of the European Union, which is entrusted with the supervision of compliance with the obligations set forth in the GDPR (in particular, a supervisory authority in a member state, in which the Client has his habitual residence, place of employment or place where the alleged violation occurred). You can find more information on the website of the Office for Personal Data Protection: https://www.uoou.cz/.