GDPR

Personal Data Processing Consent

TILLER investment company JSC Personal Data Processing Policy

On the 25th of May, 2018, the European Parliament and the European Council enacted the General Data Protection Regulation (EU) 2016/679 (further referred to as the “GDPR”). This is a regulation on the data protection of individuals that also addresses the processing of personal data and the free transfer of such data, and repeals Directive 95/46/EC (Data Protection Directive). The following text includes information about the personal data processing of the TILLER company with regard to the GDPR.

1. Who handles your personal data and who is the Controller?

TILLER investment company JSC, with its registered seat at Tillerova 123, 110 00 Prague 1, registered under Registration Number 123 45 678 with the Commerical Register maintained by the Municipal Court in Prague, File B 12345 (further referred to as the “Company“, “We“ or “Us“), handle your personal data and is the data Controller.

2. Who is a Data Protection Officer and how to contact him/her?

In order to protect the personal data of our clients, the Company has appointed a highly skilled Data Protection Officer who fulfils the tasks established by law and acts as a contact person for you - our client. Therefore, if you have any inquiries about the collecting and processing of your personal data, or about your rights regarding your personal data, you can contact the Data Protection Officer’s team.

The Company’s contact person for data protection is Ing. Dušan Klimeš, MSc. You can contact him with your submissions via mailbox dpo@tillerfunds.cz.

3. Why do We need to collect and use your personal data and what is the lawful basis underlying the personal data processing?

We collect your personal data to the minimum extent necessary and only for the clearly stated purposes listed below. If you are interested in our services and contact Us via the contact form on our website, We may require your consent to use your personal data (primarily your name and e-mail address) to be able to interact with you. We will collect only the personal data necessary to contact you. If you do not wish to continue the partnership with Us, We will cease processing your personal data upon your request. If you are interested in further collaboration, We may need to collect data get in touch with you, to find the most suitable product for you, to sign a contract and enable the operation of the contract, and fulfil the agreement’s obligations. We would not be able to provide services to you without collecting certain necessary personal details. We also have a duty to process personal data to the extent required by legislation in order to meet the legal obligations imposed on our Company (e.g., in certain transactions, to prevent money laundering and the financing of terrorism). We may also process your personal data to offer you products and services provided by the Company, which acts as the manager and administrator of the fund/sub-fund. In this case, the data processing is related to all manner of analyses and market segmentation with the aim of meeting your requirements. We will use your data with your consent or pursuant to any previous consent. We do not wish to burden our customers with pointless and inappropriate communication. We collect and process the personal data only to understand your needs better; to be able to offer you suitable solutions, such as our products; to manage customer service interactions with you; and for market research purposes. We communicate via all possible technological means, including e-mail, text messages, social media and websites. If you do not wish to receive such offers, you can opt-out from any marketing communication. Our Company or a third party can also access your personal data if a legitimate interest is justified (for example, for the recovery of claims or in litigation).

4. What personal data do We collect?

We collect and handle only the personal data necessary for the performance of our tasks. Depending on the character of the relationship between you and the Company, We may collect the following information:

• personal identity data (e.g., your name, surname, date of birth, place of birth, place of residence);
• contact details (e.g., address, phone number, e-mail);
• socio-demographic data (e.g., age, sex, employment); and/or
• information about products (e.g., type of investment).

5. Where do We collect your personal data from?

We collect the data that you provide; e.g., the data from contracts concluded between you and our Company, from public sources (such as the Commerical Register) and from third parties who cooperate with Us, if there is a legal grounding for such processing. We pledge to handle your data fairly and legally at all times.

6. How can you give Us your consent and for which purposes? Who can attain your consent?

The purpose of your consent will always be specified. However, We mostly require your consent for the following purpose:

• to be able to contact you about promotions and products, no longer than five years after the end of our contract with you.

You can give Us your consent to use your personal data mentioned above and to share your personal identity data and contact details with third parties.

7. Who can collect and process your personal data?

The legislation on personal data protection enables the data Controller (i.e., the subject that defines how the data is processed) to entrust the duty of data handling to a data processor. The processor is Us (i.e., an individual or a group who handles or keeps personal data), or it may be an outsourced to a service provider. The Company allows service providers to process this data only if they have confirmed that they apply data security and protection to the same standard as does the Company.

The service providers must fulfil all requirements to comply with legal regulations. Our service providers are:

• investment intermediaries holding a licence to offer our services or manage the funds;
• IT service providers; and/or
• marketing agencies and market research agencies.

8. For how long do We store your personal data?

We keep your personal data for the term of our contract with you and then for five years after the contract has ended, or for any other period required by the apt legislation on document archiving.

After this period or after you have withdrawn your consent, We will delete and/or anonymize your personal data, or process it where the consent is not on a lawful basis for processing and if there is another legitimate reason for such processing.

9. What are your rights relating to your personal data?

You have the following rights:

• The right of access – you can ask Us to access the data We hold about you and request a copy of such personal data. If you request a second copy, We may charge you a reasonable fee for administrative costs.
• The right of rectification – you can ask Us to correct any incorrect or incomplete personal data related to you.
• The right of erasure – you can ask Us to delete the data We hold about you if one of the following criteria is met:

  • Your personal data is no longer needed for the purposes it had been collected for or handled;

  • Your consent has been withdrawn and there is no legal reason to retain it;

  • The right to object – you can object to being a subject to automated individual decision-making or stop your data being used for direct marketing purposes if We have no legitimate reason to do so;

  • Your personal data has been collected and handled unlawfully;

  • Your personal data must be erased for compliance with a legal obligation in the Union or Member State law to which the Controller is subject;

  • Your personal data has been collected in connection with an offer of information society services.

• The right to restriction of processing – you can ask Us to restrict the processing of the data We hold about you if one of the following options happens:

  • You can contest the accuracy of your personal data for a period enabling Us to verify the accuracy of the data;

  • The processing of your personal data is unlawful; however, you refuse the erasure of the data and request the restriction of its use instead;

  • We no longer need to process your personal data; however, you require the data for the establishment, exercise or defence of legal claims;

  • You objected to the processing of your data in accordance with Article 21(1) until We verify whether our legitimate grounds supercede those of yours.

• The right to data portability – you have the right to ask Us to supply you with the personal data that We hold about you, in a structured, commonly used and machine-readable format, and to provide a copy of the data to another organisation if the rights and freedoms of others are not adversely affected;
• The right to withdraw your consent – you can withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of the personal data processing carried out before the withdrawal;
• Right to object – under certain circumstances, you can object at any time to the processing of your personal data; especially in situations in which We could process your data in the legitimate interest of the Company or a third party, or for direct marketing. Under such circumstances, your objection is apt and We will not further process your personal data; and
• The right to lodge a complaint – you have the right to lodge a complaint with Us, Tillerova 123, 110 00 Prague 1, or with a single supervisory authority, which is The Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Prague 7, www.uoou.cz.

10. Is your consent with data processing voluntary or compulsory?

Your consent to the collecting and handling of your personal data related of the promoting and advertising our products and services is entirely voluntary and can be withdrawn at any time.