Povinné informovanie

JUDr. Samuel Matejovič

Mgr. Ivan Kordík

Ing. Tomáš Dopirák

Message Us

Infoline:

E-mail:

osobnyudaj.sk, s.r.o. Námestie osloboditeľov 3/A,
040 01 Košice

Controller:

PARTNERS INVESTMENTS, o.c.p., a.s.

Address: Slávičie údolie 106 Bratislava 81102

CRN: 52413179

Certificate No.: Osobnyudaj.sk-2019-21813

Office for Personal Data Protection of the Slovak Republic

Office for Personal Data Protection of the Slovak Republic

Address:
Hraničná 12

820 07, Bratislava 27

Slovak Republic

CRN: 36 064 220

Filing room:

Monday - Thursday: 8:00 am - 3:00 pm

Friday: 8:00 am - 2:00 pm

Data protection helpline:

Tuesdays and Thursdays from 8:00 am until 12:00 pm +421 2 323 132 20

Secretariat of the President +421 2 323 132 11

Office Secretariat +421 2 323 132 14

Fax: +421 2 323 132 34

Spokesperson:

Mobile phone: +421 910 985 794

Email: hovorca@pdp.gov.sk

E-mail:

- General issues: statny.dozor@pdp.gov.sk

- Provision of information under Act No 211/2000: info@pdp.gov.sk

- Website: webmaster@pdp.gov.sk

- To submit information provision applications under Act No 211/2000 on freedom of information, please use the online form.

- Email address through which the Office provides consultancy in personal data protection. It is intended for children, youth, students, teachers, and parents suspecting abuse of their personal data: ochrana@pdp.gov.sk

Personal data officer

JUDr. Jakub Pavčík

JUDr. Samuel Matejovič

Mgr. Ivan Kordík

Ing. Tomáš Dopirák

Message Us

Infoline:

E-mail:

osobnyudaj.sk, s.r.o. Námestie osloboditeľov 3/A,
040 01 Košice

Controller:

PARTNERS INVESTMENTS, o.c.p., a.s.

Address: Slávičie údolie 106 Bratislava 81102

CRN: 52413179

Certificate No.: Osobnyudaj.sk-2019-21813

Information about Personal Data Processing Purposes and Retention Periods

Information about personal data processing purposes

One of the personal data processing principles is purpose limitation. It means that personal data may be collected only for a determined, expressly stated, and eligible purpose and must not be processed in a manner inconsistent with that purpose.

Personal data processing is to be closely related to the purpose thereof, particularly concerning a list or scope of the personal data to be processed, which should be determined so that the purpose of personal data processing can be achieved. Any artificial or additional extension of the list or scope of the personal data to be processing beyond the purposes thereof is not allowed; Where the purpose and a list or scope of personal data are determined by law, there should be compliance, and where such a list or scope is determined by the controller, they shall take care to not extend it beyond the scope of the purpose.

The Personal Data Protection Act lays down the controller’s obligation to provide a data subject with information about the purpose for processing their personal data for which it is collected and this even where personal data is not collected directly from the data subject. Such information should be provided to data subjects no later than at the time their personal data is collected, or sufficiently in advance thereof, and in a clear and comprehensible manner allowing data subjects to familiarize themselves with the information thoroughly and understand it.

Your personal data is processed by us in order to comply with legal obligations in taxes and accounting, to execute your orders, to provide ordered services, for invoicing purposes, and to deliver orders to your contact address.

Period of personal data processing and criteria for determining the period:

Your personal data is processed for as short a period of time as possible. Most often, your personal data, which is processed in a safe manner, will be deleted immediately after either you settle contractual liabilities or you withdraw your consent to personal data processing, or after the expiry of a reasonable retention period set out by us in compliance with the minimum retention under Article 5 (1) (e) of the GDPR governing personal data retention.

As the Controller, the erasure of personal data is arranged without undue delay immediately after:

All contractual relationships between you and our Company expire; and/or

All of your obligations towards our Company have been met; and/or

All your complaints and requests have been settled; and/or

All other rights and responsibilities between you and our Company have been settled; and/or

Having achieved all processing purposes either determined by legal regulations or those in respect of which you have given us your consent where processing has been carried out on the basis of the data subject’s consent; and/or

Upon the expiry of the period for which the data subject has given their consent or upon the data subject’s withdrawal of consent; and/or

Upon compliance with the data subject’s request for personal data erasure, provided that one of the reasons justifying compliance with the request occurred; and/or

A legal element conditioning the end of the processing purpose occurs simultaneously with the expiry of the retention term set out in compliance with the minimum personal data retention period principle;

The Company’s legitimate interest and its obligations cease to exist, including those whose compliance is not possible without personal data retention and are set out in generally binding legal regulations that require retention of a data subject’s personal data (in particular for the purposes of archiving, tax audits).

No accidentally collected personal data is systematically processed in any way and for any of the processing purposes defined by us. Where possible, any data subject whose personal data has been collected accidentally will be informed about it and, according to the nature of the given case, they will be provided with the cooperation necessary to restore control over their personal data. Immediately after taking all steps that are aimed at resolving the situation, all accidentally collected personal data will be safely disposed by us.

Should you be interested in further information about the specific retention period applicable to your personal data, please contact us using the contact details provided on our website.

Personal data officer

JUDr. Jakub Pavčík

JUDr. Samuel Matejovič

Mgr. Ivan Kordík

Ing. Tomáš Dopirák

Message Us

Infoline:

E-mail:

osobnyudaj.sk, s.r.o. Námestie osloboditeľov 3/A,
040 01 Košice

Controller:

PARTNERS INVESTMENTS, o.c.p., a.s.

Address: Slávičie údolie 106 Bratislava 81102

CRN: 52413179

Certificate No.: Osobnyudaj.sk-2019-21813

Data Subject Rights

Data Subject Rights

Regulation (EU) 2016/679 of the European Parliament and Council as of 27 April 2016 on the protection of natural persons with regard to the personal data processing and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation) and Act No 18/2018 on the Personal Data Protection, as amended, guarantee you, as a data subject, the following rights:

a) the data subject’s right of access to their personal data, which means:

The right to obtain from the Controller a confirmation stating whether the data subject’s personal data is subject to processing;

Where the data subject’s personal data is processed, they have the right of access to their personal data and the right to obtain the following information:

- Processing purposes;

- Personal data categories concerned;

- Recipients or categories of recipients to whom personal data has been or will be disclosed and, in particular, about the recipients from third countries or international organizations;

- Where possible, the envisaged period of personal data retention or, where this is not possible, about the criteria used to determine the retention period;

- The right to request the Controller to rectify or erase personal data and/or restrict personal data processing and the right to object to the processing;

- Information about the right to file a complaint with a supervisory authority;

- Where personal data has not been obtained from the data subject, any available information as to the source thereof;

- About automated decision-making, including profiling specified in Article 22 (1) and (4) of the Regulation and, if yes, the data subject shall receive purposeful information about applied procedures and the importance and assumed consequences of such processing of personal data for them;

The right to be informed about reasonable guarantees under Article 46 of the Regulation concerning the transfer of personal data, where the data is subject to transfer to a third country or to an international organization;

The right to receive a copy of the personal data to be processed provided the exercise of this right will have no adverse consequences for the rights and freedoms of others;

Basically, the Data Subject’s right of access to personal data means that the Data Subject has the right obtain confirmation from us, stating whether their personal data has been subject to processing and, if yes, the they have the right of access to their personal data. At the Data Subject’s request, a copy of the personal data to be processed will be provided. A reasonable fee may be charged, corresponding to administrative costs, for all other copies requested by the Data Subject. Where the Data Subject sends a request electronically, the information will be provided in a commonly used electronic form unless the Data Subject requests an alternative way of having the information provided. The information shall be provided immediately or no later than within one (1) month. We have the right to extend the request processing period by another two (2) months where the request is complicated or frequent. In any case, the Data Subject has to be informed about the grounds behind the requested extension of the processing period within one (1) month. Where a request is ungrounded or too frequent, we have the right either to charge a fee reasonable in view of our costs or to refuse the request. We are obliged to explain the reason behind the refusal and the data subject’s right to file a complaint with the supervisory authority.

b) The data subject’s right to rectification of their personal data, which means:

The right to rectification by the Controller without undue delay of the incorrect personal data concerning the data subject;

The right to supplement any incomplete personal data of the data subject by providing an additional declaration;

The right of the data subject to rectification of their personal data means that you may ask us at any time to rectify or supplement your personal data if it is inaccurate or incomplete. The data subject has the right to supplement their personal data also through a submission of an additional declaration.

c) The right of the data subject to have their personal data erased (“the right to be forgotten”),which means:

The right to erasure without undue delay by the Controller of the data subject’s personal data in case of one of the following situations:

- The personal data is no longer needed for the purposes for which it has been collected or otherwise processed;

- The data subject withdraws their consent based on which personal data processing is carried out and there is no other legal basis for personal data processing;

The data subject objects to personal data processing in compliance with Article 21 (1) of the Regulation and there are no overriding legitimate grounds for personal data processing or the data subject objects to personal data processing under Article 21 (2) of the Regulation;

- Personal data is processed unlawfully.

- Personal data is to be erased to comply with a legal obligation under the laws of the European Union or the Member State to which the Controller is subjected;

- Personal data has been obtained in connection with an offer concerning information company services under Article 8 (1) of the Regulation;

The right to request that the Controller who has disclosed the data subject’s personal data put reasonable measures including technical measures into place, taking account of available technology and the costs associated with such measures, to inform other controllers processing the personal data that the data subject requests erasure of all references to their personal data and its copies and duplicates; and

The right to erasure of personal data within the meaning of Article 17 (1) and (2) of the Regulations [i.e. the rights under clause J (c)(i) and (ii) of this document] shall not arise where personal data processing is necessary:

To exercise of the right to freedom of expression and information;
To comply with a basic obligation that necessitates the processing under the laws of the European Union or the Member State to which the Controller is subjected, or to fulfil a task in the public interest or within the exercise of the public authority entrusted to the Controller;
For reasons of public interest in the field of public health in accordance with Article 9 (2) (h) and (i) of the Regulation and Article 9 (3) of the Regulation;
For archiving purposes in the public interest, scientific or historical research, or for statistical purposes under Article 89 (1) of the Regulation where there is a likelihood that the right under Article 17 (1) of the Regulation will neither prevent nor seriously hinder achievement of the objectives of such personal data processing; or
To establish, assert, or defend legal claims;

The data subject’s right to erasure of personal data means that we are obliged to erase your personal data where (i) it is no longer necessary for the purposes for which it has been collected or otherwise processed, (ii) the processing is unlawful, (iii) you object to the processing and there are no overriding legitimate reasons for the processing, or (iv) where we are to do so by virtue of a legal obligation.

d) The data subject’s right to restriction of their personal data processing, which means:

The right to request that the Controller restrict personal data processing in any of the following cases:

- The data subject contests the personal data accuracy at a time when the Controller is able to verify the personal data accuracy;

- Personal data processing is unlawful and the data subject objects to erasure of the personal data and requests restricting of its use instead;

- The Controller no longer needs the personal data for processing purposes, but the data subject needs such data to prove, assert, or defend legal claims;

- The data subject objects to personal data processing, in compliance with Article 21 (1) of the Regulation, until it has been demonstrated that the legitimate grounds on the part of the Controller prevail over the data subject’s legitimate grounds;

Where personal data processing has been restricted under clause J (d) (i) hereof, the right to request that the personal data be subject to restricted processing may be processed further only with the data subject’s consent except for retention purposes, or for the purposes of proving, asserting, or defending of legal claims, or protection of rights of another natural or legal person, or on grounds involving an important public interest of the European Union or a Member State;

The right to be informed in advance about cancellation of the personal data processing restriction;

The subject’s right to restriction of personal data processing means that, until any issues associated with the processing of your personal data have been resolved, processing of your personal data will be restricted by us so that they may only be saved but not processed further.

e) the data subject’s right to compliance with the notification obligation towards recipients,which means:

The right to request that the Controller notify each recipient who has received personal data about each personal data rectification or erasure or processing restriction under Article 16, Article 17 (1), and Article 18 of the Regulation unless it is provably impossible or associated with unreasonable efforts;
The right to request that the Controller inform the data subject about such recipients where the data subject requests it;

The data subject’s right to compliance with the notification obligation towards recipients the Controller’s obligation to inform each recipient to whom the Controller has disclosed the personal data of the data subject about each rectification, erasure, or restriction of processing of the personal data. The Controller is not obliged to do so only where such a notification is impossible on objective grounds or is associated with unreasonable efforts.

f) The data subject’s right to portability of their personal data, which means:

The data subject has the right to obtain the personal data concerning the data subject and provided by the data subject to the Controller in a structured, commonly used, and machine-readable format and has the right to transfer the personal data to another controller without the Controller’s preventing the data subject from doing so where:

- The processing is based on the data subject’s consent under Article 6 (1) (a) or Article 9 (2) (a) of the Regulation, or on an agreement under Article 6 (1) (b) of the Regulation and, at the same time;

- The processing is carried out by automated means, and

- The right to obtain personal data in a structured, commonly used, and machine-readable format and the right to transfer such personal data to another controller without the Controller’s preventing the data subject from doing so will have no adverse effects on the rights and freedoms of other persons;

The right to the transfer of personal data directly from one controller to another controller where it is technically feasible;

The right to data portability means that you have the right to obtain from us your personal data disclosed to us in a structured, commonly used, and machine-readable format and you have the right to request us to transfer your personal data to another controller in compliance with legal requirements, where exercise of this right is without prejudice to your right to request erasure of your personal data. However, the right to portability only concerns personal data we have obtained from you on the basis of a contract to which you are one of the parties.

g) The data subject’s right to objectmeans:

The right to object, on grounds related to a specific situation, to the processing of the data subject’s personal data on the basis of Article 6 (1) (e) or (f) of the Regulation, including profiling under the above provisions thereof;

[Upon exercise of the right to object, at any time and on the grounds related to the data subject’s specific situation, to the processing of the data subject’s personal data carried out under Article 6 (1) (e) or (f) of the Regulation, including an objection to the profiling based on those provisions of the Regulation] the right to request that the Controller refrain from processing the data subject’s personal data until inevitable legitimated grounds for the processing are demonstrated, which override the interests, rights, and freedoms of the data subject, or the grounds related to proving, asserting, or defending of legal claims;

The right to object at any time to the processing of the data subject’s personal data for the purposes of direct marketing, including profiling to the extent it relates to direct marketing, where if the data subject objects to the personal data processing for the purposes of direct marketing, the personal data must not be further processed for those purposes;

(In connection with the use of information society services) the right to object, providing technical specifications, to the personal data processing via automated means;

The right to object on grounds related to the data subject’s specific situation regarding their personal data where the personal data is processed for the purposes of scientific or historical research or for statistical purposes under Article 89 (1) of the Regulation, except for cases where the processing is necessary to fulfil a task in a public interest;

The data subject’s right to object means that you, as a data subject, may object to the processing of your personal data for the purposes of direct marketing or based on legitimate grounds. We will cease personal data processing for direct marketing purposes immediately upon receiving an objection thereto.

h) The data subject’s right related to automated individual decision-making,which means:

The data subject’s right not to be subject to a decision based solely on automated personal data processing, including profiling, where the decision incurs legal effects or similarly significant consequences for the data subject, except for the cases under Article 22 (2) of the Regulation [i.e. except for cases where such a decision is: (a) necessary for entering into, or performance of a contract between the data subject and the Controller; (b) permitted by the laws of the European Union or the Member State to which the Controller is subjected and which lay down appropriate measures guaranteeing protection of the right, freedoms, and legitimate interests of the data subject; or (c) based on the data subject’s express consent];

The data subject’s right related to automated individual decision-making means that you, as a data subject, have the right not to be subject to a decision based solely on automated processing, including profiling, when the decision incurs legal effects or similarly significant consequences for you. Where such processing is necessary to enter into or perform a contract, or where it is based on the data subject’s express consent, the Controller shall take appropriate measures to protect the rights, freedoms, and legitimate interests of the data subject and, in particular, shall adopt the minimum measures, e.g. the Controller’s right to human intervention, the data subject’s right to submit their opinion and contest the decision.

i) the data subject’s right to file a petition to initiate proceedings under Section 100 of the Personal Data Protection Act, which means:

The right of the data subject, who believes that their personal data is subject to unauthorized processing or has been abused, to file with the Office for Personal Data Protection of the Slovak Republic (the ‘Office’) a petition to initiate personal data protection proceedings;

A petition for initiating proceedings may be filed in writing, personally in an oral form for the record; electronically, where it is to be signed with a guaranteed electronic signature; by telegraph or fax but, in such a case, it shall be also submitted in writing or orally for the record within three (3) days;

Pursuant to Section 100 (3) of the Personal Data Protection Act, the petition is to contain the following:

- Name, surname, permanent residence address, and signature of the petitioner;

- Identification of the person/entity against whom it is aimed; name or name and surname, registered office or permanent residence address, and legal form and identification number where appropriate;

- Subject-matter of the petition, namely any rights that have been violated according to the petitioner within personal data processing;

- Evidence supporting the claims stated in the petition;

- Copy of the document evidencing exercise of the right under Section 28 where the right may be exercised or specification of the grounds deserving special consideration;

Subsequently, the Office will decide on the petition within sixty (60) days from initiation of the proceedings. In well-grounded cases, the Office may reasonably extend the said period of time by six (6) months at most. The Office will inform the participants to the proceedings about any extension of the period;

A template of the petition for initiating personal data proceedings can be found on the Office’s website (https://dataprotection.gov.sk/uoou/sites/default/files/vzor_navrhu_na_zacatie_konania_podla_noveho_zakona.docx).

Personal data officer

JUDr. Jakub Pavčík

JUDr. Samuel Matejovič

Mgr. Ivan Kordík

Ing. Tomáš Dopirák

Message Us

Infoline:

E-mail:

osobnyudaj.sk, s.r.o. Námestie osloboditeľov 3/A,
040 01 Košice

Controller:

PARTNERS INVESTMENTS, o.c.p., a.s.

Address: Slávičie údolie 106 Bratislava 81102

CRN: 52413179

Certificate No.: Osobnyudaj.sk-2019-21813

Legal Grounds for Personal Data Processing

The Controller processes your personal data in compliance with Article 6 (1) (a) of the GDPR, i.e. Section 13 (1)(a) of the Act, whereby the data subject has given consent to the processing of their personal data for one or more specific purposes, 6 (1)(b), i.e. Section 13 (1) (b) of the Act, whereby processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, and under Article 6 (1) (c) of the GDPR, i.e. Section 13 (1) (c) of the Act, whereby processing is necessary for compliance with the controller’s legal obligations under special legal regulations. Special regulations mean in particular:

Act 395/2002 on archives and registers and on the amendment of certain laws;
Act 431/2002 on accounting, as amended;

Act 566/2001 on securities and investment services and on the amendment of certain laws (Securities Act), as amended;

Act 297/2008 on prevention of money laundering and terrorist financing and on the amendment of certain laws, as amended;

Act 186/2009 on financial intermediation and financial advisory services and on the amendment of certain laws, as amended;

Act 203/2011 on collective investments, as amended;

DIRECTIVE NO 2014/65/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 15 May 2014 on markets in financial instruments;

REGULATION NO 600/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 15 May 2014 on markets in financial instruments;

Act No 595/2003 on income tax, as amended;

Act 359/2015 on automatic exchange of financial account information in taxation and on the amendment of certain laws.

Personal data officer

JUDr. Jakub Pavčík

JUDr. Samuel Matejovič

Mgr. Ivan Kordík

Ing. Tomáš Dopirák

Message Us

Infoline:

E-mail:

osobnyudaj.sk, s.r.o. Námestie osloboditeľov 3/A,
040 01 Košice

Controller:

PARTNERS INVESTMENTS, o.c.p., a.s.

Address: Slávičie údolie 106 Bratislava 81102

CRN: 52413179

Certificate No.: Osobnyudaj.sk-2019-21813

Cookie Policy

In accordance with Section 55 (5) of Act 351/2011 of the National Council of the Slovak Republic on electronic communication, as amended, we would like to inform you about our use of cookies and about the possibility for you to change the settings of your internet browser if you are no longer satisfied with the current settings related to them.

What are cookies?
Cookies are small text files that can be sent to your internet browser when you visit a website and are stored on your device (your computer or other internet-enabled device, such as a smartphone or tablet). They are also stored in your internet browser’s file directory. Cookies typically contain the name of the website from which they originate and their expiry date. The next time you visit the site, the web browser reloads the cookies and sends this information back to the website that originally created them. The cookies we use do not harm your computer.

Use of Cookies
By using the pages operated by the Controller, you consent to the use of cookies in accordance with your browser settings. When you visit our website and your browser permits receipt of cookies, you make no changes in your browser’s settings and you continue viewing of our website, all of this will be deemed by us to be your acceptance of our cookie policy.

Why do we use cookies?
Cookies are used by us in order to optimally develop and constantly improve our services, adapt them to your interests and needs, to improve their structure and content, and to create offers that may interest you. The Controller does not use the data obtained through the use of cookies to contact you by mail, electronic mail or telephone.

How can cookie settings be changed?
Most internet browsers are initially configured to automatically accept cookies. You can change the settings to block cookies or to alert you when they are being sent to your device. Instructions for changing cookies can be found in the Help section of any browser. If you use various devices to access sites (such as a computer, smartphone or tablet), we recommend to customize the browser’s cookie preferences for each device.

You may set your browser so that it prohibits or block saving the cookies and third-party cookies on your device. It also enables blocking or permitting saving of cookies for specific websites only. The cookies already saved on your device may be deleted at any time. Use of cookies and having your browser permit them is up to you. If the settings are changed, some parts of our website may function to a limited extent, reducing user comfort.

Specific steps for the most frequently used browsers can be found here:

Chrome

Safari

Internet Explorer

Firefox

Android

Why to keep cookies?
Use of cookies and having your browser permit them is up to you. If the settings are changed, some parts of our website may function to a limited extent, reducing user comfort.

The Controller processes personal data and ensures their protection on the legal basis specified in Information about Personal Data Protection – an information memorandum about the processing of client personal data and personal data processing for marketing purposes, protection of assets, to guarantee security, and for other purposes, (found at www.partnersinvestments.sk,) ) and in compliance with Policy for Exercise of Data Subject Rights under the GDPR.

PI obtains data from visitors, users, and clients. Anybody visiting the Company’ website who consents to the use of cookies is considered a visitor, while a user is a anyone who registers for the Company’s available services (e.g. newsletter service) and a client is anybody for whom the Company intermediates investment and ancillary services.

Classification based on mutual interactions and collected data types:

Website visitor	User	Client	PI
Data necessary to make use of electronic services	Data necessary to make use of electronic services	Data necessary to make use of electronic services	Controller
Cookies	Cookies	Cookies	Controller
	Contact details	Contact details	Controller
		Identification data	Controller
		Economic data	Controller
		Social and demographic data	Controller

If any of the Company’s employees, or anyone pretending either to be employed by the Company or otherwise cooperating with it, contacts you for no reason, please do not reply or respond to their offers or proposals and inform us without undue delay at pravne@osobnyudaj.sk

Technical Provisions

In no case are third parties entitled to intervene in the website, modify it or remove and/or modify any part thereof. Should this provision be breached, PI is entitled to be compensated for any damage incurred.

Third parties are not entitled to ‘flood’ the website with a number of simultaneous access requests that could cause the site to no longer function. Should this provision be breached, PI is entitled to be compensated for any damage incurred.

Personal data officer

JUDr. Jakub Pavčík

JUDr. Samuel Matejovič

Mgr. Ivan Kordík

Ing. Tomáš Dopirák

Message Us

Infoline:

E-mail:

osobnyudaj.sk, s.r.o. Námestie osloboditeľov 3/A,
040 01 Košice

Controller:

PARTNERS INVESTMENTS, o.c.p., a.s.

Address: Slávičie údolie 106 Bratislava 81102

CRN: 52413179

Certificate No.: Osobnyudaj.sk-2019-21813

Privacy Policy

PARTNERS INVESTMENTS, o.c.p., a.s., Slávičie údolie 106, 811 02 Bratislava, Slovak Republic, CRN: 52 413 179, incorporated in the Business Register of the Bratislava I District Court, Section: Sa, Insert No. 6941/B (hereinafter only ‘Controller’ or ‘Company’) processes your personal data for the purposes and on the legal basis specified below in this Information Memorandum. It also contains more detailed information about the processing of your personal data and the rights you have as a data subject under Act 18/2018 on protection of personal data protection and on the amendment of certain laws, as amended (“Personal Data Protection Act”) and Regulation No 2016/679 (EU) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”).

The Company is the Controller of your personal data, thereby determining the purposes and means for processing of your personal data.

(1) Company contact details

Business name: PARTNERS INVESTMENTS, o.c.p., a.s.

Address: Slávičie údolie 106, 811 02 Bratislava, Slovak Republic

Relationship between the Controller and PARTNERS GROUP SK s.r.o.

As the Controller, our clients are provided by us with financial intermediation in the capital market sector, i.e.:

Provision of an investment service, whereas the Client’s orders concerning transferable securities and units, mutual funds and securities of foreign collective investment entities are accepted, forwarded and promoted; and
Provision of an investment advisory service in relation to transferable securities and units of mutual funds and securities issued by foreign collective investment entities.

These specified services are provided to our clients in compliance with Section 2 (2) of Act 186/2009 on financial intermediation and financial advisory services and on the amendment of certain laws, as amended (“Financial Intermediation Act”).

For these purposes, the Controller makes use of an intermediator - an independent financial agent – PARTNERS GROUP SK s.r.o., Slávičie údolie 106, 811 02 Bratislava, CRN: 36 750 701, incorporated in the Business Register of the Bratislava I District Court, Section: Sro, Insert No. 44999/B (“IFA”)

The IFA carries out the following activities in respect of the Controller’s clients:

Submits offers for entering into financial services contracts, enters into such contracts, and takes other steps leading to entering into financial services contracts or amendments thereto;
Provides Clients with professional assistance, information, and recommendations for the purposes of entering into, amending, or terminating financial services contracts;
Cooperates in administering financial services contracts where the nature of any given financial services allows such cooperation;
Cooperates in settling claims and in performance for Clients pursuant to financial services contracts, in particular, in connection with circumstances decisive for the rise of such claims where the nature of the given financial services allows such cooperation,
Provides an investment consultancy service in respect of the securities and services provided to Clients by the Controller.

Relationship between the Controller and subordinated financial agents of PARTNERS GROUP SK s.r.o.

PARTNERS GROUP SK s.r.o. and the IFA cooperate with subordinated financial agents (“SFAs”) who act in their relationship with PARTNERS GROUP SK s.r.o. as intermediaries and in their relationship with the Controller as sub-intermediaries.

The IFA has imposed on SFAs the same personal data protection obligations as those binding upon the IFA, which have bound SFAs to professional confidentiality in compliance with Section 79 of the Act. The duty of confidentiality shall also survive the termination of personal data processing by sub-intermediaries, i.e. SFAs.

(2) What personal data is processed by us

Regular personal data: Acting as the Controller, the Company processes the following personal data you provide to us when you fill in the account application, the forms on the Company’s website, www.....sk, or through other means. Such data, in particular, includes:
- Identification data (name, surname, title, date of birth, birth number, other data from the identity documents, nationality, client number, product number);
- Contact data (permanent or temporary residence address, e-mail address, telephone number);
- Social and demographic data (age, sex, marital status, education, income-related information, current and former occupations, information about a politically exposed person, risk profile);
- Economic data (information about ownership of movable and immovable property, debts, and investment assets);
- Transaction data (information about account transactions, beneficiaries and senders);
- Data necessary for use of electronic services (IP address, software, browser, and device related information and cookies);
- Video and audio recordings (especially recordings made by camera systems);
- Other relevant data (information about enforcement of a judgment or ruling, bankruptcy proceedings, personal bankruptcy, data related to fulfilment of your contractual obligations and commitments and about your payment behavior).
Special categories of personal data: Acting as the Controller, the Company processes no sensitive data, which specifically means data about racial or ethnic origin, political affiliation, religious or philosophical beliefs or trade union membership, or data concerning health or sexual life or orientation. If there is a requirement to process your personal data falling under a special category, your express consent will either be requested by us or the personal data will be processed by us on other, relevant legal grounds.

Contracts concluded electronically with an electronic biometric signature: Based on an agreement between the Controller and the Client, a contract may be concluded by electronic means capable of capturing the content of such acts, in particular by capturing the speed, pressure, rhythm, stroke, acceleration, tempo and inclination of the signatures of both PI and the Client (BioSign digital handwritten signature), whereas such a handwritten signature shall be considered to have been written in accordance with Section 40 (4) of Act 40/1964 of the Civil Code, as amended. If you decide to conclude a contract with us, the legal basis for such processing is your consent, in compliance with Article 6 (1) (a) of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), to the Controller’s processing of your biometric data within the scope of a dynamic biometric signature, i.e. dynamic parameters of hand movement such as speed, pressure, rhythm, stroke, acceleration, tempo and inclination, in order to conclude the contract.

(3) The purposes of personal data processing (why we have your personal data) and the legal basis for its processing (based on which we have your personal data)

Personal data related to a specific purpose: In providing our services, your personal data is always processed by us for a specific purposed, determined in advance, where each processing purpose requires only some of your personal data. Unless we receive the relevant personal data necessary for any given purpose, our Company will either not be able to provide you with the relevant service, or will only be able to provide it to a very limited extent which, in the end, does not have to be acceptable for you. We are obliged to process some of your personal data based on special regulations applicable to our Company, in connection with the nature of the services the Company provides, in particular, in compliance with the following legal regulations:

- Act 566/2001 on securities and investment services and on the amendment of certain laws (Securities Act), as amended;
- Act 297/2008 on prevention of money laundering and terrorist financing and on the amendment of certain laws, as amended;
- Act 186/2009 on financial intermediation and financial advisory services and on the amendment of certain laws, as amended;
- Act 203/2011 on collective investments, as amended;
- DIRECTIVE NO 2014/65/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 15 May 2014 on markets in financial instruments;

- REGULATION NO 600/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 15 May 2014 on markets in financial instruments;
- Act 595/2003 on income tax, as amended;
- Act 359/2015 on automatic exchange of financial account information in taxation and on the amendment of certain laws.

Processing purposes and relevant legal basis: Your personal data is processed for the following purposes and on at least one of the following legal bases:

Processing purpose:	Legal basis for processing:
Provision of services to clients of the Company – processing of the personal data concerning the former, current and potential clients for the purposes of provision of the financial services that constitute the main activities of the Company	Personal data processing for the purposes of fulfilment of contracts and within pre-contractual measures
Marketing purposes – mainly the sending of newsletters, client satisfaction surveys, offers concerning products and services the Company offers and the products and services of the Group’s companies and partners	Consent to personal data processing Legitimate interest
Accounting purposes – processing of personal data of the Company’s business partners and subcontractors who are natural persons, including their contact data, for the purposes of contractual and business relationships	Personal data processing for the purposes of fulfilment of contracts and within pre-contractual measures
Legal claims – processing of personal data for the purposes of enforcing the Company’s legal claims in court, out-of-court, arbitration, administration, enforcement, bankruptcy, and restructuring	Personal data processing on the basis of legitimate interests
Identification and contact details – basic contact details of representatives of legal entities and other natural persons, which we obtain from publicly available sources intended for that purpose, from such persons personally, and from other persons	Personal data processing on the basis of legitimate interests
Protection of property and security – processing of personal data concerning clients and other data subjects by camera systems for the purposes of protection of the Company’s assets and to provide security for the Company and data subjects within the Company’s indoor and outdoor premises	Legitimate interest
Black list – processing the personal data of legal entities and other natural persons with whom the Company will no longer conclude a contract	Legitimate interest
Contracts concluded electronically with an electronic biometric signature	Consent to personal data processing

Personal data processing on the basis of legitimate interests: The GDPR permits the Company, acting as the Controller, to process personal data on a legal basis even without consent for personal data processing having been granted to the Company, or to process personal data under a special law, e.g. for performance of a contract or fulfilment of an obligation. Article 6 (1) (f) of the GDPR entitles the Company to process personal data on the basis of a legitimate interest.

Specific purposes for data processing on the basis of legitimate interests: You may object to the processing of personal data on the basis of a legitimate interest in compliance with Article 6 (1) (f) of the GDPR. Details concerning this right are provided in clause 1.6 below. If you exercise the right to object to specific processing, the Company must no longer process the personal data unless it proves that either it has a necessary and legitimate interest to process the data overriding your interests, rights, and freedoms or unless the Company demonstrates that such processing is necessary in order to prove, assert, or defend legal claims. If you object to your personal data processing on the basis of a legitimate interest, specifically for direct marketing purposes, the Company will refrain from further processing of your personal data for that purpose.

Legitimate interest - marketing purposes: The Company has a legitimate interest in processing your personal data (in particular, title, name, surname, residence address and e-mail address) for marketing purposes (sending of newsletters, client satisfaction surveys, sending of offers concerning the Company’s products and services and those of the Group’s companies and partners) because the promotion of the Company’s products and services targeted at our former and current clients supports its development and growth and, in addition, the feedback obtained through communication with both our former and current clients enables the Company to identify opportunities for improvement of our products and services and to remove deficiencies, if any. The Company is predominantly interested in providing its clients with the best, top-quality services and products; therefore, a legitimate interest for using the basic contact details of our former and current clients is to send them information about our services and products and to obtain continuous feedback from communicating with them. Practically, this is almost an inevitable precondition for the Company to function and develop itself as, in these modern times, each company active in the market is making every effort to maintain regular contacts with its clients.

Legitimate interest in monitoring with camera systems: The Company has a legitimate interest in using camera systems to monitor both its indoor and outdoor premises within which the Company operates and provides its services. This activity is important in order to secure protection of the Company’s assets and operations, to maintain public order, and to ensure safety of our clients and other natural persons. The video recordings also serve to detect criminal activities, find perpetrators and, in particular, in order to prevent money laundering and terrorist financing, and to detect unlawful financial transactions in connection with court, criminal and misdemeanor proceedings.

Personal data recipients and their categories

Recipients of the personal data: Your personal data may be disclosed to the following recipients:
- Auditors and tax advisors providing the Company with audit services and advice;
- Banks and their branches whenever clients request the services they provide (mainly loans, credits, leases) in connection with the provision of our Company’s services and products;
- Persons cooperating with the Company and agents not employed by it who secure the Company’s operations and provision of its services and/or provide client intermediation services to the Company along with full-scale advice and service to our clients (bound financial agents and independent financial agents);
- Central Securities Depository whenever it is necessary to register for instance;
- Other securities dealers as requested by clients or where the nature of the services and products the Company provides to clients necessitates it;
- Burza cenných papierov v Bratislave, a.s., Vysoká 17, 811 06 Bratislava, CRN: 00 604 054;
- IT service providers who provide the Company with IT services and infrastructure, including the website.

State authorities and other third parties: Your personal data may also be disclosed to any competent law enforcement body, prosecutor’s office, court, regulator, supervisory authority, control body, government agency, bailiff, official receiver, municipal authority, town authority, higher territorial unit authority, ministry, the National Security Authority, the Supreme Audit Office, the Office for Personal Data Protection of the Slovak Republic, the Financial Directorate of the Slovak Republic, and/or another recipient where the Company believes that the disclosure of personal data:
- complies with a generally binding legal regulation, Personal Data Protection Act, or the GDPR; or
- is necessary for the purposes of enforcement, rise or defense of a legal right/claim of the Company; or
- is necessary for protection of the Company’s important interests or those of any other person.

Disclosure of personal data as instructed by the data subject: Your personal data may be disclosed by us to other recipients were you to give consent or instruct the Company to disclose them.

Personal data retention periods

Your personal data will be retained by us only for the period of time necessary to achieve the purpose for which the Company processes your personal data unless a generally binding legal regulation permits or requires us to retain the said personal data for a longer period of time.
Your personal data items are retained for the following terms:

Purpose:	Retention period:
Provision of services to the Company’s clients	For the term of the contract and then for ten years following the year of termination/fulfilment of the contract (in compliance with Act 431/2002 on accounting, as amended, Act 566/2001 on securities and investment services, and Act 186/2009 on financial intermediation and advice). Should any court proceedings be initiated against you as a debtor, the Company will process your personal data for the duration thereof.
Marketing Purposes	For the duration of consent (three years) or until it has been withdrawn Where personal data is processed on the basis of a legitimate interest, your data will be retained for the period of time necessary to achieve the purpose of processing it, but no longer than for five (5) years
Accounting purposes	For the term of the contract and then for ten years following the year of termination/fulfilment of the contract (in compliance with Act No 431/2002 on accounting, as amended). Should any court proceedings be initiated against you as a debtor, the Company will process your personal data for the duration thereof.
Enforcement of legal claims	The period of time necessary to enforce the Company’s rights and claims, which will neither be shorter than the limitation period under the Civil Code or the Commercial Code, nor will exceed ten (10) years. Should court or administrative proceedings be initiated, the Company will process your personal data during the period thereof.
Identification and contact details	The period of time necessary to contact specified persons but no longer than five (5) years from when the data has been obtained
Protection of assets and security	33 days
Black list	Five (5) years from obtaining the data

Transfer of personal data to third countries

The Company does not transfer your personal data to any third country.

Rights you have as a data subject in connection with processing of your personal data

Individual rights of data subjects: The Company has certain rights and obligations in protecting personal data and you likewise have certain rights in respect of protection of your personal data. These are the following:

Right of access: You have the right to obtain from the Company a confirmation stating whether the Company processes your personal data, what personal data it processes, the purposes for which it processes your personal data, the retention period, how the Company has collected your personal data, where it transfers the personal data, whether any automated decision-making and/or profiling are applied within processing of your personal data, and what other rights you have in connection with processing of your personal data. Although all that information is contained in this Information Memorandum, if you think that you lack some information about whether and which of your personal data is processed by the Company and how it is processed, you have the right of access thereto. Right of access means that you may ask the Company to provide a copy of the personal data to be processed. The first copy will be provided by the Company at no charge, while further copies are subject to a fee.

Right to rectification: If you discover that the Company is processing your personal data that is inaccurate, incorrect, or incomplete, you have the right to ask the Company to rectify or supplement your personal data.

Right to erasure (“right to be forgotten”): You have the right in the following cases to request erasure without undue delay of your personal data processed by the Company:

- Your personal data is no longer required for the purposes for which the Company has obtained or otherwise processed it; or
- You have withdrawn your consent to the processing of your personal data where your consent was required and the Company has no other reason or other legal basis to process it (for instance, enforcing the Company’s rights and claims); or
- You exercise your right to object to the processing of your personal data (more details about this right are provided in clause 1.6 below) that the Company processes on the basis of a legitimate interest and the Company establishes that it no longer has any legitimate interests entitling it to continue processing of your personal data
- The Company processes your personal data unlawfully; or
- Compliance with a legal obligation under a generally binding legal regulation applicable to the Company; or
- Personal data has been obtained in connection with an information company’s offer of services addressed directly to a child.

We would like to draw your attention to the fact that, in any of the above cases, the Company is not obliged to erase your personal data (personal data concerning you) where the processing is necessary:

- To exercise of the right to freedom of expression and information; or
- To comply with the Company’s legal obligation under a generally binding legal regulation; or
- For archiving, scientific, historical, or statistical purposes; or
- To establish, assert, or defend legal claims of the Company.

Right to restriction of processing: In addition to the right to erasure, you also have the right to restrict the processing of your personal data in certain cases. In specific cases, you may request the marking of your personal data and for it not to be subject to any other processing for a certain period of time. The Company is obliged to restrict the processing of your personal data in the following cases:

- Were you to contest the accuracy thereof at a time enabling the Controller to verify the accuracy of personal data; or
- Where the processing of your personal data is unlawful and you object to erasure thereof data and instead request restricting of its use; or
- If the Company no longer needs your personal data for processing purposes, but you need the data to prove, assert, or defend your legal claims; or
- You exercise your right to object to the processing of your personal data (more details about this rights can be found in clause 1.6 below) until such time when it has been established whether the Company’s legitimate interests override your legitimate grounds.

Where processing of your personal data has been restricted based on the right to restriction, such personal data, except for retention, may be processed by the Company only either subject to your consent or to establish, assert, or defend the Company’s legal claims; or to protect the rights of another natural or legal person; or due to an important public interest of a Member State of the European Union or a state that is a party to the European Economic Area Agreement.

Right to portability: You have the right to obtain all your personal data you have provided to the Company, where the Company has been processing such data based on the consent to personal data processing or in order to perform a contract. This provision applies solely to the personal data processed by the Company using automated means (electronically). You will be provided with your personal data in a structured, commonly used, and machine-readable format, with the right to transfer the personal data directly to another controller where it is technically feasible.

Right to object: You have the right to object to the processing of your personal data carried out on the basis of a public interest or legitimate interest and you may also object to profiling based on a legitimate interest. The Company will discontinue processing of your personal data unless it proves that it has necessary and legitimate interest for such processing which override your interests, rights and freedoms or unless the Company demonstrates that it is necessary in order to prove, assert or defend its legal claims.

Where the Company processes your personal data for direct marketing purposes, you have the right to object at any time to the processing of the personal data for such marketing, which includes profiling to the extent that it is related to direct marketing. If you object to processing of your personal data for the purposes of direct marketing, the Company will discontinue it for those purposes.

How to exercise your rights: You may exercise any of the above specified rights using the Company’s contact details specified in clause 1 above.

Right to file a complaint with the Office: In addition to exercising the above specified rights, you may also file a complaint with the Office for Personal Data Protection regarding the Company’s processing of your personal data. The address of the Office for Personal Data Protection (Úrad na ochranu osobných údajov SR) is Hraničná 12, 820 07 Bratislava, Slovak Republic. Further data can be found at: https://dataprotection.gov.sk/

Notice of a breach of personal data: Should there be a breach of your personal data, which is likely to result in a great risk to your rights and freedoms, the Company shall inform you about it without undue delay.

The right to withdraw consent to personal data processing

Where you have given the Company your consent to the processing of some of your personal data (the legal basis for the Company’s processing of some personal data is consent or express consent), you may withdraw it at any time by making use of the Company’s contact details specified in clause 1 above. The withdrawal of your consent will not affect the lawfulness of the processing of your data based on the consent carried out prior to the consent withdrawal.

Amendments to the Information Memorandum

This Memorandum providing information about personal data protection may be amended as necessary to respond to any legal, technical, or business-related changes. Appropriate measures will be taken by us to inform you of about any updating of this Information Memorandum regarding personal data protection, depending on whatever changes have been made by us.

Personal data officer

JUDr. Jakub Pavčík

JUDr. Samuel Matejovič

Mgr. Ivan Kordík

Ing. Tomáš Dopirák