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INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA
We aim to provide investment services of the highest quality, with an emphasis on capital protection and achieving above-standard returns.
Introduction
We would like to inform you clearly and transparently about how we process your personal data and what rights you have in this connection, therefore we provide you with all essential information in a clear manner below. We process and protect your personal data in full compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons in connection with the processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/EC (general regulation on the protection of personal data - hereinafter also referred to as the " GDPR Regulation ") and the Czech Act on the Processing of Personal Data.
When processing your personal data, we adhere to the following basic principles:
We process your personal data correctly and in a legal and transparent manner
We collect your personal data for specific, explicitly stated and legitimate purposes and do not further process them in a way that is incompatible with these purposes
we only process your personal data that is reasonable, relevant and limited to the necessary scope in relation to the purpose for which it is processed
we only process your accurate (and, if necessary, updated) personal data
We only process your personal data for as long as is necessary for the purpose for which they are processed
We process your personal data in a way that ensures their proper security, including their protection by means of appropriate technical or organizational measures against unauthorized or unlawful processing and against accidental loss, destruction or damage
ADMINISTRATOR / PROCESSOR OF YOUR PERSONAL DATA
The administrator of your personal data is the company IMPERIUM FINANCE s.r.o., with registered office at Strakonická 3363/2d, Hlubočepy, Prague 5 150 00, ID: 24848808, registered in the commercial register kept at the Municipal Court in Prague, section C, file 180093 (hereinafter referred to as the " Administrator " or "Company"). The Administrator is responsible for the processing of your personal data and you can invoke most of your rights listed in point 9 below against the Administrator.
The administrator has not appointed a personal data protection officer, but has appointed a person who is in charge of this area and who supervises the proper processing of your personal data.
In case of any questions regarding the processing of your personal data or in case of exercising your rights, you can contact the Administrator in one of the following ways:
in person at the Administrator's headquarters at Strakonická 3363/2d, Hlubočepy, Prague 5 150 00
by letter delivered to the registered office of the Administrator at Strakonická 1199/2d, Hlubočepy, Prague 5 150 00
by email sent to the email address lucie.vondryskova@imperium-finance.cz
by phone at +420 257 218 649
by a message delivered to the Administrator mailbox with the mailbox identifier d9j226v
In certain cases, the Company is only a processor of your personal data. These are cases where the personal data controller (i.e. the entity that determined the purpose and means of processing your personal data) is another company (e.g. another financial institution) that has entrusted the Company with the processing of your personal data (or only a certain processing operation). In such a case, the Company processes your personal data according to the instructions of the personal data administrator and is not responsible for the processing of your personal data. This responsibility is always borne by the personal data controller. The company, as a personal data processor, of course complies with the GDPR Regulation and the above-mentioned principles, however, the answers to the questions below (headings of points 3. to 9.) should in this case be provided by the given personal data administrator, and in relation to this personal data administrator, it is necessary, if necessary exercise the rights set forth in point 9 below.
The following points therefore apply to situations where the Company is the administrator of your personal data.
WHAT PERSONAL DATA DO WE PROCESS AND FROM WHOM PERSONS?
We process only such personal data as we absolutely need to be able to comply with our legal obligations, properly fulfill our contractual obligations and protect our legitimate interests. For these reasons, we process the personal data of the following persons:
our natural person customers, including potential customers and their representatives
employees and representatives of our legal entity customers, including potential ones
the beneficial owners of our legal entity customers
our natural person suppliers, or their employees
employees and representatives of our legal entity suppliers
employees and representatives of financial institutions cooperating with us (e.g. securities dealers, investment companies)
our physical sales representatives (e.g. bonded representatives), including potential ones, or their employees
employees and representatives of our business representatives of legal entities, including potential ones
our tipsters including potential ones
members of our bodies, including potential ones
Regardless of whether you belong to any of the groups of people listed above, we always process your personal data only to the extent that we absolutely need it for the given purpose of processing. In most cases, this is only your address and identification data and contact data. In the case of customers, this also includes other data, the acquisition and collection of which is imposed on us by the relevant legal regulations or which we obtain in connection with the provision of services. The same applies to the personal data of sales representatives, tipsters and members of our bodies. In exceptional cases, we also process your photos.
FOR WHAT PURPOSES DO WE NEED YOUR PERSONAL DATA?
We determine the purposes of the processing of your personal data in particular due to the nature of the contractual or other relationship with you or due to the services provided.
The purpose of processing the personal data of customers is, in particular:
creating a database of our potential customers
our promotion (presentation)
and direct marketing
provision of financial services
fulfilling our obligations related to the fight against the legalization of the proceeds of crime and the financing of terrorism
enabling the customer to draw additional services
evaluation of whether or not the customer can be provided with another service
the involvement of an external entity in our control activities
In the case of suppliers and employees of cooperating financial institutions, the purpose of processing Personal Data is mainly the processing of communication and invoicing.
We process the personal data of our sales representatives and tipsters for the purpose of:
fulfilling our obligations as a representative to our sales representatives and tipsters
our promotion (presentation)
fulfillment of our obligations towards the cooperating financial institution
the involvement of an external entity in our control activities
We also process personal data for the purpose of selecting the most suitable candidate, or creating a database of unsuccessful candidates and contacting them with an offer in the future
We process the personal data of the members of our bodies for the purpose of fulfilling our obligations as a corporation and registration in the commercial register, for the purpose of involving an external entity in our control activities, for the purpose of fulfilling our obligations towards a cooperating financial institution.
We may also process your Personal Data for the purpose of:
fulfilling the archiving obligation
checking compliance with legal regulations in our activities
defense in disputes with you or the exercise of legal claims against you
ON WHAT LEGAL REASON DO WE PROCESS YOUR PERSONAL DATA?
We always process your personal data on the basis of at least one legal reason (title). If this were not the case, we would not act in accordance with the principle of legality as one of the most important principles of the GDPR Regulation.
The processing of your personal data takes place on the basis of the following legal titles:
fulfillment of a legal obligation that applies to us - in the case of processing personal data of our customers and their representatives, real owners of our customers, sales representatives and their employees, tipsters, members of our bodies and some suppliers and their employees - this is, for example, the following legislation:
Act No. 262/2006 Coll., Labor Code,
Act No. 582/1991 Coll., on the organization and implementation of social security
Act No. 48/1997 Coll., on public health insurance,
Act No. 586/1992 Coll., on income taxes,
Act No. 187/2006 Coll., on sickness insurance,
Act No. 253/2008 Coll., on certain measures against the legalization of proceeds from criminal activity and the financing of terrorism,
Act No. 89/2012 Coll., Civil Code,
Act No. 90/2012 Coll., on Business Companies and Cooperatives (Act on Business Corporations),
Act No. 304/2013 Coll., on public registers of legal entities and natural persons and on the registration of trust funds,
Act No. 563/1991 Coll., on accounting,
by Act No. 256/2004 Coll., on doing business on the capital market, as amended, on implementing regulations for these laws
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fulfillment of the contract concluded with you (your employer) - in the case of processing personal data of our customers, sales representatives, tipsters, members of our bodies, our suppliers and employees of cooperating financial institutions.
granting your consent to the processing of personal data
if you apply for a job with us or for cooperation with us and we would like to keep your personal data even after the end of the selection process,
if we would like to use your photos for our promotion or promotion of our event.
the existence of our legitimate interest - we rely on this legal reason for the processing of your personal data only in cases where your interests or basic rights and freedoms requiring the protection of personal data do not take precedence over our interests - this is the case, for example:
on the processing of personal data of potential sales representatives or tipsters for the purposes of the selection process,
about the processing of your personal data for the purpose of involving an external entity in our control activity,
about the processing of personal data of our sales representatives, members of our bodies, for the purpose of fulfilling our obligations towards a cooperating financial institution,
on the processing of personal data of customers and potential customers for the purpose of creating a database,
about offering services (direct marketing),
about the processing of your personal data for the purpose of possible defense in disputes with you or the exercise of legal claims against you.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We store your personal data only for the time necessary for the purpose of processing. In the event that we are required by law to process your personal data, it also determines the period for which we are to do so. If we process your personal data in order to be able to fulfill the contract concluded with you, it is necessary to process your personal data for the entire period of validity of the given contract. We store personal data processed on the basis of your consent for the period for which consent was granted and, of course, only until the consent is revoked. In the event that the processing of your personal data is necessary for the purposes of our legitimate interest, we only process it for the duration of our legitimate interest.
WHO DO WE OBTAIN YOUR PERSONAL DATA FROM?
We primarily obtain your personal data directly from you or in connection with a mutual contractual relationship. You are thus in control of which personal data you provide to us and which you do not. However, some of your personal data is needed in order to be able to comply with the relevant legal regulation or to be able to enter into a contract with you. We will always notify you of the personal data you are required to provide us and the consequences of not providing this data. We can also obtain some of your personal data from public sources, e.g. from one of the public registers. In certain cases, we also obtain your personal data from other administrators, but we are obliged to inform you about this.
WHO DO WE PROVIDE YOUR PERSONAL DATA TO?
Your personal data is available to sales representatives who need it for their work. Your personal data is transferred outside our company only in necessary cases, especially in the following cases:
the transfer of your personal data is required by law (this mainly concerns the transfer of your personal data to state bodies or authorities)
the transfer of your personal data is necessary to fulfill our obligation stipulated in the contract concluded with you (e.g. transfer of your personal data to our sales representative or cooperating financial institution)
We transfer your personal data to our processor – this transfer takes place in situations where we are unable to perform a certain activity, during which your personal data is processed, ourselves (or it is disadvantageous for us) and we have entrusted its performance to another person; this person is our processor from the point of view of the GDPR Regulation; we have verified that it provides sufficient guarantees for the implementation of appropriate technical and organizational measures so that its processing of your personal data meets the requirements of the GDPR Regulation and that your rights are protected; a written contract on the processing of personal data is always concluded with this processor, which specifies the subject and duration of the processing, the nature and purpose of the processing, the type of personal data and the category of data subjects, our obligations and rights; this processor also has certain obligations set directly by the GDPR Regulation; However, we (not the processor) are always responsible for the processing of your personal data.
We never transfer your personal data to a third country (i.e. outside the European Union or the European Economic Area) or to international organizations.
WHAT RIGHTS DO YOU HAVE REGARDING THE PROCESSING OF YOUR PERSONAL DATA?
In connection with the processing of your personal data, you have a number of rights, which are explained in detail below. At the outset, however, it is necessary to provide some general information related to the exercise of your rights. We have an obligation to make it easier for you to exercise your rights, therefore it is possible to contact us in this context in various ways (in person, by letter, by email, by phone, via data box). Contact details for all of these methods can be found in point 2 above. As it is our duty to verify your identity when reviewing your application, some methods of exercising your rights are more appropriate than others. The ideal ways to exercise your rights, which will save time for you and us, are as follows:
sending a letter to the address of our headquarters
sending an email to our email address
sending a data message to our data mailbox
in person at a prearranged meeting
In order for us to be able to process your request quickly and properly, it is necessary that the following clearly follows from the request:
who submits the application (applicant's first and last name, date of birth and address)
which right of request you exercise (just describe in words, or by referring to the relevant article of the GDPR Regulation)
what you are requesting with the request and possibly why (explained in more detail below for individual rights)
how do you wish to send a reply (by letter, email, telephone, to mailbox)
Your contact details (phone, email) for our possible additional questions
Our obligation is to process your requests free of charge, however, if your requests are clearly unreasonable or unreasonable, especially because they are repeated, we have the right to demand from you the payment of a reasonable fee taking into account the administrative costs associated with providing the requested information or communication or taking the requested actions, or we have the right to refuse to comply with your request. We will always respond to your request within one month of receiving it at the latest.
And now to individual rights.
Right of access to personal data
You have the right to ask us for confirmation as to whether we are processing your personal data and to obtain an overview of this data from us. You also have the right to receive the following information from us in connection with the processing of your personal data:
purposes of processing your personal data
category of your affected personal data
recipients or categories of recipients to whom your personal data has been or will be made available
the planned storage time of your personal data
the existence of the right to request from us the correction or deletion of your personal data, the right to limit their processing or the right to object to their processing
the right to file a complaint with the supervisory authority
all available information about the source of personal data, if we did not obtain your personal data directly from you
In the event that this is not clear from your request, we may ask you to specify exactly which of your personal data your request relates to.
If you also want a copy of your personal data that we process, you have the right to do so and the first such provision is free of charge. For additional copies, we may request a reasonable payment not exceeding the costs necessary to provide the information. The exercise of this right must not adversely affect the rights and freedoms of other persons.
The right to correct personal data
You have the right to ask us to correct your personal data that we process and which are incorrect or inaccurate. Just let us know what data and how to correct it. We will do so without undue delay.
You also have the right to request that we complete your personal data that we process and that are incomplete according to your instructions. We will fulfill this wish of yours if we really need the supplemented personal data for the purposes of the given processing.
In the event that you ask us to do so as part of the exercise of this right, we will also inform you of the recipients of your personal data, through whom your personal data was made available in the past and to whom we notified you of the corrections or additions to your personal data.
Right to erasure ("right to be forgotten")
You have the right to request us to delete your personal data in the following cases:
you are of the opinion that we no longer need your personal data for the purposes for which we collected or otherwise processed them
you have withdrawn your consent to the processing of personal data, on the basis of which we processed your personal data, and you are of the opinion that we no longer have any other legal reason for processing them
you have objected to us processing your personal data on the basis of our legitimate interests and you are of the opinion that we no longer have any overriding legitimate reasons for processing them
you have objected to us processing personal data for the purpose of direct marketing
you are of the opinion that we are processing your personal data illegally
you are of the opinion that we are subject to the obligation to delete your personal data established by the law of the European Union or the law of a member state of the European Union
you are a child under the specified age and your personal data was collected with your consent in connection with the offer of information society services
When exercising this right, it is necessary for you to indicate in your request on the basis of which of the above-mentioned cases you require the deletion of your personal data and also what exact personal data you require to be deleted. Your request should also be properly justified, otherwise it cannot be granted
In the event that we find your request reasonable and the processing of your personal data will not be necessary:
for the exercise of the right to freedom of expression and information,
for the fulfillment of a legal obligation that requires processing under the law of the European Union or a member state of the European Union that applies to us, or for the fulfillment of a task carried out in the public interest or in the exercise of public authority with which we are entrusted,
for reasons of public interest in the field of public health
for the purposes of archiving in the public interest, for the purposes of scientific or historical research or for statistical purposes, if it is likely that the right to erasure would make it impossible or seriously jeopardize the fulfillment of the goals of the said processing,
for the determination, exercise or defense of legal claims,
so we will delete the personal data requested by you without unnecessary delay.
In the event that we have published your personal data and subsequently deleted them within the scope of your right to erasure, we are also obliged, taking into account the available technology and implementation costs, including technical measures, to ensure that the administrators who process your personal data are informed that you also require them to delete all references to your personal data, their copies or replications.
In the event that you ask us to do so as part of the exercise of this right, we will also inform you about the recipients of your personal data, to whom your personal data was made available in the past and to whom we notified the deletion of your personal data requested by you.
Right to restriction of processing
Restricting the processing of personal data means marking them and ending all their processing, with the exception of storage. In other words, personal data whose processing is restricted is still retained by the administrator (ie cannot be deleted), but is not authorized to use such personal data in any way.
You have the right to request us to limit the processing of your personal data in the following cases:
you deny the accuracy of your personal data
you are of the opinion that we are processing your personal data unlawfully, but instead of deleting your personal data, you only request a restriction of their use
we no longer need your personal data for processing purposes (we should therefore delete them), but you require them to determine, exercise or defend legal claims
you have raised an objection to us against the processing of your personal data based on our legitimate interests, which has not yet been decided by us.
When exercising this right, it is necessary for you to indicate in your request, on the basis of which of the above cases you request the restriction of the processing of your personal data, as well as the processing of exactly which of your personal data you request to be restricted. Your request should also be properly justified, otherwise it cannot be granted.
If we find your request reasonable, we will limit the processing of your requested personal data without undue delay. During the duration of this restriction, we are authorized to process your personal data only with your consent, or for the purpose of determining, exercising or defending legal claims, for the purpose of protecting the rights of another natural person or legal entity, or for the purpose of important public interest of the European Union or a member state of the European Union union.
If the reasons for restricting the processing of your personal data no longer exist, we will notify you of this and then cancel the processing restriction.
In the event that you ask us to do so as part of the exercise of this right, we will also inform you of the recipients of your personal data to whom your personal data was made available in the past and to whom we notified you of the requested restriction of processing of your personal data.
Right to data portability
In the event that we process your personal data on the basis of your consent or on the basis of a contract concluded with you, and we carry out this processing automatically (i.e. not manually), you have the right to demand that we transfer (or allow downloading) your personal data to you , which you have provided to us yourself, in a structured, commonly used and machine-readable format, or to request that we provide this personal data directly to another administrator. We will comply with your wish to transfer your personal data directly to another administrator only if this is technically possible. When exercising this right, it is necessary for you to indicate in your request which of your personal data this request relates to, and whether you wish us to transfer the given personal data only to you or directly to another administrator and how we should do this. Without this information, your request cannot be granted. The exercise of this right must not adversely affect the rights and freedoms of other persons. If this were to happen, we would have to reject your request or not comply with it completely.
The right to object
If we process your personal data on the basis of our legitimate interest, you have the right to object at any time and demand that we no longer process your personal data in this way. In your request, it must be clearly stated which of your personal data the objection relates to and against which processing the objection is raised. Your request should also be adequately justified. After receiving your request, it is our duty not to process your personal data further, or to prove to you that there are serious legitimate reasons for this processing that outweigh your interests or rights and freedoms, or that the processing of your personal data is necessary for the determination, performance or defense legal claims. If we process your personal data for the purposes of direct marketing, you have the right to object at any time and demand that we no longer process your personal data in this way. Your request must clearly state that you object to processing for direct marketing purposes and to which of your personal data it relates. After receiving your request, it is our duty not to process your personal data for direct marketing purposes.
Other rights
You have the right not to be subject to any decision based solely on automated processing, including profiling, which would have legal effects for you or would similarly significantly affect you, except where this decision would
was necessary to conclude or fulfill the contract concluded with you
has been permitted by the law of the European Union or a member state of the European Union which applies to us and which also provides for appropriate measures ensuring the protection of your rights and freedoms and legitimate interests
was based on your express consent
If we process your personal data based on your consent to the processing of personal data, you have the right to revoke this consent at any time. However, revocation of consent does not affect the legality of processing based on consent that was given before its revocation. In the event that you believe that the processing of your personal data has resulted in a violation of the GDPR Regulation, you have the right to file a complaint with a supervisory authority, especially in the state of your habitual residence, place of employment or the place where the alleged violation occurred. This supervisory authority for the Czech Republic is the Office for the Protection of Personal Data, with headquarters in Pplk. Sochora 27, 170 00 Prague 7, Czech Republic, ID: 708 37 627, www.uoou.cz.
CONCLUSION
We firmly believe that the above information is understandable for you. If you still do not understand something, or if you are not sure about something, do not hesitate to contact us with a question. This will avoid many misunderstandings.
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