PERSONAL DATA PROCESSING POLICY

 

  1. Introduction

At CB SICAV, a.s., acting on behalf of CB Property Investors Subfund, ID No.: 09588167, with registered office at Jindřišská 939/20, Nové Město, 110 00 Prague 1, registered in the Commercial Register maintained by the Municipal Court in Prague, Section B, Insert 25739 (hereinafter referred to as “CB SICAV” or the Fund), we take privacy protection very seriously and pay maximum attention to it.

In this document, the CB SICAV sets out the principles for the processing of personal data within the CB SICAV.

If you have any questions regarding the processing of your personal data, you can contact CB SICAV, a.s., with registered office at Jindřišská 939/20, Nové Město, 110 00 Prague 1, by e-mail at zuzana.olsen@cbpi.eu or by phone at +420 608 955 705.

 

  1. Legal regulation

The processing of personal data of CB SICAV is governed by the applicable legislation, in particular:

  • Act No. 110/2019 Coll., on the processing of personal data;
  • Regulation (EU) 2016/679 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) (” hereinafter GDPR“).

 

  1. Terms

‘Personal data‘ means any information relating to an identified or identifiable natural person; an identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, a network identifier or to one or more specific elements of that natural person’s physical, physiological, genetic, mental, economic, cultural or social identity;

“Data subject” means the natural person to whom the personal data relate;

‘Data controller‘ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, that law may determine the controller concerned or the specific criteria for its appointment. Unless otherwise specified in this Policy, in the terms of a specific contract or in the consent, the controller of personal data is CB SICAV.

“Data processor” means a natural or legal person, public authority, agency or other body which processes personal data for the controller;

‘Processing‘ means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated processes, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other disclosure, alignment or combination, restriction, erasure or destruction.

 

  1. Purpose and scope of the processing of personal data

CB SICAV processes only the information that it necessarily needs or the information for which the Data Subject provides consent beyond the necessary processing.

CB SICAV processes personal data for the following purposes:

  • performance of the contract under which the CB SICAV provides services to the client;
  • compliance with legal obligations imposed by legislation (e.g. Act No. 253/2008 Coll., on certain measures against the legalization of the proceeds of crime and the financing of terrorism)
  • legitimate interest of CB SICAV;
  • marketing and business purposes (e.g. offering products and services, sending commercial communications, invitations to cultural events)

CB SICAV processes in particular the following personal data of Data Subjects – investors:

Name, surname, birth number, date of birth, place and country of birth, telephone number, email, nationality, type, number and expiration date of ID, permanent residence, mailing address, tax domicile, TIN, whether or not a U.S. resident, U.S. taxpayer identification number, whether or not he or she is a politically exposed person, whether or not he or she is a sanctioned person, method and language of communication, bank account number, signature, AML risk category, photograph of face, copies of executed documents including identification (including a photograph from the relevant document), gender, education, and financial information. In the case of a natural person entrepreneur, it also processes the address of the place of business, the subject of the business, the name of the official register or other official record in which he/she is registered and the number of registration in this register or record, the business activity, information on the end users of the benefits, the amount of investment and its change. It shall process other data if required by the AML Law. Identity card data is only stored if required by law, in particular Act No. 253/2008 Coll. on certain measures against the legalization of proceeds of crime and terrorist financing, or if the owner of the identity card has given consent to a copy of the identity card.

In the case of other Data Subjects, this includes in particular the following personal data:

name and surname, date and place of birth, birth number, permanent residence address or other contact address, nationality, telephone number, e-mail address, number and period of validity of the identity card, details of the issuing authority.

Beyond this, any other personal data may be processed if voluntarily provided.

The transfer of data that you provide to the Data Subject with your consent is voluntary. The transmission of other data is required by the CB SICAV if its processing is necessary for the conclusion or performance of a contract, the fulfilment of legal obligations or the protection of the legitimate interests of the CB SICAV. If you do not provide such data to the Data Subject, the relevant contract cannot be concluded with the Data Subject.

 

  1. Duration of processing of personal data

Personal data is processed by CB SICAV only for the time necessary to fulfil the purposes set out in this Policy – i.e. in particular for the duration of the contractual relationship, to comply with the statutory obligation, or until the expiry of the relevant time limits for the protection of the Fund’s rights. For marketing and business purposes, we process personal data for the duration of the business relationship.

 

  1. Consent

If the CB SICAV processes personal data with the consent of the Data Subject, the Data Subject may revoke the consent at any time through the contacts listed in the introduction to this Policy.

If the CB SICAV processes personal data on the basis of consent to the processing of personal data, it processes them for the period for which consent was granted or until the consent is withdrawn.

 

  1. Sources of personal data

CB SICAV processes data received directly from Data Subjects, as well as data from publicly available sources and registers and data obtained from third parties (e.g. business partners) that are authorised to do so.

 

  1. Disclosure and transfer of personal data

CB SICAV may entrust a third party with the performance of certain activities, or transfer the data to a third party, then the processing of the relevant personal data by this third party becomes the processor of the personal data. The processor is authorised to handle the data solely for the purpose of carrying out the activity for which it has been authorised by the relevant controller. In this case, the consent of the Data Subject is not required for the purposes of the processing activity.

The subjects to whom personal data may be transferred are, in particular:

  • Czech National Bank, (supervisory authority)
  • Winstor investiční společnost, a.s., ID: 08315868, with registered office at Jungmannova 745/24, Nové Město, 110 00 Prague 1, (Fund Manager)
  • Československá obchodní banka, a. s., ID No.: 00001350, with registered office at Prague 5, Radlická 333/150, Postal Code 15057, (Depositary of the Fund)
  • BDO Czech Republic s.r.o., ID: 26402220, with registered office at Nádražní 344/23, Smíchov, 150 00 Prague 5, (auditor of the Fund)
  • Crowdberry s.o., ID: 05784972, with registered office at Jindřišská 939/20, Nové Město, 110 00 Prague 1, (provider of consulting services to the Fund on projects)
  • IT service providers,
  • attorneys, accountants, tax advisors and other consultants – natural persons engaged in business,
  • banks that provide services to CB SICAVs or project companies,
  • the project companies in which CB SICAV invests and their current and future shareholders, shareholders and directors.

Beyond the above, the CB SICAV transfers personal data outside only if it has the consent of the Data Subject or if required by law.

 

  1. Security

CB SICAV has put in place technical and organisational measures to protect personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing.

The CB SICAV restricts access to personal data to only those persons who need the information for the purpose of processing it on behalf of the CB SICAV.

 

  1. Rights of data subjects

In connection with the processing of personal data, the Data Subject may exercise the following rights with CB SICAV:

  • Right to confirm whether his/her personal data is processed by CB SICAV
  • Right of access to information
  • Right to rectification of personal data
  • Right to withdraw consent to processing
  • Right to object to processing
  • Right to erasure
  • Right to data transfer

The data subject may exercise the aforementioned rights with the CB SICAV by submitting a request in writing or by e-mail to the contact details provided in the introduction.

Right to lodge a complaint with the supervisory authority

The data subject has the right to lodge a complaint against the processing of their personal data with the supervisory authority, which is the Office for Personal Data Protection, located at Pplk. Sochor 27, 170 00 Prague 7 – Holešovice.

CB SICAV may amend this policy on the processing of personal data and publish an updated version on the website.

 

COOKIES

When using the cbpropertyinvestors.eu website, personal data is processed via cookies. “Cookies” are data files placed on the Data Subject’s computer by websites and/or applications that serve as unique identifiers.

The information obtained through cookies is used to improve the services provided, e.g. to personalise the website, to prevent the re-display of notifications already displayed or to update the website.

CB SICAV does not use cookies to identify individuals.

Each of the categories of cookies can be blocked (except for strictly necessary cookies) in the browser settings. Blocking or deactivating cookies may hinder the functionality of the website. CB SICAV uses the following cookies:

  • Strictly necessary cookies
  • Cookie web system
  • Analytical/performance cookies
  • Functional cookies

 

By using this website, you acknowledge that you accept and agree to the Privacy Policy.