Privacy notice on processing personal data and your rights

PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA AND YOUR RIGHTS

under Art. 13 of 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

(hereinafter referred to as the „GDPR“)

In case you are providing your personal data, we as a data controller – HBR SFA, s. r. o., having its registered seat at: Mlynské nivy 16, 821 09 Bratislava, Slovak Republic, ID No.: 44 127 103, registered with the Commercial Register maintained by the District Court Bratislava I, Section: Sro, File No.: 52335/B (hereinafter referred to as the “HB Reavis” or “we”), would like to inform you about the processing of your personal data and of your rights related to the said processing.

HB Reavis is part of the HB Reavis Group, which consists of all entities consolidated under the group holding HB Reavis Holding S.A. with its headquarters in Luxembourg (hereinafter referred to as the “HB Reavis Group“) due to which the reference to HB Reavis Group may be found in the Privacy Notice.

What is our purpose and legitimate interests for the processing of your personal data?

1) Promotion of our products and services, improving our brand and goodwill by providing you with our newsletters, invitations to our events, marketing alerts and follow-up marketing materials via e-mail or SMS messages.

2) Mutual communication via web-based contact forms.

3) Administration of an investment of the client.

What is our legal basis for the processing of your personal data?

1) We process your personal data on the basis of the legitimate interests under Article 6 (1) (f) of GDPR, which are promotion of our products and services.

2) We process your personal data on the basis of the legitimate interest under Article 6 (1) (f) of GDPR, which is mutual communication by sending your inquiry via web-based contact form.

3) We process your personal data on the basis of the performance of a contractual relationship and your request prior to entering into a contract under Article 6 (1) (b) of GDPR. In case of failure to provide us with your personal data, we cannot enter into contract with you and therefore provide you with the investment opportunity.

What kind of personal data do we process?

1) Name, surname, e-mail and phone number.

2) Name, surname, e-mail, phone number and the content of the message.

3) Name, surname, date of birth, birth number, residence, e-mail, phone number and bank account number.

How long do we store your personal data?

1) We store your personal data in connection with the direct marketing purpose until you unsubscribe from our database or until you exercise your right to object.

2) If you contact us via web-based form, we store your personal data until you unsubscribe from our contact database.

3) We store your personal data until 10 years after the termination of the contract.

As soon as we no longer need your personal data for the processing purposes for which the personal data have been collected, we will delete them unless the statute-barred period applies. Certain details and correspondence may be retained until the time limit for claims, in respect of the pre-contractual or contractual relationship, has expired or in order to comply with regulatory requirements regarding the retention of such personal data.

With whom do we share your personal data?

Based on the various agreements with the third parties acting as our processors, joint controllers or separate controllers.

We may share your personal data within the companies in HB Reavis Group. We also may be obliged to provide your personal data to public authorities, in particular courts and law enforcement agencies (police and prosecutors) only to the extent necessary and within the limits of the law.

From whom do we get the personal data?

We get personal data from you.

Do we use automated individual decision-making?

No, we do not use automated individual decision-making.

Do we transfer your personal data to third countries?

Your personal data are processed within the territory of the Slovak Republic and other states of the European Union. Your personal data can be processed by a country outside of European Union if this third country has been confirmed by the European Commission as a country with adequate level of data protection or if other appropriate data protection safeguards exist (for example, binding corporate privacy rules or EU standard data protection clauses).

Other information:

Personal data may also, in justified cases, be subject to use (processing) for the purpose of dealing with legal matters, including the performance of public authority obligations and monitoring for possible legal protection. Personal data may also be archived for a given public interest, as well as for scientific, historical or statistical research.

What are your rights?

Your rights as a data subject are stated below. Please note that the exact conditions to exercise these rights are set out in detail in Chapter III of GDPR, while in a particular circumstance not all rights may be exercised. You have following rights:

  • Access to personal data we process about you
  • Rectification of incorrect or inaccurate personal data and add incomplete personal data
  • Restriction, i.e. blocking of processing of your personal data
  • The deletion of personal data in case the purpose absence or unauthorized data processing
  • Submission of an objection to the processing of personal data if you believe that our data processing is not justified
  • Be excluded from automated decision-making
  • Listing of personal data in a structured and machine-readable format or for another controller
  • Revocation of consent to the processing of personal data
  • To lodge a complaint with the supervisory authority

How can you exercise your rights?

HBR SFA, s. r. o.

Electronically: dataprivacy@hbreavis.com

In writing to the address: Mlynské nivy 16, 821 09 Bratislava, Slovak Republic

Telephone: +421 918 723 243

We strive to protect your privacy as much as possible and therefore we process your personal data in compliance with GDPR and all other relevant laws. However, if you disagree with the way we handle your personal data, you can exercise your rights via our Data Protection Officer at:

Data Protection Officer’s contact: Erika Wild, contact point at Twin City C, Mlynské Nivy 16, 821 09 Bratislava, Slovak Republic, tel. +421 918 723 243, email: dataprivacy@hbreavis.com

Or you can file a complaint in supervising authority regarding the processing of your personal data. Your local supervisory authority may be found at: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm