Personal data protection policy

IAD Investments, správ. spol., a. s. with its registered office at Malý trh 2/A, 811 08 Bratislava, Slovak Republic, Identification No.: 17 330 254 registered in the Business register of the County Court Bratislava III, Section: Sa, Insertion No.: 182/B (hereinafter as „IAD“), the asset management company, provides basic information about the approach of IAD to the processing and protection of personal data in accordance with 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 as amended (hereinafter as the „GDPR“) and in accordance with Act No. 18/2018 Coll. on the protection of personal data and on the amendment to certain laws as later amended (hereinafter as the „Personal Data Protection Act“).

In case of querries regarding the processing of personal data or for other querries regarding personal data, you may contact IAD by e-mail at e-mail address info@iad.sk, by phone at toll free landline: 0800 601 601 (for Slovak Republic), 800 127 000 (for Czech Republic) or in writting by letter sent to the address of the registered office of IAD: IAD Investments, správ. spol., a. s., Malý trh 2/A, 821 07 Bratislava.

In the area of the processing and protection of personal data, IAD is a controller that alone and jointly with others determined the purpose and means of the processing of personal data and processes personal data on its own behalf. According to the Personal Data Protection Act, a data subject is any natural person whose personal data is processed.

IAD processes personal data of selected categories of data subjects. The categories of data subjects, the purpose and legal basis of processing their personal data, the recipients of personal data, the period for which the personal data will be stored are listed below:

1. Processing of personal data without the consent of the data subject
1.1. Investors, clients
Purpose: issuing and paying unit certificates of mutual funds and providing investment services and related activities (conclusion, execution and subsequent control of trades between IAD and investors or clients, identification of investors and clients and their representatives, protection and enforcement of IAD’s rights towards investors or clients, documenting activities of IAD, execution of supervision and fulfillment of the tasks and obligations of IAD arising from the relevant legal regulations)
Legal basis: processing of personal data is necessary according to a special regulation or an international agreement to which the Slovak Republic is bound (Act No. 203/2011 Coll. on collective investment as later amended, Act No. 566/2001 Coll. on securities and investment services and on amendments to certain laws (Securities Act) as later amended, Act No. 297/2008 Coll. on the protection against laundering of the proceeds from criminal activity and protection against terrorist financing and on amendments to certain laws as later amended, Act No. 359/2015 Coll. on the automatic exchange of information on financial accounts for the purposes of tax administration and on the amendment and supplementation to certain laws as later amended)
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided):

IAD entrusted the processing of personal data to:

• financial agents who carry out financial intermediation for IAD or another services. The list of financial agents can be found on the website of IAD www.iad.sk/kontakty/financni-sprostredkovatelia, resp. www.iad.sk/cs/kontakty/financni-zprostredkovatele
• for the purposes of informing investors and clients (sending confirmations, regular and annual statements, information letters) ZPC Group, s.r.o., Krasovského 3986/14, 851 01 Bratislava – municipal district Petržalka, Identification No.: 50 540 301

The range of other recipients of personal data or third parties to whom personal data may be provided:

• the depositary of the mutual funds of IAD, the auditor of IAD and mutual funds of IAD
• persons entrusted with the execution of supervision for the purposes of the execution of supervision
• a court including a notary as a judicial commissioner for the purposes of civil proceedings in which the investor or client of IAD is a party or the subject of the proceedings is the property of the investor or client of IAD
• a law enforcement authority for the purposes of criminal proceedings
• National bank of Slovakia for the purposes of its supervision
• the criminal police service, the judicial police service and the financial police service of the Police Force for the purpose of fulfilling the tasks established by a special regulation
• the tax office for the purposes of tax proceedings or to the customs authority in matters of customs proceedings
• a state administration body for the purpose of execution of a judgement according to a special regulation
• the Slovak Information Service for the purpose of fulfilling tasks established by special regulations
• management body and audit body when performing the control or audit of financial instruments
• the competent authority of the Slovak Republic according to a special regulation when fulfilling the reporting obligation

Period for which the personal data will be stored:

• data and copies of documents proving the identity of investors 18 years and clients 10 years and documents establishing the ownership of funds used by investors 18 years and clients to carry out trades and agreements and other documents about executed trades 10 years
• data related to investors’ and clients’ trades at least 10 years
• data and written documents when performing investor’s and client’s due diligence and ascertaining an unusual transaction within 10 years from the termination of the contractual relationship and all data and written documents about trade within 10 years from the execution of trade
• investor and client data related to financial account information for 10 years from the end of the calendar year in which the financial account data was provided

Transfer to a third country or international organization is not carried out.

1.2. Investors, clients
Purpose: providing the IAD ONLINE Access
Legal basis: processing of personal data is necessary for the purpose of fulfilling the agreement (the IAD ONLINE Access Agreement)
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided):
IAD entrusted the processing of personal data to:

• financial agents who carry out financial intermediation for IAD or another services. The list of financial agents can be found on the website of IAD www.iad.sk/kontakty/financni-sprostredkovatelia, resp. www.iad.sk/cs/kontakty/financni-zprostredkovatele
• for the purposes of informing investors and clients (sending confirmations, regular and annual statements, information letters) ZPC Group, s.r.o., Krasovského 3986/14, 851 01 Bratislava – municipal district Petržalka, Identification No.: 50 540 301

The range of other recipients of personal data or third parties to whom personal data may be provided:

• the depositary of the mutual funds of IAD, the auditor of IAD and mutual funds of IAD
• persons entrusted with the execution of supervision for the purposes of the execution of supervision
• a court including a notary as a judicial commissioner for the purposes of civil proceedings in which the investor or client of IAD is a party or the subject of the proceedings is the property of the investor or client of IAD
• a law enforcement authority for the purposes of criminal proceedings
• National bank of Slovakia for the purposes of its supervision
• the criminal police service, the judicial police service and the financial police service of the Police Force for the purpose of fulfilling the tasks established by a special regulation
• the tax office for the purposes of tax proceedings or to the customs authority in matters of customs proceedings
• a state administration body for the purpose of execution of a judgement according to a special regulation
• the Slovak Information Service for the purpose of fulfilling tasks established by special regulations
• management body and audit body when performing the control or audit of financial instruments
• the competent authority of the Slovak Republic according to a special regulation when fulfilling the reporting obligation

Period for which the personal data will be stored:

• data and copies of documents proving the identity of investors 18 years and clients 10 years and documents establishing the ownership of funds used by investors 18 years and clients to carry out trades and agreements and other documents about executed trades 10 years
• data related to investors’ and clients’ trades at least 10 years
• data and written documents when performing investor’s and client’s due diligence and ascertaining an unusual transaction within 10 years from the termination of the contractual relationship and all data and written documents about trade within 10 years from the execution of trade
• investor and client data related to financial account information for 10 years from the end of the calendar year in which the financial account data was provided

Transfer to a third country or international organization is not carried out.

1.3. Financial agents, subordinate financial agents
Purpose: financial intermediation of mutual funds and other services for IAD
Legal basis: processing of personal data is necessary for the purpose of fulfilling the agreements (the Financial Intermediation and Providing Other Services Agreement, the Cooperation Agreement)
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided):

• the depositary of the mutual funds of IAD, the auditor of IAD and mutual funds of IAD
• persons entrusted with the execution of supervision for the purposes of the execution of supervision
• a court including a notary as a judicial commissioner for the purposes of civil proceedings in which the investor or client of IAD is a party or the subject of the proceedings is the property of the investor or client of IAD
• a law enforcement authority for the purposes of criminal proceedings
• National bank of Slovakia for the purposes of its supervision
• the criminal police service, the judicial police service and the financial police service of the Police Force for the purpose of fulfilling the tasks established by a special regulation
• the tax office for the purposes of tax proceedings or to the customs authority in matters of customs proceedings
• a state administration body for the purpose of execution of a judgement according to a special regulation
• the Slovak Information Service for the purpose of fulfilling tasks established by special regulations
• management body and audit body when performing the control or audit of financial instruments
• the competent authority of the Slovak Republic according to a special regulation when fulfilling the reporting obligation
• ECOMAIL.CZ, s.r.o., Na Zderaze 1275/15, Nové Město, 120 00 Prague 2, Czech Republic, Identification No.: 027 62 943 for the purposes of sending information from IAD in terms of the Financial Intermediation Agreement, monitoring behavior and reactions of financial agents and subordinate financial agents to the e-mail sent with notification of statistics and their evaluation

Period for which the personal data will be stored:

• agreements with financial agents, cooperation agreements – 10 years
• when providing personal data to ECOMAIL.CZ, s.r.o., Na Zderaze 1275/15, Nové Město, 120 00 Prague 2, Identification No.: 027 62 943 is the period of storage of personal data for the duration of the Financial Intermediation Agreement

Transfer to a third country or international organization is not carried out.

1.4. Employees of IAD
Purpose: fulfillment of IAD’s obligations as an employer related to an employment relationship or a similar relationship (e.g. based on agreements on work performed outside the employment relationship), including pre-contractual relationships
Legal basis: processing of personal data is necessary according to a special regulation or an international agreement to which the Slovak Republic is bound (employment agreement, Act No. 311/2001 Coll. on the Labor Code as later amended, Act No. 552/2003 Coll. of work performance in the public interest as later amended, Act No. 580/2004 Coll. on health insurance on amendment and supplement to Act No. 95/2002 Coll. on insurance and on amendments to certain acts as later amended, Act No. 461/2003 Coll. on social insurance as later amended, Act No. 595/2003 Coll. on income tax as later amended, Act No. 43/2004 Coll. on old-age pension saving and on amendments to certain laws as later amended, Act No. 650/2004 Coll. on supplementary pension saving and on amendments to certain laws as later amended, Act No. 5/2004 Coll. on employment services and on amending and supplementing certain laws as later amended, Act no. 462/2003 Coll. on compensation of income in case of temporary incapacity for work of an employee and on amendments to certain laws as later amended, Act of the National Council of the Slovak Republic no. 152/1994 Coll. on the social fund and on amendments to Act no. 286/1992 Coll. on income taxes as later amended, Act no. 124/2006 Coll. on safety and health protection at work and on the amendment to certain laws as later amended, Act no. 355/2007 Coll. on the protection, support and development of public health and on the amendment to certain laws as later amended, Act no. 570/2005 Coll. on conscription and on the amendment to certain laws as later amended, Act No. 54/2019 Coll. on the protection of whistleblowers of anti-social activity and on the amendment to certain laws as later amended) Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided):

• Pro Partners Holding, a.s., Malý trh 2/A, 811 08 Bratislava, Identification No.: 47 257 521
• health insurance companies
• Social Insurance Agency
• tax offices
• Central Office of Labour, Social Affairs and Family
• supplementary pension management companies
• pension fund management companies
• bodies of state administration and public authority for the exercise of control and supervision (e.g. labor inspectorate)
• statistical office
• courts
• law enforcement authorities
• bailiffs
• Whistleblower Protection Office (WPO)

Period for which the personal data will be stored: IAD stores personal data in accordance with applicable legal regulations and the registry plan of IAD. Transfer to a third country or international organization is not carried out.

1.5. Persons representing the contracting party or persons authorized to act on behalf of the contracting party
Purpose: contractual relationships
Legal basis: processing of personal data is necessary for the purpose of fulfilling agreements
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided):

• the depositary of the mutual funds of IAD, the auditor of IAD and mutual funds of IAD
• persons entrusted with the execution of supervision for the purposes of the execution of supervision
• a court including a notary as a judicial commissioner for the purposes of civil proceedings in which the investor or client of IAD is a party or the subject of the proceedings is the property of the investor or client of IAD
• a law enforcement authority for the purposes of criminal proceedings
• National bank of Slovakia for the purposes of its supervision
• the criminal police service, the judicial police service and the financial police service of the Police Force for the purpose of fulfilling the tasks established by a special regulation
• the tax office for the purposes of tax proceedings or to the customs authority in matters of customs proceedings
• a state administration body for the purpose of execution of a judgement according to a special regulation
• the Slovak Information Service for the purpose of fulfilling tasks established by special regulations
• management body and audit body when performing the control or audit of financial instruments
• the competent authority of the Slovak Republic according to a special regulation when fulfilling the reporting obligation

Period for which the personal data will be stored: IAD stores personal data in accordance with applicable legal regulations and the registry plan of IAD for a period of at least 10 years.
Transfer to a third country or international organization is not carried out.

1.6. Visitors to the website of IAD
Purpose: essential cookies
Legal basis: § 109 para. 8 of Act No. 452/2021 Coll. on electronic communications as later amended
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided): third parties depending on the requirements of the specific purpose – Google, social networks.
Period for which the personal data will be stored: IAD stores personal data for the period specified in the document with the title Use of cookies available on the website of IAD on the link https://iad.sk/cookies/.
The transfer to a third country or an international organization in case the recipient of personal data is IAD does not take place, in the case of third-party services data may be transferred and processed in the USA or in other countries outside the European Union, more information on the transfer to a third country are listed in the terms of third-party privacy protection.

2. Processing of personal data based on the legitimate interests of IAD
2.1. Investors, clients, submitters of suggestions, visitors to the registered office of IAD, other data subjects in connection with the legitimate interests of IAD
Purpose: prudential management of IAD, providing additional services to investors and IAD clients (IAD ONLINE, IAD MOBILE), quality control of provided services (e.g. making audio recordings of telephone calls from the client center, front office of the private banking department, AML officer), development and testing of information systems IAD, information security of IAD, protection of the safety of employees, investors and clients of IAD, marketing purposes (especially marketing information, actions and offers in the electronic environment of IAD for investors or clients), proving, exercising and defending legal claims of IAD, prevention and detection of financial crime
Legal basis: based on the legitimate interests of IAD
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided): third parties depending on the requirements of the specific purpose
Period for which the personal data will be stored:
IAD determines the retention period of personal data depending on the requirements of a specific purpose, taking into account the protection of the rights of data subjects in accordance with the principle of minimizing data retention.
Transfer to a third country or international organization is not carried out.

3. Processing of personal data with the consent of data subject
3.1. Job applicants at IAD
Purpose: selection procedures within IAD
Legal basis: consent to the processing of personal data
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided): third parties depending on the requirements of the specific purpose
Period for which the personal data will be stored: IAD stores personal data for the duration of the purpose of processing personal data and determines it in the consent of data subject to the processing of personal data.

Transfer to a third country or international organization is not carried out.

3.2. Competitors – data subjects who are not investors nor clients of IAD, visitors to the website of IAD nor social networks of IAD
Purpose: marketing of mutual funds and services provided by IAD (especially marketing competitions), other marketing competitions of various nature
Legal basis: consent to the processing of personal data
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided): third parties depending on the requirements of the specific purpose
Period for which the personal data will be stored: IAD stores personal data for the duration of the purpose of processing personal data and determines it in the consent of data subject to the processing of personal data (it is part of the competition statute).

Transfer to a third country or international organization is not carried out.

3.3. Visitors to the website of IAD
Purpose: marketing cookies and statistical cookies
Legal basis: consent to the processing of personal data in accordance with § 109 para. 8 Act No. 452/2021 Coll. on electronic communications as later amended
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided): third parties depending on the requirements of the specific purpose – Google, social networks.
Period for which the personal data will be stored: IAD stores personal data for the period specified in the document with the title Use of cookies available on the website of IAD on the link https://iad.sk/cookies/.
The transfer to a third country or an international organization in case the recipient of personal data is IAD does not take place, in the case of third-party services data may be transferred and processed in the USA or in other countries outside the European Union, more information on the transfer to a third country are listed in the terms of third-party privacy protection.

3.4. Visitors to the website of IAD
Purpose: sending the newletter of IAD
Legal basis: consent to the processing of personal data
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided):
IAD entrusted the processing of personal data to:

• ECOMAIL.CZ, s.r.o., Na Zderaze 1275/15, Nové Město, 120 00 Prague 2, Czech Republic, Identification No.: 027 62 943 for the purposes of sending the IAD’s newsletter, monitoring the behavior and reactions of visitors to the IAD website to the e-mail sent with notification of statistics and their evaluation

The range of recipients of personal data or third parties to whom personal data may be provided:
third parties depending on the requirements of the specific purpose
Period for which the personal data will be stored: IAD stores personal data for the duration of the purpose of personal data processing, i.e. for the period of sending the IAD’s newsletter

Transfer to a third country or international organization is not carried out.

3.5. Employees of IAD
Purpose: presentation of IAD and its business activities (publication of other personal data of IAD employees on its website, possibly in marketing materials, on IAD social networks, for instance photography, education, etc.) or processing of other personal data of IAD employees (events organized by IAD, jubilee or other employee occasions)
Legal basis: consent to the processing of personal data
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided): third parties depending on the requirements of the specific purpose
Period for which the personal data will be stored: IAD stores personal data for the duration of the purpose of processing personal data and determines it in the consent of the data subject to the processing of personal data
Transfer to a third country or international organization is not carried out.

The data subjects have the following rights in connection with the processing of personal data at IAD:
Right of access to personal data – the right to request confirmation from IAD as to whether the personal data of the data subject is processed at IAD and to access personal data and information about:

• a) the purpose of the processing of personal data
• b) the category of personal data concerned
• c) the recipient or category of recipient to whom the personal data have been or will be disclosed, in particular recipient in third country or international organization, where possible
• d) where possible, the period for which the personal data will be stored or, if not possible, the criteria used to determine that period
• e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
• f) the right to lodge a complaint with a supervisory authority
• g) from which source the personal data originate, if the personal data is not originated from the data subject
• h) the existence of automated decision-making, including profiling.

Information that IAD provides to the data subject based on the right of access to personal data in accordance with the above points a) to f) regarding proccessd personal data, IAD states in this document Personal data protection policy. Confirmation as to whether IAD processes the personal data of the data subject and the personal data of the data subject processed by IAD shall be provided by IAD to the data subject upon request.

Right to rectification of personal data – the right to have IAD rectify incorrect personal data or complete incomplete personal data of the data subject.

Right to erasure of personal data – if the personal data are no longer necessary for the purpose for which they were obtained or processed, or a consent to their processing has been revoked or the data subject objects to the processing of personal data and there are no valid reasons for their processing or they are processed illegally or the reason for deletion is the fulfillment of obligations according to legal regulations or personal data was obtained in connection with the offer of information society services.

Right to restriction of processing of personal data – if the data subject objects to the correctness of the personal data or the processing is illegal and the data subject requests restriction of their use instead of deletion or IAD no longer needs the personal data, but the data subject needs it to lodge a legal claim or the data subject objects to the processing of personal data until verification as to whether the legitimate reasons on the IAD’s party prevail over the legitimate reasons of the data subjects.
IAD informs the data subject before cancelling the aforementioned restrictions on the processing of personal data.

Right to personal data portability – the right to receive personal data in a structured, commonly used and machine-readable format and the right to transmit this data to another controller, if it is technically possible and if the personal data is processed based on the consent of the person concerned or for the purposes of fulfilling the agreement and if the processing is carried out by automated means. The right must not have adverse consequences on the rights of other persons.

Right to object processing of personal data – the data subject has the right at any time, due to his specific situation, to object to the processing of personal data concerning him, which is necessary to fulfill a task carried out in the public interest or in the exercise of public authority entrusted to IAD, or to the processing of personal data which is necessary for the purpose of the legitimate interests of IAD or a third party, except when these interests are overridden by the interests or rights of the data subject requiring the protection of personal data, especially if the data subject is a child. It is also possible to object to the processing of personal data for the purpose of direct marketing, including profiling. If the data subject objects to the processing of personal data for the purpose of direct marketing, IAD must not process personal data for the purpose of direct marketing.

Automated individual decision-making, including profiling – the data subject has the right not to be subject to a decision that is based solely on the automated processing of personal data, including profiling, and that has legal effects that concern him or similarly significantly affect him, only if this is necessary for the conclusion of an agreement or performance of an agreement between the data subject and IAD or carried out on the basis of a special regulation or an international treaty to which the Slovak Republic is bound, and which also provide for appropriate measures guaranteeing the protection of the rights and legitimate interests of the data subject, or is based on the explicit consent of the data subject. IAD does not use automated individual decision-making, including profiling.

Right to lodge a complaint with a supervisory authority – the right to submit a proposal to the Office for Personal Data Protection pursuant to § 100 of the Personal Data Protection Act – if the rights of the data subject have been violated.

In the event that the investor or client does not provide IAD with personal data that IAD is obliged to obtain for the purposes specified in the generally binding legal regulations in the field of collective investment, securities, protection against the legalization of proceeds from criminal activities and protection against the financing of terrorism, automatic exchange of information about financial accounts for the purposes of tax administration and which it obtains through applications, forms, questionnaires and other documents, IAD is obliged to refuse to conclude or conduct business with the investor and client or terminate the business relationship.

In the event that the contracting party or persons representing them do not provide IAD with personal data that IAD is obliged to obtain for the aforementioned purposes, IAD cannot conclude an agreement.
If the employee does not provide IAD with personal data that IAD is obliged to obtain for the above mentioned purposes, IAD is obliged to refuse to conclude an employment agreement.

This document is effective as of 17 December 2024.