Information on the processing of personal data

Information about the operator

  1. HABERL Wealth Management, o.c.p., a.s., with registered office at Trnavská cesta 74/a, 821 02 Bratislava, ID No.: 53 070 194, registered in the Commercial Register of the District Court Bratislava I, Section: Sa, Insert No.: 7101/B, (hereinafter also referred to as the "Company"), hereby informs the data subjects, who are the Company's clients or potential clients of the Company, as the controller of the personal data, about the processing of personal data.
  2. Clients may contact the Company with questions related to the processing of personal data through the published contacts on the Company's website.
  3. As the company can only provide services on the basis of a contract in accordance with the relevant parts of Act No. 566/2001 Coll. on Securities, the client's consent to the processing of personal data is not necessary and the company is obliged to process the client's personal data.

Personal data processing principles

In particular, the company is guided by the following principles when processing clients' personal data:

  • personal data of clients are processed in a lawful manner in relation to the data subject,
    fairly and transparently;
  • personal data of clients are collected for specifically identified, explicitly stated and legitimate purposes and
    may not be further processed in a manner incompatible with those purposes;
  • personal data of clients is adequate, relevant and limited to the extent necessary
    in relation to the purposes for which it is processed;
  • clients' personal data is correct and updated as necessary;
  • personal data of clients are kept in a form which permits identification of data subjects
    for no longer than is necessary for the purposes for which the personal data are processed;
  • clients' personal data is processed in a manner that ensures adequate security of personal data, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage, by means of appropriate technical or
    organisational measures.

Purpose, scope and time of processing of personal data

  1. The company has a permit for the provision of investment services within the meaning of Act No. 566/2001 Coll. on Securities to carry out the business activity of a securities dealer. The Company, when carrying out the business of a securities dealer, concludes contracts with its clients, who are predominantly natural persons from the EU, and obtains personal data on natural persons.
  2. The company also processes personal data of clients for the purposes of compliance with legal obligations, in particular according to:
    - Act No. 566/2001 Coll. on Securities;
    - Act No. 297/2008 Coll. on the Protection against the Legalization of the Proceeds from Crime;
    - Act No. 442/2012 Coll. on International Assistance and Cooperation in Tax Administration;
    - Act No. 431/2002 Coll. on Accounting;
    - Act No. 359/2015 Coll. on Automatic Exchange of Information on Financial Accounts for the Purposes of Administration of
    Taxes and on Amendments and Supplements to Certain Acts;
    or other legal acts supplementing or replacing the aforementioned regulations.
  3. In the event of failure to provide personal data by the client, the company will not be able to conclude a contract with the client and subsequently provide its services to the client.
  4. The company processes personal data of clients in the following scope:
    - if it is a natural person, including a natural person representing a legal person, personal data
    on identity in the range of first name, surname, address of permanent residence, address of temporary residence, birth number, if assigned, date of birth, nationality, type and number of identity document, if it is a natural person who is an entrepreneur, also the address of the place of business, the designation of the official register or other official registration in which the entrepreneurial natural person is registered and the number of registration in this register or registration;
    - a contact telephone number, fax number and e-mail address, if any;
    - personal data relating to the economic identity of the client.
  5. The company obtains personal data from the identity document by copying, scanning or other
    recording within the scope of image likeness, title, first name, surname, maiden name, birth surname, birth number, date of birth, place and district of birth, permanent residence address, temporary residence address, nationality, record of restriction of legal capacity, species number of the identity document, issuing authority, date of issuance and validity of the identity document.
  6. The company processes personal data for the period of time specified by applicable law.
  7. A client is also a person who participates in the procedure by virtue of which he or she is to become a client of
    company.

Automated decision-making and profiling

  1. Before providing the service, the firm is obliged to obtain the necessary information regarding the client's or potential client's knowledge and experience in the field of investments, regarding the specific type of product or service, their financial situation, including their ability to bear losses, their risk tolerance and their investment objectives, in order to be able to recommend to the client or potential client investment services and financial instruments that are suitable for them and that, in particular, correspond to their risk tolerance and ability to bear losses.
    In the collection and subsequent processing of clients' personal data, the firm uses a uniform automated process to evaluate and create an 'investment profile' of the client. The Company uses technological solutions for the processing of personal data which consist in profiling a natural person for the purpose of making a decision concerning that person or for the purpose of analysing or predicting a client's personal preferences, behaviours and attitudes related to investing.
  2. In order to obtain and create an "investment profile" of the client, the company uses an automated form. The Company does not disclose complete information about the method of evaluation.

Disclosure of personal data to third parties

The Company provides personal data to third parties for processing only if it is its legal obligation or if it is required to do so to ensure the Company's business, i.e. for technical and administrative reasons, e.g. IT services, accounting and auditing services, in which case the Company reasonably assumes that the third party fulfils its data protection obligations. The Company processes personal data through its own employees or through its agents.

Further information

  1. The client has the right to file a petition to initiate proceedings under Section 100 of the Act.
  2. The provision of personal data by the Client is both a legal requirement and a requirement
    that is strictly necessary for the conclusion of the relevant contract with the Company or the provision of services by the Company to the Client. The Client is obliged to provide the personal data, in case the personal data is not provided by the Client to the Company, the Company cannot conclude the relevant contract with the Client or provide the services requested by the Client to the Client.
  3. Before further processing of the Client's personal data for a purpose other than the one defined above, the Company is obliged to provide the Client with information about this other purpose and other relevant information as specified above.
  4. The Company as a controller does not obtain personal data about the Client from third parties, but exclusively from the Client.
  5. The Company is obliged to notify the Client without undue delay in accordance with Section 41 of the Act of a personal data breach if such personal data breach may lead to a high risk to the rights of a natural person.
  6. The company is obliged to provide the information in accordance with this instruction to the client in paper or electronic form, generally in the same form in which the request was made. If the Client so requests, the Company may also provide the information orally if the Client proves his/her identity in another way.
  7. The Company is obliged to provide the Client with information about the measures it has taken on the basis of the Client's request pursuant to Sections 21 to 28 of the Act within one month of receipt of the request. This period may be extended by a further two months in justified cases, even repeatedly.

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