Personal Data Protection

The management company IAD Investments, správ. spol., a. s., with its registered office at Malý trh 2/A, 811 08 Bratislava, Slovak Republic, Company ID: 17 330 254, registered in the Commercial Register of the Municipal Court Bratislava III, Section: Sa, File No.: 182/B (hereinafter referred to as “IAD“) provides basic information on IAD’s approach 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, repealing Directive 95/46/EC (General Data Protection Regulation) as amended (hereinafter referred to as “GDPR”) and in accordance with Act No. 18/2018 Coll. on the Protection of Personal Data and on the amendment and supplementation of certain acts as amended (hereinafter referred to as the “Personal Data Protection Act“).

Contact Details of IAD

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

Processing of Personal Data

IAD is a controller in the area of personal data processing and protection, which alone and jointly with other persons has determined the purpose and means of personal data processing and processes personal data in its own name. Under the Personal Data Protection Act, a data subject is any natural person whose personal data are processed.

Categories of Data Subjects, Purpose, Legal Basis for Processing Their Personal Data, Recipients of Personal Data, Retention Period for Personal Data, Transfer of Personal Data

IAD processes the personal data of selected categories of data subjects. The categories of data subjects, the purpose and legal basis for processing their personal data, the recipients of personal data, and the retention period for personal data are set out below:

1. Processing of Personal Data Without the Consent of the Data Subject
1.1. Investors, Clients
Purpose: issuing and redeeming units of mutual funds, distribution of securities of foreign collective investment entities, provision of investment services and related activities (in particular, entering into contracts, identification of investors and clients and their representatives, execution and subsequent control of trades of investors or clients, protection and enforcement of IAD’s rights against investors or clients, documentation of IAD’s activities, exercise of supervision and fulfilment of IAD’s tasks and obligations arising from the relevant legislation)
Legal basis: processing of personal data is necessary under a specific regulation or an international treaty by which the Slovak Republic is bound (Act No. 203/2011 Coll. on Collective Investment as amended, Act No. 566/2001 Coll. on Securities and Investment Services and on the amendment and supplementation of certain acts (Securities Act) as amended, Act No. 297/2008 Coll. on the Prevention of Legalisation of Proceeds of Criminal Activity and on the Prevention of Terrorist Financing and on the amendment and supplementation of certain acts as amended, Act No. 359/2015 Coll. on the Automatic Exchange of Financial Account Information for Tax Administration Purposes and on the amendment and supplementation of certain acts as amended, legislation of the state in which the authorisation for the activities of the foreign entity was issued and in which it is subject to supervision).
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided):

IAD has entrusted the processing of personal data to:

  • – financial agents who carry out financial intermediation or other services for IAD. The list of financial agents is available on IAD’s website at www.iad.sk/kontakty/financni-sprostredkovatelia or www.iad.sk/cs/kontakty/financni-zprostredkovatele
  • – for the purpose of informing investors and clients (sending confirmations, regular and annual statements, information sheets), the company ZPC Group, s. r. o., Krasovského 3986/14, 851 01 Bratislava – Petržalka borough, Company ID: 50 540 301

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

  • the depositary of IAD’s mutual funds, IAD’s auditor and the auditor of IAD’s mutual funds
  • persons authorised to exercise supervision for the purpose of exercising supervision / the National Bank of Slovakia for the purpose of supervision carried out by it
  • a court, including a notary as a court commissioner, for the purpose of civil court proceedings in which the investor or client of IAD is a party or the subject of which is the property of the investor or client of IAD
  • the authority active in criminal proceedings for the purpose of criminal proceedings
  • the Criminal Police Service, Judicial Police Service and Financial Police Service of the Police Corps for the purpose of fulfilling tasks established by a specific regulation
  • the tax authority for the purpose of tax proceedings or the customs authority in customs proceedings matters
  • a public administration authority for the purpose of enforcing a decision under a specific regulation
  • the Slovak Information Service for the purpose of fulfilling tasks established by specific regulations
  • the managing authority and audit authority in the exercise of control or audit of financial instruments
  • the relevant authority of the Slovak Republic under a specific regulation in the fulfilment of the notification obligation
  • In connection with the distribution of securities of a foreign collective investment entity carried out by IAD, personal data may also be provided to the following range of other recipients of personal data or third parties: the foreign collective investment entity (which issued the securities of the foreign collective investment entity), the foreign management company (managing the foreign collective investment entity that issued the securities of the foreign collective investment entity) and service providers under specific legislation for the foreign collective investment entity that issued the securities of the foreign entity (e.g. auditor, central administrator, depositary), supervisory authorities or other financial regulators, state authorities and public authorities (in particular courts and authorities active in criminal proceedings) in the state in which the authorisation for the activities of the foreign entity was issued and in which it is subject to supervision, and only to the extent required by the relevant legislation.

Retention period for personal data:

  • data and copies of documents proving the identity of investors for 18 years and of clients for 10 years, and documents on the verification of ownership of funds used by investors for 18 years and by clients to execute a trade and contracts and other documents on completed trades for 10 years
  • data relating to the trades of investors and clients for at least 10 years
  • data and written documents in the exercise of due diligence with respect to the investor and client and the identification of unusual business operations for 10 years from the end of the contractual relationship and all data and written documents on a trade for 10 years from the execution of the trade
  • data of investors and clients relating to financial account information for 10 years from the end of the calendar year in which the financial account data were provided

Transfer to a third country or international organisation does not take place.

1.2. Investors, Clients
Purpose: provision of IAD ONLINE Access
Legal basis: processing of personal data is necessary for the performance of a contract (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):

  • – financial agents who carry out financial intermediation or other services for IAD. The list of financial agents is available on IAD’s website at www.iad.sk/kontakty/financni-sprostredkovatelia or www.iad.sk/cs/kontakty/financni-zprostredkovatele
  • – for the purpose of informing investors and clients (sending confirmations, regular and annual statements, information sheets), the company ZPC Group, s. r. o., Krasovského 3986/14, 851 01 Bratislava – Petržalka borough, Company ID: 50 540 301

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

  • the depositary of IAD’s mutual funds, IAD’s auditor and the auditor of IAD’s mutual funds
  • persons authorised to exercise supervision for the purpose of exercising supervision / the National Bank of Slovakia for the purpose of supervision carried out by it
  • a court, including a notary as a court commissioner, for the purpose of civil court proceedings in which the investor or client of IAD is a party or the subject of which is the property of the investor or client of IAD
  • the authority active in criminal proceedings for the purpose of criminal proceedings
  • the Criminal Police Service, Judicial Police Service and Financial Police Service of the Police Corps for the purpose of fulfilling tasks established by a specific regulation
  • the tax authority for the purpose of tax proceedings or the customs authority in customs proceedings matters
  • a public administration authority for the purpose of enforcing a decision under a specific regulation
  • the Slovak Information Service for the purpose of fulfilling tasks established by specific regulations
  • the managing authority and audit authority in the exercise of control or audit of financial instruments
  • the relevant authority of the Slovak Republic under a specific regulation in the fulfilment of the notification obligation
  • In connection with the distribution of securities of a foreign collective investment entity carried out by IAD, personal data may also be provided to the following range of other recipients of personal data or third parties: the foreign collective investment entity (which issued the securities of the foreign collective investment entity), the foreign management company (managing the foreign collective investment entity that issued the securities of the foreign collective investment entity) and service providers under specific legislation for the foreign collective investment entity that issued the securities of the foreign entity (e.g. auditor, central administrator, depositary), supervisory authorities or other financial regulators, state authorities and public authorities (in particular courts and authorities active in criminal proceedings) in the state in which the authorisation for the activities of the foreign entity was issued and in which it is subject to supervision, and only to the extent required by the relevant legislation.

Retention period for personal data:

  • data and copies of documents proving the identity of investors for 18 years and of clients for 10 years, and documents on the verification of ownership of funds used by investors for 18 years and by clients to execute a trade and contracts and other documents on completed trades for 10 years
  • data relating to the trades of investors and clients for at least 10 years
  • data and written documents in the exercise of due diligence with respect to the investor and client and the identification of unusual business operations for 10 years from the end of the contractual relationship and all data and written documents on a trade for 10 years from the execution of the trade
  • data of investors and clients relating to financial account information for 10 years from the end of the calendar year in which the financial account data were provided

Transfer to a third country or international organisation does not take place.

1.3. Financial Agents, Subordinate Financial Agents
Purpose: financial intermediation of mutual funds, securities of foreign collective investment entities and other services for IAD
Legal basis: processing of personal data is necessary for the performance of contracts (financial intermediation and provision of other services agreement, 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 IAD’s mutual funds, IAD’s auditor and the auditor of IAD’s mutual funds
  • persons authorised to exercise supervision for the purpose of exercising supervision / the National Bank of Slovakia for the purpose of supervision carried out by it
  • a court, including a notary as a court commissioner, for the purpose of civil court proceedings in which the investor or client of IAD is a party or the subject of which is the property of the investor or client of IAD
  • the authority active in criminal proceedings for the purpose of criminal proceedings
  • the Criminal Police Service, Judicial Police Service and Financial Police Service of the Police Corps for the purpose of fulfilling tasks established by a specific regulation
  • the tax authority for the purpose of tax proceedings or the customs authority in customs proceedings matters
  • a public administration authority for the purpose of enforcing a decision under a specific regulation
  • the Slovak Information Service for the purpose of fulfilling tasks established by specific regulations
  • the managing authority and audit authority in the exercise of control or audit of financial instruments
  • the relevant authority of the Slovak Republic under a specific regulation in the fulfilment of the notification obligation
  • the company ECOMAIL.CZ, s.r.o., Na Zderaze 1275/15, 120 00 Prague 2, Czech Republic, Company ID: 027 62 943, for the purpose of sending information from IAD in accordance with the financial intermediation agreement, monitoring the behaviour and reactions of financial agents and subordinate financial agents to the sent e-mail with statistical notification and their evaluation
  • In connection with the distribution of securities of a foreign collective investment entity carried out by IAD, personal data may also be provided to the following range of other recipients of personal data or third parties: the foreign collective investment entity (which issued the securities of the foreign collective investment entity), the foreign management company (managing the foreign collective investment entity that issued the securities of the foreign collective investment entity) and service providers under specific legislation for the foreign collective investment entity that issued the securities of the foreign entity (e.g. auditor, central administrator, depositary), supervisory authorities or other financial regulators, state authorities and public authorities (in particular courts and authorities active in criminal proceedings) in the state in which the authorisation for the activities of the foreign entity was issued and in which it is subject to supervision, and only to the extent required by the relevant legislation.

Retention period for personal data:

  • agreements with financial agents, cooperation agreements – 10 years
  • when providing personal data to ECOMAIL.CZ, s.r.o., Na Zderaze 1275/15, 120 00 Prague 2, Company ID: 027 62 943, the retention period for personal data is for the duration of the financial intermediation agreement

Transfer to a third country or international organisation does not take place.

1.4. IAD Employees
Purpose: fulfilment of IAD’s obligations as an employer related to the 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 under a specific regulation or an international treaty by which the Slovak Republic is bound (employment contract, Act No. 311/2001 Coll. Labour Code as amended, Act No. 552/2003 Coll. on the Performance of Work in the Public Interest as amended, Act No. 580/2004 Coll. on Health Insurance and on the amendment of Act No. 95/2002 Coll. on Insurance and on the amendment and supplementation of certain acts as amended, Act No. 461/2003 Coll. on Social Insurance as amended, Act No. 595/2003 Coll. on Income Tax as amended, Act No. 43/2004 Coll. on Old-Age Pension Saving and on the amendment and supplementation of certain acts as amended, Act No. 650/2004 Coll. on Supplementary Pension Saving and on the amendment and supplementation of certain acts as amended, Act No. 5/2004 Coll. on Employment Services and on the amendment and supplementation of certain acts as amended, Act No. 462/2003 Coll. on Compensation of Income during Temporary Incapacity for Work of an Employee and on the amendment and supplementation of certain acts as amended, Act of the National Council of the Slovak Republic No. 152/1994 Coll. on the Social Fund and on the amendment of Act No. 286/1992 Coll. on Income Taxes as amended, Act No. 124/2006 Coll. on Occupational Safety and Health Protection and on the amendment and supplementation of certain acts as amended, Act No. 355/2007 Coll. on the Protection, Promotion and Development of Public Health and on the amendment and supplementation of certain acts as amended, Act No. 570/2005 Coll. on Military Duty and on the amendment and supplementation of certain acts as amended, Act No. 54/2019 Coll. on the Protection of Whistleblowers of Anti-Social Activities and on the amendment and supplementation of certain acts as amended)
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided):

  • the company Pro Partners Holding, a.s., Malý trh 2/A, 811 08 Bratislava, Company ID: 47 257 521
  • health insurance companies
  • the Social Insurance Agency
  • tax offices
  • the Central Office of Labour, Social Affairs and Family
  • supplementary pension management companies
  • pension management companies
  • public administration and public authority bodies for the exercise of control and supervision (e.g. the labour inspectorate)
  • the Statistical Office
  • courts
  • authorities active in criminal proceedings
  • executors
  • the Office for the Protection of Whistleblowers of Anti-Social Activities (ÚOOPÈ)

Retention period for personal data: IAD retains personal data in accordance with applicable legislation and IAD’s records management plan.
Transfer to a third country or international organisation does not take place.

1.5. Persons Representing a Contracting Party or Persons Authorised to Act on Behalf of a Contracting Party
Purpose: contractual relationships
Legal basis: processing of personal data is necessary for the performance of contracts
Recipients of personal data (the range of recipients of personal data or third parties to whom personal data may be provided):

  • the depositary of IAD’s mutual funds, IAD’s auditor and the auditor of IAD’s mutual funds
  • persons authorised to exercise supervision for the purpose of exercising supervision / the National Bank of Slovakia for the purpose of supervision carried out by it
  • a court, including a notary as a court commissioner, for the purpose of civil court proceedings in which the investor or client of IAD is a party or the subject of which is the property of the investor or client of IAD
  • the authority active in criminal proceedings for the purpose of criminal proceedings
  • the Criminal Police Service, Judicial Police Service and Financial Police Service of the Police Corps for the purpose of fulfilling tasks established by a specific regulation
  • the tax authority for the purpose of tax proceedings or the customs authority in customs proceedings matters
  • a public administration authority for the purpose of enforcing a decision under a specific regulation
  • the Slovak Information Service for the purpose of fulfilling tasks established by specific regulations
  • the managing authority and audit authority in the exercise of control or audit of financial instruments
  • the relevant authority of the Slovak Republic under a specific regulation in the fulfilment of the notification obligation
  • In connection with the distribution of securities of a foreign collective investment entity carried out by IAD, personal data may also be provided to the following range of other recipients of personal data or third parties: the foreign collective investment entity (which issued the securities of the foreign collective investment entity), the foreign management company (managing the foreign collective investment entity that issued the securities of the foreign collective investment entity) and service providers under specific legislation for the foreign collective investment entity that issued the securities of the foreign entity (e.g. auditor, central administrator, depositary), supervisory authorities or other financial regulators, state authorities and public authorities (in particular courts and authorities active in criminal proceedings) in the state in which the authorisation for the activities of the foreign entity was issued and in which it is subject to supervision, and only to the extent required by the relevant legislation.

Retention period for personal data: IAD retains personal data in accordance with applicable legislation and IAD’s records management plan, for a period of at least 10 years.
Transfer to a third country or international organisation does not take place.

1.6. Visitors to IAD’s Website
Purpose: necessary cookies
Legal basis: Section 109(8) of Act No. 452/2021 Coll. on Electronic Communications as 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.
Retention period for personal data: IAD retains personal data for the period specified in the document entitled Use of Cookies available on IAD’s website at the link www.iad.sk/cookies.
Transfer to a third country or international organisation, where IAD is the recipient of personal data, 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 is provided in the privacy conditions of the third parties.

2. Processing of Personal Data Based on the Legitimate Interests of IAD
2.1. Investors, Clients, Intermediaries, Whistle-blowers, Visitors to IAD’s Registered Office, Other Data Subjects in Connection with the Legitimate Interests of IAD
Purpose: prudent business conduct of IAD, provision of supplementary services to IAD’s investors, clients and intermediaries (IAD ONLINE Access), quality control of services provided (e.g. making audio recordings of telephone calls of the client centre, AML officer, Private Banking department), development and testing of IAD’s information systems, information security of IAD, protection of the safety of IAD’s employees, investors and clients, marketing purposes (in particular marketing information, promotions and offers in IAD’s electronic environment for investors or clients), demonstrating, exercising and defending IAD’s legal claims, 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
Retention period for personal data: IAD determines the retention period for personal data depending on the requirements of the specific purpose, taking into account the protection of the rights of data subjects in accordance with the principle of data minimisation.
Transfer to a third country or international organisation does not take place.

3. Processing of Personal Data with the Consent of the Data Subject
3.1. Job Applicants at IAD
Purpose: IAD’s selection procedures
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
Retention period for personal data: IAD retains personal data for the duration of the purpose of processing personal data and determines it in the data subject’s consent to the processing of personal data.
Transfer to a third country or international organisation does not take place.

3.2. Competition Participants – Data Subjects Who Are Not Investors or Clients of IAD, Visitors to IAD’s Website or IAD’s Social Networks
Purpose: marketing of financial products provided by IAD (in particular marketing competitions), other marketing competitions of various kinds
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
Retention period for personal data: IAD retains personal data for the duration of the purpose of processing personal data and determines it in the data subject’s consent to the processing of personal data (it forms part of the competition rules).
Transfer to a third country or international organisation does not take place.

3.3. Visitors to IAD’s Website
Purpose: marketing cookies and statistical cookies
Legal basis: consent to the processing of personal data pursuant to Section 109(8) of Act No. 452/2021 Coll. on Electronic Communications as 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.
Retention period for personal data: IAD retains personal data for the period specified in the document entitled Use of Cookies available on IAD’s website at the link www.iad.sk/cookies/.
Transfer to a third country or international organisation, where IAD is the recipient of personal data, 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 is provided in the privacy conditions of the third parties.

3.4. Visitors to IAD’s Website
Purpose: sending the IAD newsletter
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):

  • the company ECOMAIL.CZ, s.r.o., Na Zderaze 1275/15, Nové Mìsto, 120 00 Prague 2, Czech Republic, Company ID: 027 62 943, for the purpose of sending the IAD newsletter, monitoring the behaviour and reactions of visitors to IAD’s website to the sent e-mail with statistical notification and their evaluation

The range of other recipients of personal data or third parties to whom personal data may be provided: third parties depending on the requirements of the specific purpose
Retention period for personal data: IAD retains personal data for the duration of the purpose of processing personal data, i.e. for the duration of sending the IAD newsletter.
Transfer to a third country or international organisation does not take place.

3.5. IAD Employees
Purpose: presentation of IAD and its business activities (publication of other personal data of IAD’s employees on its website, or in marketing materials, on IAD’s social networks, such as photographs, education, etc.) or processing of other personal data of IAD’s employees (events organised by IAD, anniversary or other occasions of the employee)
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
Retention period for personal data: IAD retains personal data for the duration of the purpose of processing personal data and determines it in the data subject’s consent to the processing of personal data.
Transfer to a third country or international organisation does not take place.

Information on the Rights of Data Subjects

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 from IAD confirmation as to whether the data subject’s personal data are being processed at IAD and access to personal data and information on:

  • a) the purpose of processing personal data
  • b) the category of personal data processed
  • c) the identification of the recipient or the category of recipient to whom the personal data have been or are to be provided, in particular the recipient in a third country or an international organisation, where possible
  • d) the retention period for personal data; where this is not possible, information on the criteria for its determination
  • e) the right to request the controller to rectify personal data concerning the data subject, to erase them or to restrict their processing, or the right to object to the processing of personal data
  • f) the right to lodge a complaint with the supervisory authority – a proposal to initiate proceedings
  • g) the source of personal data, if the personal data were not obtained from the data subject
  • h) the existence of automated individual decision-making, including profiling.

The information that IAD provides to the data subject on the basis of the right of access to personal data pursuant to points a) to f) above concerning the personal data processed is set out by IAD in this Personal Data Protection document. Confirmation of whether IAD processes the data subject’s personal data and the data subject’s personal data that IAD processes will be provided by IAD to the data subject upon request.

Right to rectification of personal data – the right to have IAD rectify inaccurate personal data or supplement 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 the consent to their processing has been withdrawn, or the data subject objects to the processing of personal data and no legitimate grounds for their processing prevail, or they are processed unlawfully, or the reason for erasure is the fulfilment of obligations under legislation, or the personal data were obtained in connection with the offer of information society services.

Right to restriction of processing of personal data – if the data subject contests the accuracy of the personal data, or the processing is unlawful and the data subject requests restriction of their use instead of erasure, or IAD no longer needs the personal data but the data subject needs them to exercise a legal claim, or the data subject objects to the processing of personal data until it is verified whether the legitimate grounds on the part of IAD prevail over the legitimate grounds of the data subject.

Right to data portability – the right to obtain personal data in a structured, commonly used and machine-readable format and the right to transfer such data to another controller, where technically feasible, and where the personal data are processed on the basis of the data subject’s consent or for the purpose of performing a contract and where the processing is carried out by automated means. The right must not adversely affect the rights of other persons.

Right to object to the processing of personal data – the data subject has the right at any time, on grounds relating to their particular situation, to object to the processing of personal data concerning them which is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in 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 where such interests are overridden by the interests or rights of the data subject requiring the protection of personal data, in particular where the data subject is a child. Objections may also be raised against 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 may no longer process the 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 based solely on automated processing of personal data, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless it is necessary for the conclusion of a contract or the performance of a contract between the data subject and IAD, or is carried out on the basis of a specific regulation or an international treaty by which the Slovak Republic is bound, and which also establishes appropriate measures to safeguard the rights and legitimate interests of the data subject, or is based on the data subject’s explicit consent. IAD does not use automated individual decision-making, including profiling.

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

Obligation to Provide Personal Data Based on Legal Requirements

If an investor or client does not provide IAD with the personal data that IAD is obliged to obtain for the purposes set out in generally binding legislation in the area of collective investment, securities, prevention of legalisation of proceeds of criminal activity and prevention of terrorist financing, automatic exchange of financial account information for tax administration purposes, and which it obtains through requests, forms, questionnaires and other documents, IAD is obliged to refuse to conclude or execute a trade with the investor and client, or to terminate the business relationship.

If a contracting party or persons representing them do not provide IAD with the personal data that IAD is obliged to obtain for the above-mentioned purposes, IAD cannot conclude the contract.

If the employee does not provide IAD with the personal data that IAD is obliged to obtain for the above purposes, IAD is obliged to refuse to conclude the employment contract.

This document takes effect on 25 June 2025.