Privacy policy

Information on the processing of personal data

1) Who we are and our contact details

We are DRFG Investment Group a.s., Company ID No.: 19977255, with its registered office at Vinařská 460/3, Pisárky, 603 00 Brno, Czech Republic, registered in the Commercial Register maintained by the Regional Court in Brno, Section B, File No. 8899, e-mail: media@drfg.cz. We act as the data controller within the meaning of Article 4(7) 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 (the “GDPR”).

2) General information on the processing of personal data

This information on the processing of personal data applies to certain data which constitute personal data and which are processed via websites operated by our company.

Personal data means any information relating to an identified or identifiable living natural person. Personal data also include various pieces of information which, taken together, may lead to the identification of a specific person.

Within our company, we ensure that all personal data provided via our websites are collected and processed in accordance with the GDPR, other applicable legal regulations in this area, and this information on the processing of personal data

3) What data we process

In connection with the operation of our websites, we process various personal data, which can generally be divided into the following categories:

• Cookies
  Unique identifiers that are part of cookies;
• Identification data
  In particular: title, first name, last name, permanent residence address, registered office address, correspondence address, Company ID number, Tax ID number, type of identity document and its number, signature;
• Contact data
  In particular: telephone number and e-mail address;
• Data obtained from communication
  Data included in communication and obtained in the course of provided services, in particular any personal data you provide to us in connection with the provision of services or communication.

4) How and on what legal basis we use personal data

We process personal data for the following purposes and on the following legal bases:

• Consent (Article 6(1)(a) GDPR)
  By voluntarily providing your personal data via a contact form or other contact method published on our website, you grant us your consent to process such personal data for the purpose of further communication, responding to your inquiries, and providing information about services offered by our company or services of third parties presented via our website.
• Performance of a contract (Article 6(1)(b) GDPR)
  If our company concludes a contract with you, we use the personal data provided (in particular identification data, contact data and data obtained from communication) for the performance of that contract, in particular for the fulfilment of our obligations and further communication. The provision of such data is a contractual requirement; without providing such data, we are not able to properly perform the concluded contract. This also applies to steps taken prior to entering into a contract.
• Compliance with legal obligations (Article 6(1)(c) GDPR)
  We also process identification and contact data for the purpose of fulfilling legal obligations, particularly in the area of accounting and taxation. The provision of such data is a legal requirement; without providing such data, we would not be able to properly fulfil our legal obligations.
• Legitimate interests (Article 6(1)(f) GDPR)
  The processing of certain personal data (in particular technical cookies) is necessary to ensure the functioning of our website. Our company therefore has a legitimate interest in processing such personal data for the purpose of ensuring the proper operation of the website for its visitors. Certain other personal data (in particular data obtained from communication) may also be retained for the purpose of evidencing them in administrative or judicial proceedings when defending our rights.

Furthermore, we declare that we do not carry out automated individual decision-making or profiling that would have any legal effects.

5) Sharing of personal data

Affiliated recipients
Certain of your personal data obtained via the contact form or otherwise provided by you through our website may be provided to the following companies:

• EFEKTA obchodník s cennými papíry a.s., Company ID No.: 60717068, with its registered office at Vinařská 460/3, Pisárky, 603 00 Brno, Czech Republic, registered in the Commercial Register maintained by the Regional Court in Brno, Section B, File No. 1388, e-mail: info@efekta.cz, https://www.efekta.cz/
• EFEKTA Brokerpool a.s., Company ID No.: 29048770, with its registered office at Radlická 365/154, 158 00 Prague 5, Czech Republic, registered in the Commercial Register maintained by the Municipal Court in Prague, Section B, File No. 20978, e-mail: kancelar@efektabp.cz, https://www.efektabrokerpool.cz/

These companies share at least one ultimate beneficial owner with our company and are therefore affiliated with us. The provided data are transferred for the purpose of responding to your inquiries or any requests submitted via our website, or for the evaluation of input data entered through tools located on our website (e.g. calculators).

Processors
We engage third-party service providers who provide us with various services, such as accounting and tax services. These partners, acting as data processors, are obliged to comply with strict confidentiality obligations in accordance with applicable legal regulations and/or agreements concluded with them.

Our processors are in particular persons and companies ensuring for us the operation of websites, maintenance services, legal services, provision of technical and IT services, and other advisory and consulting activities. A current list of recipients, including processors, is available upon request at the above-mentioned e-mail address.

Other recipients
We share personal data with legal entities, natural persons, public authorities and public institutions where we are in good faith convinced that access to such information, its use, storage or disclosure is reasonably necessary to:

• comply with applicable legal regulations or enforceable requests of public authorities;
• enforce relevant contractual terms, including the investigation of potential breaches;
• protect against damage to the rights, property or safety of our company, our clients or the public, as required or permitted by law.

We always ensure that we do not provide more data than is necessary to achieve the given purpose of processing. All of the above recipients act as independent data controllers, each responsible for processing personal data within the scope and for the purposes determined by them.

6) Your rights

Right of access
You have the right to request confirmation as to whether we process your personal data and, if so, to obtain a copy of such data and information pursuant to Article 15 GDPR. Where a large amount of data is involved, we may request that you specify your request.

Right to rectification
If we process inaccurate or incomplete data, you have the right to request their correction or completion in accordance with Article 16 GDPR.

Right to erasure
If the conditions set out in Article 17 GDPR are met, you may request the erasure of your personal data. You may request erasure, for example, if you withdraw your consent and there is no other legal basis for processing, or if we process personal data unlawfully, or the purpose for which the data were processed no longer exists. However, we will not erase personal data where they are necessary for the establishment, exercise or defence of legal claims or for compliance with a legal obligation.

Right to restriction of processing
If the conditions set out in Article 18 GDPR are met, you may request that we restrict the processing of your personal data. You may request restriction, for example, while you contest the accuracy of the processed data, or where processing is unlawful and you oppose erasure and request restriction instead. We may continue processing personal data where there are grounds for the establishment, exercise or defence of legal claims or for compliance with a legal obligation.

Right to data portability
Where processing is based on your consent or carried out for the purpose of performing a contract concluded between you and our company, and at the same time carried out by automated means, you have the right, in accordance with Article 20 GDPR, to receive personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format.

Right to object
Where we process your personal data for the performance of a task carried out in the public interest or in the exercise of official authority vested in us, or where processing is based on our legitimate interests or the legitimate interests of a third party, you have the right, in accordance with Article 21 GDPR, to object to such processing. Based on such objection, we will restrict the processing of personal data and, unless we demonstrate compelling legitimate grounds for processing which override your interests, rights and freedoms, we will no longer process your personal data. You also have the right to object at any time to the processing of your personal data for direct marketing purposes. Following such objection, we will no longer process your personal data for that purpose.

Objections may be submitted in person or via postal services to the address of our registered office (Vinařská 460/3, Pisárky, 603 00 Brno, Czech Republic), via data box (ID: 5vvtsby), by e-mail (media@drfg.cz), or via the contact form on our website. After receiving your objection, we will inform you within one month of the measures taken, or that no measures have been taken, including the reasons for such decision.

Right to lodge a complaint
If you believe that we process your personal data in breach of the GDPR or other data protection regulations, you have the right to lodge a complaint with a competent supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. For the Czech Republic, the supervisory authority is: Office for Personal Data Protection, Pplk. Sochora 27, Holešovice, 170 00 Prague 7, Czech Republic, www.uoou.cz, Tel.: +420 234 665 111.

Right to withdraw consent
Where the processing of personal data is based on your consent, you have the right, in accordance with Article 7(3) GDPR, to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal.

Cookie settings
If you do not wish our company to continue processing your data obtained via cookies, you may change your browser settings and disable the storage of cookies. If you block all cookies, you may not be able to fully use all features of our website.

7) Data retention

We retain personal data for varying periods depending on the purpose of processing. In general, we process and retain personal data for:

• the duration of the business relationship or mutual communication;
• a further period of 10 years following the termination of the business relationship or communication for the purpose of protecting our legitimate interests, in particular for the establishment, exercise and defence of our rights, interests and claims, however no longer than until an objection is raised where your rights and interests override our legitimate interests.

8) Changes to this policy

We are entitled to amend this information, in particular in order to reflect legislative changes or changes in the purposes or means of processing. However, we will not restrict your rights arising from this information or applicable legal regulations. Where changes capable of affecting your rights occur, we will inform you appropriately and in advance.