Information on the processing of personal data and the rights of the client as a data subject
This information is intended for clients of Sympatia Financie, o.c.p, a.s., having its registered office at: Vajnorská 100 / B, Bratislava – Municipality Nové Mesto 831 04, IČO: 35 842 369, registered in the Commercial Register of the District Court Bratislava I, Section: Sa, insert no. 2995 / B (hereinafter referred to as “Sympatia”) in relation to which Sympatia performs investment services and investment activities and ancillary investment services in the performance of the activities of an investment firm (hereinafter referred to as “Client”) pursuant to Act no. On Securities and Investment Services and on Amendments and Supplements to Certain Acts, as amended (hereinafter referred to as the “Securities Act”). Sympatiais obliged to fulfill the information duty towards the Client as a data subject.
Sympatia hereby informs the Client that it is processing the Client’s personal data in order to:
- performance and administration of the investment service provided by the trader within the meaning of the Securities Broker (hereinafter the “Investment Service Purpose”) and
- direct marketing of the Client’s personal data for the purpose of conducting a marketing research and familiarizing the Client with the Sympatia product portfolio if the Client has granted Sympatiaconsent to the processing of the Client’s personal data for this purpose (hereinafter referred to as the “marketing purpose”).
The purpose of the investment service and the purpose of marketing are hereinafter collectively referred to as ‘both purposes’.
In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulations) ( hereinafter referred to as the “Regulation”) and with the Act no. 18/2018 Coll. on the protection of personal data (hereinafter referred to as the “OOU Act”), which entered into force on 25.05.2018, Sympatia Financie, o.c.p, a.s. will inform you of the following facts concerning the processing of your personal data:
Operator identification and contact details
Sympatia Financie, o.c.p, a.s.
registered office: Vajnorská 100 / B, Bratislava – Nové Mesto 831 04
Company ID: 35 842 369
registration in the Commercial Register of the District Court Bratislava I, section: Sa, file no. 2995 / B
tel. number: +421 2 3263 0700
Contact details of the responsible person and method of exercising rights
Sympatia is not obliged to designate a responsible person in accordance with the Regulation or in accordance with the OOU Act.
If you have any questions, please do not hesitate to contact email@example.com or tel. number: +421 2 3263 0700.
You may exercise your rights and requirements by e-mail to the address above, in person or by any other means specified above. If you deliver your application, objection, opinion or withdrawal of consent other than by letter with your signature, by e-mail with a qualified electronic signature, or personally, we may require additional credible verification of your identity, otherwise we will not be obliged to comply with your request. Your application may not be granted even in cases governed by law.
Your requests will be processed no later than one month after receiving them. This period may be extended for a further two months, even repeatedly, in the case of a justified case and with regard to the complexity and number of requirements. We will inform you about the extension of the deadline.
We will provide you with information, confirmations and notices free of charge. In the case of repeated requests or requests that are manifestly unfounded or disproportionate, we may require you to pay the administrative costs incurred in their execution, or we may refuse to do so.
If we contact you by phone or contact you directly, these telephone conversations will be recorded. You will be informed about this at the beginning of the telephone conversation. If you do not wish the interview to be recorded, please contact us in another way or request a phone call from an uncontrolled line.
Sources of personal data processing
Sympatia collects your personal information directly from you. The personal information (i) is primarily contained in the contracts we have entered into with you, or (ii) you have filled in the form, or (iii) have been sent or provided to us by mutual correspondence or communication, or (iv) derived from other data you provided us.
Method of processing personal data
Sympatia processes your personal data primarily electronically through automated information systems, which it operates itself.
The purposes of the processing for which the Client’s personal data are intended, as well as the legal basis of the processing
- the purpose of the investment service – the legal basis is Article 6 (1). 1, par. c) GDPR Regulations in conjunction with § 73a of the Securities Act, while the legal basis for processing are for this purpose also other legislation than Act no. 297/2008 Coll. on protection against money laundering and protection against terrorist financing and on amendments to certain acts, as amended, and Act no. 359/2015 Coll. on the automatic exchange of information on financial accounts for the purposes of tax
- administration and on amendments to certain laws, as amended (hereinafter referred to as “Other Related Specific Regulations”);
purpose of marketing – the legal basis is Article 6 (1). 1, par. a) GDPR Regulations in conjunction with Client’s consent, if any.
The Client’s personal information category
- purpose of the investment service – the category of the Client’s personal data specified in the provision of Section 73a of the Securities Act and other related special regulations;
- purpose of marketing – common personal data.
Recipients or categories of recipients of the Client’s personal data
- beneficiaries performing IT service / support and IT development (both);
- beneficiaries providing Sympatia services related to the execution of payments under a special regulation (valid for the purpose of the investment service);
- recipients of the Sympatia forwarding activity, including the printing of shipments, mailing in envelopes, mailing by post, receipt of returned shipments and receipts (both);
- recipients providing document archiving services (valid for both purposes);
- beneficiaries providing an audit of the Sympatia financial statements (valid for both purposes).
Identification of the requirement to provide personal data
Providing Client’s data in the above scope is a legal requirement. Sympatia shall not provide the Client with investment services and investment activities and ancillary investment services without providing Client information. In the event that a potential client has demonstrated a demonstrable interest in investment services and investment activities and ancillary investment services, Sympatia shall not be entitled to provide him with investment services and investment activities and ancillary investment services without providing the client details above.
Voluntary or obligation to provide the Client’s personal data
Purpose of the Investment Service – Sympatia may not perform the Investment Service for the Client without providing the Client’s personal data pursuant to Section 73a of the Securities Act and in accordance with other related special regulations;
Purpose of Marketing – The Client provides the Client’s personal data voluntarily; failure to consent to the processing of the Client’s personal data for marketing purposes has no effect on the performance of the Investment Service for the Client by Sympatia; The Client may withdraw the consent at any time.
Procedures used, importance and expected consequences of profiling
Sympatia performs profiling of the Client’s personal data, ie it performs automated processing of the Client’s personal data, which consists of using Client’s personal data to evaluate certain personal aspects relating to the Client, in particular behavior, position or movement, in particular to familiarize the Client with the current Sympatia product portfolio so that the products meet the Client’s individual financial, social and other needs, and to identify potential frauds and problems in the FATCA, CRS and income legalization areas crime and terrorist financing (both).
The source of the Client’s personal data, if the Client’s personal data were not obtained from the Client
If the Client’s personal data were obtained by a Sympatia from a source other than the Client himself, this source was primarily the legal or authorized representative of the Client (valid for both purposes).
Transfer of personal data to a third country or international organization
Sympatia does not intend to transfer the Client’s personal data to a third country or international organization. In the case of a Third Country Client, Sympatia shall apply an exemption for special situations within the meaning of Article 49 (1). 1, par. (b) GDPR (applicable for both purposes).
Rights of the data subject
Sympatia hereby informs you, in accordance with the Regulation and the OOU Act, in the event that such a contractual relationship applies, as a client in the position of the data subject, to the following extent:
- Period of Retention of Personal Data The provision of an investment service (hereinafter referred to as the “ Agreement”) and the period necessary for the fulfillment of the rights and obligations of Sympatia arising from this Agreement and the Securities Act, even for 10 years after termination of the Agreement;
- Purpose of Marketing – the duration of the Contract and the period of one year after the termination of the Contract or until the date of delivery of the withdrawal of the Client’s consent to the processing of the Client’s personal data for the purpose of marketing, respectively. by the date specified as the effective date of the withdrawal of consent in such served appeal.
- Right to request from the controller access to personal data concerning the client: As a client you have the right to obtain from the controller confirmation of: a) the purpose of processing personal data,
(b) the category of personal data processed;
(c) the recipient to whom personal data have been / are to be provided;
(d) the period of retention of personal data;
e) to require the controller to correct personal data / delete or restrict processing / to object to the processing of personal data;
(f) the right to initiate proceedings on the protection of personal data;
(g) sources of personal data;
(h) the existence of automated individual decision making, including profiling.
- Right to correct personal data : The Client has the right to have the operator correct incorrect personal data concerning him without undue delay. With respect to the purpose of processing personal data, the Client has the right to complete incomplete personal data.
- Right of deletion or restriction on the processing of personal data : The Client has the right to have the data deleted by the controller without undue delay. The controller shall delete personal data without undue delay if
personal data are no longer necessary for the purpose for which they were collected or processed,
- The Client shall withdraw the consent to the processing on the basis of which the processing of personal data is carried out and there is no other legal basis for the processing of personal data,
The client objects to the processing of personal data,
personal data is processed illegally,
is the reason for the cancellation of the fulfillment of the obligation under the law, a special regulation or an international treaty by which the Slovak Republic is bound.
The Client has the right for the controller to restrict the processing of personal data if:
The Client disputes the correctness of personal data during the period allowing the operator to verify the correctness of personal data,
the processing of personal data is illegal and the Client objects to the deletion of personal data and requests the restriction of their use instead,
the controller no longer needs personal data for the purpose of processing personal data, but the Client needs it to make a legal claim, or
the Client objects to the processing of personal data until it is verified that the justified reasons on the part of the operator outweigh the legitimate reasons of the Client.
- Right to portability of personal data : The Client has the right to obtain personal data relating to him provided to the Operator in a structured, commonly used and machine-readable format and has the right to transfer such personal data to another Operator, if technically possible and aka) personal data are processed on the basis of consent or is necessary for the performance of the contract to which the Client is a party,
(b) the processing of personal data shall be carried out by automated means.
Withdrawal of consent : The client has the right to withdraw the consent to the processing of personal data at any time, if the legal basis of the processing is consent.
- Revocation of consent shall not affect the lawfulness of the processing of personal data based on consent prior to its revocation. The Client may withdraw the consent in the same way as the consent was granted by sending the withdrawal of the consent to the following address: Sympatia Financie, o.c.p, a.s., Vajnorska 100 / B, Bratislava – Municipality Nove Mesto 831 04 or by e-mail at firstname.lastname@example.org
- Right to file personal data protection proceedings : If the Client suspects that his / her rights as a natural person have been violated in the processing of personal data, he / she has the right to file personal data protection proceedings under the OOU Act.
Existence of automated individual decision making, including profiling : The operator does not perform such an activity.
The right to object to the processing of personal data : The client has the right to object to the processing of his / her personal data for reasons related to his / her specific situation performed for the legitimate interests of the controller. The Controller may not further process personal data unless he / she proves the necessary legitimate interests in the processing of personal data that outweigh the rights or interests of the Client or the reasons for claiming a legal claim. The Client has the right to object to processing personal data concerning him If the Client objects to the processing of personal data for the purpose of direct marketing, the operator shall not further process the personal data for the purpose of direct marketing.
Principles of personal data processing
(a) PRINCIPLE OF LAW : We process personal data fairly, transparently and solely on a legitimate basis (consent of the data subject, performance of the contract, performance of a legal obligation, protection of vital interests of the data subject or other natural person, performance of public interest or , Sympatia’s legitimate interest). We will not violate the rights of the person concerned when processing.
(b) PURPOSE OF LIMITATION OF PURPOSE : We may only process personal data for a specific, well-defined, explicitly stated and legitimate purpose, otherwise only for archival, scientific, statistical or historical research purposes.
(c) PRINCIPLE OF MINIMIZING PERSONAL DATA : We can only process personal data that we absolutely need or that allows us to process the law. We will not process or request unnecessary personal data. It is also up to you to provide us with only those personal data that are strictly necessary for the purpose for which we will process them and do not provide us with unnecessary data (eg when communicating with each other, etc.).
(d) PRINCIPLE OF CORRECTITY : We only process correct and current personal data. If the personal data we process is incorrect or incomplete, we will correct or complete it. We will delete incorrect personal information. The accuracy of your personal information also depends on you, so it is essential that you always provide us with correct and complete personal information.
(e) PRINCIPLE OF MINIMUM STORAGE : We will only process personal data for as long as it is necessary for the purpose or specified by law. We will only process them for archival, scientific, statistical or historical research purposes.
(f) PRINCIPLE OF INTEGRITY AND CONFIDENTIALITY : We protect personal data from loss, accidental deletion, damage, theft or destruction. We will ensure that there is no unlawful processing of personal data. The security of personal data is important and we ensure it through standard appropriate technical and other measures.
(g) RESPONSIBILITY PRINCIPLE : We are responsible for the security and protection of personal data for you and the Office for Personal Data Protection of the Slovak Republic, which is authorized to review the processing of personal data in the framework of the personal data protection proceedings.
Contact details of the Office for Personal Data Protection of the Slovak Republic
Address: Hraničná 12
820 07 Bratislava 27
ID No .: 36 064 220
- in general:
- for the provision of information pursuant to Act no. 211/2000 Coll .:
- email address through which the Office will provide you with advice on personal data protection. It is intended for children, youth, students, teachers, parents who suspect that their personal data have been misused:
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