1 Personal data collected on the website

1.1. Introductory information

By providing any personal data on this website you confirm that you have fully understood the terms of processing of this personal data to the extent stated in this notice.

1.2 What personal data is collected when visiting www.cyrruscs.cz?

To access www.cyrruscs.cz, we do not require registration - however, if you participate in any of the activities or services offered at www.cyrruscs.cz, we will collect personal data that we need in order to provide these services. These may be for example:

• Address and identification data (e.g. name, surname, address);
• Contact information (e.g. telephone number, email address, postal address, or mobile telephone number);
• Descriptive data (e.g. your message in the form, data from the rate calculator, information filled in the electronic contract).

We do not collect sensitive personal data from you through the mentioned website.

1.3. Technical information

When you visit this website, we may collect technical information such as IP address (Internet Protocol), details of the web pages you visit on www.cyrruscs.cz, other pages you visit on the website and which browser you used to display www.cyrruscs.cz.

This website collects standard internet logs and technical data that measure and improve the effectiveness of this website, help diagnose problems with our server, manage this website, find out where website traffic is coming from and identify our users. We also collect additional information through the website, such as website activity and preferences, also known as demographic or profile data. In this context, we use "cookies" to collect this information. You can find more information in our cookie policy.

1.4 When do we collect personal data via the website www.cyrruscs.cz?

We collect personal data from you in the following cases:

• If you are registered for the newsletter subscription
• If you want to receive current information and offers from us
• If you arrange a meeting with our broker
• If you ask us to contact you
• If you ask us to send you documents
• If you register for a webinar
• If you contact us via live chat or via social networks
• If you contact us with a request for further information…
• If you fill in an electronic contract

We collect the minimum amount of information that will allow us to deal with your application. We will indicate where the provision of information is voluntary or mandatory. We will usually request additional information only if it allows us to provide a more appropriate response to your request.

1.5 On what basis do we handle your personal data

We must have a legal basis for the processing of your personal data. In most cases, the legal basis will be one of the following:

• Conclusion of the contract and fulfillment of our contractual obligations towards you
• Fulfillment of legal obligations to which we are subject (especially Act No. 256/2004 Coll., the Capital Market Undertakings Act, Act No. 253/2008 Coll., on Certain Measures against the Legalization of Proceeds from Crime and Terrorist Financing)
• Consent to the processing of personal data in the case of sending, for example, a newsletter or other business messages
• Enforcing our legitimate interests, such as keeping our records current and accurate.

1.6 How do we use your personal data?

We only use the personal data you provide to us so that we can deal with your request and manage www.cyrruscs.cz and the services we offer you through the website.

When you submit a request for materials on your part or request that someone from our company contact you, we will be able to obtain additional information that may be the subject of your interest in our products.

2 Cookies

2.1 Introduction

We collect information about the users of this website automatically as well as if you decide to provide us with this information yourself - for example, by filling out a form at www.cyrruscs.cz. This information is processed confidentially and CYRRUS CORPORATE SOLUTIONS, s.r.o. uses it only in accordance with the conditions set out in this privacy notice. We may use "cookies" to store and sometimes to track information about you.

For more information about cookies click here.

3 Sending business messages

We may process your personal data (name, surname, telephone number, email address) in order to send business messages (newsletter, information and comments on investment opportunities, tips, offers, invitations to webinars, etc.). We send commercial communications in accordance with Act No. 480/2004 Coll., on Certain Information Society Services, only with your prior consent (login via a form on the website, consent by telephone). You can revoke this consent at any time, and you can unsubscribe from receiving commercial communications in any email.

If you are our client, we can send you a business message without prior consent. In this case, you have the option to refuse to receive further business communications at any time.

4 Recording telephone calls and electronic communications

According to Section 17 of para. 4 letter a) of Act No. 256/2004 Coll., the Capital Market Undertakings Act, we must record telephone calls and electronic communications that are related to the services we provide. We must keep these records in accordance with Section 17 (1) of said Act. The records kept must be sufficient to enable the Czech National Bank to monitor compliance with the statutory obligations.

The legal period for keeping records is 5 years. In the case of records of agreed contractual obligations, we are obliged to keep records for the duration of the contract, but at least 5 years from the termination of the contract.

5 Personal data collected by the company outside the website

We may also get in touch with you outside of the website and process your personal data. You may be a party interested in a service, a customer, our supplier, or a job seeker. In these cases, we process your personal data in order to:

• Be able to conclude a contract with you and fulfill our obligations agreed in the contract with you
• Ensure that our records are accurate and up-to-date
• Ensure the protection of the property of our company
• To fulfil the legal obligations to which we are subject (especially Act No. 256/2004 Coll., the Capital Market Undertakings Act, Act No. 253/2008 Coll., on Certain Measures against the Legalization of Proceeds from Crime and Terrorist Financing).

To do this, we must have a legal basis for the processing of your personal data. In most cases, the legal basis will be one of the following:

• Conclusion of the contract and fulfillment of our contractual obligations towards you
• Fulfillment of legal obligations which we are subject to
• Consent to the processing of personal data
• Enforcing our legitimate interests, such as keeping our records current and accurate.

6 Rights associated with the processing of personal data

6.1 Your rights

You have the right to request:

• Access to personal data
• Update or correct your data
• Hand over your personal data to another controller
• Unsubscribe from further information from the company
• Request that your personal data be removed from our systems
• Alternatively, raise an objection to the processing of data

that is by sending an e-mail to osobniudaje@cyrrus.cz. We will address all these requirements in accordance with the applicable law.

If you decide not to receive promotional or marketing e-mails from us in the future, you can let us know by sending an e-mail to osobniudaje@cyrrus.cz stating the e-mail address you wish to be removed from our mailing list. However, your choice not to accept promotional and marketing emails does not prevent us from communicating - by email or otherwise - about your current relationship with us.

CYRRUS CORPORATE SOLUTIONS s.r.o. will, in accordance with the law, exercise the relevant rights also with regard to the available technology and the cost of taking appropriate steps, including technical measures.

6.2 The right to revoke consent to the processing of personal data

If you have consented to certain types of processing, including processing for sending commercial communications, you can revoke it at any time. If you revoke the consent, this does not affect the lawfulness of the processing of personal data before this revocation.

7 For how long do we keep your personal data?

We only store your data for the time necessary to fulfill your request or other legitimate processing purposes and will delete it in accordance with our data retention policy.

8 Sharing personal data

We do not provide your personal data to third parties (other than service providers who process personal data for us and on our behalf) unless we have a legal basis to do so.

We may enter into an agreement with other companies or individuals to deal with your application or otherwise operate this website or our business activities. We may provide such companies with access to your personal information on our behalf in connection with these purposes.

We may share your personal data within the CYRRUS GROUP holding.

We do not provide information to third parties for their own marketing purposes and we do not send emails on behalf of third parties.

As a result of the sale, merger, consolidation, change of control, transfer of assets, reorganization or liquidation of our company ("reorganization event"), we may transfer, sell or transfer your personal data to third parties as part of this reorganization event.

The situations in which we may provide your personal information to a third party are:

• to the extent permitted by applicable law, in order to protect and defend our rights, property and legitimate interests; and
• if required by the applicable law (for example, public authorities, including public administration).

9 Transfer of data outside the Czech Republic

Your personal data may be also transferred, stored and processed in a country other than the Czech Republic. If we do so, we transfer personal data in accordance with the applicable regulations on personal data protection. If the transfer takes place to a country outside the EEA, we will use the standard contractual clauses approved by the European Commission.

10 Securing data

We have established generally accepted technological and operational security standards to protect personal data from loss, misuse, modification or destruction. We require all employees and representatives of our organization to keep personal information confidential. Only authorized personnel have access to this data.

We store your personal data in accordance with our data retention policy.

11 Contact us

If you have questions or concerns about how your personal data has been used, please contact our DPO - Data Privacy Officer at osobniudaje@cyrrus.cz.

We are committed to cooperating with you to reach a fair solution to any potential complaints or concerns regarding the protection of personal information. However, if you believe that we have not been able to assist you with your complaint or concern, you have the right to file a complaint with the Office for Personal Data Protection, registered office: Pplk. Sochora 27, 170 00 Prague 7, CRN: 70837627, phone: +420 234 665 111, website: https://www.uoou.cz.

12 Update of this notice on personal data protection

This notice on personal data protection may be progressively modified or updated. You will be able to find out when we last updated this notice, as it will always include the revision date. Changes and amendments to this privacy notice are valid from the date of their publication. Please read this privacy notice from time to time to see if any changes have been made to the way we use your personal data.

Last modified on April 25, 2018