Information on the Processing of Personal Data
Identity and Contact Details of the Controller
The controllers of personal data providing the information set out in this document are:
• Jet Investment, a.s., Company ID No.: 038 90 333, registered office: Brno, Hlinky 49/126, Post Code 60300, entered in the Commercial Register kept by the Regional Court in Brno, Section B, Insert 7268
• Jet Base SICAV, a.s., Company ID No.: 117 30 111, registered office: Brno, Hlinky 49/126, Post Code 60300, entered in the Commercial Register kept by the Regional Court in Brno, Section B, Insert 8590
• Jet 2, investiční fond, a.s., Company ID No.: 070 15 526, registered office: Brno, Hlinky 49/126, Post Code 60300, entered in the Commercial Register kept by the Regional Court in Brno, Section B, Insert 7935
• Jet 3 SICAV, a.s., Company ID No.: 142 74 311, registered office: Brno, Hlinky 49/126, Post Code 60300, entered in the Commercial Register kept by the Regional Court in Brno, Section B, Insert 8678
(each hereinafter also referred to as the “Company” or the “Controller”, or collectively as the “Jet Group”).
telephone: +420 543 427 011
Purpose and Scope of Personal Data Processing
The Company processes personal data for the following purposes:
• performance of the contract under which the Company provides services to the client,
• compliance with legal obligations imposed by legal regulations (e.g. Act No. 253/2008 Coll., on Certain Measures Against the Legalisation of Proceeds of Crime and the Financing of Terrorism; Act No. 256/2004 Coll., on Capital Market Business; Act No. 240/2013 Coll., on Management Companies and Investment Funds; or Act No. 90/2012 Coll., on Commercial Corporations),
• marketing and business purposes (e.g. offering products and services, sending commercial communications, invitations to cultural or sporting events).
The Jet Group processes personal data of the following categories of data subjects:
• clients (investors)
• potential clients (investors)
• other persons, in particular for marketing outreach or commercial communications,
to the extent in which the data were provided upon conclusion of a contract or during negotiations on its conclusion, or subsequently communicated by the client during the contractual relationship, or to the extent to which consent to the processing of personal data has been granted by these persons, and further to the extent in which they are recorded in the client’s account maintained by the Company for the client under the contract.
This includes in particular the following personal data: name and surname, date and place of birth, personal identification number, permanent residence address or other contact address, nationality, telephone number, email address, number and validity period of an identity document, details of the authority that issued the identity document, tax domicile, bank account number, value of funds or investment instruments on the client’s account maintained by the Company, the range of the client’s annual income, the client’s regular source of income, the client’s occupation (employment, business activity), the value of the client’s assets, information on political exposure, and others.
The Company processes copies of identity documents only in cases where required to do so by legal regulations (in particular Act No. 253/2008 Coll., on Certain Measures Against the Legalisation of Proceeds of Crime and the Financing of Terrorism), or in cases where the holder of the identity document has granted consent to the making and processing of the copy.
Personal data are processed manually and automatically using computer technology.
Legitimate Interests of the Controller
The Company also processes clients’ personal data for the purpose of direct marketing, based on its legitimate interest in promoting its products and services.
Recipients of Personal Data
Personal data are processed by the Company’s employees whose job responsibilities include activities requiring the processing of personal data.
The Company may provide personal data to processors, i.e. companies performing activities requiring the processing of personal data for the Company under a contract (e.g. sending statements from investment accounts, accounting services, payroll processing, computer network administration, etc.).
The Company may further provide personal data to supervisory authorities (e.g. the Czech National Bank), law enforcement authorities, or other administrative authorities where necessary to fulfil obligations imposed by legal regulations.
Personal Data Processing Period
The Company processes personal data for the duration of the contractual relationship with the client and for the period for which it is required to retain the personal data under legal regulations. Even if no contract is concluded between the Company and a potential client, the Company retains the personal data of the potential client for the period required by legal regulations.
If the Jet Group processes personal data on the basis of consent, it processes the data for the period for which the consent was granted or until the consent is withdrawn.
Rights of Data Subjects
A person whose personal data are processed is hereinafter also referred to as the “data subject”.
The data subject has the right to object at any time to the processing of personal data. Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to processing for such marketing, and the Controller shall cease the processing of personal data for direct marketing purposes.
The data subject has the right to request confirmation from the Company as to whether it processes personal data concerning them. If the Company does process such data, the data subject has the right to access those personal data and to information on the purpose of processing, the categories of personal data concerned, the recipients of the personal data, the planned processing period and their rights in connection with the processing of personal data.
The data subject has the right to the rectification of inaccurate personal data and the completion of incomplete personal data.
The data subject further has the right to the erasure of personal data if:
• the data are no longer necessary for the purposes for which they were processed,
• they withdraw consent to the processing of personal data and no other legal basis exists for the processing,
• they object to the processing and no overriding legitimate grounds for the processing exist,
• the personal data have been processed unlawfully,
• the erasure is necessary for compliance with a legal obligation, or
• the personal data were collected in connection with the offer of services by the Company to a child under the age of 13.
The data subject further has the right to the restriction of processing if:
• they contest the accuracy of the personal data, for the period necessary to verify the accuracy of the personal data,
• the processing is unlawful and the data subject refuses the erasure of the personal data and instead requests restriction of their use,
• the Controller no longer needs the personal data for the purposes of processing, but the data are required by the data subject for the establishment, exercise, or defence of legal claims, or
• they have objected to the processing until it is verified whether the Controller’s legitimate grounds override those of the client.
The data subject further has the right to the portability of personal data processed on the basis of consent or for the performance of a contract, meaning the right to obtain their personal data provided to the Controller in a structured, commonly used and machine-readable format, and the right to transmit those data to another controller, or the right to have the data transmitted directly from one controller to another, where technically feasible.
Where personal data are processed on the basis of consent, the data subject has the right to withdraw such consent at any time by sending an email to tlacbabova@jetinvestment.cz or by sending a letter to the Company’s address. The lawfulness of processing prior to the withdrawal of consent remains unaffected.
The data subject has the right to lodge a complaint with the Office for Personal Data Protection at any time if they believe that legal regulations have been infringed.
Voluntariness of Providing Personal Data
Providing personal data to the Company is voluntary; however, failure to provide such data prevents the Company from concluding a contract with the client and providing the requested service. If a client wishes to conclude a contract with the Company, they must provide personal data, as required by legal regulations.
This document enters into force on 25 May 2018.
Updated: 1 July 2022