Private Policy
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GDPR Privacy Notice: Principles of Personal Data Processing of Individuals in FINREKA real estate fund ltd.

We would like to assure you that FINREKA real estate fund sro, a company headquartered at Bučovická 141, Slavkov u Brna, registered in the Commercial Register kept at the regional court in Brno under the file C 47337, company ID: 26944405 (hereinafter "us") , as part of WPC Holding. SE, will pay maximum attention to the security of your personal information. In addition to Regulation (EU) 2016/679 (GDPR), we follow the applicable laws of the Czech Republic and the binding corporate rules approved by the supervising supervisors within the EU.

We process all data we collect only for legitimate purposes, for a limited time and with the maximum possible security.

Data protection of our customers, as well as recipients, suppliers, partners and, of course, employees, is our priority. In connection with the GDPR Regulation, we provide you below with the principles of processing your personal information. Data Protection Officer (DPO), we have extensive knowledge of data protection and the task of supervising compliance with GDPR. If you have any questions regarding the processing of your personal information, please do not hesitate to contact us at info@finreka.com.

In this document you will find information about what personal data we process about our customers, especially about the users of our site and investors, whether we process the data by consent or other legal reason, for what purpose we use it, whether we act as an administrator or processor, to whom we may transmit your personal information and what rights you have in relation to the processing of your personal data.

What data we process

We process the following personal data:

a) identification data, which means especially the name and surname, username and password, your ID number, your ID and VAT number, if you are an entrepreneur, and your function in the organization if you represent a legal entity;

b) contact details, which means personal information that allows us to contact you, especially the email address, telephone number, delivery address, billing address;

(c) the details of the ordered services you or your company have ordered with you, the method of payment, including the payment account number, and the claim data;

d) information about your behavior on the web, including when you view it through our mobile app, in particular the services you display, the links you click on, and the data on the device from which you view our site, such as the IP address az its derived location, device identification, its technical parameters as the operating system and its version, screen resolution, used browser and its version, as well as data obtained from cookies and similar technologies for device identification;

e) data related to the use of the call center or visit to our facility, which include, in particular, call records with the call center, identification of the messages you are sending to us, identifiers, such as IP addresses, and recordings from camera systems at branches.

Why do we process and process personal data?
As part of our activity, we process personal data for various purposes and to varying degrees either:
(a) without your consent based on performance of the contract, our legitimate interest or the performance of a legal obligation, or
b) based on your consent.
What processing we can do without your consent depends on the purpose of the processing in question and the position you are taking with us - whether you are just a visitor to our site or have a contract with us or order a service with us.

Purposes of processing

1. If you order tokens or contract us with us

In case you order a token purchase with us or you conclude a service contract or other agreement with us, we perform the following processing:

1.1. Processing based on contract performance

If you order a consignment as a natural person, we process your personal data for shipments of ordered tokens, in case of another contract, in order to fulfill this contract, your identification and contact details and your order details.

If you order tokens with us as a representative of a legal entity, we process for the purpose of transporting and tracking the shipment, in the case of another contract, in order to fulfill this contract, your identification, contact details and ordered services data, based on our legitimate interest in the closure and performance of the contract with the person you represent.

The use of these data for the purpose of shipping and tracking a shipment or performance of a contract means that we use them in particular:

so that we can communicate with you about the shipment, such as sending you confirmation;

for the purpose of payment for the delivery of tokens or other service or for the purpose of performing the service;

  • in connection with a claim;
  • in connection with your other requests, such as using the call center.

For this purpose, we use personal data during the delivery of tokens or performance of the contract.

1.2. Processing based on legitimate interest

If you order a token purchase or contract with us, we will keep your identification and contact information and data on the services ordered based on our legitimate interest (without your consent) in order to protect our legal claims and our internal records and controls. Our legitimate interests include the protection of legal claims and the control of the proper provision of our services.

In order to protect legal claims, property protection and our internal records and controls, we process your data for the duration of the limitation period of 10 years and one year after its expiration with respect to the claims enforced at the end of the limitation period. In the event of legal, administrative or other proceedings, we process your personal data to the extent necessary for the duration of such proceedings and the remainder of the limitation period after termination.

We further process, based on our legitimate interest (ie without your consent) your identification and contact details and the data of the services ordered for the purpose of sending offers via e-mail; our legitimate interest is the promotion of our products and services. For this purpose, we use personal data for 6 months from the last order or one month after termination of the contract.

We have the right to object to these processing carried out on our legitimate interest.

We also have to comply with certain statutory obligations. If we process your personal information just for this reason, we do not need to obtain your consent for such processing. Based on this legal basis, we process your identification, contact details, and data on ordered services, in compliance with the following in particular:

Act No. 89/2012 Coll., the Civil Code,

of Act No. 634/1992 Coll., on Consumer Protection (if you order the shipment as a natural person).

of Act No. 235/2004 Coll., on Value Added Tax,

of Act No. 563/1991 Coll., on accounting,

IATA rules for air transport,

EU Counter-Terrorism Orders, Money Laundering.

For these purposes, we use personal data for up to 10 years.

2. If you visit our site

2.1. Using cookies and other technologies

When you visit our site, we store and read small files as cookies on your device. Cookie is a small set of letters and numbers that we store in your internet browser or your computer's hard drive. Some cookies allow us to link your activities while browsing our site from the moment you open the web browser window until you close it. As soon as you close the browser window, these cookies are deleted. Others stay on the device for a set amount of time and activate each time you visit the website that created the cookie. We not only store cookies on your device, but we also read the cookies stored on your site by your device. Also, in this document, we will talk about storage only for simplicity.

Some cookies on your device are stored directly on our site. These cookies help us:

Identify you when navigating between individual pages of our site and during repeated visits, such as saving what version of our site we want to see when the site offers multiple variations at a given time;

to record that you have given us permission under this document.

Such cookies and other files are necessary for the operation of our website. If you block these cookies in your browser, our website may not work properly and we may not be able to provide our services.

Next to your device:

we store cookies from our site that allow us:

Track traffic to our site, its individual sites, generate statistics and reports, and measure ad performance;

to show you different versions of our site if we test new features;

we allow you to save cookies to third parties who may use them:

to collect data about your behavior on our site and on other websites;

to view customized bids and targeted ads within ad networks on sites other than our site.

In order to display customized bids and targeted ads on advertising and social networks on sites other than our site, we also provide advertising and social networks with information about your Web site behavior. However, we do not pass on your identifying information to such partners. For a list of social and advertising networks that we use, see Who processes your personal information and who does it?

If you do not disable the use of third-party cookies and the transmission of your data to advertising and social networks in your browser and you remain on our site or click on the "Understand" button that is part of the alert, we will assume that using these cookies and passing your data to and social networks. You can revoke your permission at any time by turning off this feature in your browser. A full list of cookies is available on the our website under Privacy & Cookies.

2.2. Use of site visitors' personal information

If you visit www.finreka.com, we process your website's data on our legitimate interest (ie without your consent) in order to:

Get information that will help us improve your site in the future. our legitimate interest here is to improve our services for you;

creating statistics and reports, especially tracking our site traffic, individual pages, and measuring ad performance; our legitimate interest here is measuring our site's efficiency and advertising costs;

We do not gain information about your behavior on the web by cookies only. We also include:

The IP address of your device (the address of your device through which you communicate with other devices on the Internet);

  • the operating system of your device, its version, and the language setting;
  • the browser you use on your device, its version and language settings;
  • website address (URL) from which you come to our site.

For this purpose we use personal data for 14 months. You have the right to object to this processing.

3. If you communicate with us through different channels

If you communicate with us via different channels, especially through the Call Center, Email, and Social Networks, we will process your identification, contact and tracking information, including call records, based on our legitimate interest (ie without your consent)

meeting your requirements; if you have ordered a shipment or have entered into a different contract with us and your claim relates to this agreement, we may do this on fulfillment of the contract with you;

documenting your requirements so that we can check that we do it properly and in a timely manner;

Demonstration that we have accepted and dealt with your request, for example, when you order or dispose of a claim with us in this way;

their analysis to improve the quality of our services.

For these purposes, we keep personal data for 3 months. Against processing based on our legitimate interest, you have the right to object.

4. If you visit our office:

If you visit our branch office or its vicinity, we will process a recording from a camera system to which you may be captured, based on our legitimate interest (ie without your consent) in order to protect our and your property and those moving in and out of the shop , which is our legitimate interest at the same time.

For this purpose, we keep your personal information for 1 month. You have the right to object to this processing.

5. If you give us your consent:

If you do not use our services (you have not signed a contract with us or you have not ordered a shipment) and give us your consent, we may use your identification and contact details to send you a quotation by email, a text message, our offers by telephone or other electronic means, or We can send them to you by post.

Your consent is completely voluntary and you can revoke it at any time. Please contact us to revoke your consent in the manner described in How do individual rights apply? Revocation of consent does not affect the lawfulness of the processing until the time of such an appeal.

Who processes your personal data and to whom does it pass?

We process all of these personal data as an administrator. This means that we determine the above-defined purposes for which we collect your personal data, identify the processing resources, and respond to them for proper performance.

We may also share your personal information with other entities that are in the role of administrator, namely:

if you are the addressee of the service that is ordered with us, to our partners involved in this performance, as listed in the section "If you are an addressee of a service ordered by us

in fulfilling our legal obligations, to pass on some personal data to the authorities and state authorities if we are called upon to do so.

based on your consent to advertising and social networks, as described in the "Using Cookies and Other Technologies," "Transmission of Data to Advertising and Social Networks, specifically:

Google Ireland Limited (registration number: 368047), located at Gordon House, Barrow Street, Dublin 4, Ireland; this company's Privacy Policy is available here: https://policies.google.com/technologies/ads

For the processing of personal data we also use the services of other processors who process personal data only according to our instructions and for the purposes described in Why do we process personal data and what entitles us to do so? Such processors are in particular:

a) our partners providing services under our brand;

(b) cloud service providers and other suppliers of technology, support, and related services for our internal processes;

(c) operators of marketing tools and marketing agencies;

(d) service providers for the management and recording of telephone conversations;

e) Providers of SMS, e-mail and other communication tools when processing personal data to mediate our communication with you;

(f) security monitoring providers, in particular managing our CCTV system,

(g) lawyers, tax advisors, auditors, recovery agencies.

How do we get personal data from?In most cases, we process personal information you provide to us when ordering services or communicating with us.
Transmission of data outside the EUAs part of the data transfer to the recipients listed in "Who processes your personal data and to whom we forward it?", We may also transmit your data to third countries outside the European Economic Area that do not provide an adequate level of privacy protection. All such transfers will only be made if the relevant recipient undertakes to comply with some of the standard contractual clauses issued by the European Commission and available at https://eur-lex.europa.eu/legal-content/en/TXT/?uri= CELEX% 3A32010D0087.
What are your rights to processing your personal information?Just as we have our rights and obligations to process your personal information, you also have certain rights to process your personal data. These rights include:
1. Right of access
Simply put, you have the right to know what data we process about you, for what purpose, for what period of time, where we collect your personal data, who we pass on, who is processing outside of us, and what other rights you have with your personal data processing. You can find out all of this in this document "Privacy Policy for Individuals". However, if you are unsure of which personal data we process about you, you may ask us to confirm that personal data concerning you are processed by us or not and, if so, you have the right to access this personal data . As a right of access, you can ask us for a copy of the processed personal data, with the first copy available to you free of charge and additional copies at a charge.
2. Right to repair
They are human. If you find that the personal data we process about you is inaccurate or incomplete, you are entitled to have it repaired or supplemented without undue delay.
3. Right to delete
In some cases, you have the right to delete your personal information. We will delete your personal information without undue delay if any of the following is true:
we no longer need your personal data for the purposes for which we processed it;You withdraw consent to the processing of your personal data, and these are data that your consent is necessary to process and at the same time we have no other reason why we need to process these data further;you exercise your right to object to the processing (see section Right to object to processing) to personal data we process based on our legitimate interests, and we find that no such legitimate interests as to entitle such processing have oryou believe that our processing of personal data has ceased to comply with generally binding regulations.Please keep in mind, though, if one of these reasons is, it does not mean that we will immediately delete all your personal information. This right does not apply if the processing of your personal data is still necessary to fulfill our legal obligation or to determine, enforce or defend our legal rights (see Why do we process personal data and what entitles us to do so?).
4. Right to limit processing
In some cases you may, in addition to the right of cancellation, exercise the right to limit the processing of personal data. This right allows you, in certain cases, to require your personal data to be tagged, and these data are not subject to any further processing operations - in this case not forever (as in the case of a right of cancellation) but for a limited time. We need to restrict the processing of personal data when:
you deny the accuracy of personal data before agreeing what data is correct;we process your personal data without a sufficient legal basis (for example, beyond what we need to process), but you will only prefer to restrict such data before deletion of such data (for example, if you expect us to provide such data in the future);we no longer need your personal data for the above-mentioned processing purposes, but you require them to identify, exercise or defend your legal claims, or you object to the processing. The right to object is described in more detail below in the "Right to object to processing" chapter). For the period we are saving, if your objection is justified, we are obliged to limit the processing of your personal information.5. Right to portability
You have the right to obtain from us all of your personal data that you have provided to us and which we process based on your consent (see section If You Grant Your Assent) and the performance of the Agreement. We will provide your personal information in a structured, commonly used and machine-readable format. In order to easily convert your data to your request, it can only be data that we process automati- cally in our electronic databases.


5. Right to portability

You have the right to obtain from us all of your personal data that you have provided to us and which we process based on your consent (see section If You Grant Your Assent) and the performance of the Agreement. We will provide your personal information in a structured, commonly used and machine-readable format. In order to easily convert your data to your request, it can only be data that we process automati- cally in our electronic databases.

6. Right to object to processing

You have the right to object to the processing of personal data that occurs on our legitimate interest (see Why do we process personal data and what entitles us to do so?). In the case of marketing activities, we will no longer process your personal data without further processing; otherwise we will do so unless we have serious legitimate reasons to continue such processing.

7. Right to file a complaint

By exercising your rights in the above manner, your right to file a complaint with the relevant supervisory authority is unaffected. You may exercise this right in particular if you believe that we process your personal data unjustifiably or in violation of generally binding legal regulations. You may file a complaint against our processing of personal data with the Personal Data Protection Office located at Pplk. Sochora 27, 170 00 Praha 7.