This document contains transparent and comprehensible information about the way in which the personal data controller REDSIDE investiční společnost, a.s., company ID number: 24244601, registered office: V Celnici 1031/4, 110 00 Prague 1 (hereinafter “REDSIDE”) works with investors’ personal data. The document contains the following parts:
REDSIDE primarily processes data that concerns investors in the funds that REDSIDE manages, including possible future investors that are interested in REDSIDE’s services. If it is necessary due to the nature of the situation, it also processes data about investors’ representatives. It also processes data that results from telephone or written communications with an investor or his representative. REDSIDE only processes the data necessary so that it can provide investors with investment company services.
Data necessary for identification is kept by REDSIDE to the extent foreseen by legal regulations, in particular Act No. 240/2013 Sb., on investment companies and investment funds (hereinafter the “Investment Companies and Investment Funds Act”), Act No. 256/2004 Coll., on capital market undertakings (hereinafter the “Act on Capital Market Undertakings”), and Act No. 253/2008 Coll., on some measures against money-laundering and financing terrorism (hereinafter the “AML Act”).
In this category REDSIDE especially draws investors’ attention to the fact that it processes their birth number, if allocated.
This is data necessary for the performance of duties that result for REDSIDE from legal regulations, in particular the AML Act, the Investment Companies and Investment Funds Act and the Act on Capital Market Undertakings. It is data concerning a person’s source of income, the relationship of the investment to the expected amount of income, risk tolerance, etc. Also information about whether an investor is a politically exposed person or a person with US status (in accordance with the FATCA agreement).
It is also information about the expertise and experience of an investor with the capital markets and investments, including information about whether an investor is a qualified investor and whether an investor is an eligible counterparty, a professional client or non-professional client.
In this category REDSIDE draws investors’ attention to the fact that it processes a copy or duplicate of an identity document and the data stated therein.
In the event that an investor has access to the client section at the website www.redsidefunds.com, then REDSIDE administers access details, in particular the log-in name and any password.
REDSIDE has a legitimate interest in making and keeping records of telephone calls with an investor for the purposes of performance of a contract and to deal with investors’ wishes and complaints. An investor takes note that in the event that a REDSIDE employee calls an investor on the telephone number he stated in the contract it is not necessary for him to say that the call is being recorded at the start of the call. In the event of an incoming call, REDSIDE must draw the caller’s attention to the recording of the call. Telephone recordings are stored so that they can be used as evidence in the event of a dispute in accordance with Section 17 of Act No. 256/2004 Coll., on capital market undertakings.
During communication with an investor (including a future investor), REDSIDE can obtain information such as the number of the investor’s asset account or data about proceedings conducted against the investor.
In connection with the use of the www.redsidefunds.com website, cookies are saved on the investor’s device. Cookies are used only for the Google Analytics service.
If an investor or future investor completes the contact form at the www.redsidefunds.com website, REDSIDE only processes the data input into the form (e-mail address, telephone number and any data stated in a message). REDSIDE processes these data for one month for the purpose of contact with the investor.
This primarily concerns the provision of a service, realisation of a transaction or provision of other performance in accordance with a contract concluded with REDSIDE, including negotiations on the conclusion or amendment of the relevant contract.
This primarily concerns:
In the event REDSIDE does not have the aforementioned legal grounds for processing the investor’s personal data, it can only process data in the event the investor expressly agrees to the processing. This concerns, for example, processing a copy or duplicate of an ID document and the data stated therein.
REDSIDE obtains investors’ personal data from the following sources:
REDSIDE works with data in such a manner that it always ensures the maximum degree of protection and safety of investors’ personal data. The personal data is processed manually, as well as automatically in electronic information systems.
For the systems that REDSIDE uses it applies that in them employees have access to personal data and all persons that have access to personal data are bound by confidentiality.
In the case of co-operation with investment intermediaries and brokerage firms REDSIDE insists that they ensure the same degree of personal data protection.
REDSIDE has the duty to store personal data for the statutory period, i.e. 10 years following the end of the calendar year in which the contractual relationship was terminated. After the expiry of this period, personal data will irretrievably be deleted from the system.
In accordance with the General Data Protection Regulation (GDPR), investors have the right:
The personal data that REDSIDE obtained from an investor in connection with the aforementioned procedures can be disclosed to another party without the investor’s consent only in the following cases:
REDSIDE can disclose an investor’s personal data to persons it has authorised to perform its contractual and statutory duties, including the realisation of rights under contractual relations.
REDSIDE can also hand investors’ personal data over to persons it has authorised in accordance with Section 50 of the Investment Companies and Investment Funds Act to perform its contractual and statutory duties (outsourcing). In such cases there can be processing of the relevant personal data by an authorised person, who can become a personal data processor. A processor is entitled to handle data solely for the purposes of performing the activities it was authorised to perform by the relevant controller and for the purposes of performance of processing activities there is no requirement for the investor’s consent, as such processing is enabled directly by a legal regulation.
Authorised persons can be:
With an investor’s consent we can disclose personal data or hand it over to another person.
After the termination of the contractual relationship with REDSIDE, an investor can ask for the restriction of the processing of personal data for purposes that do not result from legal regulations. REDSIDE will continue to store the investor’s personal data, but only for the performance of its statutory duties.
When processing and protecting investors’ personal data we always proceed in accordance with valid legal regulations and protect data in a manner that is allowed by generally available technical means.
You can find more information about rights concerning personal data in 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 (GDPR).
This document will be updated regularly.