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Privacy Policy and Processing of Personal and Other Data

Data Controller

Your personal data is processed under the conditions set out below by:

STARTEEPO s.r.o. Company ID No.: 061 77 522 Registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, File 277543 Registered office: V Parku 2308/8, 148 00 Praha 4 - Chodov

(hereinafter also referred to as the “Company” or the “Controller”)

Controller Contact Details

info@starteepo.com V Parku 2308/8, 148 00 Praha 4 - Chodov

Websites Covered by This Policy

www.starteepo.com www.starteepo-portal.com

Personal Data You Provide to Us in Connection with Our Services

  • Name and surname
  • Date and place of birth
  • Personal identification number (rodné číslo)
  • Permanent residence address or other contact address
  • Nationality
  • Email address
  • Phone number
  • Username and password (when using the client section at www.starteepo-portal.com)
  • IP address
  • Cookies
  • Other online identifiers
  • Identity document number and expiry date, and the authority that issued it
  • Value of funds or investment instruments held in the client’s account maintained by the Company
  • Range of the client’s annual income
  • The client’s occupation or business activity (employment, self-employment)
  • Value of the client’s assets, and other data

Copies of identity documents are made only where required by law (in particular Act No. 253/2008 Coll., on Certain Measures against the Legitimisation of Proceeds of Crime and Financing of Terrorism) or where the holder of the identity document consents to a copy being made and processed.

Personal data is processed both manually and automatically using computer technology.

Purposes of Processing Your Personal Data

  • Performance of the contract under which the Company provides services to the client
  • Responding to enquiries you have sent us or made by phone
  • Improving the quality of the services we provide to you
  • Carrying out analyses to improve the delivery of our services
  • Processing your preferences and displaying content that matches them
  • Sending marketing campaigns and commercial communications to your email address (you can unsubscribe at any time by writing to info@starteepo.com)
  • Compliance with legal obligations (e.g. under Act No. 253/2008 Coll., on Certain Measures against the Legitimisation of Proceeds of Crime and Financing of Terrorism)

Recipients of Personal Data

Personal data is processed by Company employees whose duties include activities requiring the processing of personal data.

The Company may provide personal data to processors, i.e. companies that perform activities requiring the processing of personal data for the Company under a contract.

Where necessary, the Company may also provide personal data to supervisory authorities (e.g. the Czech National Bank), law enforcement authorities or other administrative bodies if required to comply with legal obligations.

Third Parties with Access to Your Personal Data

  • Under certain conditions, law enforcement authorities and other public authorities
  • Operators of technical solutions that allow us to show you relevant advertising and content
  • Parties ensuring the technical operation of the services and technologies we use to provide our services
  • Operators of marketing and communication tools
  • Burza cenných papírů Praha, a.s. (Prague Stock Exchange), registered office Rybná 14/682, Praha 1, Company ID No.: 471 15 629, registered in the Commercial Register maintained by the Municipal Court in Prague, File B 1773, which is our client
  • STARTEEPO SICAV a.s., registered office V Parku 2308/8, 148 00 Praha 4 - Chodov, Company ID No.: 065 87 194, registered in the Commercial Register maintained by the Municipal Court in Prague, File B 22975

Cookies

A cookie is a small text file that a website sends to your browser when you visit it. It allows the website to record information about your visit, such as your preferred language and other settings, making your next visit easier and more efficient. Cookies are important; without them, browsing the web would be much more complicated.

Cookies serve a wide range of purposes. We use them, for example, to store your safe search settings, select relevant advertising, track the number of visitors to a page, make it easier to sign up for new services and protect your data.

This information does not allow users to be identified, not even in combination with other information we process about you. Cookies pose no risk and are not used to collect sensitive personal data.

Third-party cookies are processed and managed by those third parties, and we have no access to read them. These third parties are:

  • Google Ireland Limited, registered office Gordon House, Barrow Street, Dublin 4, Ireland
  • Seznam.cz, a.s., registered office Radlická 3294/10, 150 00 Praha 5, Czech Republic
  • Meta Platforms Ireland Limited, registered office 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

Most web browsers allow you to disable cookies in their settings. Please refer to your browser’s help section and follow the instructions provided. If your browser is set to accept cookies, we assume that you consent to the use of cookies on our websites. Please note that disabling cookies may significantly reduce the convenience of using our services.

Processing of Personal Data Without Your Consent

  • When performing a contract concluded between us
  • On the basis of our legitimate interests
  • When complying with a legal obligation

Retention Period

We process personal data for the duration of the contractual relationship with the client and thereafter for the period required by law. Even if no contract is concluded between the Company and a prospective client, the Company retains the prospective client’s personal data for the period required by law.

You may withdraw your consent at any time by writing to info@starteepo.com. Such withdrawal does not affect the processing of data that we carry out for the performance of a contract, to comply with a legal obligation or on other grounds arising from applicable law.

Your Rights

A person whose data is processed by the Company is hereinafter also referred to as the “data subject”. The data subject has the right to object to the processing of personal data at any time. Where personal data is processed for direct marketing purposes, the data subject has the right to object at any time to such processing, and the Controller will cease processing the 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 processes the data subject’s personal data, the data subject has the right to access such data and to information about the purpose of processing, the categories of personal data concerned, the recipients of the personal data, the intended retention period and their rights in relation to the processing. The data subject has the right to have inaccurate personal data rectified and incomplete personal data completed.

The data subject also has the right to erasure of personal data where:

  • the data is no longer necessary for the purposes for which it was processed,
  • they withdraw their consent to processing and there is no other legal ground for processing,
  • they object to processing and there are no overriding legitimate grounds for processing,
  • the personal data has been processed unlawfully,
  • erasure is necessary to comply with a legal obligation, or
  • the personal data was collected in connection with the offer of information society services to a child under 13.

The data subject also has the right to restriction of processing where:

  • they contest the accuracy of the personal data, for the period needed to verify its accuracy,
  • the processing is unlawful and the data subject opposes erasure and requests restriction of use instead,
  • the Controller no longer needs the personal data for the purposes of processing, but the data subject requires it for the establishment, exercise or defence of legal claims, or
  • they have objected to processing, pending verification of whether the Controller’s legitimate grounds override those of the client.

The data subject also has the right to data portability for personal data processed on the basis of consent or for the performance of a contract. This means the right to receive the personal data they have provided to the Controller in a structured, commonly used and machine-readable format, and the right to transmit this data to another controller, or to have it transmitted directly from one controller to another where technically feasible.

Where personal data is processed on the basis of consent, the data subject has the right to withdraw that consent at any time. This does not affect the lawfulness of processing carried out before the withdrawal.

The data subject has the right to lodge a complaint with the Office for Personal Data Protection (Úřad pro ochranu osobních údajů) at any time if they believe the law has been breached.

Voluntary Provision of Personal Data

Providing personal data to the Company is voluntary; however, without it the Company cannot conclude a contract with the client or provide the requested service. If the client wishes to conclude a contract with the Company, they must provide their personal data, as required by law.

This policy was last updated on 2 September 2026.