Legal documents
Privacy Policy
Last updated: 15 July 2026 · Version 1.3 · The Czech version prevails in case of discrepancy.
1. Data controller
Company ID (IČO): 29630681
File no.: C 449770, Municipal Court in Prague
Registered office: Příčná 1892/4, Nové Město, 110 00 Prague 1, Czech Republic
E-mail: office@atavus.cz
Website: atavus.cz
As the controller of personal data (the "controller"), we process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and Act No. 110/2019 Coll., on the Processing of Personal Data.
2. Data Protection Officer (DPO)
The controller is not required to appoint a data protection officer under Article 37 GDPR. The controller is not a public authority, does not process special categories of personal data on a large scale, and does not carry out systematic monitoring of individuals to an extent that would establish an obligation to appoint a DPO. A DPO has therefore not been appointed.
Please send questions about the processing of personal data to office@atavus.cz.
3. Purposes and legal bases of processing
We process your personal data exclusively for the purposes listed below and on the basis of the corresponding legal bases under Article 6 GDPR:
| Purpose of processing | Legal basis (Art. 6 GDPR) | Description |
|---|---|---|
| Sending program materials | Consent · Art. 6(1)(a) | Processing based on your explicit consent given by checking the box on the contact form. |
| Contacting you to prepare an investment | Pre-contractual steps at your request · Art. 6(1)(b) | Processing necessary to respond to your specific interest and to discuss a future contractual participation in the private asset management program under Section 15 ZISIF. |
| Fulfilling a legal obligation | Legal obligation · Art. 6(1)(c) | Obligations under Act No. 240/2013 Coll. (investor identification, AML obligations). |
| Protecting the controller's legitimate interests | Legitimate interest · Art. 6(1)(f) | Protection against fraudulent conduct, keeping records of communication for complaint-handling purposes. |
Consent is used only to send materials that you voluntarily request. Subsequent pre-contractual communication initiated at your request relies on Article 6(1)(b) GDPR. Withdrawal of consent does not end processing supported by another legal basis, in particular pre-contractual steps, a legal obligation, or the protection of legal rights.
4. Categories of personal data processed
Through the contact form we process the following categories of personal data:
- Identification data: first and last name
- Contact data: e-mail address, phone number (optional)
- Communication data: selected type of inquiry and message content (optional)
- Technical records: submission date and time and IP address, used for security, abuse prevention and server logs
We do not process any special categories of personal data within the meaning of Article 9 GDPR (health data, biometric data, political opinions, etc.).
5. Recipients and processors of personal data
We disclose your personal data only to the extent necessary and on the basis of a written data-processing agreement under Article 28 GDPR, to the following categories of recipients:
| Category of recipient | Specific entity | Purpose of disclosure |
|---|---|---|
| Auditor and accountant | To be specified after a contractual relationship is concluded | Auditing of the financial statements and bookkeeping · fulfilment of statutory obligations |
| Tax adviser | To be specified after a contractual relationship is concluded | Tax compliance, preparation of tax returns |
| Legal adviser / law firm | To be specified after a contractual relationship is concluded | Fulfilment of legal obligations, protection of the controller's legitimate interests, contract administration |
| IT and hosting provider | Contabo GmbH, Aschauer Straße 32a, 81549 Munich, Germany (EU) | Operation of the website and server infrastructure within the EU; no transfer to third countries takes place |
| AML/KYC verification provider | To be specified after a contractual relationship is concluded | Client identification and screening under Act No. 253/2008 Coll. (the AML Act), verification of the investor's regulatory route, and a suitability assessment |
We disclose personal data to public authorities (the Czech National Bank, the Office for Personal Data Protection, courts, AML authorities) only to the extent and on the basis provided for by law.
6. Transfer of personal data to third countries
The controller does not currently transfer personal data to third countries outside the European Economic Area (EEA) or to international organisations. The web fonts and all static assets are hosted locally (self-hosted) on server infrastructure in the EU; the website does not load any external CDN. Should a transfer to a third country take place in the future, it will be carried out solely on the basis of an adequacy decision or appropriate safeguards under Article 46 GDPR.
7. Retention period for personal data
| Category of data | Retention period | Reason |
|---|---|---|
| Voluntary request for program materials | Until consent is withdrawn, for no longer than 3 years from the last contact, unless another legal basis requires further retention | Consent · Art. 6(1)(a) GDPR |
| Pre-contractual communication requested by the interested person | For the duration of the discussions and then only as long as necessary to evidence their course and protect legal rights | Pre-contractual steps · Art. 6(1)(b), followed where applicable by legitimate interest · Art. 6(1)(f) GDPR |
| Investor documentation | 10 years from the end of the investment relationship | Statutory obligation (Act No. 563/1991 Coll., AML regulations) |
| Server logs | 90 days | System security, misuse detection |
After the retention period expires, personal data is securely deleted or anonymised.
8. Your rights as a data subject
As a data subject you have the following rights under GDPR:
Right of access (Art. 15 GDPR)
You have the right to obtain confirmation as to whether we process your personal data, and a copy of that data along with information on how it is processed.
Right to rectification (Art. 16 GDPR)
You have the right to request the correction of inaccurate personal data or the completion of incomplete data.
Right to erasure / the "right to be forgotten" (Art. 17 GDPR)
Subject to the statutory conditions, you have the right to have your personal data erased · in particular if you withdraw your consent or the data is no longer needed for the purpose for which it was collected.
Right to restriction of processing (Art. 18 GDPR)
You have the right to request the restriction of the processing of your data, for example if you contest its accuracy or the lawfulness of the processing.
Right to data portability (Art. 20 GDPR)
Where processing is based on consent or a contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
Right to object (Art. 21 GDPR)
Where we process your personal data on the basis of a legitimate interest, you have the right to object. We will stop the processing unless we can demonstrate compelling legitimate grounds for continuing it.
Right to withdraw consent
You may withdraw consent to receive the requested materials at any time · without affecting the lawfulness of processing before the withdrawal · by e-mail at office@atavus.cz. Withdrawal does not affect processing based on pre-contractual steps, a legal obligation, or a legitimate interest.
Right to lodge a complaint with the supervisory authority
If you believe that the processing of your personal data violates the GDPR or Act No. 110/2019 Coll., you have the right to lodge a complaint with the Office for Personal Data Protection:
Pplk. Sochora 27, 170 00 Prague 7, Czech Republic
Tel.: +420 234 665 111
E-mail: posta@uoou.gov.cz
Website: uoou.gov.cz
Please submit any request to exercise your rights by e-mail at office@atavus.cz. We will respond to your request without undue delay, and no later than one month after receiving it.
9. Automated decision-making and profiling
The controller does not carry out automated decision-making or profiling within the meaning of Article 22 GDPR. All decisions concerning investors are made by human staff.
10. Cookies and local storage
Information on cookies and how consent is managed can be found in a separate document: Cookie Policy.
11. Changes to this Privacy Policy
This policy may be updated from time to time in line with changes in legislation or in the way personal data is processed. The date of the last update is always shown at the top of the document. In the event of a material change, we will inform you via the website or by e-mail.
12. Controller contact details
For questions about the processing of personal data or to exercise your rights, please contact:
Company ID (IČO): 29630681
Příčná 1892/4, Nové Město, 110 00 Prague 1, Czech Republic
E-mail: office@atavus.cz
This policy is drawn up in accordance with Regulation (EU) 2016/679 (GDPR) and Act No. 110/2019 Coll., on the Processing of Personal Data, as amended.