1 Personal data collected on the website

1.1 Introductory information

By providing any personal data on this website you confirm that you have fully understood the terms of processing of this personal data to the extent stated in this notice.

All processing of personal data by CYRRUS FX, a.s., ID 28880293, with registered office at Na Florenci 2116/15, 110 00 Prague 1 (hereinafter referred to as "CYRRUS FX"), is always carried out in accordance with 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").

1.2 What personal data is collected when visiting www.cyrrus-fx.cz?

o access www.cyrrus-fx.cz, we do not require registration - however, if you participate in any of the activities or services offered at www.cyrrus-fx.cz, we will collect personal data that we need in order to provide these services. These may be for example:

• Address and identification data (e.g. name, surname, address);
• Contact information (e.g. telephone number, email address, postal address, or mobile telephone number);
• Descriptive data (e.g. your message in the form, data from the rate calculator, information filled in the electronic contract).

We do not collect sensitive personal data from you through the mentioned website.

1.3 Technical information

When you visit this website, we may collect technical information such as IP address (Internet Protocol), details of the web pages you visit on www.cyrrus-fx.cz, other pages you visit on the website and which browser you used to display www.cyrrus-fx.cz.

This website collects standard internet logs and technical data that measure and improve the effectiveness of this website, help diagnose problems with our server, manage this website, find out where website traffic is coming from and identify our users. We also collect additional information through the website, such as website activity and preferences, also known as demographic or profile data. In this context, we use "cookies" to collect this information. You can find more information in our cookie policy.

1.4 When do we collect personal data via the website www.cyrrus-fx.cz?

We collect personal data from you in the following cases:

• If you are registered for the newsletter subscription
• If you want to receive current information and offers from us
• If you arrange a meeting with our broker
• If you ask us to contact you
• If you ask us to send you documents
• If you register for a webinar
• If you contact us via live chat or via social networks
• If you contact us with a request for further information…
• If you fill in an electronic contract

We collect the minimum amount of information that will allow us to deal with your application. We will indicate where the provision of information is voluntary or mandatory. We will usually request additional information only if it allows us to provide a more appropriate response to your request.

1.5 On what basis do we handle your personal data

We must have a legal basis for the processing of your personal data. In most cases, the legal basis will be one of the following:

• Conclusion of the contract and fulfillment of our contractual obligations towards you
• Fulfillment of legal obligations to which we are subject (especially Act No. 256/2004 Coll., the Capital Market Undertakings Act, Act No. 253/2008 Coll., on Certain Measures against the Legalization of Proceeds from Crime and Terrorist Financing)
• Consent to the processing of personal data in the case of sending, for example, a newsletter or other business messages
• Enforcing our legitimate interests, such as keeping our records current and accurate.

1.6 How do we use your personal data?

We only use the personal data you provide to us so that we can deal with your request and manage www.cyrrus-fx.cz and the services we offer you through the website.

When you submit a request for materials on your part or request that someone from our company contact you, we will be able to obtain additional information that may be the subject of your interest in our products.

2 Cookies

2.1 Introduction

We collect information about the users of this website automatically as well as if you decide to provide us with this information yourself - for example, by filling out a form at www.cyrrus-fx.cz. This information is processed confidentially and CYRRUS FX, a.s. uses it only in accordance with the conditions set out in this privacy notice. We may use "cookies" to store and sometimes to track information about you.

2.2 Cookies

Cookies are small text files that are downloaded to your computer or mobile device when you visit websites or applications. Your web browser (for example, Internet Explorer, Mozilla Firefox or Google Chrome) will send these cookies back to the website or application each time you visit, so that your data can be recognized and remembered, for example, personal data or user preferences. Cookies will not damage your system. You can reset your browser so that you can reject any cookie or be notified when a cookie is sent.

We use cookies to manage the system and analyze traffic to our website in order to improve the user experience and services. This provides us with information about the number of visitors to different parts of our website.

CYRRUS FX, a.s. does not share this information with third parties. Our cookies do not store information such as your name or address, but rather allow us to see your behavior on the website, which will help improve your user experience. However, if you want to restrict, block or delete cookies from the address www.cyrrus-fx.cz and www.topcertifikaty.cz or other websites, you can use your browser. Every browser is different, so take a look at the "Help" menu of a specific browser (or mobile phone manual) to learn how to change your cookie preferences.

2.3 How to control Cookies

There are various ways you can control and manage cookies, which are described in more detail below. Keep in mind, however, that any settings you change will not only affect the cookies from www.cyrrus-fx.cz. These changes will apply to all websites you visit (unless you choose to block cookies only from specific websites).

2.4 Managing cookies in the browser

Most modern browsers allow you to:

• Find out what cookies you have and delete them individually
• Block cookies of third parties
• Block cookies of specific websites
• Block sending all cookies
• Delete our cookies after closing the browser

You should be aware that if you delete cookies, any preferences will be lost. This includes sites where you have opted out of cookies because it requires cookie opt-out settings. If you block cookies, many websites will not work properly and some functions on these websites will not work at all.

2.5 Management of cookies for analysis

It is also possible to opt out of the recording of activities in the mode of anonymized browsing within websites, which is performed by cookies for analysis. www.cyrrus-fx.cz uses Google Analytics and it is up to you whether you decide to opt out of your cookies on the Google Analytics opt-out page. Please note that you will be redirected to the Google Analytics website so that a "no thanks" cookie may be generated, which will stop other cookies set by these third parties.

2.6 More information about cookies and how to manage them

To learn more about cookies and how to manage them, visit aboutcookies.org (Please note that we cannot be responsible for the content of external websites).

2.7 List of cookies used on the website

The name of the	Cookie type	Who uses it?	Expiration	Description
ASP.NET_SessionId	Functional and safety	CYRRUS	Session	Used in Microsoft ASP.Net web applications to maintain anonymous user session state between page views.
_GRECAPTCHA	Functional and safety	Google	Session	Uses Google reCaptcha for risk analysis.
__cf_bm	Functional and safety	Claudflare	Session	This cookie keeps visitors safe. The __cf_bm file is a cookie required to support Cloudflare Bot Management as part of our bot management service, this cookie helps manage incoming traffic that matches bot criteria.
lidc	Functional	LinkedIn	1 day	Uses LinkedIn for routing.
li_gc	Functional	LinkedIn	6 months	Used by LinkedIn to store visitors' consent to the use of cookies for non-essential purposes.
_ga_*	Analytical	Google	1 year	Contains a unique identifier used by Google Analytics 4 to determine that two different views belong to the same user within browsing sessions.
bcookie	Analytical	LinkedIn	1 year	This is a Microsoft MSN 1st party cookie for sharing website content through social media.
CMSCsrfCookie	Marketing	Kentico	Session	These cookies are associated with advertising and tracking the products that users have viewed.
_gcl_au	Marketing	Google	3 months	Used by Google AdSense to understand user interaction with the website by generating analytical data.
test_cookie	Marketing	Doubleclick	15 minutes	Used to check if the user's browser supports cookies.
_fbp	Marketing	Facebook	3 months	Facebook Pixel first party advertising cookie. Used by Facebook to track website visits to provide a range of advertising products, such as real-time offers from third-party advertisers.
li_sugr	Marketing	LinkedIn	3 months	Used by LinkedIn to probabilistically match a user's identity outside of designated countries.
UserMatchHistory	Marketing	LinkedIn	1 month	Contains a unique identifier that LinkedIn uses to determine that two different hits belong to the same user across browsing sessions.
AnalyticsSyncHistory	Marketing	LinkedIn	1 month	Used by LinkedIn to store information about the time the lms_analytics cookie was synced for users in specified countries.
bscookie	Marketing	LinkedIn	1 year	Used by LinkedIn to track the use of embedded LinkedIn services on the CYRRUS website.
sid	Functional	Seznam	30 days	Cookie used for device identification within all Seznam.cz services

 

3 Sending business messages

We may process your personal data (name, surname, telephone number, email address) in order to send business messages (newsletter, information and comments on investment opportunities, tips, offers, invitations to webinars, etc.). We send commercial communications in accordance with Act No. 480/2004 Coll., on Certain Information Society Services, only with your prior consent (login via a form on the website, consent by telephone). You can revoke this consent at any time, and you can unsubscribe from receiving commercial communications in any email.

If you are our client, we can send you a business message without prior consent. In this case, you have the option to refuse to receive further business communications at any time.

4 Recording telephone calls and electronic communications

According to Section 17 of para. 4 letter a) of Act No. 256/2004 Coll., the Capital Market Undertakings Act, we must record telephone calls and electronic communications that are related to the services we provide. We must keep these records in accordance with Section 17 (1) of said Act. The records kept must be sufficient to enable the Czech National Bank to monitor compliance with the statutory obligations.

The legal period for keeping records is 5 years. In the case of records of agreed contractual obligations, we are obliged to keep records for the duration of the contract, but at least 5 years from the termination of the contract.

5 Personal data collected by the company outside the website

We may also get in touch with you outside of the website and process your personal data. You may be a party interested in a service, a customer, our supplier, or a job seeker. In these cases, we process your personal data in order to:

• Be able to conclude a contract with you and fulfill our obligations agreed in the contract with you
• Ensure that our records are accurate and up-to-date
• Ensure the protection of the property of our company
• To fulfil the legal obligations to which we are subject (especially Act No. 256/2004 Coll., the Capital Market Undertakings Act, Act No. 253/2008 Coll., on Certain Measures against the Legalization of Proceeds from Crime and Terrorist Financing).

To do this, we must have a legal basis for the processing of your personal data. In most cases, the legal basis will be one of the following:

• Conclusion of the contract and fulfillment of our contractual obligations towards you
• Fulfillment of legal obligations which we are subject to
• Consent to the processing of personal data
• Enforcing our legitimate interests, such as keeping our records current and accurate.

6 Rights associated with the processing of personal data

6.1 Your rights

You have the right to request:

• Access to personal data
• Update or correct your data
• Hand over your personal data to another controller
• Unsubscribe from further information from the company
• Request that your personal data be removed from our systems
• Alternatively, raise an objection to the processing of data

that is by sending an e-mail to [email protected]. We will address all these requirements in accordance with the applicable law.

If you decide not to receive promotional or marketing e-mails from us in the future, you can let us know by sending an e-mail to [email protected] stating the e-mail address you wish to be removed from our mailing list. However, your choice not to accept promotional and marketing emails does not prevent us from communicating - by email or otherwise - about your current relationship with us.

CYRRUS FX, a.s. will, in accordance with the law, exercise the relevant rights also with regard to the available technology and the cost of taking appropriate steps, including technical measures.

6.2 The right to revoke consent to the processing of personal data

If you have consented to certain types of processing, including processing for sending commercial communications, you can revoke it at any time. If you revoke the consent, this does not affect the lawfulness of the processing of personal data before this revocation.

7 For how long do we keep your personal data?

We only store your data for the time necessary to fulfill your request or other legitimate processing purposes and will delete it in accordance with our data retention policy.

8 Sharing personal data

We do not provide your personal data to third parties (other than service providers who process personal data for us and on our behalf) unless we have a legal basis to do so.

We may enter into an agreement with other companies or individuals to deal with your application or otherwise operate this website or our business activities. We may provide such companies with access to your personal information on our behalf in connection with these purposes.

We may share your personal data within the CYRRUS GROUP holding.

We do not provide information to third parties for their own marketing purposes and we do not send emails on behalf of third parties.

As a result of the sale, merger, consolidation, change of control, transfer of assets, reorganization or liquidation of our company ("reorganization event"), we may transfer, sell or transfer your personal data to third parties as part of this reorganization event.

The situations in which we may provide your personal information to a third party are:

• to the extent permitted by applicable law, in order to protect and defend our rights, property and legitimate interests; and
• if required by the applicable law (for example, public authorities, including public administration).

9 Transfer of data outside the Czech Republic

Your personal data may be also transferred, stored and processed in a country other than the Czech Republic. If we do so, we transfer personal data in accordance with the applicable regulations on personal data protection. If the transfer takes place to a country outside the EEA, we will use the standard contractual clauses approved by the European Commission.

10 Securing data

We have established generally accepted technological and operational security standards to protect personal data from loss, misuse, modification or destruction. We require all employees and representatives of our organization to keep personal information confidential. Only authorized personnel have access to this data.

We store your personal data in accordance with our data retention policy.

11 Contact us

If you have questions or concerns about how your personal data has been used, please contact our DPO - Data Privacy Officer at [email protected].

We are committed to cooperating with you to reach a fair solution to any potential complaints or concerns regarding the protection of personal information. However, if you believe that we have not been able to assist you with your complaint or concern, you have the right to file a complaint with the Office for Personal Data Protection, registered office: Pplk. Sochora 27, 170 00 Prague 7, CRN: 70837627, phone: +420 234 665 111, website: https://www.uoou.cz.

12 Update of this notice on personal data protection

This notice on personal data protection may be progressively modified or updated. You will be able to find out when we last updated this notice, as it will always include the revision date. Changes and amendments to this privacy notice are valid from the date of their publication. Please read this privacy notice from time to time to see if any changes have been made to the way we use your personal data.

Last modified on April 26, 2023