Privacy Policy

Personal data processing policy of Electronics Trade Platforms s.r.o. in accordance with Regulation (EU) 2016/679 (GDPR) and Czech Act No. 110/2019 Coll.

Effective: April 1, 2026

1. Data Controller

Electronics Trade Platforms s.r.o. (hereinafter "ETP" or "Controller") is the controller of personal data processed to the extent necessary for the provision of its services and compliance with statutory obligations.

2. What personal data we process

We only process personal data that is necessary for a specific purpose. Typically this includes:

• Identification data — first name, last name, title, date of birth
• Contact data — email address, phone number, mailing address
• Investor qualification data — information on trading experience, investor profile, and source of funds where required by law
• Technical data — IP address, browser and device type, language preferences
• Communication data — content of email or phone communication with ETP

3. Purposes and legal basis of processing

a) Communication with prospects and clients

Processing is necessary for the performance of a contract or to take steps prior to entering into a contract at the request of the data subject (Art. 6(1)(b) GDPR).

b) Compliance with legal obligations

Accounting, archiving, reporting under Czech Act No. 240/2013 Coll. (ZISIF), AML/KYC obligations — Art. 6(1)(c) GDPR.

c) Legitimate interest

Protection of the Controller's rights and interests, fraud prevention, system security — Art. 6(1)(f) GDPR.

d) Consent

For marketing communication unrelated to an existing relationship — Art. 6(1)(a) GDPR. Consent may be withdrawn at any time.

4. Retention period

We retain personal data only for as long as necessary for the given purpose:

• Client data — for the duration of the contractual relationship and subsequently for the period required by law (typically 10 years due to accounting and tax regulations)
• Prospect contact data — maximum 12 months from last contact, unless a contract is concluded
• Technical logs — typically 12 months

5. Recipients of personal data

We do not share your personal data with third parties beyond what is necessary. Processors who may process data on our behalf include:

• Providers of email and communication services
• Providers of cloud storage and hosting (including CDN)
• External accounting, legal, and tax advisors
• Public authorities, where required by law

We have concluded data processing agreements with all processors pursuant to Art. 28 GDPR.

6. Transfers to third countries

Where some of our processors (e.g. cloud service providers) are based outside the EU/EEA, data transfers are carried out exclusively on the basis of standard contractual clauses approved by the European Commission or another appropriate mechanism under Art. 46 GDPR.

7. Your rights

In connection with the processing of your personal data, you have the following rights:

• Right of access — to find out what data we process about you
• Right to rectification — for inaccurate or incomplete data
• Right to erasure ("right to be forgotten") — where data is no longer needed for the purpose of processing
• Right to restriction of processing — in cases specified by law
• Right to data portability — to receive data in a structured format
• Right to object — to processing based on legitimate interest
• Right to withdraw consent — at any time, without affecting the lawfulness of earlier processing
• Right to lodge a complaint with the supervisory authority — Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Prague 7, www.uoou.cz

8. Exercising your rights

You may exercise your rights in writing at the Controller's registered office or by email at info@etp-platform.com. We will respond to your request no later than 30 days from receipt. In justified cases, this period may be extended by another 2 months, of which we will inform you.

9. Cookies

This website uses only strictly necessary technical cookies required for basic site functionality. We do not use analytical, marketing, or profiling cookies that would require consent under Section 89 of Czech Act No. 127/2005 Coll.

10. Changes to this policy

We may update this policy from time to time. The current version is always available at etp-platform.com/en/gdpr/. The date of the last update is shown at the top of this document.

11. Contact

If you have any questions regarding the processing of personal data, please contact us at info@etp-platform.com.