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Privacy Policy

Principles of personal data processing

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TCF-Cap Services s.r.o., with its registered office at Na Příkopě 392/9, 110 00 Prague 1, Company ID No.: 090 00 909, registered in the Commercial Register maintained by the Municipal Court in Prague under file No. C 328980 (hereinafter also referred to as "We"), as the personal data controller, hereby informs you about the processing of personal data and the principles of protecting your privacy as described below.

Below, you will learn in particular:

1.     what personal data we will process and the purposes of processing;

2.     to whom your personal data may be disclosed;

3.     how long we will process your personal data;

4.     information about cookies;

5.     what your rights are in relation to the processing of your personal data.

If you need any part of the text explained, advice or to discuss further processing of your personal data, you can contact us at any time atlegal@tcfcap.com .

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1. SCOPE OF PERSONAL DATA PROCESSING BY PURPOSE OF PROCESSING

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1.1. Handling of enquiries/requests/suggestions

If you contact us with an enquiry/request/suggestion, we process your personal data that we need to properly handle your enquiry/request/suggestion. This data may include, in particular:

1.     Your first and last name,

2.     your email address,

3.     subject of the enquiry/request/comment.

Personal data is processed on the basis of our legitimate interest, which is to handle your enquiry/request/suggestion.

1.2. Project support – investment recipients

If you express interest in support for your project, we process your data to the extent of:

1.     Your first and last name,

2.     address,

3.     business name,

4.     company headquarters,

5.     identification number and tax identification number,

6.     telephone number,

7.     e-mail address,

8.     project information,

9.     information about your financial circumstances,

10.  bank details,

11.  financial information,

12.  and any other information you provide to us.

In the preparatory phase, we process your data for the purpose of taking measures prior to concluding a contract. If we conclude a contract, we process your data for the purpose of performing the contract and for the purpose of fulfilling the legal obligations that apply to us. The provision of personal data is necessary for the purpose of performing the contract; failure to provide such data may result in the contract not being concluded.

We also process your data on the basis of our legitimate interest, which consists primarily in assessing risks and investment opportunities.

1.3. Project support – investor

If you express interest in supporting our projects, we process your data to the extent of:

1. Your first and last name,

2. address,

3. business name,

4. company headquarters,

5. identification number and tax identification number,

6. telephone number,

7. e-mail address,

8. documents necessary to verify your identity,

9. information about your financial circumstances,

10. bank details,

11. and any other information you provide to us.

In the preparatory phase, we process your data for the purposes of taking measures prior to concluding a contract, preparing a suitable offer, and fulfilling our legal obligations.

If we conclude a contract, we process your data for the purposes of performing the contract and for the purposes of fulfilling our legal obligations. The provision of personal data is necessary for the purposes of performing the contract; failure to provide such data may result in the contract not being concluded.

We also process your data on the basis of our legitimate interest, which consists primarily in assessing risks and investment opportunities.

1.4. Family finance management

If you express an interest in family finance management, we process your data to the extent of:

1. Your first and last name,

2. address,

3. business name,

4. company headquarters,

5. identification number and tax identification number,

6. telephone number,

7. e-mail address,

8. documents necessary to verify your identity,

9. information about your financial circumstances,

10. bank details,

11. and any other information you provide to us.

In the preparatory phase, we process your data for the purposes of taking measures prior to concluding a contract, preparing a suitable offer, and fulfilling our legal obligations.

If we conclude a contract, we process your data for the purposes of performing the contract and for the purposes of fulfilling the legal obligations that apply to us. The provision of personal data is necessary for the purposes of performing the contract; failure to provide such data may result in the contract not being concluded.

We also process your data on the basis of our legitimate interest, which consists primarily in assessing risks and investment opportunities.

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1.5. Conducting selection procedures and keeping records of job applicants

If you wish to join our team, we process the personal data you voluntarily provide to us. This data may include, in particular, information contained in your CV and cover letter, as well as your contact details (telephone number, email address, postal address, LinkedIn contact details).

We use the data you provide to us to stay in touch with you and to assess your suitability for a specific job position.

The legal basis for processing the above data, which is necessary for the recruitment process, is the fulfilment of measures prior to the conclusion of an employment contract and pre-contractual negotiations. If we process other data based on your consent, for example for inclusion in our talent pool, the legal basis is your consent.

We will process your personal data for the duration of the selection process for a specific position and for a further 6 months after its completion on the basis of our legitimate interest in keeping proper records of the recruitment process.

If you give us your consent to contact you with a similar job offer in the future, we will process your personal data for a period of 2 years. You can withdraw your consent at any time during this period.

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1.6. Management of relations with suppliers

If you are our contractual partner (natural person), we process your personal data that we need for the proper fulfilment of our contractual obligations. This data may include, in particular:

1. Your first and last name,

2. address,

3. business name,

4. company headquarters,

5. identification number and tax identification number,

6. telephone number,

7. e-mail address.

Personal data is processed for the purpose of fulfilling the contract, protecting our legitimate interests, which consist primarily of recording the essential circumstances of our contractual relationship with you, and for the purpose of fulfilling the legal obligations that apply to us. The provision of personal data is necessary for the purpose of fulfilling the contract; failure to provide such data may result in the contract not being concluded.

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1.7. Sending commercial communications and marketing

If you give us your consent to send commercial communications and marketing communications, we process your data to the extent of:

1. Your first and last name,

2. e-mail address,

3. telephone number.

We process your data for the purposes of sending commercial communications and other marketing communications (newsletters, invitations to events, information about new products), direct marketing and personalisation of offers.

The legal basis for processing is your consent. You can withdraw your consent at any time by sending an email tolegal@tcfcap.comor by clicking on the unsubscribe link in the email sent to you. Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal.

We will process your personal data for the duration of your consent (usually 5 years) or until you withdraw your consent. If necessary, we may contact you to confirm whether your consent is still valid and whether the data provided is up to date.

If we obtain certain data in connection with the sale of our services and if you have not refused our authorisation, we are entitled, on the basis of legitimate interest, to use your first name, surname, email address and telephone number to send you commercial communications by electronic means (email, SMS), i.e. to inform you about the services we provide, even without your consent. You will have the option to subsequently refuse to receive commercial communications directly in such communications, or please contact us.

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2. PROCESSING OF THIRD PARTY PERSONAL DATA

If you provide us with personal data of third parties (e.g. personal data of employees and customers of our suppliers, other natural persons involved in cooperation with us, or other data we receive in connection with the conclusion or performance of a contract), you are responsible for obtaining the necessary consent for their provision and processing or for fulfilling another legal basis for their processing, and you are obliged to inform us of any changes to such personal data. We will process this personal data in accordance with applicable law for the purpose of performing contracts for the duration of the contractual relationship and further for the period specified by special legal regulations, or for a longer period if there is a justified need to retain the data in connection with a specific case.

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3. PERSONAL DATA PROCESSING PERIOD

We will process your personal data for the period specified for the purpose of processing.

For the purposes of performing the contract, we will process your data for the duration of the contract, until the necessary steps have been taken after the termination of the contract.

We will continue to process your personal data for the purpose of fulfilling our legal obligations for the period specified by the relevant legal regulation from the termination of the contract (usually 10 years).

If the contract is concluded with a legal entity, we process the relevant contact person's data for a period of 12 months after the termination of the contract or up to 12 months from the date on which they ceased to be the contact person.

For the purposes of protecting our legitimate interests, we will process your data for a maximum of four years from the start of data processing, unless otherwise provided by specific legal regulations, or unless there is a justified need to store the data for a longer period in connection with a specific case.

For the purposes of negotiating the conclusion of a contract, we will process your data for a period of 12 months from the start of negotiations on the conclusion of the contract.

In the case of personal data processing based on your consent, we will process personal data for the duration of the consent, i.e. for 2 to 5 years (as described above), or until the consent is revoked, which you can do at any time.

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4. RECIPIENTS AND PROCESSORS OF PERSONAL DATA

We will process your personal data as the controller. We only disclose your personal data to authorised employees and cooperating persons or individual personal data processors contracted by us, or to other controllers, but always only to the extent necessary to fulfil the individual purposes and on the basis of the appropriate legal title for the processing of personal data.

Processors and recipients include, in particular: external law firms, processors who provide us with server, web, marketing cloud or IT services, accountants and tax advisors, auditors, banks and financial institutions (only to the extent necessary for payment processing) and public authorities and agencies on the basis of a legal obligation (in particular the Financial Analytical Office, the Czech National Bank, the Czech Police, law enforcement authorities, courts, bailiffs, notaries, the Tax Office and the Office for Personal Data Protection).

All processors are selected with due care and personal data processing agreements are concluded with them in accordance with Article 28 of the GDPR, which ensure appropriate technical and organisational measures to protect your personal data.

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5. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

When using certain IT services and tools, personal data may be transferred to third countries outside the European Economic Area, in particular to the United States of America. The transfer of personal data to third countries is secured by the following safeguards:

• standard contractual clauses approved by the European Commission pursuant to Article 46(2)(c) of the GDPR;

• European Commission decisions on adequate levels of protection pursuant to Article 45 of the GDPR (e.g. EU-US Data Privacy Framework for certified companies);

• binding corporate rules for certain multinational processors.

The specific recipients in third countries are: [to be completed].

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6. AUTOMATED DECISION-MAKING AND PROFILING

We do not carry out automated individual decision-making, including profiling within the meaning of Article 22 of the GDPR, which would have legal effects on the data subject or significantly affect them in a similar manner.

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7. SECURITY OF PERSONAL DATA

We take all reasonable technical and organisational measures to secure personal data against unauthorised or accidental access, destruction, loss, alteration, misuse and any other unauthorised processing. All persons who come into contact with personal data in the course of its processing are bound by a duty of confidentiality.

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8. COOKIES

Our website www.tcfcap.com only uses necessary cookies that are technically necessary for the functioning of the website (e.g. session cookies). These cookies do not require your consent.

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9. YOUR RIGHTS ARISING FROM THE PROCESSING OF PERSONAL DATA

You have the following rights in relation to our processing of your personal data:

1.     the right to access your personal data;

2.     the right to rectification;

3.     the right to erasure ("right to be forgotten");

4.     the right to restrict data processing;

5.     the right to object to processing;

6.     the right to data portability;

7.     the right to withdraw consent; and

8.     the right to lodge a complaint about the processing of personal data.

Your rights are explained below so that you can get a clearer idea of their content.

You can exercise your rights by contacting us atlegal@tcfcap.com .

The right of access means that you can request confirmation from us at any time as to whether or not personal data concerning you is being processed and, if so, for what purposes, to what extent, to whom it is disclosed, how long we will process it, whether you have the right to rectification, erasure, restrict processing or object, where we obtained the personal data, and whether your personal data is used for automated decision-making, including profiling. You also have the right to obtain a copy of your personal data, with the first provision being free of charge and subsequent provisions subject to a reasonable fee to cover administrative costs.

The right to rectification means that you can ask us at any time to correct or complete your personal data if it is inaccurate or incomplete.

The right to erasure means that we must erase your personal data if (i) it is no longer necessary for the purposes for which it was collected or otherwise processed, (ii) the processing is unlawful, (iii) you object to the processing and there are no overriding legitimate grounds for the processing, or (iv) we are required to do so by law.

The right to restriction of processing means that until we resolve any disputed issues regarding the processing of your personal data, we must restrict the processing of your personal data so that we can only store it and, if necessary, use it for the purpose of determining, exercising or defending legal claims.

The right to object means that you may object to the processing of your personal data that we process for direct marketing purposes or for legitimate interests. If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

The right to data portability means that in the case of automated processing of personal data based on a contract or your consent, you have the right to the so-called portability of this data, which will be provided to you in a structured, commonly used and machine-readable format (e.g. Excel file). You may also have the right to request that your personal data be transferred directly to another personal data controller.

The right to withdraw consent means that we will terminate any processing based on your consent. This does not affect the processing carried out on the basis of your consent prior to its withdrawal.

You can lodge a complaint with the supervisory authority, which is the Office for Personal Data Protection (www.uoou.cz). Contact details for the Office for Personal Data Protection: Pplk. Sochora 27, 170 00 Prague 7, e-mail:posta@uoou.cz , telephone: +420 234 665 111.

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10. FINAL PROVISIONS

We continuously update and amend these Personal Data Processing Principles in line with changes in legislation, case law or our business activities. We will inform you of any significant changes in an appropriate manner, for example by e-mail. If you have any questions or concerns, please contact us at legal@tcfcap.com or at our registered office address.

This Privacy Policy is effective from 1 January 2025 and is updated regularly.

Last updated: January 2026.

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