Privacy Policy
RIVENITY SICAV a.s., IČO: 245 92 064, se sídlem Opletalova 1626/36, Nové Město, 110 00 Praha 1, zapsaný v obchodním rejstříku vedeném u Městského soudu v Praze pod sp. zn. B 30530, zastoupený DELTA Investiční společnost, a.s., IČ: 032 32 051(dále jen „Fond“).
1. Introductory Provisions
The Fund, as the personal data controller, in accordance with the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter referred to as "GDPR"), Act No. 110/2019 Coll., on the processing of personal data, and other relevant legal regulations, hereby informs the Fund's investors, clients, and partners (hereinafter referred to as the "Client") of the scope, purpose, and duration of the processing of their personal data and of the rights arising from the GDPR.
2. General Principles and Obligations
The Fund processes personal data in accordance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality.
Client Obligations: The Client or any other person providing personal data (e.g., a representative of a legal entity) is obliged to provide the Fund with true, accurate, and complete information and to inform the Fund in writing of any change thereto without undue delay.
Fund Commitments: The Fund collects data only to the extent necessary to fulfill the purpose and undertakes to protect it. It ensures that data processing systems are used only by authorized persons based on special user authorizations, keeps records of processing activities according to Art. 30 of the GDPR, and adopts technical and organizational security measures.
3. Scope of Processed Personal Data
The Fund processes data primarily to the extent provided by the Client within the contractual documentation and the fulfillment of legal obligations. These include, in particular:
Identification and contact details: First name, surname, title, date and place of birth, personal identification number (if provided), ID number (IČO), tax ID number (DIČ), address of permanent residence or place of business, e-mail and telephone number.
Financial and investment data: Bank account number, investment volume, investment profile and investor classification pursuant to Act No. 240/2013 Coll., on Investment Companies and Investment Funds (ZISIF).
Regulatory data (AML/KYC): Copy of identity card or passport, documentation for the prevention of money laundering (AML) and know your customer (KYC) procedures, including information on political exposure (PEP status) and proof of origin of funds.
Technical data: IP address (in electronic communication).
4. Purposes, legal bases, and processing period
As an investment fund for qualified investors, the Fund processes personal data mostly without the consent of the Client, based on the following legal grounds:
Compliance with legal obligations (Art. 6(1)(c) GDPR): Fulfillment of obligations arising from the ZISIF, Act No. 253/2008 Coll. (AML Act), tax and accounting regulations, and requirements of supervisory authorities. Records for AML/KYC purposes are kept in accordance with the law for a period of 10 years from the termination of the business relationship.
Performance of contractual obligations (Art. 6(1)(b) GDPR): Execution of the subscription agreement, management of the investor account, and exercise of shareholder rights. The data is kept for the duration of the contractual relationship.
Legitimate interests of the Fund (Art. 6(1)(f) GDPR): Protection of the Fund's legal claims, complaint procedures, or judicial enforcement of receivables. The data is kept for the duration of the limitation periods, up to a maximum of 10 years from the termination of the contractual relationship.
Consent to processing (Art. 6(1)(a) GDPR): Data processing may also occur on the basis of consent granted, e.g., for the purpose of sending marketing communications. Consent can be revoked at any time and the data is kept until its revocation.
5. Recipients of personal data
The Fund shares personal data with third parties only to the extent necessary. Personal data is not transferred to third countries outside the European Economic Area, except where required by law. Recipients include:
Fund Partners: Fund Manager, Fund Administrator and Fund Depositary, who process the data for the performance of their legal and contractual functions.
Public authorities: Czech National Bank (CNB), Financial Analytical Office (FAÚ), tax administrators, courts and law enforcement authorities within the scope of their legal powers.
Contractual processors: External tax, accounting, legal or IT advisors of the Fund. All processors meet the requirements of the GDPR and provide appropriate data protection guarantees. The Fund will provide a list of processors upon request.
Financial institutions: Banks and insurance companies for the purposes of making payments and fulfilling obligations.
6. Rights of Data Subjects
Under the GDPR, clients have the following rights in relation to their personal data:
The right of access to your personal data (Art. 15).
The right to rectification of inaccurate data (Art. 16).
The right to erasure of data, provided this does not conflict with the Fund's legal obligations (Art. 17).
The right to restriction of processing (Art. 18).
The right to data portability (Art. 20).
The right to object to processing (Art. 21).
The right to withdraw consent, if the processing is based on consent.
Rights can be exercised in writing at the address of the Fund's registered office or by email at: info@klrock.com. The client also has the right to file a complaint with the Office for Personal Data Protection (www.uoou.cz). The processing does not involve automated decision-making or profiling within the meaning of Article 22 of the GDPR.
7. Final Provisions and Safety Measures
The Fund, its statutory representatives, manager, administrator, and all potential collaborators are strictly bound by confidentiality regarding all processed personal data and implemented security measures. This obligation continues even after the termination of the contractual relationship. Without the Client's consent or a legal basis, the data will not be provided to any unauthorized third party.
In the event of any changes to this policy, you will always find the current version on the website: www.rivenity.cz. For any questions regarding the processing of personal data, please contact us at the email: info@rivenity.cz.
In Prague on March 1, 2026