The company IBIS INGOLD LTD., having its registered office at 20-22 Wenlock Road, London, N1 7GU, United Kingdom, registered under number 11599014, acting on behalf of and on the account of the company IBIS InGold®, a. s., having its registered office at Rybná 682/14, Staré Město, 110 00 Praha 1, Česká republika, entered in the Commercial Register maintained at the Metropolitan Court in Prague, file B 18920, Company Number: 25525433, Taxpayer Identification Number: CZ25525433, mailing address: Jiráskova 908, 676 02 Moravské Budějovice, Česká republika, contact e-mail: [email protected], website: www.ibisingold.com (hereinafter referred to as the “Company”), provides its customers with information in this document on the manner in which it processes their personal data, doing so 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 (hereinafter referred to as the “Regulation”).

A) Concluding and performing contracts

Should you conclude a purchase contract or order with the Company or express an interest in doing so, the Company, as the personal data controller, will process your personal data in the following way.

Processed personal data

The Company will process the personal data that you provided it during registration of the Customer’s Account, the purchase contract, or the order concluded between you and the Company (hereinafter referred to as the “Contract”), within the bounds of concluding these or when amending them, and in fulfilling the rights and obligations arising from such Contracts. Primarily the following personal data shall be processed: first and surname, address, date of birth, e-mail address, bank account number, payment card number, and telephone number, and any other personal data relating to the subject-matter of the Contract communicated to the Company in connection with concluding or performing the Contract.

The purpose of personal data processing

The Company shall process your personal data

• For the purpose of concluding a Contract between you and the Company and discussions to that end. The processing of your personal data for this purpose is required to conclude a Contract in accordance with subparagraph 6(1)(b) of the Regulation. Your personal data shall be processed for this purpose until a Contract has been concluded, or if no Contract is concluded, until such time as it is entirely undoubted that no Contract shall be concluded.

• For the purpose of performing a Contract between you and the Company and for the exercise of the rights and obligations arising from it, in particular for assurance of the purchase and delivery of investment precious metals. The processing of your personal data for this purpose is required for performance of the Contract in accordance with subparagraph 6(1)(b) of the Regulation. Your personal data shall be processed for this purpose for the duration of the obligations arising from the Contract.

• For the purpose of setting up (unless already set up) and managing your Customer’s Account, which is one of the fundamental forms of communication between you and the Company. The processing of your personal data for this purpose is required for the conclusion and performance of the Contract in accordance with subparagraph 6(1)(b) of the Regulation. Your personal data will be processed for this purpose until the Contract has been concluded and for the duration of the obligations arising from the Contract (or any other contracts between you and the Company for the conclusion and performance of which the Customer’s Account is required). If no Contract is concluded, your personal data will be processed for this purpose until such time as it is entirely undoubted that no Contract shall be concluded.
  
  If, however, you have provided consent to this in accordance with subparagraph 6(1)(a) of the Regulation (for example, when setting up the Customer’s Account or concluding the Contract), your Customer’s Account will be managed thereafter until such time as your Customer’s Account is closed at your request or at the decision of the Company. Such processing of your personal data is not required for the performance of the Contract. You may withdraw consent to personal data processing for this purpose at any time by using the contact e-mail or Customer’s Account.

• If you have provided consent to this in accordance with subparagraph 6(1)(a) of the Regulation (for example, when concluding the Contract), your personal data will also be processed for the purpose of sending news and information about new products or services. Such processing of your personal data is not required for the performance of the Contract. Your personal data shall be processed for this purpose for the duration of the obligations arising from the Contract (or from another contract concluded between the Contracting Parties) and for a period of a further 4 years. You may withdraw consent to personal data processing for this purpose at any time by cancelling the Customer’s Account or by using the contact e-mail or the Customer’s Account and the Company will erase personal data from the database used for marketing purposes.

• The Company may also use your personal data to protect its rights and legitimate interests, in particular in the case of judicial disputes associated with the Contract, and the prevention of such disputes. Such processing of your personal data is required for the purposes of the legitimate interests of the Company in accordance with subparagraph 6(1)(f) of the Regulation. Your personal data may be processed for the purposes for a time corresponding to the relevant limitation periods, generally for up to ten-to-fifteen years from the commencement of the last of the limitation periods. This time limit is interrupted and does not run if you exercise any right vis-à-vis the Company in relation to the Contract between you and the Company, until the time at which the judgment of the competent public authority on the right exercised becomes final. An objection may be lodged against personal data processing for this purpose, according to Article 21 of the Regulation.

B) Management of the Customer’s Account

If you set up a Customer’s Account at ibis.ibisingold.com, the Company, as the personal data controller, will process your personal data in the following way.

Processed personal data

The Company will process the personal data about you presented in the Customer’s Account. Primarily the following personal data will be processed: first name and surname, address, date of birth, e-mail address, bank account number, payment card number, and telephone number.

The purpose of personal data processing

The Company processes your personal data for the purpose of managing the Customer’s Account. The Customer’s Account can be used to conclude a purchase contract or order and is used to send the customer news and information about new products or services. Your personal data is processed for this purpose with your consent, in accordance with subparagraph 6(1)(a) of the Regulation, which you give to the Company when setting up the Customer’s Account. Your personal data will be processed for this purpose until such time as your Customer’s Account is closed at your request or at the decision of the Company. You may withdraw consent to personal data processing for this purpose at any time by using the contact e-mail or Customer’s Account.

Should you conclude a purchase contract or order with the Company, or express an interest in doing so, your Customer’s Account will be managed for the purpose of concluding and performing those contracts - see Part A) above for details.

C) Recipients of personal data

The Company pays strict attention to the fact that all obligations which arise on the controller from the Regulation are fulfilled, and the Company will primarily process your personal data itself or through the following processor: Axians redtoo s.r.o., having its registered office at Na strži 2097/63, Krč, 140 00 Praha 4, Česká republika (Czech Republic), entered in the Commercial Register maintained at the Metropolitan Court in Prague, file C 200961, Company Number 24236594, Taxpayer Identification Number CZ24236594, so that you, as the data subject, are protected from unauthorised interventions in your private and personal life.

Your personal data may be disclosed to the following third parties (recipients) in accordance with the legal regulations which govern personal data protection:

• the company IBIS INGOLD LTD., having its registered office at 20-22 Wenlock Road, London, N1 7GU, United Kingdom, registered at Companies House under number 11599014, if representing the Company in entering into a Contract with you;

• other contractual partners of the Company that might be involved in the arrangement and management of the Contract or of other contracts between you and the Company (in particular commercial representatives);

• providers of professional services such as lawyers and tax advisors bound to the statutory or contractual obligation of confidentiality;

• persons that have a legal ground for access to data (for example, law enforcement bodies or other audit bodies having legal authorisation to access information); or

• other parties if this is required to protect the rights of the Company (for example, the court).

• Your personal data will not be transferred to countries outside the European Union or to international organisations. The exception here is the company IBIS INGOLD LTD., having its registered office at 20-22 Wenlock Road, London, N1 7GU, United Kingdom, registered at Companies House under number 11599014, if representing the Company in entering into a Contract with you.

D) Your rights arising from the Regulation

As the data subject, you have all rights according to the Regulation, in particular:

• the right to receive from the Company confirmation that your personal data are or are not being processed and if so the right of access to that personal data and to the other information specified in Article 15 of the Regulation, in particular about the purpose of their processing, the categories of concerned personal data, and the categories of recipients to whom they have been or will be disclosed;

• the right to demand the rectification of inaccurate data to concern you, according to Article 16 of the Regulation;

• the right to demand the erasure of personal data to concern you if any of the grounds specified in Article 17 of the Regulation is in place; for example if your personal data are no longer required for the purposes for which they were collected or otherwise processed;

• the right to request that the Company restrict processing if any of the cases specified in Article 18 of the Regulation should occur; in particular if you contest the accuracy of the processed personal data;

• the right to receive the personal data to concern you in a structured, commonly used, and machine-readable format and the right to transfer such data to another controller, without the Company preventing this, under the terms and conditions specified in Article 20 of the Regulation;

• the right to lodge an objection to the processing of your personal data according to Article 21 of the Regulation;

• The right to lodge a complaint with the supervisory authority if you believe that the processing of your personal data leads to breach of the Regulation; the supervisory authority in the Czech Republic is Úřad pro ochranu osobních údajů (Office for Personal Data Protection), having its registered office at Pplk. Sochora 27, 170 00 Praha 7.

You may exercise the rights specified above at the Company’s address or at the contact e-mail address.

E) Processing the personal data of third parties

If you provide the Company with any personal data relating to a third party, for example a person authorised to receive the Subject-matter of Purchase or the owner of an account, please make sure that those personal data are transferred in accordance with the Regulation. In particular, please ensure that such person has been properly informed of the fact that his/her personal data will be transferred to the Company, and for which purpose.

Such personal data will be processed for the purposes of the legitimate interest of the Company in the due provision of services, in accordance with subparagraph 6(1)(f) of the Regulation, for the time absolutely required to achieve the purpose of processing.

The value of investment and the income from it may fluctuate during the investment period and the invested amount returns are not guaranteed. The information specified on the websites of the Company is of indicative character and does not serve as a guideline for investing and does not represent an investment recommendation or other invitation to buy or sell any investment tool and no rights can be based on it. The calculations are approximate and are specified based on the conditions and prices valid at the time given. If any revenue is mentioned, it should always be based on the principle that the last revenue is not a guarantee of any future revenue and that any investment includes the risk of fluctuations and changes of exchange rates and that the return of the originally invested funds is not by any means guaranteed and so is not the amount of any potential profit. In case of predictions, it is not possible to provide any guarantee that the real development of markets shall proceed according to the perspectives considered. The expected future performance is based on presumptions that might not occur. Information specified on the websites of the Company is gained from the resources that are considered by the Company as reliable, though, the Company is not responsible for completeness, reliability, up-to-dateness and/or correction of all the above-mentioned information and is not responsible for any damage that shall occur in relation to its use. The real investment returns shall depend on the real market development. Not all fees need be included in the stated calculations, neither does the resulting amount include inflation.

Your investment in precious metals should be always preceded by consultations with a professional advisor who will ensure that the investment planned shall be in compliance with your knowledge and experience in the area of precious metals and that the investment planned shall be in compliance with your needs and priorities. Information on the past performance or future performance anticipated provided by the professional advisor is of a purely informative character and is not any guarantee of any future return. The Input Price Increase of the Purchase Contract iiplan^®; is found in the price list, which is freely available at the Company’s website.

The storing money into precious metals belongs among the most advantageous long-term products, however, by its nature, it is investment, which contains risks. The value of portfolio and individual investment tools may in time both grow and decline. The past revenues are not a guarantee of future revenues. Basic product information is also found in the Information provided to interested parties before concluding a Purchase Contract iiplan^® (pre-contract information) or in the (Commercial) Terms and Conditions, with which you may familiarise yourself at the Company’s website before investing.

Buyer – a consumer is entitled to an out-of-court consumer dispute settlement. The subject of an out-of- court consumer dispute settlement is the Czech Trade Inspection Authority (www.coi.cz).

Out-of-court dispute settlement

If you are not satisfied with our services, you can lodge a written complaint to the address for delivery or to e-mail address [email protected]. We will handle a complaint within the shortest possible time. We handle complaints as quickly as possible, in that we will invariably confirm having received your complaint to your e-mail address within 10 calendar days and will subsequently inform you of the result of the investigation.

If we fail to settle the dispute (complaint, claim), you are as a buyer – consumer entitled to an out-of-court consumer dispute settlement. The subject of an out-of-court consumer dispute settlement is the Czech Trade Inspection Authority (www.coi.cz). The consumer has the right of initiation of an out- of-court dispute settlement only when he fails to solve the dispute directly with the seller. The consumer is obliged to prove this fact to the Czech Trade Inspection Authority. The consumer is entitled to submit a proposal to the Czech Trade Inspection Authority at latest within 1 year from the day of exercising his right, which is the subject of the dispute, by the seller for the first time. The out-of-court consumer dispute settlement shall not be subject to a charge. Limitation periods stop to run from the moment of initiating the out-of-court consumer dispute settlement. It is without prejudice to your right to apply to the courts. The court having jurisdiction in accordance with legal regulations of the Czech Republic is entitled to decide on disputes arising out of the Contract concluded.

Seller

Representative for the purpose of concluding a contract

Statutory body – board of directors

Chairman of the Board of Directors: LIBOR KOCHRDA

Vice-Chairman of the Board of Directors: MILADA KSELÍKOVÁ

Vice-Chairman of the Board of Directors: Ing. ZDEŇKA HOBZOVÁ

Supervisory Board

Chairman of the Supervisory Board: Ing. RADEK KOCHRDA

Vice-Chairman of the Supervisory Board: LADISLAVA HARTMANOVÁ

Member of the Supervisory Board: DOBROMILA DAVIDOVÁ

Registered capital

1 000 000 CZK

As part of the access to its website, the Company processes log files on the access to the websites to protect its rights and legitimate interests. These log files are processed without the consent of the website visitor.

As part of the log files, the Company processes the following data that may (but do not have to) include personal data of the website visitor:

• a website from which the visitor came to the websites of the Company;

• IP address;

• date and time of access;

• eventual visitor’s question;

• code of the answer http;

• transferred data groups;

• information on the search engine and operational system of the computer that was used to visit the website.

Cookies are small text files that are stored on the hard disk (including mobile devices) of the user/visitor by websites. This file identifies specific information from previous visits of the device to the website. The information can include for example IP-address of connecting PC, date and time of access, referrer URL (from where the visitor has arrived to the page), pages/products visited on our website, used type of browser and visited pages and others. The validity/functionality of cookies shall expire at the end of the Internet session (after disconnecting the device from the website/Internet) or after a certain period of time.

We hereby inform you that our servers use so-called cookies for their activities in accordance with the provision of § 89 of Act No 127/2005 Coll. on electronic communications. – Cookies are generally very small data files/records which are sent by our servers to your computer and that enable better use of our servers and adapting their content to your needs and preferences. Cookies are used by almost every website in the world. Cookies are generally useful because they enhance the user-friendliness of repeatedly visited websites. If you use the same computer and the same browser for your visit to our website, cookies shall help your computer remember visited sites and your preferred setting of individual websites.

Reason for use

Our company makes efforts to use these files and information in order to enhance and develop services which we offer and provide here. The use of cookies enables us to improve the usability of websites for the visitor and makes their use more enjoyable. We use cookies so that no user would be identifiable based on the information/data thus obtained, not even while using other information available to us.

There are two types of cookies – session cookies that are stored on your computer and that expire at the end of a browser session and persistent cookies that are stored on your computer for a longer period of time.

• Session cookies enable to store information when moving from one website to the other and they eliminate the need to repeatedly enter some data.

• Persistent cookies help us identify your computer if you re-visit our website, however, they do not enable to identify you personally. Another advantage of persistent cookies is that they enable us to adjust our website to your interests and not to display the same advertisement repeatedly. However, we cannot identify you personally in this case either and we store appropriate data fully anonymized and we do not associate them with any other data.

Setting of cookies in browsers:

Standard websites (Internet Explorer, Mozilla Firefox, Google Chrome and others) support management of cookies. Within the setting of browsers, you may manually delete individual cookies, block or completely prohibit their use, they may be blocked or enabled only for individual websites. For more detailed information, please use the help of your browser. If cookies are enabled in your current web browser, we will assume that you agree with the use of standard cookies by our servers.

Options of setting the management of cookies within main browsers can be found here:

• Google Chrome

• Microsoft Edge

• Internet Explorer

• Mozilla Firefox

• Safari

Third-party services on the websites

Please note that elements allowing the collection of personal data or monitoring the behaviour of users of the site by third parties may be placed on our websites. Third parties that can gain access to your personal data based on the character of the service you use or have used may be:

• parties conducting the analysis of traffic to our websites or Internet,

• providers of payment gateways (or providers of payment cards),

• operators of advertising systems in relation to targeted advertising or so called remarketing.

Data gained as part of targeted advertising or remarketing may be shared with other parties to the relevant network, however, always only in the form that does not allow your identification. Our websites also enable the function of content sharing on social networking sites through third-party applications such as sharing by means of the button “Like” by Facebook, further sharing within the social networks Twitter, Google+. These applications may collect and use information on your behaviour on our websites.

Google Analytics and Google Adwords
The Company uses the Google Analytics service, developed and operated by Google Inc., having its registered office at Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) in order to analyse websites by means of cookies.

The analysis by means of the Google Analytics service is performed thus that information on the use of the websites generated by cookies is transferred to a Google server located in the USA where it is analysed.

Google shall not associate the data transferred, including eventual shortened IP addresses, with other data. The visitor of the websites can prevent the collection of cookies and their analysis by means of the Google Analytics service by changing the setting of the browser.

As part of Google Analytics, the Company uses related advertising functions provided by Google such as Google Display Network (GDN) Impression Reporting, extended reporting of anonymous demographic data (e. g. age, gender, interests) or showing ads on the content network, based on product views (so called remarketing), including Google AdWords used for customizing ads and improving targeting of ads and so called remarketing. The company can then offer visitors of its websites advertising contents which will be as interesting as possible.

The visitor of the websites of the Company can disable or adjust the personalization of advertising by means of their Google account. If the visitor of the websites does not agree with the collection of cookies, he/she can prevent it by changing the setting of his/her browser, namely by means of the function “Options” or “Help”.

The websites of the Company include third-party social plug-in by means of which the website visitors can share the content with their friends and other contacts. The social plug-in is a button used for sharing contributions from the websites of the Company with other users of the social network given.

These are:

• Facebook’s Social Plug-in which is administered by Facebook Inc., 1601 South California Avenue, Palo Alto, CA 94304, USA. The operator of facebook.com is Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland. These plug-ins are marked with a Facebook logo. For Facebook’s Privacy Policy see facebook.com.

• Youtube Plugin which is administered by YouTube, LLC 901 Cherry Ave., 94066 San Bruno, CA, USA, subsidiary company of Google Inc., Amphitheatre Parkway, Mountain View, CA 94043. This plug-in is marked with a YouTube logo. For YouTube’s Privacy Policy see youtube.com.

• Instagram Plug-in, which is administered by Instagram Inc., 1601 Willow Road, Menlo Park, California 94025, USA. This plug-in is marked with an Instagram logo. For Instagram Privacy Policy see instagram.com.

• Twitter Plug-in is operated by Twitter Inc. This plug-in is operated by Facebook Inc., 1601 South California Avenue, Palo Alto, CA 94304, USA. This plug-in is marked with a Twitter logo. For Twitter Privacy Policy see twitter.com.

• Google+ Plug-in is operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. This plug-in is marked with a Google+ logo. For Google Privacy Policy see google.com.

• YANDEX Plug-in is operated by Yandex Europe AG, a Swiss company, having its registered office at Werftestrasse 4, 6005 Luzern, Switzerland. This plug-in is marked with a “Y” logo. For Yandex Europe AG Privacy Policy see yandex.com.

• LinkedIn Plug-in is operated by LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085 USA. This plug-in is marked with an “in” logo. For LinkedIn Corporation Privacy Policy see linkedin.com.

These social plug-ins are not administered by the Company. Therefore, the Company is not responsible for any processing of personal data by the above-mentioned operators (administrators) of these plug-ins or websites to which they refer nor for their functionality or eventual damages that could be caused by them.

The appearance and content of plug-ins in the browser are determined by these social networks. Plug-ins shall be automatically integrated into the websites.

If you visit any of the Company’s websites by means of one of these plug-ins, your browser (e. g. Internet Explorer) shall automatically create a link to the server of the social network given, regardless the fact if you used the plug-in. Information on your visit to the Company’s website shall then be shared by means of this link.

If you are logged on to one of the social networks during your visit to the Company’s websites, the data transferred shall be connected to your user’s account on the social network. This is true even if you are using a plug-in.

The Company does not control the processing of data on the part of the above-mentioned services and applications. If it concerns processing of data performed by them, you must contact the operator of such services.

This information summarizes basic principles of processing personal data on the part of IBIS InGold if it concerns recording phone calls on the customer’s helpline. The customer shall be always informed on recording the call (e. g. by informing that the call is being monitored).

If you do not want your calls with our call centre to be recorded, contact us in another way or ask for a call from unmonitored line. Our employees or our commercial representatives shall then call you back from the unmonitored line. However, we may ask you in this case to confirm your will otherwise (e. g. by written declaration which shall be archived by us).

Our IBIS InGold application and tools may contain antimalware / antivirus detection and detection of amended administrator rights (root/jailbreak) to determine if the device, from which you access our applications or tools, is secure or has been affected by a virus risk. These tools collect and then process information about the device security setting (e.g. deactivated screen lock, etc.), information about integrity of application and operating system (e.g. modified administrator rights [root/jailbreak]; start in emulator, use of hooking framework, etc.), device information (e.g. device model, anonymous device identifier to check whether the application is run on the same device as originally installed), metadata of potentially harmful applications and setting of notifications.

The above-mentioned data are processed in order to prevent fraud, to ensure user security, to comply with legislation and to conduct analysis for the purposes of improving security and evaluating potential threats.

The contents of our websites are protected by copyright. Any use of the contents of these websites or their part, especially in the form of reproduction, distribution, processing and association with other work, is prohibited except for personal use. The use other than for personal needs is allowed only with the previous written consent of the Company and eventually of authors of copyright works included on these websites.

The Company is an entitled user of all trademarks, logos and signs placed on these websites (hereinafter referred to as “signs”). Nothing on these websites may be considered as granting a license or permission to the use of signs in any way or form.