ALPINE BIRD S.R.O.

Address: Chudenická 1059/30, Hostivař,

102 00 Praha 10, Czech Republic

PRIVACY POLICY

Introduction

Your privacy is of paramount importance to us, and we are committed to being transparent about how we collect, use, and share your personal data and other re -
lated information. This commitment aligns with our adherence to the applicable regulations of the European Union and the Czech Republic regarding the process -
ing of personal data, specifically the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, known as the General Data Pro -
tection Regulation (the “GDPR”).

This Privacy Policy ("Policy") is designed to help you understand:

1. WHAT INFORMATION WE COLLECT ABOUT YOU

2. HOW WE USE THE INFORMATION WE COLLECT
3. HOW WE SHARE THE INFORMATION WE COLLECT
4. HOW WE STORE AND SECURE THE INFORMATION WE COLLECT
5. HOW TO ACCESS AND CONTROL YOUR INFORMATION
6. OTHER IMPORTANT PRIVACY INFORMATION

This Policy applies to the personal data we collect about you when you visit our website, download information, request information from us, or use our services.
It also explains your choices regarding the use of your information and the purposes for which we may process the data we collect about you. Your choices
include:

 How you can object to certain uses of information about you.

 How you can access and update certain information about you.

In this Policy, "Alpine Bird," "we," or "us" refers to Alpine Bird s.r.o. (registration number 19816383, registered in the Czech Republic), which controls the infor -
mation collected when you use our services. This Policy also refers to our website www.alpinebird.net, including its domain and subdomains. Our
services encompass processes such as account opening, maintenance, closing, and execution of client orders/requests under agreements by Alpine Bird for our
clients.

Data Controller/Processor of Personal Data

 Name: Alpine Bird s.r.o.

 Registration Code: 19816383
 Address: Chudenická 1059/30, 102 00, Praha 10 – Hostivař, Czech Republic
 Contact: info@alpinebird.net

1. What Information We Collect About You

We collect certain personal data as defined in the GDPR from clients, business contacts (including personnel of clients, prospects, and partners), and other website
users. This information includes, but is not limited to:

Information You Provide to Us: We collect information you provide directly to us when you input it into the Website or services provided through the Website.

 Account and Profile Information: We collect user names, passwords, and other details when you register for an account, create or modify your pro-
file, set preferences, and sign-in through the Website. We track your preferences when you select settings within the Website.
ALPINE BIRD S.R.O.
Address: Chudenická 1059/30, Hostivař,
102 00 Praha 10, Czech Republic

 Personal Details: This includes full name, personal identification code, date and place of birth, place of residence, address, identity document data or
copies, sphere of activity, provided selfie photos, legal documents, due diligence data, and other necessary information to provide services.
 Contact Information: We collect information such as email and phone numbers when you access the user zone or customer platform through the
Website.
 Information About Transactions: Details of transactions made through the Website are collected.
 Customer Support: We collect information from communications between you and Alpine Bird, including emails, calls, and requests made through
the Website.

Information We Collect Automatically When You Use the Website: We collect information about you when you use, browse, and take certain actions on our
Website.

 Connection Information: Standard information from your web browser (such as browser type and language) and your Internet Protocol (IP) address.
 Cookies and Other Tracking Technologies: We may use cookies to provide functionality and recognize you on the Website. For more information,
please see our Cookies and Tracking Notice, which includes information on how to control or opt out of these cookies and tracking technologies.
 Other Data: Any other data generated as a result of using our Website or services not listed here.

2. How We Use the Information We Collect

The way we use your information depends on which services you use, how you use them, and any preferences you have communicated to us. We collect and
process your information only where such processing is lawful under the GDPR and other applicable EU and national laws. The legal basis for processing your
data depends on the services you use and how you use them, which may include:

 Consent: You have given us consent for a specific purpose.

 Legitimate Interest: The processing satisfies a legitimate interest (not overridden by your data protection rights or interests) to improve our services,
market our products, or protect our legal rights and interests.
 Legal Obligation: We need to process your data to comply with a legal obligation.
 Contractual Necessity: The processing is necessary to perform a contract or take steps at your request before entering into a contract.

Specific purposes for which we use the information we collect include:

 To Provide Services and Personalize Your Experience: Authenticating you when you log in, providing customer support, and accessing informa -
tion about your transactions and account details.
 To Improve Our Services: Identifying trends, usage, activity patterns, and areas for integration and improvement of the Website.
 To Communicate About Services: Sending communications via email and within the services, including responding to your comments, questions,
and requests for information.
 To Market and Promote Services: Sending communications aimed at driving engagement and maximizing the value of our services for clients,
prospects, and business partners.
 Customer Support: Resolving issues, responding to requests for assistance, analyzing log files, and improving the services.
 To Protect Our Legal Rights: Using information in connection with legal claims, compliance, regulatory, and audit functions.

3. How We Share Information We Collect

We do not sell your information to advertisers or third parties for commercial purposes. However, we may share your information as follows:

 Relevance: Only relevant personnel of Alpine Bird with a need to access your information for the purposes mentioned will be given access.
 International Transfers: Your information may be stored in the Czech Republic and shared with Alpine Bird offices outside the EU. We process
your information in accordance with standard contractual clauses approved by the European Commission.
ALPINE BIRD S.R.O.
Address: Chudenická 1059/30, Hostivař,
102 00 Praha 10, Czech Republic

 Links to Third-Party Sites: Services may include links to other websites whose privacy practices differ from ours. Your use of such sites is gov -
erned by their privacy policies.
 Compliance with Legal Requests: In exceptional circumstances, we may share your information to comply with applicable law, enforce our agree -
ments, protect the security of our products and services, or protect Alpine Bird, our customers, or the public from harm or illegal activities.

4. How We Store and Secure Information We Collect

Alpine Bird is committed to protecting the personal data you provide. We implement organizational and technical measures to ensure appropriate security of the
personal data we collect, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage.

 Information Storage and Security: Access to your personal data is limited to personnel bound by strict confidentiality obligations.
 Security Measures: We apply sophisticated measures to protect the information system environment where data is stored. However, no internet data
transfer can be fully secure. Therefore, you acknowledge and accept that Alpine Bird is not liable for any damages resulting from the transmission of personal
data.

Retention of Information:

 Account Information: Retained until you delete your account. Some information is retained as necessary to comply with legal obligations, resolve
disputes, enforce agreements, support business operations, and improve services.
 Transaction Information: Retained to fulfill contractual obligations and allow continued use of services by your organization.

5. How to Access and Control Your Information

You have certain choices regarding your information, including:

 Opt-Out of Communications: You can opt out of receiving marketing communications by using the unsubscribe link in emails. Operational mes-
sages about services will continue to be sent.
 Withdrawal of Consent: You can withdraw your consent to the processing of personal data by emailing info@alpinebird.net. Note that this may re -
sult in the closure of your account.

6. Other Important Privacy Information

For inquiries, requests, or complaints about the processing of your personal data, contact info@alpinebird.net. Complaints can also be filed with the Data Protec -
tion Commission ( https://www.dataprotection.ie). Our services are not directed at individuals under 18. We may update this Privacy Policy
from time to time. We encourage you to review it regularly to stay informed about our data privacy practices.

By using our services or website, you consent to the collection and use of your information as described in this Privacy Policy.

Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or for other operational, legal, or regulatory reasons. When we make changes to this Policy,
we will revise the "Last Updated" date at the top of this page. We encourage you to periodically review this Policy to stay informed about how we are protecting
your information.

Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:
ALPINE BIRD S.R.O.
Address: Chudenická 1059/30, Hostivař,
102 00 Praha 10, Czech Republic

 Email: info@alpinebird.net
 Address: Chudenická 1059/30, 102 00, Praha 10 – Hostivař, Czech Republic

Thank you for trusting Alpine Bird with your personal data. We are committed to ensuring that your privacy is protected and respected.

Appendix

Legal References

1. General Data Protection Regulation (GDPR): Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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.
2. Czech Data Protection Authority (DPA): Office for Personal Data Protection (Úřad pro ochranu osobních údajů, UOOU).

Detailed Data Processing Activities

To provide a comprehensive understanding of how we process your data, the following section elaborates on specific processing activities and their legal bases
under the GDPR:

Purpose of Processing: Account and Profile Management

Legal Basis: Contractual necessity

Description: We process your personal data to create and manage your account, personalize your experience, and authenticate you when you log in. This includes
collecting data such as your name, email address, and other profile information.

Purpose of Processing: Service Delivery and Enhancement

Legal Basis: Legitimate interest

Description: To improve our services, we analyze usage patterns and feedback. This helps us identify trends, optimize functionality, and enhance user satisfac-
tion. We collect data such as usage statistics, preferences, and feedback.

Purpose of Processing: Marketing Communications

Legal Basis: Consent

Description: With your consent, we use your contact information to send promotional materials, updates, and offers related to our services. You can withdraw
your consent at any time by opting out of these communications.

Purpose of Processing: Legal Compliance

Legal Basis: Legal obligation

Description: We process personal data to comply with legal and regulatory requirements, such as anti-money laundering (AML) and counter-terrorist financing
(CTF) laws. This includes collecting and verifying identification documents, transaction details, and other necessary information.
ALPINE BIRD S.R.O.
Address: Chudenická 1059/30, Hostivař,
102 00 Praha 10, Czech Republic

Purpose of Processing: Customer Support

Legal Basis: Legitimate interest

Description: To provide effective customer support, we process personal data from your interactions with us, including emails, phone calls, and support requests.
This helps us resolve issues, respond to inquiries, and improve our support services.

Data Subject Rights Under GDPR

As a data subject, you have the following rights under the GDPR:

1. Right to Access: You can request access to your personal data and obtain information about how we process it.
2. Right to Rectification: You have the right to request corrections to any inaccurate or incomplete personal data.
3. Right to Erasure: You can request the deletion of your personal data, subject to certain conditions and exceptions.
4. Right to Restriction of Processing: You can request the restriction of processing your personal data in certain circumstances.
5. Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to
transmit it to another controller.
6. Right to Object: You can object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
7. Right to Withdraw Consent: If processing is based on your consent, you have the right to withdraw it at any time.

To exercise any of these rights, please contact us at info@alpinebird.net. We will respond to your request in accordance with applicable data protection laws.

Security Measures

Alpine Bird implements a range of security measures to protect your personal data, including:

 Encryption: We use encryption to protect personal data during transmission and storage.
 Access Controls: Access to personal data is restricted to authorized personnel who need it for their job functions.
 Regular Audits: We conduct regular security audits and assessments to ensure the effectiveness of our security measures.
 Incident Response: We have an incident response plan in place to address and mitigate any data breaches or security incidents promptly.

Data Retention Policy

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, account-
ing, or reporting requirements. The criteria used to determine our retention periods include:

 Nature and Sensitivity of Data: We consider the type and sensitivity of the data when determining retention periods.
 Legal Obligations: We comply with applicable legal requirements for data retention.
 Business Needs: We retain data as needed to provide our services, maintain accurate records, and support business operations.

Conclusion

Alpine Bird is dedicated to protecting your privacy and ensuring that your personal data is handled with the utmost care and respect. We continuously review and
improve our privacy practices to comply with regulatory requirements and to meet the expectations of our clients and users.

If you have any questions or concerns about this Privacy Policy or how we handle your personal data, please do not hesitate to contact us. Thank you for your trust
and confidence in Alpine Bird.
ALPINE BIRD S.R.O.
Address: Chudenická 1059/30, Hostivař,
102 00 Praha 10, Czech Republic