This Privacy Policy anticipate what information we collect about you, about the processing of personal data that we carry out when you visit our website or when you use one of our services and what your rights are according to the Law on the protection of personal data. We process personal data legally, fairly, and transparently in accordance with the Law on the protection of personal data and other legal and by-law regulations that we apply in our operations.
Controller: Open-end and close-end investment funds management company KB Invest AD Skopje (hereinafter: KB Invest);
Headquarters: St. Cyril and Methodius 50, Skopje, Republic of North Macedonia
Company number: 6443532
Tax number: 4030009055739
Phone:+389 (0)2 3204 490
e-mail: info@kbinvest.mk
Website: www.kbinvest.mk
In our operations, we simultaneously respect and apply all the principles related to the processing of personal data, to ensure that your personal data are processed in accordance with the regulations for the protection of personal data, that is, that they are:
- process lawfully, fairly and in a transparent manner in relation to you ("lawfulness, fairness and transparency");
- collect only for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes ("purpose limitation");
- adequate, relevant, and limited to what is necessary in relation to the purposes for which we process them ("minimum volume of data");
- accurate and kept up to date, whereby we always take measures to promptly delete or correct data that may be incorrect or incomplete, always guided by the purposes for which we process it ("accuracy");
- kept in a form which permits identification of data subjects, for no longer than is necessary for the purposes for which the personal data are processed, or longer than the legally established period ("storage limitation");
- processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing, and against accidental loss, destruction, or damage, using appropriate technical or organizational measures ("integrity and confidentiality").
We collect and process data related to the following categories of personal data subjects:
- Visitors to our website www.kbinvest.mk and use of the services through the website
As a visitor to our website, we usually collect data about your navigation that is used to analyze visits and to maintain information security. On our website you will also find the term cookies. Internet cookies are small text files that are saved on the device from which you accessed it, with the purpose of recognizing it and improving your user experience. The visitor, i.e. the user of the website, can save, limit, or disable these cookies. Cookies register the interests of the natural person, their preferences and experiences and improve the efficiency of the search for information, but without the possibility of identifying the specific user. You can read more about the use of internet cookies in our Cookie Policy.
When visiting our website, as well as using contact forms, you can voluntarily decide if, when and how you want to contact us (e-mail, online form). KB Invest uses data related to visiting our website for the following purposes:
- facilitation and forwarding of your searches and simple access to the necessary information regarding KB Invest and the products and services we offer;
- complaints, help and support in the use of products and services;
- implementation of prize games, contests and promotional offers;
- usage of the service My Investments of KB Invest;
- monitoring usage habits and experience in order to improve the content of the website;
- for direct marketing purposes (if you have consent to the processing of your data for this purpose);
- technical maintenance and development of the KB Invest website and services.
- Natural persons – clients, i.e. users of our services and products
KB Invest processes personal data necessary for the purposes of establishing a business relationship, for acting on requests of our customers, applications, complaints, activities regarding collection and transfer of claims, as well as for the purposes of fulfilling legal obligations, when processing is mandatory for fulfilling these purposes. Without identification data, KB Invest is unable to provide the appropriate services and products and establish a business relationship with a client in accordance with the law.
The primary source of personal data is the data that the subjects submit when filling out the Application for client registration, and when establishing a business relationship in accordance with the law.
Natural persons who apply, i.e. submit a request for a specific service or product of KB Invest, such as, for example, purchase or redemption of shares, exchange, or transfer of shares in open-end investment funds, submit information containing identity data in their requests and personal data of other persons included in the requests that are necessary for their processing, in accordance with the law.
KB Invest uses these data only for the purposes of its operations, and always in correlation with the regulations for the protection of personal data and at the same time applying all the principles for the protection of personal data that are established in the Law on the protection of personal data.
- Data relating to, and in connection to the business relationship with customers, such as:
- identification data - name, surname, date and place of birth, unique ID number, number of valid identification document (identity card or passport);
- contact data - place and address of residence, telephone number and e-mail;
- data on your creditworthiness - economic, family and property situation, profession, regular and additional income, data on your employer;
- data related to transactions;
- data about the communication channels and in connection with the KB Invest application you use;
- contact details with KB Invest (requests, letters, praises, complaints, reports etc.).
- Data that users voluntarily submit independently of the business relationship
The personal data that we collect when you visit our website, or when you send us an e-mail, or contact us by phone, are those that you voluntarily decide to submit to us, and for purposes established by law, in order to enable us to realize and fulfill the service or product that we offer you (for example: name and surname, residential address, contact phone number, e-mail, data about your social networks, if you have accessed KB Invest information through a social network (Facebook, LinkedIn), data on potential candidates for employment.
- Data related to complaints, appeals, praises, reports of criminal, unethical or other illegal or impermissible behavior
Personal data that you will share with us when you contact us in order to praise us, complain or report an action that in your opinion is criminal, unethical, illegal or impermissible, and in connection with your identity and/or the identity of the one to whom the address refers (for example: name and surname, contact data, content of the request/letter/application which may also contain personal data about the person to whom the address refers, with evidence and attachments, etc.).
We collect personal data through various channels and methods of communication, namely:
- through your visit to the website www.kbinvest.mk;
- through contact forms provided on the website;
- through our e-mail;
- through mail;
- through KB Invest investment agents;
- directly in KB Invest offices.
We collect and process your personal data when:
- you establish a business relationship with KB Invest for the purpose of using our products and services within the framework of business activities;
- you visit and use our website;
- you use the service My Investments;
- you use the contact forms provided on our website;
- you request information about products and services offered by KB Invest;
- you request information from us about you;
- you praise us or when you complain;
- you report a certain suspicion of harmful behavior;
- fill out surveys or other forms of providing your opinion;
- you are a participant in prize games organized by KB Invest;
- you have agreed to contact you for direct marketing purposes;
- ask for advice when using our product or service;
- apply for employment or internship;
- according to the legal and by-law regulations, we will have an obligation to do so.
The processing of personal data in KB Invest processes related to services and products, including those data that are available through the KB Invest website, is performed by KB Invest employees who are in charge and authorized to perform these services and products.
We at KB Invest do not share data about you or your visit to our website to third parties, except in the case of:
- Engagement of service providers, which KB Invest engages as processors in accordance with the Law on the protection of personal data only if they provide a guarantee for the application of appropriate technical and organizational measures in such a way that the processing of personal data will take place in accordance with this law and that they provide protection of your rights;
- Request of judicial or other competent state authorities, institutions and other entities and bodies to exercise their competences and only if there is a legal basis.
The data we collect for you are stored and processed in accordance with the law no longer than is necessary for the purposes for which they are processed. At the same time, the term of keeping your personal data is determined according to the law, and depending on the purpose for which we use and process it. For example, we may need to process it to answer your question about a particular product or service and as a result we may retain personal data for as long as you use our products or services. The moment the need for your data ceases, we will immediately delete it or anonymize it by removing all information that can identify you. If we have requested and received your consent to process your personal data and then you withdraw your consent, and we have no other legal basis to continue with that processing, we will immediately delete your personal data, except in the case where longer terms are established by law for their storage and processing.
If the processing of personal data is necessary to fulfill a legal obligation, in such a case the retention period is determined in the specific law (for example: KB Invest has a legal obligation to keep the client file of all its clients for ten years from the termination of the business relationship with the client or from the date of execution of the occasional transaction, in accordance with the Law on prevention of money laundering and financing of terrorism). In any case, after fulfilling the purpose for which the data was processed, and if there is no other legal basis or legal obligation to keep the personal data, they are deleted, destroyed or anonymized accordingly.
The list of personal data retention periods is an integral part of KB Invest personal data protection documentation, and you as a data subject may always exercise your right of access regarding whether personal data is being processed for you and to get information, inter alia, about the period for which your personal data is stored, and if that is not possible, the criteria that we use in accordance with the law to determine that period.
We process your personal data that is collected through our website, and other types and methods of communication, only when we have a legal reason, purpose and by all means a legal basis for it. In addition, legality is determined based on the purposes for which we collect your personal data, and it is ensured if at least one of the following conditions is met:
- Consent - In certain cases, we will need your consent to process your personal data. In such a case, we may use your personal data only for the purpose for which we have received your consent. For example, we need your consent to process your personal data for direct marketing purposes. If you have agreed to this type of communication and processing, you have the right to withdraw your previously given consent to receive these direct marketing messages at any time in a simple way, after which the processing of your personal data for the purposes of direct marketing will stop.
- Contract - In certain cases, the processing of your personal data will be necessary for the fulfillment of a contract where you are a contracting party, or to take actions at your request before entering into a contract.
- Legal obligation - In certain cases, as a controller we have a legal obligation to process your personal data, such as, for example, a case where we establish a business relationship with you as our client in accordance with the law.
- Legitimate interest - In certain cases, the processing of your personal data will be necessary for the purposes of our legitimate interests. In such a case, we, as an accountable and responsible controller, first assess whether our legitimate interest prevails over your interests, and in terms of respecting your rights and freedoms. For example, it is our legitimate interest to promote our services and products on our website, in which case we analyze what content is viewed by visitors to our website, so that we can understand how it is used and improve its content, or when we analyze which content is viewed most often and in relation to which products and services there is the greatest interest, in order to legitimately strive to improve our services and products.
We at KB Invest strive to always apply the most up-to-date technological solutions and achievements, by applying technical and organizational measures that ensure a level of processing security appropriate to the risk, and in order to protect your personal data from unauthorized processing or their loss, damage or destruction. Taking care of your privacy, we at KB Invest also apply technical measures to prevent internet fraud. Namely, our website uses the kbinvest.mk and kbi.mk domain. In addition to this, KB Invest also uses the domain moivlozuvanja.kbinvest.mk.
We recommend that, every time you log in or search our website, or a link that redirects you to our domains, before sharing your data, check whether one of the KB Invest indicated domains appears in the search engine.
Part of the personal data that we collect about you may be transferred to member countries of the European Union (EU) or the European Economic Area (EEA), for which KB Invest, as a responsible controller, notifies the Personal Data Protection Agency, while continuing to protect your personal data by applying appropriate protective measures in accordance with the regulations for protection of personal data that govern the transfer of personal data.
If there is a need to transfer personal data to other countries that are not members of the EU and the EEA, we ensure the protection of your personal data by consistently respecting and applying appropriate measures regarding the processing in relation to the transfer, and in accordance with the regulation for protection of personal data.
According to the Law on the protection of personal data, you have the right to:
- be informed about the processing of personal data;
- access to personal data;
- rectification and erasure of personal data;
- restriction of processing personal data;
- object and
- data portability.
For additional information and/or to exercise your personal data protection rights, you may contact our Personal Data Protection Officer at the following e-mail: dpo@kbinvest.mk.
The Company will not charge you a fee to access your personal data or to exercise any of the other rights. However, Company may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests, and in such a case, we will notify you.
If you believe that the processing we carry out of your personal data violates the regulations for the protection of personal data, you can submit a request to the Personal Data Protection Agency as a supervisory body that is competent to supervise the legality of the activities undertaken during the processing of personal data in the territory of the Republic of North Macedonia, as well as the protection of the fundamental rights and freedoms of natural persons in relation to the processing of personal data.
The privacy policy will be regularly amended and supplemented according to the changes and our activities according to the law.
If you have concerns or questions related to this privacy policy, you can send us an email at info@kbinvest.mk or you can write to us at 50 Sv. Kiril i Metodij, Skopje, Republic of North Macedonia.