LEGAL INFORMATION
Privacy policy
Data controller
The data controller for this website is PLANETS GROUP d.o.o., Ivanićgradska ulica 38, 10310 Šumećani, Croatia (VAT ID 90924418279). Contact for data protection enquiries: info@koykan-capital.com.
Purposes of processing and legal basis
Purpose 1: responding to investor enquiries (legitimate interest and the data subject’s consent). Purpose 2: compliance with identity verification and anti-money laundering obligations on entry to the closed portal (legal obligation under the Croatian Anti-Money Laundering and Terrorist Financing Prevention Act and the HANFA framework). Purpose 3: marketing communication (consent). Purpose 4: website analytics (consent via the cookie banner).
Categories of data
Identification data (name, contact details), enquiry data (how you heard about us, investor type, jurisdiction, content of the enquiry), identity verification data where applicable (identity document, proof of residence, beneficial ownership for legal entities, source of funds declaration), technical data (IP address, browser type, cookies).
Recipients of data
Koykan’s internal team, for handling enquiries and investor relations. Odoo CRM as a data processor under a data processing agreement. Sumsub as the identity verification processor under a data processing agreement. HANFA, where required by Croatian law. Legal, audit and tax advisers, subject to a duty of confidentiality.
Retention periods
Enquiry data is retained for the duration of the active relationship, and thereafter for as long as required by applicable capital markets legislation. Identity verification data is retained for five years from the end of the relationship, in accordance with the Anti-Money Laundering and Terrorist Financing Prevention Act. Marketing data is retained until consent is withdrawn. The specific periods will be confirmed by legal counsel prior to publication.
Data subject rights
Access, rectification, erasure, restriction of processing, portability, objection, withdrawal of consent, and the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP). The practical procedures for exercising each right will be described in the final version of this policy.
International transfers
Description of transfers outside the EEA together with the applicable safeguards (standard contractual clauses, adequacy decisions).