JonatanMars Invest, borznoposredniška družba d.o.o..
Dunajska cesta 5, 1000 Ljubljana, Slovenia
Tax number: SI 79822819
Registration number: 9125108000
e-mail: info@jonatanmars.com website: https://jonatanmars.com
PRIVACY POLICY
1. GENERAL PROVISIONS
1.1. Together with the General Terms of Business (hereinafter also: the "Terms"), this privacy policy
governs the collection, processing and use of personal data by JonatanMars Invest,
borznoposredniška družba d.o.o., Dunajska cesta 5, 1000 Ljubljana, registration no. 9125108000
(hereinafter: JonatanMars Invest), when using:
o the website at the domain https://jonatanmars.com (together with all subdomains,
hereinafter also: the "Website"),
o the mobile application and web application (hereinafter also: the "Mobile Application"),
which provides services to users with registered accounts and unregistered users in
accordance with the Terms,
o all other services accessible through the mobile application managed by JonatanMars
Invest (hereinafter: the "Services").
This policy sets out the basis on which JonatanMars Invest collects, processes and uses
personal data that you provide to us directly or indirectly through use of the Mobile Application.
1.2. Personal data means any information that can be linked to a specific person (also referred to as
"you" or the "user") and can be used to identify that person directly or indirectly, in particular
by reference to an identifier such as a name, address, email address, identification number,
location data, an online identifier, or one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that natural person, as well as other
information that the user provides to obtain and manage a registered account (collectively referred
to in this policy as "personal data").
1.3. JonatanMars Invest is committed to protecting and respecting your privacy and your right to fair
and lawful processing of your personal data. This privacy policy is intended to help you understand
how we collect, use, process and retain your personal data and describes your choices regarding
certain types of processing. We understand the importance of handling personal data and assure you
that we comply with all applicable data protection laws, including the General Data Protection
Regulation (EU) 2016/679 (hereinafter: the GDPR).
1.4. Unless otherwise stated, terms used in this document have the same meaning as in the GDPR.
1.5. JonatanMars Invest is the controller of personal data. This privacy policy is issued on behalf of
JonatanMars Invest. References in this privacy policy to JonatanMars Invest, "we", "us" or "our"
refer to JonatanMars Invest as the company responsible for processing your data.
1.6. Any questions about this privacy policy, including requests, may be sent using the contact details below.
1.7. JONATANMARS INVEST CONTACT DETAILS:
Full name of the legal entity: JonatanMars Invest, borznoposredniška družba d.o.o.
Email address: privacy@jonatanmars.com
Postal address: Dunajska cesta 5, 1000 Ljubljana, Slovenia
1.8. PROTECTION OF PERSONAL DATA
JonatanMars Invest is responsible for:
▪ monitoring compliance with GDPR and local data protection laws;
▪ raising awareness of data protection issues;
▪ training JonatanMars Invest staff and conducting internal audits; and
▪ cooperation with supervisory authorities.
If you have any questions about this privacy notice/policy, including requests to exercise your
rights, write to JonatanMars Invest at privacy@jonatanmars.com.
Complaints
If you have any concerns that your rights concerning your personal data have been infringed, you
may contact us at any time. If you are not satisfied with our response, you always have the right
to lodge a complaint concerning your personal data with the Information Commissioner.
JonatanMars Invest:
▪ will always keep your personal information secure and private.
▪ will not sell your personal data.
▪ allows you to manage and review your marketing preferences at any time.
JonatanMars Invest does not collect or process data concerning your genetic or physiological
characteristics, mental condition, racial or ethnic origin, cultural or social identity, political
opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual
orientation.
2. COOKIE POLICY
2.1. When users access the Website or use the Mobile Application, JonatanMars Invest may place
small data files called cookies on users' computers or other devices. This helps us provide a
good experience when you use the applications or browse our Website and allows us to improve
the Mobile Application and our Website. JonatanMars Invest uses these technologies to recognise
you as a user of the Website, Mobile Application and/or other Services, customise the Website
and advertising content, measure communication and marketing effectiveness, and collect
information about users' devices to reduce risk, help prevent fraud and promote trust and security.
2.2. We may use cookies, pixel tags, web beacons and other tracking technologies in connection with
our Services, including information about your browsing behaviour in the Mobile Application.
2.3. Most web browsers accept cookies by default. You can reject most cookies if your browser or
browser extension allows this, but removing or disabling cookies may limit your use of the
Services and their functionality. We may also use certain persistent cookies that are not affected
by your browser settings, but we will use them exclusively for identity verification and
fraud prevention. For more information about cookies and how to block, delete or disable them,
see your browser instructions or contact us at privacy@jonatanmars.com.
2.4. Cookie schedule: Detailed information about the cookies used on JonatanMars Invest websites
is available at https://jonatanmars.com/piskotki.
3. INFORMATION WE COLLECT ABOUT YOU
JonatanMars Invest may collect, use, store and transfer various types of personal data about you,
which we classified as follows:
3.1. Submitted personal data:
This is personal data that you provide by completing forms on the Website, Mobile Application
and/or applications, or by corresponding with us by post, telephone, email or otherwise. This
includes personal data that you provide in the following ways:
− completing forms in the application, on the Website and/or in the Mobile Application and/or
subscribing to our news (such as JonatanMars Invest news and updates about the latest
developments concerning the Mobile Application and the company, promotions and industry
news), downloading documents from the Website, registering for a webinar, entering a
competition, survey or other JonatanMars Invest marketing activity; and/or
− corresponding with us actively (for example by email, through chat functions in the application
and/or on the Website, through our customer service, or otherwise) and/or participating in
discussions or other social media functions in the application or on the Website;
− providing the required personal data and documents for user identification and fraud detection,
the prevention of any other financial crime, or other purposes necessary for successful use
of the Mobile Application.
(hereinafter also collectively: Submitted personal data)
3.1.1. The submitted personal data includes in particular:
1. Identity data: first name, maiden name, surname, job title, date of birth,
username, password and other registration data and/or similar identifiers,
2. Contact information: address, email address, telephone number,
3. Financial data, such as, for example:
• the balance of your assets on (registered JonatanMars Invest account),
• the origin of the funds deposited on the registered JonatanMars Invest account,
• the financial background of all assets deposited into the registered JonatanMars Invest
account, including the occupation and business activity of the beneficial payer,
• and/or your bank account information, including your bank account number,
bank code, IBAN, details of your debit and credit cards, including long
number, relevant validity dates and CVC,
• information provided by third-party services
4. Identity verification information, such as images of your government-issued identity card,
passport, national identity card or driving licence, the identity document number,
numbers you may use or have registered with your local tax authority, or other information
that may be used for personal identification and may be required to comply with legislation on
the prevention of money laundering, terrorist financing, fraud or
other financial crime
5. Residency verification information such as utility bill with appropriate
data,
6. Marketing and communications information that includes your submitted preferences regarding
receiving marketing materials from us and our third parties and your preferences regarding
communications.
7. Beneficial owners: When establishing a legal relationship with JonatanMars Invest
and/or concluding occasional transactions using JonatanMars Invest services through
legal entities and similar bodies, JonatanMars Invest may identify the beneficial owners.
A "beneficial owner" means the natural person on whose initiative or in whose interest
a transaction or activity is carried out or a business relationship is ultimately established.
For such legal entities, the "beneficial owner" is also the natural person who ultimately
owns or controls the legal entity.
The above includes information you provide when you open an account, use the JonatanMars Invest
Services and communicate with us by email or through our social media channels.
The information (if necessary) that we collect from the user's company is described below:
• basic information about the company (company name, address, phone number, email address, tax
number, country, date of establishment and other information),
• information about the legal existence of the company (for example, a certificate of incorporation,
official register extracts, etc.),
• personal data of each individual at the company who uses the Mobile Application and whom the
company identifies in the Mobile Application,
• information about ownership, beneficial owners, authorised representatives and bodies that use
the Mobile Application.
3.2. Personal data collected using automated technologies or interactions:
This is personal data that may be collected about you when you interact with our websites.
In this case, we may automatically collect and process technical data about your equipment and
browsing, including your IP address, patterns and other activity when using the Website, applications
and/or the Mobile Application. JonatanMars Invest collects and processes this personal data using
cookies, server logs and other similar technologies. This allows us to recognise users and avoid
repeated requests for the same data. Using automated technologies, we track, collect, process and
store user behaviour on the Website. However, JonatanMars Invest does not allow other websites to
read cookies from our Website.
(collectively also referred to as: Automated Personal Data)
3.2.1. Automated personal data includes in particular:
a) Transaction data: Monitoring of completed transactions and/or the transfer of your assets
in the applications and/or on the Website, and transfers back to your bank account or other
accounts relevant to the JonatanMars Invest Services. Transaction data collected includes
the date, time, amount, currencies used, beneficiary details, information and location of the
counterparty connected with the transaction, the sender's and recipient's IP addresses, the
sender's and recipient's names and registration details, messages sent or received with a
payment, information about the device used to enable the payment, and the payment
instrument used;
b) Order execution data: For monitoring purposes (in the sense of "order execution" under the
GDPR) and for the purpose of identifying and/or preventing potential manipulation, we also
collect certain information about your use of Services in the application, including:
• monitoring completed transactions with assets and/or transfers of your assets in the
application and/or on the Website and back to your bank account,
• tracking financial instruments and/or assets that you search for and/or save.
c) Profile data: purchases or orders you have made, your interests, preferences, feedback
information and survey responses.
d) Usage data: includes information about how you use the Website, mobile
application and/or Services.
e) Technical data: includes the Internet Protocol (IP) address, login data,
mobile device, browser type and version, time zone setting and location, types and
browser plug-in versions, operating system and application, and other technology on
the devices you use to access our websites and/or application.
3.3. Personal data obtained from authorized third parties or publicly available sources:
We may obtain personal data about you from authorised partners and public sources, namely
publicly available registers, such as registers of political parties, international sanctions lists,
company registers and other publicly available sources that provide reliable information about you. This personal
data is obtained, processed and stored for the purposes of contractual use (Article 6 (1) (c)
GDPR) in accordance with user due diligence and verification. This personal data is obtained,
processed and retained exclusively to the minimum extent necessary to perform the contract with
you or your company.
(collectively also referred to as: Personal data obtained from third parties)
3.4. Personal data obtained from third parties includes, in particular, information about the identity of
users, their family members (a spouse, a partner who is equivalent to a spouse under national
law, children and their spouses or partners, and parents) and/or close business associates, where
these details match the identity data of persons identified in public registers of political parties,
international sanctions lists, trade sanctions lists and other publicly available sources that
provide JonatanMars Invest with reliable information for carrying out customer due diligence
under regulations on the prevention of money laundering and terrorist financing.
3.5. Third parties may include business partners, subcontractors for technical, payment and delivery
services, advertising networks, analytics providers, search information providers, fraud prevention
agencies and service providers that ensure compliance with the GDPR (Article 28 GDPR).
4. USE OF PERSONAL DATA
4.1. Below is a summary of the key types of personal data we use as part of
the JonatanMars Invest Services. More detailed information on the use of individual types of data and
the purposes for which they are used is provided in the table below (section 5 of this privacy policy).
4.2. We use the data held about you in the following ways:
4.2.1. Submitted personal data is used:
▪ to perform our obligations arising from transactions you enter into with us, for example
to provide the JonatanMars Invest Services in accordance with the Terms, including
opening an account, executing and transmitting orders and transferring funds;
▪ to verify your identity, protect against fraud and other financial crime, and confirm
your eligibility to use our products and the Mobile Application;
▪ to notify you of changes to the Mobile Application and the Terms;
4.2.2. Automated personal data is used:
▪ to identify and/or prevent possible misappropriation of assets;
▪ to provide information about other services we offer that are similar
to those you have already used or inquired about;
▪ to ensure that content from our Website is presented in the most efficient way for
you and your computer and/or smartphone;
▪ to manage our websites and applications for internal business, including
troubleshooting, data analysis, testing, research, statistics
and control;
▪ to improve our websites and applications to ensure that the content is presented in
the most effective way for you and your computer;
▪ to allow you to participate in the interactive functions of the mobile application;
▪ as part of our efforts to ensure the safe use of websites and applications;
▪ to measure or understand the effectiveness of relevant advertising, which
we provide to you and to third parties;
▪ to make recommendations about use of our websites and applications;
▪ for identity verification, protection against fraud, and other measures to combat
financial crime and confirm your eligibility to use the Mobile Application; and
▪ to fulfill regulatory obligations;
▪ to fulfill contractual obligations with you and your company.
4.2.3. Personal data obtained from third parties: We combine this data with Submitted
Personal Data that you provide to us and Automated Personal Data that we collect
about you. We will use this data and the combined data:
▪ to help us better understand your circumstances and behaviour so that we can
make decisions about how we manage your account or your use of the Mobile Application;
▪ to process applications available through us in the Mobile Application, including
deciding whether we agree to approve any product or functionality; and
▪ for the above purposes (depending on the type of information we receive).
4.3. We can associate any category of personal data with any other category of personal data
and will treat the combined information as personal data in accordance with this policy for as long
as it remains combined. For example:
• we may cross-check personal data obtained from third parties against Submitted Personal Data
to verify the authenticity of an individual user and perform thorough customer due diligence
required by laws on the prevention of money laundering, terrorist financing and other financial crime.
• under the Slovenian Prevention of Money Laundering and Terrorist Financing Act
(ZPPDFT-2), JonatanMars Invest must establish and maintain due diligence files for
documentation and reporting purposes. In this regard, JonatanMars Invest combines
Submitted Personal Data with Automated Personal Data and Personal Data obtained
from third parties to establish a profile for an individual user containing the following
information:
- documents and records used to identify and verify the identity of the user and
beneficial owner;
- where the beneficial owner can be identified as a legal entity, proof that
the necessary legal conditions for the application of these provisions are met,
- the established business profile of the relationship between JonatanMars Invest and
the individual user at the start of that relationship, including in particular:
o information about users and the beneficial owner,
o authorised representatives and bodies that conduct business with JonatanMars Invest,
o the origin of deposited assets,
o the financial background of all assets, including the occupation and business
activity of the beneficial payer of the assets, and
o the intended use of the funds.
4.4. We use anonymised data for advertising networks to meet relevant advertising needs
among target segments. JonatanMars Invest will never disclose identifiable data to advertisers.
5. PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
The table below describes how we use Personal Data and the legal bases on which we rely.
We may process your Personal Data on more than one lawful basis, depending on the purpose for
which we use it. Contact us through support in the applications if you need information about
the specific legal basis on which we rely where more than one basis applies.| Purpose of processing personal data | Type/category of personal data | Legal basis | Legitimate interests |
|---|---|---|---|
Identification and prevention of money laundering, organised crime and terrorist financing in
accordance with applicable anti-money laundering legislation. | - General personal data (first name and surname, address, identity document number, etc.).
- Identity verification documents (a scan of a passport, a scan of a utility bill, etc.).
- Detailed financial information where required, including the source/origin of tradable funds,
personal data obtained by third parties such as fraud prevention agencies, and/or publicly
available sources such as political-party and company registers.
- Automated Personal Data, including transaction, trading, profile, usage and technical data. | Compliance with legal obligations that apply to JonatanMars Invest under the Slovenian Prevention
of Money Laundering and Terrorist Financing Act (ZPPDFT-2). | Developing and improving methods for preventing financial crime. |
Provision of JonatanMars Invest Services: registering your account, performing our obligations
arising from transactions you enter into with us, providing Services in the application and/or on
the Website, and providing the information, products and Services you request from us. | - Submitted Personal Data, including general personal data and contact information.
- Automated Personal Data, including transaction, profile, usage and technical data. | Performance of a contract to which the user is a party, or taking steps at the user's request before
entering into a contract with JonatanMars Invest. | Efficient performance of our legal and contractual obligations, providing you with good service in
an efficient manner, and complying with the regulations that apply to us. |
Maintenance and operation of the JonatanMars Invest Services: managing our Website and application
for internal operations, including troubleshooting, data analysis, testing, research, statistical and
survey purposes; notifying you of changes to our Services; and protecting our Website and application. | - Submitted Personal Data, including general personal data and contact information.
- Automated Personal Data, including transaction, profile, usage and technical data. | Processing is necessary for the legitimate interests of JonatanMars Invest and/or for performance
of a contract. | Ensuring that the content of our Website is presented effectively and preventing potential misuse of
the Website, application or Services. |
Using data analytics to improve our Website, Services, marketing, client relationships and user experience. | - Automated Personal Data, including transaction, profile, usage and technical data. | Processing is necessary for the legitimate interests of JonatanMars Invest. | Defining customer groups for our Services, keeping our Website current and relevant, developing our
business and informing our marketing strategy. |
Improving the quality of our Services and preparing suggestions and recommendations about Services
or events that may interest you. | - Submitted Personal Data, including general contact information.
- Automated Personal Data, including transaction, profile, usage and technical data. | Processing is necessary for the legitimate interests of JonatanMars Invest. | Understanding users' interests and supporting the continued development and improvement of Services. |
Preparing customised offers and presenting Services on a targeted basis. | - Submitted Personal Data, including general personal data and contact information.
- Automated Personal Data, including transaction, profile, usage and technical data. | Processing is necessary for the legitimate interests of JonatanMars Invest. | Processing personal data, including contact and financial data such as the value of assets under
management, the share of uninvested cash and the types of products and strategies in which you are
invested, for analysis and segmentation. This allows us and our authorised tied agents to understand
your needs and present the investment Services most relevant to you. |
What we mean when we use the words: Legitimate Interest: This means our business interest in operating and managing JonatanMars Invest so that we can provide you with JonatanMars Invest Services and offer you the most secure experience. Before we begin processing your Personal Data for our legitimate interests, we make sure that we examine and balance any potential impact on you (both positive and negative) and your rights. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law). For the purpose of "legitimate interest", JonatanMars Invest also pursues its legitimate interest in identifying and/or preventing potential insider trading and/or market manipulation. We therefore also collect and process certain data about your use of Services in the application, such as application usage, identification data, transaction data, order execution data, profile data, usage data and technical data. Performance of contractual obligations: We process your Personal Data where this is strictly necessary to enter into and perform a contract that you have concluded with us (for example, a financial instruments management agreement). This includes activities such as opening and managing your account, executing your orders, calculating fees and resolving any complaints. Compliance with legal and regulatory obligations: As a regulated investment firm, we are required to process certain Personal Data in order to comply with strict legal requirements. This primarily includes implementing measures to prevent money laundering and terrorist financing in accordance with the Prevention of Money Laundering and Terrorist Financing Act (ZPPDFT-2), and complying with the obligations imposed on us by the Financial Instruments Market Act (ZTFI-1), such as assessing the appropriateness and suitability of the client and reporting to supervisory authorities.
6. MARKETING
6.1. JonatanMars Invest strives to provide clear information about the use of Personal Data
for our marketing purposes and easy access to communication management through individual
settings or the option to opt out (unsubscribe) from receiving any marketing communication
from us whenever you wish.
6.2. We offer you clear choices regarding the use of anonymised Personal Data for marketing and
advertising purposes. You can access the page for managing your personal communication
settings at any time through our email address (privacy@jonatanmars.com).
7. OUR PROMOTIONAL OFFERS
7.1. We use Personal Data (for example, Submitted Personal Data and Automated Personal Data)
to form a view of what we think you may want or need, or what may be of interest to you. This is
how we decide which products, Services and offers may be important to you.
7.2. You will receive marketing communications from us if you have registered and/or use the mobile
application, unless you have disabled the receipt of marketing notifications.
8. THIRD PARTY MARKETING
8.1. We will not share your Personal Data with any company outside the JonatanMars Invest
group that is not our contracted data processor, which is required to process Personal Data
on behalf of JonatanMars Invest in compliance with GDPR requirements.
9. ADVERTISING COMMUNICATION SETTINGS
9.1. You can stop receiving advertising communications at any time in the management settings
for the account linked to your email, or by contacting privacy@jonatanmars.com.
10. DISCLOSURE OF YOUR PERSONAL DATA
10.1. We may disclose your information:
• to other entities in the JonatanMars Invest group;
• to third parties that provide us with services such as hosting, system management and
support, data analysis, advertising enablement, data backup, and data protection and
storage services;
• to tied agents who, in the name and on behalf of JonatanMars Invest, present JonatanMars
Invest Services in a targeted manner, provide information about JonatanMars Invest
products, maintain contact with clients or, within the scope of the authority granted,
facilitate the conclusion of contracts relating to JonatanMars Invest investment Services;
• to relevant third parties in connection with corporate transactions such as a reorganisation,
merger, sale, joint venture, assignment, transfer or other disposal of all or part of our
company, assets or shares;
• to competent government and public authorities, in each case to comply with legal or
regulatory obligations or requirements; and
• to other third parties where we consider this necessary or appropriate: (a) under applicable
law; (b) to comply with legal proceedings; (c) to enforce our terms and conditions;
(d) to protect our activities and those of our affiliates; (e) to protect our rights, privacy,
security or property and/or the rights of our affiliates, you or others; and (f) to enable
us to pursue available legal remedies or limit damage that we may incur.
10.2. The disclosures described in this section may result in your information being transferred to
countries or regions with data protection laws that differ from those in your country of residence.
By providing us with your information and using this website, you acknowledge that your
information may be transferred to countries outside your country of permanent residence.
10.3. Where your information is transferred outside your country of residence, we take steps to ensure
that appropriate safeguards are in place to protect it. If you are based in the EU/EEA, such
safeguards may include a data transfer agreement with the recipient of the data based on
standard contractual clauses, or another mechanism approved by the European Commission for
transfers of Personal Data to third countries. For further details about the transfers described
above and the appropriate safeguards used in connection with them, please contact us at
privacy@jonatanmars.com.
11. SECURITY OF STORAGE AND INTERNATIONAL TRANSFERS
11.1. The Personal Data we collect from you will be transferred to and stored within the EEA. As we
provide an international service, your Personal Data may be processed outside the EEA so that
we can fulfil our contractual obligations to you. The processing of Personal Data is necessary,
for example, to process payment data and provide ongoing support Services. We will take all
measures to ensure that your data is processed securely and in accordance with this Privacy
Policy.
11.2. All information you provide to us is stored on our secure servers and encrypted at rest and in use.
All payment transactions carried out by us or our selected payment processing service provider
will be encrypted. If we have created a password for you (or you have chosen one) that gives you
access to certain parts of our application and/or website, you are responsible for keeping that
password confidential. Please do not share your password with anyone.
11.3. The transmission of information over the internet and/or a blockchain protocol is not completely
secure. Although we will do our best to protect your data, we cannot guarantee the security of
data sent to our applications or websites with complete certainty. Every transfer of data is at
your own risk. Once we receive your information, we will use strict procedures and security
features to prevent unauthorised access.
11.4. Some Services may include social networking features, chat rooms or forums. When using these
features, make sure that you do not send any Personal Data that you do not want to be seen,
collected or used by other users or third parties.
12. DATA STORAGE
12.1. Under the Slovenian Prevention of Money Laundering and Terrorist Financing Act (ZPPDFT-2),
JonatanMars Invest is required to retain Personal Data about you and your transactions with
JonatanMars Invest for at least ten years from the conclusion of a transaction or from its
preparation. We therefore use this retention requirement as a criterion for all Personal Data
that we receive from you. To avoid retaining your data for longer than strictly necessary, we
will not retain your Personal Data for more than 11 years after the end of our business
relationship.
13. YOUR RIGHTS
13.1. Under data protection legislation, you have certain rights in relation to Personal Data, as set
out below:
• Access to your Personal Data (commonly known as a "data subject access request"). This
allows you to receive a copy of the Personal Data that we hold about you. If you require
this, please contact our support team (privacy@jonatanmars.com).
• Correction of the Personal Data that we hold about you. This allows you to correct incomplete
or inaccurate information that we hold about you, although we may need to verify the
accuracy of the new data you provide to us. If you require this, please contact our support
team (privacy@jonatanmars.com).
• Request deletion of your Personal Data. This allows you to ask us to delete or remove
Personal Data where there is no reason for us to process it. You also have the right to ask
us to delete or remove your Personal Data where you have successfully exercised your right
to object to processing (see below), where we may have processed your data unlawfully, or
where the deletion of Personal Data is required under local law. Please note, however, that
we may not always be able to comply with your request for deletion for specific legal
reasons, which we will notify you of where applicable. Please note that these retention
requirements override any right to deletion under applicable data protection laws. As a
person subject to due diligence requirements under the regulations on the prevention of
money laundering and terrorist financing, JonatanMars Invest must retain certain data for
at least 10 years (see above).
• Objection to processing based on a legitimate interest (General): Where JonatanMars Invest
processes your Personal Data on the basis of a legitimate interest, you have the right to
object to such processing at any time for reasons relating to your particular situation. In
this case, we will stop processing your data unless we can demonstrate compelling and
legitimate grounds for the processing that override your interests, rights and freedoms, or
the data is necessary for the establishment, exercise or defence of legal claims. If you
object to the processing of data that is strictly necessary to ensure the security or basic
operation of the system, we may no longer be able to provide you with certain Services,
which may lead to the closure of your account.
• Objection to processing for direct marketing and profiling purposes: You also have the
right to object at any time to the processing of your Personal Data for direct marketing
purposes. This explicitly includes an objection to profiling and the analysis of your financial
data (for example, a review of your portfolio balance, unallocated funds or types of products),
which is carried out by us or our authorised tied agents for the purpose of targeted offers
and the customised presentation of Services. If you object, we will no longer process your
Personal Data for direct marketing purposes, and our tied agents will no longer have access
to view your portfolio for this purpose. Exercising this right is free of charge and will not
affect the provision of the core Services under your financial instruments management
agreement.
• Request restriction of the processing of Personal Data. This allows you to ask us to stop
processing your Personal Data in the following circumstances:
a) if you want us to establish whether the data is accurate;
b) where the use of the data is unlawful, but you do not want us to delete it;
c) where we need to retain the data, even if we no longer require it, for example for
the establishment, exercise or defence of legal claims; or
d) you have objected to our use of your data, but we need to verify whether we have
overriding legitimate grounds for using it.
• Request the transfer of your Personal Data to you or to a third party. We will provide the
Personal Data to you in a structured, commonly used, machine-readable format, which you
may then transfer to the relevant third party. If you require this, please contact our support
team at privacy@jonatanmars.com.
• Withdraw consent at any time where the processing of Personal Data relies on consent. This
will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you withdraw your consent, we may not be able to provide you with the full JonatanMars
Invest Services. Regardless of the withdrawal of consent, JonatanMars Invest is required to
process and retain the relevant Personal Data of users for a certain period in order to comply
with legislation on the prevention of money laundering, terrorist financing, fraud or any
other financial crime.
13.2. Please note that any requests concerning the restriction of the processing of your data may mean
that we cannot perform a contract that we have entered into, or are trying to enter into, with you
(including the JonatanMars Invest Services). In this case, we may need to cancel your use of the
JonatanMars Invest Services, but we will notify you of this.
14. MISCELLANEOUS
14.1. Additional payments You do not have to make any additional payment to access Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. In these circumstances, we may refuse your request or ask for an additional payment. 14.2. What information we need In some cases, we will need 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 anyone who is not entitled to receive it. We may also contact you for additional information concerning your request in order to speed up our response. 14.3. Time limit We try to respond to all legitimate requests within one month. Occasionally, it may take longer than one month if your request is particularly complex or you have submitted several requests. In this case, we will notify you and keep you informed. 14.4. Cooperation in providing the requested data Where we are required to collect Personal Data by law or under a contract that we have with you, and you do not provide that data when requested, we may not be able to perform the contract that we have entered into, or are trying to enter into, with you (including the JonatanMars Invest Services). In this case, we may need to cancel your use of the JonatanMars Invest Services, but we will notify you immediately.
15. PRIVACY POLICY CHANGES
15.1. Any changes that we make to our Privacy Policy in the future will be published on this page
and, where necessary, notified to you by email and/or the next time you launch the mobile
application or sign in to the website. The new policy may appear on the screen and you may
need to read and accept it in order to continue using the mobile application and/or Services.
16. CONTACT
16.1. All questions concerning data and your privacy are welcome and should be directed to our support
team. If you have any questions, comments or requests concerning this Privacy Policy, please
email us through our support team at privacy@jonatanmars.com.
In Ljubljana, 14 April 2026
JonatanMars Invest d.o.o.