Privacy and Personal Data Protection

At JonatanMars d.o.o., we pay particular attention to data protection and handle personal data carefully, responsibly and in accordance with applicable regulations. We respect your right to privacy and process data in a manner that protects your interests, fundamental rights and freedoms. We process personal data lawfully, fairly and transparently, ensuring an appropriate level of security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage through appropriate technical or organisational measures. Before we begin processing your personal data, we carefully assess whether the intended processing is proportionate in light of any positive or negative impact on you or your rights from a personal data protection perspective.

Legal basis

The legal basis for the processing of personal data includes:

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 - General Data Protection Regulation (GDPR),

Personal Data Protection Act,

Investment Funds and Management Companies Act,

Electronic Communications Act,

Prevention of Money Laundering and Terrorist Financing Act,

Rules on the technical conditions to be met by secure remotely controlled or electronic procedures and means of identification,

tax regulations,

any other regulations governing the processing and/or protection of personal data.

Data controller

The controller of personal data is JonatanMars d.o.o., Dunajska cesta 165, 1000 Ljubljana. Access to your personal data and the right to process it for specifically defined purposes are granted only to authorised employees of JonatanMars and carefully selected authorised contractual processors of the company that can provide sufficient guarantees, including the security of processing, and that have entered into a personal data processing agreement with us, binding them to the same standards of personal data processing as we apply.

JonatanMars has appointed a Data Protection Officer. The Data Protection Officer can be contacted at dpo@jonatanmars.com.

Personal data

Personal data means any information relating to an individual, such as a first name, surname, tax number, email address and any other data that may identify an individual and relate to that individual.

You are required to provide us with true, accurate and complete personal data and to notify us of any changes.

Purposes of personal data processing

We process your personal data on the basis of our business relationship with you (a signed subscription/application form or agreement), on the basis of law, on the basis of our legitimate interests and on the basis of your consent.

Processing data for purposes other than those for which the personal data were originally collected is permitted only where such processing is compatible with the purposes for which the personal data were originally collected or where permitted by applicable regulations.

Except where required by law, we will not disclose your personal data to any third party without your written consent. As a rule, we process your personal data within the EU and the European Economic Area ("EEA").

Processing on the basis of a contract

We process your personal data in connection with the provision of investment services in order to fulfil our obligations arising from our business relationship with you.

When establishing a relationship (by signing a subscription/application form or agreement), we require all data that we are obliged to obtain from you under applicable regulations. If you do not provide all the necessary data, we will ask you to provide it. If you still do not wish to provide it, we reserve the right not to enter into the relationship with you or to terminate it. When establishing the relationship or at a later stage, you may also voluntarily provide us with other data that are not expressly required when the relationship is established. In certain cases and in accordance with applicable regulations, we may obtain certain data from third parties or public sources.

Before entering into a relationship, we may process the data you provide for the purpose of contacting you in connection with advisory services, determining your financial profile so that an appropriate product can be recommended, or informing you about our offering.

Processing on the basis of law

We process personal data pursuant to various laws in order to comply with our legal obligations and for purposes required by applicable regulations (e.g. tax regulations, regulations governing the prevention of money laundering and terrorist financing, etc.).

Processing on the basis of legitimate interests

We may process personal data for the purposes of our legitimate interests or those of third parties, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject that require the protection of personal data, in particular where the data subject is a child. Our legitimate interests are interests connected with conducting our business in a user-friendly and secure manner and in compliance with prescribed requirements. We substantiate processing based on legitimate interests by means of an impact assessment in which we identify the legitimate interest and assess whether the interests of the individuals whose data are to be processed may override the company's legitimate business interest.

The company's legitimate interests include developing, advertising and offering a range of products and services, improving business processes, ensuring legal and regulatory compliance, ensuring the security of business operations and data processing, better tailoring our offering and improving your user experience.

Processing on the basis of consent

We may also process personal data on the basis of your voluntary consent. By giving consent, you agree that personal and other data collected in connection with the provision of our services or through other forms of interaction may be collected, stored and used for selected purposes. We receive data directly from you or from other sources (social networks, websites or other public sources), or from contractors who collect personal data or conduct surveys or market research on our behalf. If your consent form is incomplete, you allow us to enter in the relevant database any missing data that we hold from other contractual, transaction or sales documentation. Within the scope of your consent, you may select one or more of the following purposes for processing personal data:

direct marketing (e.g. information about the company's promotional activities and targeted (segmented) marketing, such as sending news, articles, our own magazines, invitations to events, offers, promotional materials, greeting cards, newspapers and prize competitions),

surveys or market research for our own purposes,

statistical processing,

profiling, monitoring a customer's purchasing behaviour (including for previous periods) based on past activities, processing and receiving messages and benefits intended and tailored specifically for you.

Consent is intended primarily for the development of our products and services, the tailoring of our offering, improvement of your user experience, receipt of company notifications and assistance with financial decisions. Your consent does not affect any prior approvals or consents that we may have obtained from you before it was given, insofar as it does not conflict with them. Communications based on consent are sent through the communication channels you selected when giving your consent.

Retention period for personal data

The retention period for personal data varies according to the type and purpose of personal data processing. Certain data are retained for 10 years or more after the termination of the business relationship or completion of a transaction. Data processed on the basis of voluntary consent are retained until consent is withdrawn. The law may require a longer retention period.

Personal data that we process for one-off events (conferences, meetings, lectures, prize competitions, visits and excursions) are retained in accordance with applicable law and the rules applicable to each individual event, or until consent is withdrawn.

If we receive a request for deletion of data, we will fulfil the request by restricting the processing of the data solely to the purposes prescribed by applicable regulations or internal rules.

If we anonymise personal data so that they can no longer be linked to a particular person, we may retain and process them without a retention time limit.

Data subject rights

We facilitate the exercise of your rights relating to the processing of personal data without undue delay and, in any event, no later than one month after receiving a request. The period for exercising these rights may be extended by up to two additional months; in such a case, we will inform you within one month of receiving the request and explain the reasons for the delay.

In relation to your personal data, you have the following rights:

– the right to inspect your personal data or otherwise obtain access to the data,

– the right to rectify inaccurate data. In this regard, we reserve the right to request documentation showing the changes,

– the right to obtain a transcript and copies of the data. You are entitled to one free copy of your personal data in electronic or printed form. For additional copies, we may charge a reasonable fee taking into account the cost of preparing the copy,

– the right to restrict data processing on lawful grounds,

– the right to object to processing and to request erasure of data,

– the right to be notified of rectification, erasure or restriction of processing,

– the right to receive a list of recipients to whom your personal data have been disclosed, including when, on what legal basis and for what purpose,

– the right to information about the purpose of processing and the categories of personal data being processed, together with all necessary explanations in this regard, including all available information about the source where personal data have not been collected from the data subject,

– the right to an explanation in the event of automated decision-making involving the processing of personal data,

– the right to lodge a complaint with a supervisory authority if you believe that the processing infringes applicable law.

Where you have given voluntary consent, you may withdraw or amend your consent to the processing of personal data at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal. You can do this at our registered office or by sending a notice to dpo@jonatanmars.com. For any additional information, you can contact us on the toll-free number 080 35 08.

JonatanMars is not liable for any disclosure of personal data or misuse of an individual's identity resulting from inadequate protection, by you or third parties, of your privacy and personal data or of the computer or other equipment on which personal data are stored.

Right to lodge a complaint

If you believe that your rights have been infringed in connection with the processing of your personal data, you may lodge a complaint by sending it to JonatanMars d.o.o., Dunajska cesta 165, 1000 Ljubljana, or by email to dpo@jonatanmars.com.

You also have the right to lodge a complaint with the supervisory authority if you believe that the processing infringes applicable law. The supervisory authority is the Information Commissioner of the Republic of Slovenia,

https://www.ip-rs.si.

Changes to the Privacy Policy

This Privacy Policy may be amended or supplemented at any time. You will be informed of any changes on this website and, in the event of material changes affecting the processing of personal data, also by email.

Cookies: this website does not use them

We do not use or install any cookies on www.jonatanmars-group.com (first-party, third-party, analytics, functional or advertising cookies). We do not collect data through cookies, track visitors or disclose data to third parties through cookies. Therefore, consent for the use of cookies is not required. If this changes, we will update this policy before introducing cookies and obtain any consent that may be required.

Updated 12 October 2026. This Policy applies from the date of its publication on the website.