Dear visitor,

Thank you for visiting our website and expressing your interest in our services. In operating this website and providing our services, we process the personal data you provide to us. The protection of this data is extremely important to us.

In this document, you will find information regarding the processing of your personal data and information about your rights under Regulation (EU)2016/679 of the European Parliament and of the Council 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") and Act No. 110/2019 Coll., on the processing of personal data ("Act").

In addition, this document contains information about cookies used on our website in accordance with Act No. 127/2005 Coll., on electronic communications, as amended.

Data Controller

Stable Labs s.r.o., with registered office at Kaprova 42/14, Staré Město, 110 00 Prague 1, ID No.: 21367477, registered in the Commercial Register maintained by the Municipal Court in Prague under the Commercial Register No. C 400861 (hereinafter referred to as "we" or "Stable Labs") acts as a personal data controller within the meaning of the GDPR and the Act, which determines the purpose and means of processing your personal data as the data subject.

Scope, purposes and legal title for the processing of personal data

Stable Labs processes your personal data in the following situations:

• For the purposes of creating statistics and developing new products, we process data about your use of our website and our services. In particular, this includes data about the services you view on our website, the links you click on, the way you move around our website, as well as data about the device from which you view our website, such as the IP address, the location derived from it, the identification of the device, its technical parameters and information from cookies and similar technologies. The legal basis for the processing of personal data in this case is our legitimate interest.
• For the purposes of fulfilling our contract with you and providing our services, we process information about your transactions, their execution, information about payments within transactions, etc. Without this processing we would not be able to provide you with our services. The legal basis for the processing of personal data in this case is the performance of the contract with you.
• For the purpose of dealing with your requests and for the purpose of communication with you, we process information about your requests, your email address, name, surname, or telephone number. The legal basis for the processing of personal data in this case is our legitimate interest.
• For the purpose of fulfilling our legal obligations in the field of accounting, taxes, document management and registers we process data on the performance of contracts with you, your name, surname, address and, where applicable, other data required by law. The legal basis for the processing of personal data in this case is the fulfilment of the obligations laid down by law.
• For the purpose of protecting our interests and legitimate claims, we process your name, surname, address and data on the performance of contracts with you as well as data on the services we have provided to you. The legal basis for the processing of personal data is our legitimate interest.
• For the purpose of promoting our services and our company through the newsletter, we use your name and surname and email address on the basis of your consent, or, if you create an account or order a service with us and do not refuse the sending of commercial communications, also in accordance with the law and without your consent. The legal basis for the processing of personal data is either your consent or our legitimate interest.

In the case of processing of your personal data for the performance of contractual (or pre-contractual) obligations arising from the contract with you, for the performance of legal obligations, in particular the obligations set out in the AML regulations, such processing is a condition for the provision of our services. If you do not provide us with personal data to the extent requested, we cannot provide you with our services.

If the processing of your personal data by us is based on legitimate interest, the processing is carried out following the balance adequacy tests developed by our company. If you do not provide us with the data, we would not be able to realise this interest. When processing your personal data, we are mindful of your rights, respect the principle of data minimisation with regard to the purpose of the processing and are guided by the balance tests carried out. If you still believe that your rights are violated by this processing, you can object pursuant to Art. 7 below. In this case, we will restrict the processing of your personal data until we have demonstrated to you that there are legitimate grounds for such processing which outweigh your interest in not being subject to processing. If we do not demonstrate this, we would no longer process your data for these purposes. If you object to processing for direct marketing purposes, we will restrict processing without further action.

Unless otherwise stated, we only obtain the personal data we process directly from you.

Who do we pass your personal data to?

In most cases, we process your data for the purposes set out by us as the data controller. In this case, we carry out the processing ourselves through our employees. Occasionally, in order to properly provide our services, it is necessary to use external service providers who process your personal data for us on the basis of the purposes set by us, in particular:

• service providers necessary for your identification and compliance with AML regulations;
• providers of analytical and statistical tools;
• cloud service providers and other technology and support suppliers; and
• providers of marketing tools.

In some cases, we transfer your personal data to other persons in their capacity as controller. This occurs where a third party is required to provide our service to you, where such third party is the data controller in providing that service and determines the purposes of the processing itself. These include:

• payment system providers for the purpose of securing payment, in particular in relation to card payments; and
• legal service providers, auditors and tax advisors.

In the case of processing your personal data via social networks, we are also joint controllers with the operators of the individual social networks (in particular Facebook, Instagram). In this case, we are obliged to inform you of such processing and we must provide proof of the legal basis for the processing of your personal data. For more information on the processing of personal data via Facebook and Instagram, please visit:

Facebook: https://www.facebook.com/policy.php
Instagram: https://help.instagram.com/519522125107875

If generally binding legal regulations so provide, we are also obliged to transfer your personal data to the relevant public administration and local government authorities, in particular administrative authorities and their bodies, law enforcement authorities, tax authorities and tax administrators. However, in this case, we only transfer your data to the extent necessary, as provided for by law.

Transfer to third countries

Most of the processing of personal data by our company and its partners takes place in the EU, the European Economic Area, the United Kingdom of Great Britain and Northern Ireland or Switzerland. However, in some cases we may also transfer your data to third countries that do not provide an adequate level of data protection as part of a transfer to processors.

However, any such transfer shall only be made on the basis of a written contract containing standard contractual clauses issued by the European Commission. At the same time, we continuously monitor the level of security and data protection of such contractual partner.

Retention period of personal data

In the context of processing personal data, Stable Labs retains your personal data for the period necessary to achieve the purpose of processing or for the period required by generally binding legal regulations. If you give us your consent to process your personal data, we will process your personal data until you withdraw your consent. This period may vary according to the individual purpose, but we always take care to minimise the processing of personal data and only process the amount of data that is necessary to fulfil the purpose. After the purpose has ended, we delete or anonymise your data.

We process your personal data for the following period:

• we process the data necessary for the performance of the contract between you and our company for the duration of the contract and for the duration of the general limitation period plus one year;
• we process the data required for the generation of statistics and the development of new products for 9 months;
• we process the data necessary for the resolution of your requests and communication with us for the period necessary for the resolution of the request and for the general limitation period plus one year;
• we process the data necessary for the performance of our accounting, tax, document management and registry obligations for a maximum period of 10 years;
• we process the data necessary for the protection of our interest and legitimate claims for the duration of the general limitation period plus one year and for the duration of the proceedings concerning the disputed claims.

Your rights

As a data subject, you have a number of rights related to the processing of your personal data by Stable Labs in accordance with Article 12 et seq. of the GDPR in conjunction with the relevant provisions of the Act.

The primary right is your right to information about the processing of personal data. This right is implemented by Stable Labs in this document, which will tell you all the essentials.

Your other rights under the GDPR are:

• the right of access to personal data, i.e. the right to obtain confirmation as to whether personal data concerning you are processed by Stable Labs;
• the right to rectification if the personal data concerning you is inaccurate;
• the right to erasure of personal data if the processing of personal data relating to you no longer has a purpose or legal title, or if such processing is unlawful, if we have been ordered to do so by a supervisory authority or if you have objected to the processing and there are no overriding legitimate grounds for processing the personal data;
• the right to restrict processing if, in your opinion, the personal data is inaccurate until we correct it, if there is no legal basis for the processing but no erasure has taken place, if we do not need the personal data for processing but you need it for the establishment, exercise or defence of legal claims, or if you have objected to the processing and we are investigating whether there are overriding legitimate grounds for continuing to process the personal data;
• the right to data portability if the data processing is based on your consent or on a contract concluded with you and is carried out by automated means. In this case, we will provide you with your data in a structured, commonly used and machine-readable format for the purpose of transferring it to another controller;
• the right to object if the processing is based on a legitimate interest, in which case we will restrict the processing of your personal data until we assess the existence of overriding legitimate grounds, or in the case of processing for direct marketing purposes, we will immediately stop processing your personal data for this purpose;
• the right to a review of a decision in the context of automated individual decision-making by a human being where such automated individual decision-making occurs;
• the right to lodge a complaint with the supervisory authority, which is the Office for Personal Data Protection, located at Pplk. Sochora 727/27, Holešovice, 170 00 Prague 7.

You can exercise the above rights by sending a request by email to legal@stablelabs.co or in writing to our company. In the case of your request, we reserve the right to verify your identity first. We will process your request without delay, at the latest within one month of receipt of your request or verification of your identity. If, due to the complexity of the response or the number of requests, we find it necessary to extend the deadline, we may extend it by a further two months. We will inform you of the extension within the first period together with the reasons for the delay.

Cookie Policy

Definition of cookies
Cookies are small text files that are downloaded to your electronic device (e.g. smartphone, tablet or computer) when you visit a website. The purpose of using cookies is to improve the overall experience of our website and to enable certain features (depending on the type of cookie).

We may set and use cookies that are necessary for the proper functioning of our website without your consent ("essential cookies"). All other cookies must be approved by you before they can be set.

The processing of the cookies themselves cannot be attributed to a specific person. However, we can already associate the data obtained from them with a specific person. For more information on the processing of such data, see above in Art. 2.

Type and purpose of cookies used
In terms of time, we distinguish between the following types of cookies used:

• short-term (session) cookies, which are temporary and activated whenever you visit the website and are deleted when you finish browsing; or
• persistent cookies, which remain stored in your web browser until a set expiry date, unless you delete them before their expiry date as part of your browser settings.

We use both short-term and persistent cookies on our website.

From a functional point of view, we distinguish between the following types of cookies used:

• Essential cookies, i.e. cookies that enable the basic functions of the website. These cookies enable you to use our website and its basic functions. If you restrict them within your browser settings, they may make it very difficult or impossible to browse our website. These cookies do not collect any information about you that could be used for marketing purposes, nor do they remember your browsing history. The use of essential cookies is a legitimate interest of ours, so we do not need your consent to use them, but you can always refuse their use in your web browser settings. However, we cannot guarantee the full functionality of our website without the use of essential cookies.
• Functional cookies,i.e. cookies used to remember information about you as a visitor to our website, e.g. language settings, time zone, enhanced content, interface themes. We need your explicit consent to use these cookies.
• Performance and analytics ("performance") cookies,which we use to find out how you use our website as a visitor, to record the number of visitors to our website, to compile statistics about visitors' movements around the website (including the number of pages viewed, the number of visits and the time spent on each page) and to track clicks and conversions so that we can improve the quality of our service by collecting data about what you view most often. These cookies cannot be used to directly identify a specific visitor. We need your active consent to use them.

We also use so-called third-party cookies, i.e. cookies that are managed by a third party and our company has allowed their placement on its website.

Managing your cookie settings
The first time you visit our website, you will see a small pop-up window with information about cookies, where you can also choose which cookies you want to allow. By selecting and clicking on the "Accept all" box, you agree to the use of all the types of cookies described above, By clicking on the "Preferences" box, you can set the individual types of cookies you want us to allow. Click on the "Reject all" box to refuse the use of cookies. In this case, we will only store the necessary cookies. You can manage the use of cookies directly via a pop-up window or also via your web browser:

• in Google Chrome using the procedure described at: https://support.google.com/chrome/answer/95647?hl=sk&hlrm=en
• in Internet Explorer using the procedure described at: https://support.microsoft.com/sk-sk/topic/odstr%C3%A1nenie-a-spr%C3%A1va-s%C3%BAborov-cookie-168dab11-0753-043d-7c16-ede5947fc64d
• in Microsoft Edge using the procedure described at: https://support.microsoft.com/cs-cz/microsoft-edge/odstran%C4%9Bn%C3%AD-soubor%C5%AF-cookie-v-aplikaci-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
• in Mozilla Firefox using the procedure described at: https://support.mozilla.org/sk/kb/enhanced-tracking-protection-firefox-desktop?redirectslug=povolenie-zakazanie-cookies&redirectlocale=sk