PRIVACY POLICY

Introductory Notes

This document constitutes the official Privacy Policy of the website named “FS Capital Management,” located at the internet address: https://fscapital.ba/ (hereinafter: the Website), owned by the Alternative Investment Fund Management Company FS CAPITAL MANAGEMENT Ltd. Banja Luka, Vidovdanska 2, 78000 Banja Luka, Registration No: 11671446, TIN: 4405343420000 (“FS Capital,” “we,” “us,” or “our”) (as per data protection law: the Controller).

In accordance with the Law on Personal Data Protection (“Official Gazette of BiH”, No. 12/25) (“LPDP”), the Website owner governs all types of personal data processing through the Website and hereby publishes this Privacy Policy.

This Privacy Policy constitutes a contract of adhesion, as the Website user is given the opportunity to accept or reject the Policy. Acceptance of the Privacy Policy is required for submitting any digital form to the Website owner, since such forms involve a certain amount of personal data and functionalities dependent on their submission.

This contract is concluded between the Website owner and the Website user upon submission of the digital form and the user’s declaration of consent.

The Privacy Policy is accepted by a positive act through which the user confirms having read and understood it.

The purpose of the Website is to provide users with easy access to information about the owner’s training programs and other services.

Personal Data Collected
Article 1

The Website owner collects the following personal data via the Website:

• Full name, email, phone number, occupation, and the name of the legal entity making the payment;
• Full name, email address, phone number, and message (user's communication with the Website owner);
• Email address, full name, phone number, and occupation (digital marketing – newsletter).

Subject Matter
Article 2

This Privacy Policy aims to define the scope, method, purpose, legal basis, storage, and further processing of personal data collected through the “FS CAPITAL MANAGEMENT” Website (https://fscapital.ba/).

Purpose of Data Collection
Article 3

Data collected under Article 2, Paragraph 1, Item 1 is used by FS Capital to establish and maintain communication with the user and inform them about investment products and services, booking consultations, and other services offered by the Website owner. The Website aims to facilitate timely and accessible information about FS Capital’s investment offerings and specialized services.

Data collected under Article 2, Paragraph 1, Item 2 is used to respond to user inquiries and provide information tailored to topics selected by the user. This ensures that each user can ask questions regarding investments, regulatory frameworks, or other services offered by the Website owner.

Data collected under Article 2, Paragraph 1, Item 3 is used for sending electronic newsletters. Subscribers will receive priority updates on new investment opportunities, products and services, conferences, and other opportunities developed by FS Capital. This communication channel supports our policy of transparency and continuous client engagement.

Legal Basis for Data Collection
Article 4

The legal basis for collecting data under Article 2, Paragraph 1, Item 1 is the user’s consent granted by accepting this Privacy Policy.

The legal basis for collecting data under Article 2, Paragraph 1, Item 2 is also the user’s consent through acceptance of this Privacy Policy.

The legal basis for collecting data under Article 2, Paragraph 1, Item 3 is likewise the user’s consent by agreeing to this Privacy Policy.

User Consent for Data Processing
Article 5

User consent for personal data processing is an expression of their free will. Such consent may be withdrawn at any time. In such cases, the Website owner will stop processing the concerned user’s data and notify the user accordingly.

Consent must be granted clearly, unambiguously, and with acceptance of this Privacy Policy.

Users may withdraw their consent at any time by submitting a written statement to: office@fscapital.ba.

If the Controller intends to process personal data for a purpose different from that for which it was originally collected, the Controller must, prior to further processing, provide the data subject with information about that new purpose and obtain renewed consent in line with their right to be informed.

Data Protection
Article 6

Collected data is stored electronically in databases accessible only to a limited number of individuals within the Website owner’s organization. The electronic system is protected by antivirus software.

The hosting company is required to treat any personal data it accesses in the same manner as the Website owner.

In case of serious threats to the data—such as data leaks, hacking, or theft of databases—the Website owner will inform the Personal Data Protection Agency.

In case of suspected unauthorized access to the Website owner’s IT infrastructure, passwords will be changed promptly and other necessary security measures implemented.

Data Retention Period
Article 7

Personal data will not be retained longer than necessary for the purpose for which it was processed.

If a retention period is prescribed by law, the Website owner will retain the data in accordance with such legal obligation. Once the purpose is fulfilled, or the legal retention period expires, the data will be permanently deleted.

In certain cases, data may be retained for longer periods to fulfill legal obligations or for the establishment, exercise, or defense of legal claims, in accordance with applicable laws.

Individuals may request the deletion of their personal data at any time.

Links to Other Websites
Article 8

This Website may contain links to other websites that are not controlled by the Website owner and are not subject to this Privacy Policy. If a user accesses such third-party websites, those operators may collect data subject to their own privacy policies, which may differ from this one. Such processing is unrelated to and independent of the processing conducted under this Privacy Policy.

Cookies
Article 9

The Website uses cookies to enhance user experience. A cookie notice is displayed to new users on their first visit, in the form of a separate Cookie Policy.

Automated Decision-Making and Profiling
Article 10

The Website owner does not make decisions or perform profiling using automated means.

Data Subject Rights
Article 11

Data subjects whose personal data is processed through the Website have the following rights:

• Right to information – Users have the right, in line with LPDP, to be informed about their rights and obligations and any issues related to the processing of their personal data, even before processing begins.
• Right of access – Users have the right to request access to their personal data and to know the purpose, method, and scope of processing.
• Right to rectification and amendment – After accessing their data, users may request correction, supplementation, or updating of their personal data.
• Right to erasure – Users may request, in line with LPDP, deletion of their personal data or suspension of processing, in accordance with the data protection law.
• Right to withdraw consent – Where processing is based on consent, users may withdraw it at any time in writing.
• Right to restrict processing – Users may request, in line with LPDP, that the Controller restrict the processing of their data.
• Right to data portability – Users may request their data in a structured, machine-readable format and transmit it to another controller, where technically feasible.
• Right to object and automated decision-making – Users may object to processing for direct marketing purposes or where automated decisions significantly affect them, including profiling.

Transfer of Personal Data
Article 12

The Website owner does not transfer personal data to third parties in Bosnia and Herzegovina or abroad without the explicit consent of the data subject, except in exceptional cases prescribed by law. Personal data will only be disclosed to public authorities when legally required.

In the event of a sale of the business entity owning the Website, the database will become the property of the purchaser, who will be bound by previously accepted contracts including the Terms of Use and this Privacy Policy.

Data Export
Article 13

The Website owner does not export personal data to third countries. All data is stored on servers located within Bosnia and Herzegovina, accessible only to the Website owner and under its designated organizational capacity.

Data Protection Mechanisms
Article 14

Available protection mechanisms for individuals who believe their data has been endangered include internal and external remedies. Internal remedies involve contacting the Website owner, while external remedies involve the competent state authority.

Internal Mechanism
Article 15

For any inquiries or complaints regarding personal data processing, users may contact the Website owner at: office@fscapital.ba.

Supervisory Authority
Article 16

The competent authority for data protection in Bosnia and Herzegovina is the Personal Data Protection Agency, located at Dubrovačka 6, 71000 Sarajevo, Bosnia and Herzegovina. The Agency may be contacted by email at: azlpinfo@azlp.ba or by phone: +387 33 726 250.

Amendments to the Privacy Policy
Article 17

The Website owner reserves the right to amend this Privacy Policy at any time deemed appropriate. All amendments shall take effect on the day of their publication. You will be adequately notified of any significant changes.

In Banja Luka, Dated: 14th May 2025