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STOCKERO COOKIE POLICY

Version: 1.5Effective from: 24 October 2026

This English text is a translation provided for your convenience. The binding version is the Czech original, Zásady cookies Stockero, available at https://stockero.com/cookies/. In the event of any discrepancy, the Czech version prevails.

1. Who uses these technologies

The controller of personal data processed through cookies and similar technologies is:

FinBits s.r.o.
registered office at Jičínská 226/17, Žižkov, 130 00 Prague 3, Czech Republic
Company ID: 19630981
registered in the Commercial Register kept by the Municipal Court in Prague, Section C, Insert 388729
e-mail for privacy enquiries: support@stockero.com

(hereinafter "FinBits" or "we").

This policy applies to the website stockero.com and the web application app.stockero.com (hereinafter the "Application"). If Stockero starts using another domain with a different technical setup, that domain must be added to this policy and to the technology inventory before it is put into use.

2. What cookies and similar technologies are

Cookies are small files or records that a website stores on your device or reads from it. Local storage, pixels, tags, SDKs, device identifiers, embedded elements and certain measurement or session-recognition techniques may work in a similar way. For simplicity, this policy refers to all of them collectively as "cookies".

Cookies may be:

3.1. Without consent we use only those cookies that are strictly necessary for the transmission of communication or for a service you have expressly requested. Depending on the specific and individually assessed setup, this may include security, sign-in, session maintenance, an order or payment initiated by you, load balancing and storing your cookie choice. Labelling a tool as security-related, fraud-prevention or operational does not in itself make it permissible without consent.

3.2. We activate analytics, marketing and other optional cookies only after you have given prior consent. The same applies to third-party cookies, embedded media, measurement and similar technologies, unless they are genuinely necessary in the given setup for a function you have requested. The live customer support chat is an exception under Article 3.6.

3.3. Consent to the storing of or access to strictly necessary cookies is not required only to the extent of the exemption under the second sentence of Section 89(3) of Czech Act No. 127/2005 Coll. Any subsequent processing of personal data relies, depending on the specific purpose, on the performance of a contract, compliance with a legal obligation or our legitimate interest in the secure and functional operation of the service under Article 6(1)(b), (c) or (f) GDPR; the exact legal basis is stated for each technology in Article 6.

3.4. For optional cookies, the basis for storing them on or reading them from your device is your consent under Section 89(3) of Act No. 127/2005 Coll., and the basis for the subsequent processing of personal data is your consent under Article 6(1)(a) GDPR.

3.5. Consent is voluntary. Refusing optional cookies does not prevent you from making a purchase or from using the Application in its basic scope; however, optional elements that depend on a particular third party, such as embedded video, may remain unavailable. In such a place we may offer you the option to enable only that specific service or provider, without forcing consent for the rest of the service.

3.6. The live customer support chat loads automatically on all pages of the website, including before you make your cookie choice. We use it as our standard customer support channel and its immediate availability is necessary in order to provide that support; we rely on our legitimate interest under Article 6(1)(f) GDPR. The chat stores on your device only the data needed for the conversation to work, which are listed specifically in Article 6. We do not use chat data for advertising audiences, targeting or campaign measurement. You can block the chat in your browser settings as described in Article 7.5; it will then be unavailable.

A. Strictly necessary

These ensure the basic functioning of the website and the Application, security, sign-in, session management, ordering, payment, load balancing and storing your consent choice. They also include the live customer support chat under Article 3.6. They cannot be switched off through our banner, because without them the requested service could not work properly or securely. You can block them in your browser, but parts of the service may then stop working.

B. Functional and personalisation

These remember optional preferences or enable elements that are not necessary for the basic service, such as external video or advanced customisation. We use them only after consent, unless they are objectively necessary for a function you have requested at that moment.

C. Analytics

These help us understand how visitors use the website and the Application, which parts work and where errors occur. Where they store or read information on your device and this is not strictly necessary technical diagnostics without such access, we use them only after consent. Before consent, an optional analytics tool must not store or read information on your device or send non-essential measurement signals; any "cookieless" or "consent mode" setting is assessed by us on the basis of actual network traffic, not the name of the mode.

D. Marketing

These serve to measure campaigns, build audiences, carry out remarketing or display personalised advertising on other services. We use them only after your explicit consent. Refusal does not mean you will see no advertising, but it should not be based on tracking through these technologies.

5. What data cookies may process

Depending on the specific technology, this may include in particular:

We do not link marketing or analytics identifiers with payment data, DK Investment Club membership status, watchlist contents, symbols associated with an account, the text of notes, or the specific analyses displayed to a signed-in user. We do not use such data for advertising audiences, targeting or campaign measurement.

6. Current list of cookies and similar technologies

Below is the complete list of technologies actually used by the stockero.com website. The list is available even before consent is given and we update it whenever anything changes. We operate the consent banner ourselves, without an external consent management platform; its only storage item is shown in the first row.

Name / technologyProvider, role and domain1st/3rd partyCategoryRegime under Section 89Purpose, data and GDPR basisCookie/storage lifetimeServer-side retentionRecipient and countryTransfer outside the EEA and safeguardLink
`stockero_consent` (cookie)FinBits s.r.o. – controller, domain `.stockero.com`1st partyStrictly necessaryWithout consent under the second sentence of Section 89(3)Storing and evidencing your cookie choice. Pseudonymous choice identifier, date and time, selected purposes and policy version. Article 6(1)(c) and (f) GDPR12 monthsRecord of the choice for as long as it is valid and 3 years thereafterFinBits s.r.o., Czech RepublicNo—
`ssupp_<chat key>` (local storage)Smartsupp.com, s.r.o. – processor, domain `smartsuppchat.com`3rd partyNecessary for the chatWithout consent, legitimate interest in providing customer support (Article 3.6)Maintaining the state and continuity of the conversation, an unsent message, information about the chat window being opened and the number of visits. Article 6(1)(f) GDPRPersistent, until deleted by the user or the applicationConversation content for the time needed to handle the request and 3 years thereafter under Article 5 of the Privacy PolicySmartsupp.com, s.r.o., Czech RepublicNohttps://help.smartsupp.com/en/articles/12647741-data-privacy-gdpr
`ssupp.vid` (cookie, set when a conversation starts)Smartsupp.com, s.r.o. – processor, domain `.stockero.com`3rd partyNecessary for the chatWithout consent, legitimate interest in providing customer support (Article 3.6)Pairing a visitor with an ongoing conversation after the page is reloaded. Article 6(1)(f) GDPRPersistent, until deleted by the user or the applicationAs for the previous itemSmartsupp.com, s.r.o., Czech RepublicNohttps://help.smartsupp.com/en/articles/12647741-data-privacy-gdpr
`__stripe_mid`, `__stripe_sid` (cookies, order page only)Stripe Payments Europe, Limited – processor or separate controller depending on the activity, domain `.stockero.com`3rd partyNecessary for paymentWithout consent, necessary for a payment you have expressly requestedProcessing the payment and preventing fraud. Device and session identifier. Article 6(1)(b) and (f) GDPRAs configured by StripeUnder Stripe's termsStripe group companies, Ireland and, depending on the service, other countriesYes, standard contractual clauses or the EU–U.S. Data Privacy Frameworkhttps://stripe.com/legal/cookies-policy
`formLastVisit_<form identifier>` (local storage, order page only)FAPI Business s.r.o. – processor, script `form.fapi.cz`3rd partyNecessary for the orderWithout consent, necessary for an order you have expressly requestedRemembering your last visit to the order form. Article 6(1)(b) GDPRPersistent, until deleted by the user or the applicationUnder FAPI's termsFAPI Business s.r.o., Czech RepublicNohttps://fapi.cz
`rc.js` (script on `c.seznam.cz`) and identifiers stored by Seznam on its own domainSeznam.cz, a.s. – separate controller, domain `.seznam.cz`3rd partyMarketingTraffic measurement without consent, inclusion in remarketing audiences only with consent under Section 89(3)Website traffic measurement and remarketing in the Sklik advertising network. We pass the script a `consent` parameter: 0 without your consent, where the visit is only counted and you are not added to advertising audiences, and 1 after consent. We do not pass Seznam any e-mail addresses or other identifiers. Art. 6(1)(f) GDPR for measurement, Art. 6(1)(a) GDPR for remarketingPer Seznam.cz termsPer Seznam.cz termsSeznam.cz, a.s., Czech RepublicNohttps://o.seznam.cz/ochrana-udaju/
`_gcl_au` and similar Google Ads identifiers (script on `googletagmanager.com`)Google Ireland Limited – separate controller, domain `.stockero.com` and Google domains3rd partyMarketingWith consent under Section 89(3)Measuring conversions from Google Ads campaigns and evaluating their performance. Click and device identifier. Art. 6(1)(a) GDPRPer Google settings, typically 90 daysPer Google termsGoogle Ireland Limited, Ireland and other Google group countriesYes, standard contractual clauses or the EU–US Data Privacy Frameworkhttps://policies.google.com/technologies/cookies
`stockero_lang`, `stockero_geo` (cookie and local storage)FinBits s.r.o. – controller, domain `.stockero.com`1st partyStrictly necessaryWithout consent, necessary to deliver the language version you have requestedRemembering your language choice and the country derived from your IP address, so that the site opens in the right language. Country code only, not the IP address itself. Article 6(1)(f) GDPR12 months (cookie); local storage until deletedNot stored on our serversFinBits s.r.o., Czech RepublicThe country is determined by the GeoJS service (geojs.io), which receives your IP address for that single queryhttps://www.geojs.io/

Neither analytics cookies nor third-party measurement technologies are currently deployed on the website; we measure traffic solely by our own means without cookies, as described below.

Our own anonymous traffic statistics (no cookies)

So that we know how many people visit the website and how many of them register, we also count visits ourselves on our own server. We store nothing on your device, no cookies and no other data, and we do not track you across websites. This is therefore neither storage of information on your device nor access to it within the meaning of Section 89(3) of Act No. 127/2005 Coll., and no consent is required.

When a page is displayed, your browser sends us only the address of the page visited, information about where you came from (the campaign tag in the address or the domain of the referring website) and whether this is the first page of the visit. To tell unique visitors apart, we create a one-way fingerprint (SHA-256) from your IP address and browser information using a random key that changes every day; the fingerprints and the key for that day are deleted once it ends and we do not store the IP address. All that remains permanently are daily aggregate figures, for example “120 visitors to a page, 6 registrations”, from which no one can be identified. We count successfully submitted webinar registrations in the same aggregate way. The legal basis is our legitimate interest in measuring and improving the website under Article 6(1)(f) GDPR. The marketing technologies listed in the table above are activated in full only after your consent under Article 3.2; without consent, Sklik receives only an anonymous record of the visit and you are not added to advertising audiences. Once we introduce further technologies, we will add them to the table with a specific purpose and lifetime.

7. How to manage your choice

7.1. If you visit us without a valid stored choice, we display a banner with equally available options:

Closing the banner or continuing to browse is not treated by us as consent and optional tools remain switched off. Optional categories are not pre-enabled. The banner does not make access to basic content conditional on consent and does not unreasonably obstruct your use of the website.

7.2. You can change your choice or withdraw your consent at any time through the permanently available "Cookie settings" link in the footer of the website and the Application. Withdrawal is as easy as giving consent and takes effect for future processing. It does not affect the lawfulness of processing carried out previously.

7.3. We normally remember your consent choice for no more than 12 months, after which we may ask you to renew it. Following a refusal, and absent any significant change to the setup, we will not ask you for the same choice again for at least 6 months, unless you delete the cookie storing the choice or visit the website from a different device or browser.

7.4. To evidence your choice we store a pseudonymous consent identifier, the date and time, the purposes selected and the version of the banner and of this policy. We do not retain your full IP address for this purpose unless its short-term use is technically necessary and duly justified. We keep the record for as long as the choice is valid and for 3 years thereafter, on the basis of our obligation to demonstrate lawfulness and our legitimate interest in defending legal claims.

7.5. You can also delete or block cookies in your browser settings. Those settings are separate from our banner and may affect the functioning of sign-in and other requested features. You will find instructions in your browser's help.

8. Embedded content and third-party services

Our pages may contain embedded video, maps, sign-in elements or other third-party services. Where they are not strictly necessary, we do not load them before you consent to the relevant category. In place of such an element we may display a placeholder panel with an explanation and a button to enable that specific service or provider; enabling one element must not, without a further choice, activate an unrelated service. The live customer support chat is an exception and loads automatically under Article 3.6.

Once enabled, a third party may obtain technical data and information about your visit. Its exact identity, its role as controller or processor, its country and a link to its own information must be clearly stated in the current list in Article 6.

9. Transfers of data outside the EEA

Some providers may process data outside the European Economic Area. The specific legal entity, its role, country, sub-processors and the safeguard actually used are stated for the relevant technology in Article 6. Depending on the actual setup, this will be a European Commission adequacy decision, a verified valid certification of the specific recipient under the EU–U.S. Data Privacy Framework, or standard contractual clauses actually concluded and supplemented by an assessment and any necessary measures.

10. Your rights

Where cookies process your personal data, you have, subject to the conditions set out in the GDPR, in particular the right of access, rectification, erasure, restriction, data portability, withdrawal of consent and the right to object to processing based on legitimate interest. The lifetime of each cookie and the related server-side retention period are set out in Article 6. A detailed description of your rights and how to exercise them can be found in the Stockero Privacy Policy at https://stockero.com/en/privacy/.

You can send your request to support@stockero.com or to FinBits s.r.o., Jičínská 226/17, Žižkov, 130 00 Prague 3, Czech Republic.

You also have the right to lodge a complaint with:

the Office for Personal Data Protection
Pplk. Sochora 27, 170 00 Prague 7, Czech Republic
e-mail: posta@uoou.gov.cz
web: https://uoou.gov.cz/verejnost/stiznost-na-spravce-nebo-zpracovatele

11. Changes to this policy

We update this policy when technologies, purposes or legal requirements change. The current version is always marked with its effective date. If a change requires fresh consent or significantly extends the processing, we will ask you to make a new choice before activating the technologies concerned.