Information on the processing of personal data
Your personal data are processed by a controller – AS PNB Banka (hereinafter – the Bank).
When the Bank has a business or commercial legal interest to process your personal data or the legal interest that is based on the protection of legitimate interests of the Bank or a third party, your personal data are processed “for the consideration of legitimate interests”. However, in these cases, too, the Bank processes your personal data in good faith, taking into account your interests or fundamental rights and freedoms that require protection of personal data.
Please see below the purposes, legal basis and the Bank’s legitimate interests in the processing of your personal data:
To provide you with services of a consistently high quality and be able to offer you products that meet your needs, the Bank uses personal data of various types. The personal data processed by the Bank are grouped into categories for the Bank to be able to manage them in the most efficient way and for you to be able to see the amount of client information managed by the Bank. The Bank does not use all personal data the same way – some of the types of personal data are useful for marketing purposes, others – for provision of direct services or for fulfilment of legal obligations applicable to the Bank. At the same time, the Bank guarantees to its clients that the personal data under the Bank’s management are being processed according to the highest security standards in the field of personal data processing.
According to the general procedure, the Bank is entitled to store your personal data for 10 years as from the moment of termination of business relationships unless the laws and regulations set other time-limits for storing the data. The Bank complies with this general time limit for storing the client’s personal data:
IMPORTANT: Upon expiry of the data storage period, your personal data are being destroyed in a secure way.
What are the possible consequences if you choose not to provide your personal data (or other information) upon the Bank’s request?
The Bank might need to obtain your personal data (or other information) according to the requirements of the laws and regulations or for the Bank to be able to conclude or perform an agreement with you. If you choose not to provide the information (incl. personal data) requested by the Bank, it may limit the Bank’s possibilities to perform an agreement concluded with you, or delay or preclude the Bank from fulfilling legal obligation applicable thereto according to the requirements of the laws and regulations.
You have the following rights:
How does the Bank process your personal data for marketing purposes, in particular, to prepare commercial offers for you?
The Bank carries out marketing activities to inform you of the Bank’s services, products or special offers prepared for your particular needs (incl. various lotteries, special offers or equivalent activities). Under the marketing activities, the Bank carries out surveys to clarify your assessment of the quality of the Bank’s provided services or the compliance of the Bank’s provided services with your needs.
The Bank may use your personal data to send you commercial offers if you have given to the Bank your consent to commercial communication or the Bank has a legitimate interest in implementing such communication.
Irrespective of your choice, you will still receive important notifications or other important information from the Bank (e.g. on changes in the existing services or products).
The Bank uses automated systems to make decisions without engaging the Bank’s specialists in relation to you or your company. The automated systems help taking decisions in a fast, honest, efficient and correct way based on the objective information (incl. personal data) at the Bank’s disposal. The automated individual decisions can affect the Bank’s services, products or possibilities of receipt thereof that the Banks offers to you today or in the future, and can affect a fee set by the Bank for its services or products. The automated individual decisions are based on the information (incl. personal data) that you have submitted to the Bank or that has already been at the Bank’s disposal, or that the Bank is allowed to receive from third parties.
Based on the automated systems, the Bank can decide on the amount of fee to establish for various Bank’s products or services. For instance, if you use the Bank’s online calculators (currency calculator, deposit calculator, loan calculator), the automated systems will use your inputted personal financial information to establish which type of a financial offer the Bank can make you.
Under the marketing activities, for instance, the Bank by means of the automated systems can form client groups that are further used to examine and learn more about the clients’ needs and make decisions. This allows developing products, services and offers for various client groups and adjusting commercial communication demonstrated by the Bank in its and other web pages and mobile applications, including mass media.
The Bank uses the automated systems to monitor operations with finances on your personal and company’s accounts to detect – according to the regulatory requirements – fraudulent or money laundering activities. The automated systems allow the Bank to establish the instances when the client’s account is used in an atypical or unusual way.
At the moment of account opening, the Bank may use the automated systems to verify whether a particular product or service of the Bank is suitable for you, i.e. using the automated systems, the Bank can assess whether you or your company fulfils the conditions required for opening an account with the Bank. In this case, the automated systems use the information provided by you – e.g. on the financial situation if you apply for the Bank’s lending product.
The Bank uses the automated systems to make decisions on granting loans, e.g. when you apply for a consumer loan. In the said cases, the automated systems perform credit scoring. The purpose of such processing is to assess your ability to repay the Bank’s loan. For such processing, not only your provided information on your financial situation can be used but also information on similar loans or on the transactions you made on your accounts.
IMPORTANT: Credit scoring is initiated only when the Bank has received your application for the respective Bank’s service or product which such method is applied to. The Bank verifies regularly credit scoring methods to make certain that they are honest and objective.
The Bank may pass your personal data (incl. other information) to external organisations to ensure provision of the Bank’s services or products (e.g. Mastercard), manage the Bank’s business (e.g. to external auditors) and fulfil legal obligations applicable to the Bank (e.g. to supervisory authorities).
IMPORTANT: The Bank processes your personal data in cooperation with insurance service providers or investment service providers if you have chosen the respective products, therefore under this cooperation your personal data can be communicated to the representatives of these organisations.
The Bank may pass your personal data (incl. information on you) beyond the European Union or the European Economic Area in the following cases:
If the Bank cooperates with service providers that process clients’ personal data in third countries, the Bank makes certain whether these service providers meet the Bank’s requirements in the field of personal data protection and the general requirements of the European Union regarding the compliance with the level of personal data protection.
The processing of your personal data is regulated and your rights in the field of protection and legality of processing of personal data are protected by:
The Bank is a responsible controller of your personal data. To demonstrate clearly that the Bank performs a lawful, fair and transparent processing of your personal data, the Bank has created and maintains a system of accountability that is based on:
However, if you have any suggestions or objections regarding the processing of personal data performed by the Bank, you are entitled to submit to the Bank a suggestion, feedback, application or complaint. You may submit an application or complaint in a way that is most convenient for you:
IMPORTANT: If you file a complaint, the complaint will be considered by the Bank’s Data Protection Committee. The Bank’s Data Protection Committee is a permanent collegial body that has been established pursuant to the decision of the Board of the Bank and that in its operation is governed by the Bank’s regulatory documents, valid laws and regulations of the Republic of Latvia, valid binding legislation (regulations, directives, decisions, case-law) of the European Union, recommendations of the Data State Inspectorate, guidelines, recommendations and best practice of the European Data Protection Board, best practice of the Association of Commercial Banks of Latvia, rules and recommendations of the Financial and Capital Market Commission.