Legal information
Privacy policy
Version date: 06.03.2024
This privacy policy describes how SIA "E lats" (reg. No. 40003482835) processes the Client's personal data in accordance with the General Data Protection Regulation (GDPR) and the laws of the Republic of Latvia.
General provisions
This Privacy Policy (hereinafter - the Policy) describes the manner in which SIA "E lats" (registration number 40003482835, hereinafter - the Company) processes the Client’s personal data.
The Policy applies where the Client uses, has used, or has expressed a wish to use the services provided by the Company, or is otherwise connected with the services provided by the Company, including in relations with the Client established before these provisions of the Policy entered into force.
Within the framework of the applicable regulatory enactments, the Company ensures the confidentiality of personal data and has implemented appropriate technical and organisational measures to protect personal data against unauthorised access, unlawful processing or disclosure, accidental loss, alteration or destruction.
The Client may contact the Company regarding questions about the processing of personal data, withdrawal of consent, requests, the exercise of data subject rights, and complaints about the use of personal data, using the contact information indicated in Clause 5.3 of the Policy.
The Company has the right to make amendments to the Policy unilaterally. The current version of the Policy will be available on the Company’s website www.e-kredits.lv.
The controller of the Client’s personal data is the Company - a provider of lending services, on whose behalf and in whose interests the Client’s personal data are processed and which is responsible for the processing of the Client’s personal data.
A Client is any natural person who uses, has used, or has expressed a wish to use any of the services provided by the Company, or is connected with them in any other way.
Personal data means any information directly or indirectly related to the Client.
Processing of personal data means any operation performed on personal data (including collection, recording, storage, alteration, granting of access, making enquiries, transfer, deletion, etc.).
Information obtained from and about Clients is processed and protected in accordance with this Policy, the documents developed by the Company, and the requirements of regulatory enactments.
Processing of personal data
Clients’ personal data are used in the Company’s activities in order to provide the Client with high-quality services and to improve them, to send notifications, offers and advertising, to protect the rights and interests of the Company and third parties, and to comply with the requirements of regulatory enactments. If the Client does not provide their personal data in cases where its processing is necessary for the conclusion and performance of a contract or in accordance with legal acts, the Company cannot ensure the provision of services.
2.1.Personal data processed
The Company collects and processes various types of the Client’s personal data in accordance with the purposes set out in the Policy. The Company processes both information identifying the Client and information about the Client’s financial situation, as well as information that the Company is required to obtain in accordance with regulatory enactments.
- Identification data - given name, surname, personal identity number, date of birth, data and image of an identity document (for example, a copy of a passport, ID card), signature;
- Contact information - declared and actual address, telephone number, email address, language of communication;
- Professional data - professional career, name of the employer, contact information of the place of work;
- Financial data - accounts, transactions, loans, monthly income and expenses, liabilities;
- Data on the origin of assets or wealth - the Client’s transaction partners, economic activity;
- Data on trustworthiness and due diligence - in connection with the prevention of money laundering and terrorism financing, and compliance with international sanctions;
- Data obtained in the performance of obligations provided for by regulatory enactments - information requests from investigative authorities, notaries, tax authorities, courts and bailiffs;
- Service-related data - performance of contracts, concluded and terminated contracts, submitted applications, complaints, interests, service fees.
2.2.Purposes of personal data processing
Before concluding a contract, the Company identifies the Client in order to protect the Client and the Company from unlawful use of data and fraud, and to carry out due diligence of the Client in accordance with regulatory enactments. The processing of personal data is based on the Company’s legitimate interest and on the legal obligation to comply with the requirements of regulatory enactments in the field of preventing terrorism financing and money laundering. For the conclusion and performance of a contract, data are processed in connection with the handling of the lending application, the creditworthiness assessment, the preparation of the contract and its performance.
2.3.Obtaining personal data
The Client’s personal data are obtained in the following ways: by the Client providing information in person at the Company’s office or at the places of business of cooperation partners; by the Client providing information remotely using the Company’s website, email, telephone or other electronic means of communication; by the Company receiving information from various databases in connection with the lending application submitted by the Client. The processing of data by making an audio recording of a telephone conversation is carried out for the purpose of ensuring and improving the quality of services and protecting the Company’s legitimate interests.
2.4.Retention period of personal data
Personal data will be processed only for as long as necessary to achieve the specific purpose. In order to retain evidence of the verification of the Client’s identity and of the conclusion and performance of the contract, the Company retains the Client’s personal data for at least 5 (five) years from the moment of performance or termination of the contract. For accounting purposes, data are stored for at least 5 (five) years. Audio recordings of telephone conversations are stored for a period not exceeding 6 (six) months, except in cases where the audio recording captures potentially unlawful conduct.
2.5.Maintenance of the "Blacklist"
The Company has the right to include the Client’s personal data in the "Blacklist" in the following cases: the Client violates generally accepted norms of conduct (including displaying aggressive behaviour); unlawful actions of the Client are established; the pledged property is seized or confiscated as a result of a decision of law enforcement authorities; information is obtained from state authorities about possible unlawful conduct; property is pledged that does not correspond to the content indicated in the contract. The Client has the right to contest inclusion in the "Blacklist" by submitting a written application (in person or electronically with a secure electronic signature) - the review of the application is a paid service and takes place within 30 calendar days.
Automated decision-making
The Company carries out automated decision-making to assess the Client’s creditworthiness by calculating the ratio of the Client’s income to credit obligations and forming an individualised conclusion for each submitted credit application, in order to provide the Client with a response about receiving the loan and determining its amount as promptly as possible.
The Company carries out profiling by applying automated processing of the Client’s data in order to assess the Client’s personal characteristics and analyse the economic situation, in order to use the data for direct marketing and advisory purposes.
Automated decision-making is used in risk management and transaction monitoring to prevent fraud and is based on the performance of the Company’s legal obligations and on the performance of the contract.
By using profiling, personalised offers are made to the Client based on the information available to the Company. In order to send personalised informational materials, the Company processes the Client’s contact information, financial data and contract data.
The Company uses profiling in order to assess the Client’s interests, determine the most suitable services and analyse economic activity.
Recipients of personal data
The Client’s personal data are processed within the Company or its structural units and may be transferred to other recipients on the basis of a lawful ground for the transfer of data.
4.5.Personal data may be transferred to the following institutions and organisations
- Law enforcement authorities, sworn bailiffs, notaries, the tax administration authority, the supervisory and financial investigation authority;
- The Company’s cooperation partners for the preparation and performance of lending contracts;
- Providers of accounting services, auditors, lawyers, financial consultants;
- Maintainers of various registers - credit registers and other registers for the purposes of creditworthiness assessment;
- The State Revenue Service and the State Social Insurance Agency;
- Providers of debt recovery services, courts, out-of-court dispute resolution authorities, insolvency administrators, sworn bailiffs;
- The Company’s service providers - providers of archiving, postal, website maintenance and marketing services.
Client’s rights under the GDPR
In accordance with the General Data Protection Regulation (GDPR), you have the right to access your personal data, rectify it, erase it, restrict processing or object to processing, request data portability, as well as lodge a complaint with the Data State Inspectorate.
5.3.Contact information for exercising rights
To exercise these rights (except for lodging a complaint with the Data State Inspectorate), please submit a written application to the Company: in person (bring a passport or ID card for identification) or by sending an application signed with a secure electronic signature to the email address: elats@elats.lv. We will respond to your application within one month.
Rules on the use of cookies
"Cookies" are a small amount of information that a website stores on a computer or mobile device when the Client visits the Company’s website. It allows the server to collect information from the Client’s browser, so that there is no need to re-enter data when returning to the website or moving from one page to another.
The SIA "E lats" website uses technical cookies that ensure the functioning of the website. They are always used and do not require the Client’s consent.
With the Client’s consent, the website also uses analytical cookies - the Google Analytics service (provided by Google Ireland Limited). Their purpose is to understand, in aggregate form, how the website is used and to improve it. The Client gives consent by pressing the corresponding button in the cookie notice; until then analytical cookies are not loaded. Consent can be withdrawn at any time by clearing the browser data for this website.
Marketing or advertising cookies are not used. Data collected by analytical cookies is not used to make decisions about an individual Client, including decisions on granting a loan.
Data protection contacts