• Article 6, Paragraph one, point (c) of the regulation 
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other related legal acts, guidelines
• Law on International and National Sanctions of the Republic of Latvia and other sanctions-related legal acts, guidelines

Public interest arising from the law

• Article 6, first paragraph, point (e) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other related legal acts, guidelines 

• Register of invalid documents
• Cooperation partners who ensure identification when applying for services 
• Information systems maintainers

5 years from the date of termination of business relationship

7 years from the date of termination of the business relationship, if the information has been requested by the supervisory authority - the Bank of Latvia

Client

Name, surname, personal identity number, date of birth, number of identity document, date of issue, country, issuing authority of the document, expiration date, photo, video image, biometric data (use of facial image for video identification. A photo or video of your face is compared to an image of your identity document (such as a passport or ID card) to make sure that the owner of the document is you), address, phone number, e-mail address, place of birth, country of tax residence, source of income, name of the place of work, amount of planned payments per month in bank accounts, PEP status, information related to client identification and research, device identifier, MobileSCAN license number, IP address.

Statutory obligation 

• Article 6, Paragraph one, point (c) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other related legal acts, guidelines
• Cabinet Regulation No. 392 of 03.07.2018 Procedures by which the Subject of the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing Performs the Remote Identification of a Client
• Law on International and National Sanctions of the Republic of Latvia and other sanctions-related legal acts, guidelines

Public interest arising from the law

• Article 6, first paragraph, point (e) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other related legal acts, guidelines 

• Cooperation partner performing remote video identification 
• Creditinformation Bureau
• Register of invalid documents
• Maintainers of information systems

Identity verification in the electronic environment (authentication) 

For you to use our services, we are obliged to verify your identity. Identity verification or authentication is most often carried out using the tools we offer MobileSCAN/Digipass 780, code card/code calculator; tools offered by other service providers - Smart-ID, eID card or eParaksts Mobile.

We do not process your biometric data (e.g. face or fingerprint data). This data is processed by companies that offer you authentication services.

Client/any natural person

Name, surname, personal identification number, phone number, user login name, password, device identifier, account number, IP address, transaction history.

Conclusion and performance of the contract 

• Article 6, Paragraph one, point (c) of the regulation

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on the digital operational resilience of the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU) No 909/2014 and (EU) 2016/1011
• Commission Delegated Regulation (EU) 2018/389 of 27 November 2017 supplementing Directive (EU) 2015/2366 of the European Parliament and of the Council regarding regulatory technical standards on secure user authentication and common and secure open communication standards

• Authentication service providers - SK ID Solutions AS, SJSC Latvian State Radio and Television Centre
• Information systems maintainers

Client including a minor (status of politically exposed person, beneficial owner (client or family member or person closely related to him)) 

Name, surname, personal identity number, date of birth, place of birth, country, number of identity document, date of issue, country, issuing authority of the document, expiration date, photo, citizenship, address, telephone number, e-mail, social status/name of place of work, position, information related to previous professional activities, type of occupation, reputation, education, tax identification number, place of tax residence, source of income, planned turnover in bank accounts (incoming/outgoing payments and their origin, cash deposits/withdrawals), banking services used, information related to family members, kinship, politically exposed person (PEP) status, account number, account balance, payment card number, transaction history, movable/immovable property owned, relationship with companies, shares, information related to the identification and research of the client, criminal records, signature.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and related legislation and other related legal acts, guidelines
• Law on International and National Sanctions of the Republic of Latvia and other sanctions-related legal acts, guidelines

Public interest arising from the law

• Article 6, first paragraph, point (e) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and related legislation and other related legal acts, guidelines

• Public registers: Population register, Lursoft, Enterprise Register, Land Register, State Revenue Service registers, Register of Invalid Documents, CSDD State Register of Vehicles and Their Drivers
• Information systems maintainers
• Citadele Group Companies

5 years from the date of termination of business relationship 

7 years from the date of termination of the business relationship, if the information has been requested by the supervisory authority - the Bank of Latvia

 (Banks and/or other financial institutions securely exchange client data with each other to improve the quality of client checks, spot suspicious transactions or persons who may be involved in money laundering, sanctions, protect banks from financial crime. This exchange takes place in a closed, secure, non-publicly accessible system that is accessed only by authorized personnel)

Client including a minor (politically exposed person, beneficial owner (client or family member or person closely related to him))

 Name, surname, personal identity number, date of birth, place of birth, country, information related to family members, kinship, name of place of work, position, place of tax residence, status of a politically exposed person (PEP) status, source of income, transaction history, existence/absence of insolvency proceedings, transactions with financial instruments, information related to the identification and research of the client, criminal records.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other related legal acts, guidelines
• Law on International and National Sanctions of the Republic of Latvia and other sanctions-related legal acts, guidelines

Public interest arising from the law

• Article 6, first paragraph, point (e) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other related legal acts, guidelines

• Cooperation partner in the provision of client research tool and maintainers of other information systems
• Banks in Latvia

Client 

Name, surname, personal identification number, date of birth, identity document number, date of issue, country, document issuing authority, expiration date, account number, payment card number, account balance.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other related legal acts, guidelines
• Law on International and National Sanctions of the Republic of Latvia and other sanctions-related legal acts, guidelines

Public interest arising from the law

• Article 6, first paragraph, point (e) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other related legal acts, guidelines

• Financial Intelligence Unit
• Information systems maintainers

5 years from the date of termination of business relationship

7 years from the date of termination of the business relationship, if the information has been requested by the supervisory authority - the Bank of Latvia

Client including a minor

 (status of politically exposed person, beneficial owner (client or family member or person closely related to him)) Name, surname, personal identity number, date of birth, place of birth, country, number of identity document, date of issue, country, issuing authority of the document, expiration date, photo, citizenship, address, telephone number, e-mail, social status/name of place of work, position, information related to previous professional activities, type of occupation, reputation, education, tax identification number, place of tax residence, source of income, planned turnover in bank accounts (incoming/outgoing payments and their origin, cash deposits/withdrawals), banking services used, information related to family members, kinship, politically exposed person (PEP) status, account number, account balance, payment card number, transaction history, movable/immovable property owned, relationship with companies, shares, information related to the identification and research of the client, criminal records, signature. In addition, within the framework of sanctions management, transaction/payment details (date, amount and currency, payer and payee (name, surname, personal identification number, title, registration number, country of registration), account numbers and credit institution where the account is opened, payment details, a brief description of the nature of the transaction/payment, information, facts and documents indicating a violation of sanctions or their signs, actions performed with the payment – refused to execute and returned to the payer, funds frozen, transaction has already taken place (i.e. in cases where a violation of sanctions is detected after the payment has been executed)).

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other related legal acts, guidelines
• Law on International and National Sanctions of the Republic of Latvia and other sanctions-related legal acts, guidelines 
• 17.08.2021 Republic of Latvia Cabinet Regulation No. 550 Regulations Regarding the Procedures for the Submission of Reports on Suspicious Transaction and the Threshold Declaration and Content Thereof

Public interest arising from the law

• Article 6, first paragraph, point (e) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other related legal acts, guidelines

• Financial Intelligence Unit of Latvia
• State Revenue Service
• Information systems maintainers

5 years from the date of termination of business relationship 

7 years from the date of termination of the business relationship, if the information has been requested by the supervisory authority - the Bank of Latvia

Reporting of unusual and suspicious transactions in financial instruments to the Bank of Latvia 

(We accurately monitor clients' transactions in financial instruments and report if it notices anything suspicious to protect both clients and the bank from financial risks)

Client 

Name, surname, personal identification number, date of birth, address, employer, position, taxpayer number, account number, transaction history.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other related legal acts, guidelines
• Regulation (EU) No 596/2014 of the European Parliament and of the Council of 16 April 2014 on market abuse (market abuse regulation)
• Commission Delegated Regulation (EU) 2016/957 of 9 March 2016 supplementing Regulation (EU) No 596/2014 of the European Parliament and of the Council regarding regulatory technical standards on appropriate measures, systems and procedures, as well as notification templates for the prevention, detection and reporting of abusive practices and suspicious orders or transactions (Text with EEA relevance)

Public interest arising from the law

• Article 6, first paragraph, point (e) of the regulation
• Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other related legal acts, guidelines

• Bank of Latvia
• Information systems maintainers

5 years from the date of termination of business relationship

7 years from the date of termination of the business relationship, if the information has been requested by the supervisory authority - the Bank of Latvia 

Client

Name, surname, personal identity number, date of birth (for non-residents), identity document (type, date of issue, period of validity, country of issue), address, phone number, place of birth, country, place of tax residence, taxpayer number, citizenship, signature (if the application is submitted in person), account number in the bank, account balance, information related to accounts of deposits and financial instruments, value of the securities portfolio, amount of interest credited.

Statutory obligation

•  Article 6, Paragraph one, point (c) of the regulation 
• Agreement between the Government of the United States of America and the Government of the Republic of Latvia to Improve International Tax Compliance and to Implement FATCA 
• Chapter XII of the Law on Taxes and Fees 
• Cabinet Regulation No. 134 of 24.03.2015 Procedures by which the Information is provided to the State Revenue Service to Ensure the Compliance with the Requirements Laid Down in the Law on the Agreement between the Government of the United States of America and the Government of the Republic of Latvia to Improve International Tax Compliance and to Implement FATCA
• Cabinet Regulation No. 210 Regulations Regarding Automatic Exchange of Information on Reportable Cross-border Arrangements

Client 

Name, surname, personal identity number, date of birth (for non-residents), place of tax residence, taxpayer number, bank account number, account balance, information related to accounts of deposits and financial instruments, value of the securities portfolio, amount of interest credited.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation 
• Agreement between the Government of the United States of America and the Government of the Republic of Latvia to Improve International Tax Compliance and to Implement FATCA
• Chapter XII of the Law on Taxes and Fees
• Cabinet Regulation No. 20 of 05.01.2016, Procedures by which a Financial Institution Implements the Due Diligence Procedures for Financial Accounts and Provides Financial Accounts Information to the State Revenue Service Cabinet Regulation No. 134 of 24.03.2015 Procedures by which the Information is provided to the State Revenue Service to Ensure the Compliance with the Requirements Laid Down in the Law On the Agreement between the Government of the United States of America and the Government of the Republic of Latvia to Improve International Tax Compliance and to Implement FATCA Cabinet Regulation No. 210 Regulations Regarding Automatic Exchange of Information on Reportable Cross-border Arrangements

Creditworthiness assessment

(For products - mortgage, consumer loan, card credit limit, restructuring loan (Debt payment agreement)

The creditworthiness assessment includes assessment of the creditworthiness of the client (borrower and co-borrower/guarantor) and/or decision-making for the granting of credit (of all types). (Determination of the probability of credit risk in case of default of the client, assessment of possible losses, definition of signals and special conditions - (e.g. gambling, negative history, suspicious contributions to the account), provision of an internal rating system, including an automated individual decision-making in the issuance of credit.

Name, surname, personal identity number, date of birth, age, employer, type of occupation (salaried employee, salaried employee abroad, pensioner, board member/company owner, self-employed, sailor, unemployed), level of education (primary education/secondary, secondary vocational, incomplete higher, higher), account transactions (incoming and outgoing payments of the bank, as well as statements of other bank accounts received through PSD2 (with the client's permission) solution or PDF) (Income level, payments of bonuses, benefits, etc., which indicate the income of clients and the source of its extraction. Credit obligations, actual payments (incoming and outgoing) of the country of nationality, validity of the residence permit and its period of validity, internal bank information on the client's assets and repaid loans/leases (type of obligation, start/end date, status, amount issued/balance/interest rate, days of delay/amounts), write-off debts, status of the client (dead, unwanted, incapacitated, insolvent, debtor, cooperation terminated, unacceptable, rejected client), information from sworn bailiffs on outstanding debt obligations. Information related to the composition of the household - name, surname, age, personal identity number, marital status (married, unmarried, cohabitation of unmarried partners), number of children (for calculating the subsistence minimum), connection of the co-borrower / guarantor with the client (1st degree relatives - spouse, cohabiting partner, parents, children).

Credit Information Bureau: name, surname, personal identity number.

KIB. SRS: SRS income for the last 3 years, income type, amount, date of commencement of employment, name of employer and reg. number.

KIB. SSIA: amount of benefit group and / or pensions for the last 6 months, start and end date of disbursements, if any.

KIB.debts: type of indebtedness (telecommunications services, utilities, etc.), start and end date of indebtedness, starting amount and balance, number of claims for the borrower, type of credit obligation (what kind of loan), current and termination status, start and end date of credit, starting amount and balance, start and end date of delay, days and amount of delay, role of the client at the level of obligations (borrower, co-borrower, guarantor), insolvency history and current status.

KIB. Crefo: Type of credit obligation, start and end date of indebtedness, starting amount and balance, start and end date of late payment and days of delay.

SSIA (database was used until 31.12.2022) name, surname, personal identity number, amount of income for the last 6 months, name of employer and reg. No., date of start and end of work, place of work, type of income (including benefits and pensions).

Bank of Latvia's Credit Register: name, surname, personal identity number, active and terminated liabilities, current and termination status of liabilities, initial loan amount, balance, start and end date of liabilities, days of delay, role of the client at the level of liabilities (borrower, co-borrower, guarantor).

Lursoft: Information is requested about the individual who owns the company or the employer of the individual: name, surname, personal identity number, company reg. No., liquidation/ insolvency, financial statement of the company, number of employees), presence/absence of client shares/shares, start and end date for ownership of shares/shares. May be attributed to conclusions relating to the solvency of the enterprise, which may affect the granting of a loan to the client.

Insolvency register: name, surname, personal identity number, date and status of insolvency.

Legitimate interests in ensuring responsible lending, assessing the ability of clients to repay the loan, thus protecting the interests of both the bank and the client and preventing the emergence of excessive indebtedness.

• Article 6, Paragraph one, point (f) of the regulation

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Regulation No. 265 of the Bank of Latvia of 18.12.2023 Credit Risk Management Regulations
• EBA/GL/2020/06 29.05.2020. Guidelines on loan initiation and supervision applicable from 30.06.2021.
• EBA/GL/2017/15 23.02.2018. Guidelines on interconnected clients in accordance with Article 5(1)(39) of Regulation (EU) No 575/2013
• Consumer Rights Protection Law
• Guideline No. 15 of the Consumer Rights Protection Centre of 15.12.2021 Consumers' ability to repay loans for assessment of lenders providing lending services to consumers
• Regulation No. 350 of the Bank of Latvia of 25.11.2024 Rules for obtaining permission to use internal models in the calculation of capital requirements

Public/private registers:

• Credit register of the Bank of Latvia
• SSIA (until 31.12.2022.)
• Creditinformation Bureau
• Lursoft
• Crediweb
• Insolvency register

10 years

3 years for applications that have not materialized in the service

3 years from the date of requesting information from public/private registers

For personal data used for identification, see the information in the section On-site and electronic identity verification (authentication).

Granting and servicing of credit limit

(including identification, creditworthiness assessment, receipt of commissions and other payments, communication within the framework of the service)

Client

Name, surname, personal identification number, date of birth, phone number, e-mail address, address, account number, card number, transaction information, signature.

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

5 years from the date of termination of the business relationship

For the personal data used in the creditworthiness assessment, see the section Creditworthiness assessment.

Provision of consumer credit service

(including identification, creditworthiness assessment, receipt of commissions and other payments, communication within the framework of the service)

Name, surname, personal identification number, date of birth, phone number, e-mail address, address, account number, transaction information, signature.

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

For the personal data used in the creditworthiness assessment, see the section Creditworthiness assessment.

Provision of mortgage loan service

(including identification, creditworthiness assessment, receipt of commissions and other payments, communication within the framework of the service)

Client (co-borrower, pledger)

Name, surname, personal identity number, date of birth, telephone number, e-mail address, address, account number, information about the transaction, movable property and real estate, signature.

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

• Financial institution Altum
• Real estate appraisers
• Land register
• Lursoft

5 years from the date of termination of business relationship

For the personal data used in the creditworthiness assessment, see the section Creditworthiness assessment.

Restructuring of credit transactions

(including identification, creditworthiness assessment, receipt of commissions and other payments, communication within the framework of the service) Restructuring means changing the terms of the loan to make it easier for you to repay it. For example, you can extend the loan repayment period, reduce the interest rate or postpone principal payments for a while. We do this if you are having trouble repaying your loan as originally planned.

Client

Name, surname, personal identity number, date of birth, telephone number, e-mail address, address, account number, information about the transaction, movable property and real estate, signature.

Conclusion and performance of the contract

Article 6, Paragraph one, point (b) of the regulation

• Land register
• Lursoft
  
  

For the personal data used in the creditworthiness assessment, see the section Creditworthiness assessment.

Name, surname, personal identification number, date of birth, account number, transaction history (outgoing and incoming payments), signature.

• Article 6, Paragraph one, point (b) of the regulation

• recipients of transfers
• cooperation partners involved in the execution of payments
• other credit and financial institutions, financial service intermediaries and third parties involved in the execution of payments
• participants and persons associated with local, European and international payment systems
• third parties in relation to their contracts and transactions
• information systems maintainers

Opening and servicing an escrow account

(including receipt of commission and other payments, communication within the framework of the service, identification)

Client (buyer, seller)

Name, surname, personal identity number, date of birth, telephone number, address, e-mail address, escrow account number, transaction information, movable property and real estate, signature.

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

• recipients of transfers
• cooperation partners involved in the execution of payments
• other credit and financial institutions, financial service intermediaries and third parties involved in the execution of payments
• participants and persons associated with local, European and international payment systems
• third parties in relation to their contracts and transactions
• information systems maintainers

Client, including a minor

Name, surname, personal identity number, date of birth, phone number, account number, information about the transaction, kinship (in case of inheritance payment), information obtained in contact with the bank, signature.

• Article 6, Paragraph one, point (b) of the regulation

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Cabinet Regulation No. 625 of 14.09.2021 Requirements for supporting documents for cash receipts and cash expenses and for keeping the cash book

• recipients of transfers
• cooperation partners involved in the execution of payments
• other credit and financial institutions, financial service intermediaries and third parties involved in the execution of payments
• participants and persons associated with local, European and international payment systems
• third parties in relation to their contracts and transactions
• information systems maintainers

(including receipt of commission and other payments, communication within the service, identification)

Client, including a minor

Name, surname, personal identification number, audio recording, voice password, phone number, account number, transaction information, signature.

• Article 6, Paragraph one, point (b) of the regulation

• recipients of transfers;
• cooperation partners involved in the execution of payments
• third parties in relation to their contracts and transactions
• information systems maintainers

Client, including a minor

Name, surname, personal identification number, audio recording, voice password, phone number, account number, transaction information, signature.

• Article 6, Paragraph one, point (b) of the regulation

• recipients of transfers
• cooperation partners involved in the execution of payments
• other credit and financial institutions, financial service intermediaries and third parties involved in the execution of payments
• participants and persons associated with local, European and international payment systems
• third parties in relation to their contracts and transactions
• information systems maintainers

Client

Name, surname, personal identification number, phone number, audio recording, voice password, account number and balance, transaction information.

• Article 6, Paragraph one, point (b) of the regulation

• Information systems maintainers

Client

Name, surname, personal identification number, phone number, address, e-mail, account number, transaction information, signature.

• Article 6, Paragraph one, point (b) of the regulation

• recipients of transfers
• cooperation partners involved in the execution of payments
• other credit and financial institutions, financial service intermediaries and third parties involved in the execution of payments
• participants and persons associated with local, European and international payment systems
• third parties in relation to their contracts and transactions
• information systems maintainers

Issuance and servicing of payment cards (debit cards) (in branches, client service centres, by mail)

(including, receipt of commission and other payments, communication within the service, identification)

Client, including a minor

Name, surname, personal identification number, date of birth, phone number, address, e-mail address, audio recording, account number, payment card number, employer (if cards are ordered by the employer), signature.

• Article 6, Paragraph one, point (b) of the regulation

• Postal and courier service providers

Client

Name, surname, date of birth, phone number, email address, payment card number, transaction history (outgoing, incoming payments).

• Article 6, Paragraph one, point (b) of the regulation

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Accounting Law

• cooperation partner for the provision of the service
• information systems maintainers

Provision of online banking service (including, in the mobile application)

(including communication within the service, identification)

Client, including a minor

Name, surname, date of birth, personal identification number, phone number, e-mail address, information related to online banking connection (user login name, password, device identifier, account number, IP address), transaction history, signature.

• Article 6, Paragraph one, point (b) of the regulation

Statutory obligation

• Article 6, Paragraph one, point (c)
• Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on the digital operational resilience of the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU) No 909/2014 and (EU) 2016/1011
• Commission Delegated Regulation (EU) 2018/389 of 27 November 2017 supplementing Directive (EU) 2015/2366 of the European Parliament and of the Council regarding regulatory technical standards on secure user authentication and common and secure open communication standards

• Information systems maintainers

10 years from the date of termination of the business relationship

18 months for storing online banking audit records

Provision of SMS banking service

(sending information in the form of SMS to the client about transactions)

Client, including a minor

Name, surname, date of birth, personal identification number, phone number, account number, transaction information, signature.

• Article 6, Paragraph one, point (b) of the regulation

• telecommunications service provider
• Information systems maintainers

Provision of deposit services (term deposit, including green savings account, savings box (Piggy)) provision of the service)

(including receipt of commission and other payments, communication within the framework of the service, identification)

Client, including a minor

Name, surname, personal identification number, date of birth, phone number, audio recording, account number, transaction history, account balance, signature.

• Article 6, Paragraph one, point (b) of the regulation

• information systems maintainers

Client

Name, surname, phone number, audio recording, voice password, account number, transaction history.

• Article 6, Paragraph one, point (b) of the regulation

Provision of brokerage and financial instrument (investment funds, shares, bonds/debt securities) account servicing (by phone, online banking, client service centres)

(including receipt of commission and other payments, communication within the framework of the service, identification)

Client

Name, surname, personal identification number, date of birth, email address, phone number, audio recording, voice password, account number, account balance, transaction history, signature.

• Article 6, Paragraph one, point (b) of the regulation

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Financial Instrument Market Law

• IPAS CBL Asset Management
• Nasdaq
• Clearstream
• US Tax authority
• third parties appointed by issuers
• maintainers of information systems

For personal data used to protect investors' interests, see the section Organisation of the Bank's activities – Protection of investors' interests in transactions in financial instruments.

The types of data may vary depending on the type of service provided. Client and related persons, including minors Name, surname, personal identification number, date of birth, phone number, address, email address, audio recording, voice password, account number, payment card number, transaction history, signature.

• Article 6, Paragraph one, point (b) of the regulation

• various cooperation partners in the provision of the service (e.g. tourism, ticketing, car rental service providers)
• maintainers of information systems

Priority pass service provision

Priority pass is a service for users of certain payment cards that provide a stay in airport lounges)

Client and related persons

Name, surname, address, e-mail address, account number.

• Article 6, Paragraph one, point (b) of the regulation

• Priority Pass Ltd.
• Maintainers of information systems

Provision of the borrower's life insurance distribution service

(service provider - AAS CBL Life)

Client/insured person

Name, surname, personal identity number, date of birth, gender (for statistics), phone number, e-mail address, number and series of identity document, signature, information on credit obligations, health data, account number, information about the insurance contract.

Beneficiary

Name, surname, personal identification number, date of birth, phone number, e-mail address.

Consent

• Article 9, paragraph two, point (a)

Consent

• for the processing of health data for the provision of the service and risk assessment;
• for receipt of information from medical treatment institutions and doctors regarding health (performed examinations and analyses) 
• for the transfer of health data to the reinsurer for the purpose of reinsurance

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Insurance contract law
• Insurance and Reinsurance Law

• AS Citadele banka
• AAS CBL Life
• maintainers of information systems

Real estate insurance

(service provider - AAS BTA Baltic Insurance Company)

Client

Name, surname, personal identification number, date of birth, signature, phone number, e-mail address, information about real estate, information related to insurance (insurance period, amount and payment procedure, coverage, risks, amount, conditions).

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Insurance contracts law

• AS Citadele banka
• AAS BTA Baltic Insurance Company
• maintainers of information systems

Provision of accident insurance distribution service

(service provider - AAS CBL Life)

Client/insured person/beneficiary

Name, surname, personal identity number, date of birth, phone number, e-mail address, account number, information about the insurance contract (insurance period, amount and payment procedure, coverage, risks, amount, conditions).

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Insurance contracts law

• AS Citadele banka
• AAS CBL Life
• maintainers of information systems

Client/insured person

Name, surname, personal identity number, date of birth, phone number, e-mail address, account number, information about the insurance contract (insurance period, amount and payment procedure, coverage, risks, amount, conditions). 

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Insurance contracts law

• Balcia Insurance SE
• AS Citadele banka
• maintainers of information systems

Client/insured person

Name, surname, personal identity number, date of birth, phone number, e-mail address, account number, information about the insurance contract (insurance period, amount and payment procedure, coverage, risks, amount, conditions), e-signature.

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Insurance contracts law

• Compensa Vienna Insurance Group ADB
• AS Citadele banka
• maintainers of information systems

Client/insured person

Name, surname, personal identification number, date of birth, phone number, e-mail address, card number.

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Insurance contracts law

• Compensa Vienna Insurance Group ADB
• AS Citadele banka
• maintainers of information systems

Remote reservation of a branch visit

Clients can remotely book a visit to the bank branches, as well as the bank can more efficiently plan the workload of employees and branches.

Client, including a minor

Name, surname, phone number,

email address, date and time of the planned visit.

Legitimate interests to provide you with the opportunity to remotely book a visit to the bank branch, as well as to allow us to more efficiently plan the

workload of employees and branches.

• Article 6, Paragraph one, point (f) of the regulation

Physical security

We take care of security in the bank's premises, territory and other places to protect employees, clients and property. Our goal is to prevent and detect crime, control access and provide evidence to protect the bank's interests.

Client, including a minor

Video image, name, surname, personal identification number, information indicated in the identity document, information related to violations.

Legitimate interests in the protection of the bank, your security and property, the prevention and detection of possible crimes, the control of access to the bank's premises, the collection of evidence in the event of disputes or violations.

• Article 6, Paragraph one, point (f) of the regulation

Cooperation partner ensuring the provision of physical security services

The amount of data varies depending on the type of event.

Client, including a minor

Name, surname, personal identification number, date of birth, phone number, e-mail, data indicated in the identity document, place of tax residence, history of transactions made, information related to the prizes won, account number, signature.

Consent to receive notifications and offers

• Article 6, Paragraph one, point (a) of the regulation

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

Cooperation partners who ensure the provision of the service

Maintenance and promotion of the bank's image

(in-person and online events, social media and media)

The amount of data varies depending on the type of event.

Client, any person, including a minor

Name, surname, phone number, e-mail address, address, addresses of social accounts, audio recording, photograph, video recording, position, profession, type of occupation, length of service, employer, membership in professional associations, education, interests, use of banking services and compliance with the client's needs. Any other personal data that you have disclosed at the event in written text/audio/photo/video, IP address.

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

Legitimate interest in

creating and maintaining the bank's image, attracting new customers, ensuring the trust and well-being of existing customers.

• Article 6, Paragraph one, point (f)

Cooperation partners who ensure the provision of the service

Assessment of the suitability of real estate for the provision of credit

(including communication, identification)

We conduct a property inspection to understand how much it is worth as collateral for a loan. We also collect data from public registers on third-party real estate to assess the value of the property, which serves as collateral for credit. This is necessary so that we can assess the risk that the loan will not be repaid and make appropriate decisions on granting the loan.

Client, seller, pledger

Name, surname, personal identification number, date of birth, e-mail address, address, phone number, transaction information, real estate.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Consumer Rights Protection Law
• Regulation No. 265 of the Bank of Latvia of 18.12.2023 Credit Risk Management Regulations

Legitimate interests in managing credit risks and ensuring responsible lending.

• Article 6, Paragraph one, point (f) of the regulation

• Real estate appraisers
• Land register
• State Land Service Cadastre Information System, Real Estate Market Database, Address Register

Client

Name, surname, personal identification number, date of birth, e-mail address, address, phone number, information about credit obligations, account number.

Legitimate interest in debt recovery.

• Article 6, Paragraph one, point (f) of the regulation

Transfer of the debt to another person – the collector (assignment)

If you have a debt to the bank, the bank can transfer your debt to another company. This means that the debt does not disappear anywhere – you still must pay it, it just changes who you pay it to, for whom you will receive the appropriate notification.

Client

Name, surname, personal identification number, date of birth, e-mail address, address, telephone number, signature, credit obligations and other obligations, insolvency status, account number and balance, transaction history.

Legitimate interest in debt recovery.

• Article 6, Paragraph one, point (f) of the regulation

Debt recovery in insolvency proceedings

Insolvency is the process of sorting out and, as far as possible, repaying debts when the borrower can no longer pay them.

Client

Name, surname, personal identity number, date of birth, e-mail address, address, telephone number,

position, date of termination of employment relationship, employer, transaction history, owned real and movable property, account number and account balance, payment card number, credit obligations and other obligations.

Statutory obligation

• Article 6, Paragraph one, point (c)
• Insolvency Law

Client, including a minor

Name, surname, date of birth,

phone number, email address, authorization means, device identifier, IP address, payment card number, transaction history, account balance.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Law on Payment Services and Electronic Money

Credit risk monitoring

(including the Early Warning System), monitoring of significant increases in credit risk, monitoring credit quality, measuring, assessing and monitoring credit risk, evaluating the effectiveness of credit quality management, as well as making decisions on extending the credit limit.

Protection of investors' interests in transactions in financial instruments

(According to the information provided by you, we evaluate and assign you the status of a client – retail client, professional client or eligible counterparty. We check whether the investment services match your interests, experience and knowledge. From the status you are granted depends on how much protection you get).

Client

Name, surname, personal identity number, date of birth, identity document number, telephone number, e-mail address, employer, profession, position, education, risk tolerance with financial instruments, knowledge and experience with financial instruments, financial condition, balance of the account of financial instruments (money and securities), income, signature.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Financial Instrument Market Law
• Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU
• Regulation (EU) No 600/2014 of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Regulation (EU) No 648/2012
• Commission Delegated Regulation (EU) 2017/565 of 25 April 2016 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive

5 years from the date of termination of business relationship

7 years from the date of termination of the business relationship, if the information has been requested by the supervisory authority - the Bank of Latvia

Quality check of broker transactions

To make sure that brokers work in accordance with the requirements of the bank and the law, we check the transactions carried out by brokers.

Client

Name, surname, personal identification number, audio recording, voice password, phone number, e-mail address, transaction information.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation

European Commission Delegated Regulation (EU) 2017/565 of 25 April 2016 supplementing Directive 2014/65/EU of the European Parliament and of the Council regarding organisational requirements and operating conditions for investment firms and definitions for the purposes of that Directive

• Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directives 2002/92/EU and 2011/61/EU (recast) Text with EEA relevance

• Guidance on certain aspects of MiFID II compliance function requirements

Clients and any person participating in testing

Name, surname, personal identification number, video recording, audio recording, phone number, e-mail address, information related to the client's interests, habits, use of banking services and their compliance with the client's needs, signature.

Consent to the processing of personal data for the evaluation/improvement (testing) of the quality of products/services and the provision of communication

• Article 6, Paragraph one, point (a) of the regulation

Provision of audit (checks)

The bank shall provide an independent internal/external audit to verify that the bank is operating honestly, safely and in accordance with the law. This helps protect the interests of both customers and employees.

Client, any natural person, including a minor

Considering the amount of data and information specified in various documents, the following data is processed:

Name, surname, personal identity number, date of birth, photograph, type of identity document, number, date of issue, issuing country, issuing authority, signature, telephone number, address, e-mail address, password for telephone identification, audio recording of the call, marital status, kinship, number of family members, employer, type of occupation, level of education, country of nationality, validity of the residence permit and its period of validity, place of tax residence, taxpayer number, place of birth, country, citizenship, information obtained in communication with the bank, authorization device, transaction history, information related to client identification and research, PEP status, criminal record information, health data, account number, payment card number, transaction history (outgoing, incoming payments indicating income and its source of extraction, debts, expenses, account balance), credit and other liabilities, information on financial literacy, real estate, movable property.

Statutory obligation

• Article 6, paragraph one, point (c) of the Regulation
• Credit Institution Law

Legitimate (legitimate) interest in verifying that the bank operates honestly, safely and in accordance with the law.

• Article 6, Paragraph one, point (f) of the regulation

Client/any natural person

Name, address, telephone number, e-mail address, signature.

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

• Postal service providers
• Delivery, courier service providers

Client, any natural person, including a minor

Considering the amount of data and information specified in various documents, the following data is processed:

Name, surname, personal identity number, date of birth, photograph, type of identity document, number, date of issue, issuing country, issuing authority, signature, telephone number, address, e-mail address, password for telephone identification, audio recording of the call, marital status, kinship, number of family members, employer, type of occupation, level of education, country of nationality, validity of the residence permit and its period of validity, place of tax residence, taxpayer number, place of birth, country, citizenship, information obtained in communication with the bank, authorization device, transaction history, information related to client identification and research, PEP status, criminal record information, health data, account number, payment card number, transaction history (outgoing, incoming payments indicating income and its source of extraction, debts, expenses, account balance), credit and other liabilities, information on financial literacy, real estate, movable property.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Archives Law and national document standards
• Credit Institution law
• Financial Instrument Market Law
• Law on the Prevention of Money Laundering and Terrorism and Proliferation
• Law on International and National Sanctions of the Republic of Latvia and other sanctions-related legal acts
• Law on Accounting
• Civil Law and other laws and regulations

Archiving in the public interest

• Article 9, Paragraph two, point (j) of the regulation

Communication about your products and services and their changes

(by phone, email, mobile app, video calls)

Client

Name, surname, personal identification number, voice password, audio recording, video recording, phone number, email address, information about bank products, services you use.

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

Consent to receive notifications and offers

• Article 6, Paragraph one, point (a) of the regulation

Client satisfaction surveys

(We regularly conduct surveys to find out the opinions of clients and residents about the bank's services and products. In the surveys, we also find out opinions about bank`s image and daily money usage habits. This information helps us improve services and ensure high quality of service)

Clients

Name, surname, personal identity number, date of birth, audio cording, e-mail address, telephone number, number of family members, marital status, age, type of occupation, position, profession, education, permanent resident or foreigner, history of transactions carried out for the selection of respondents, information about the interests of the client, the use of banking services, signature.

Consent to receive notifications and offers

• Article 6, Paragraph one, point (a) of the regulation

Personalized offers on Facebook and Google

We use Facebook and Google platforms so that you can receive relevant offers.

Consent to receive notifications and offers

• Article 6, Paragraph one, point (a) of the regulation

• Meta 
• Google

Client

Name, surname, personal identification number, date of birth, signature, audio recording, address, e-mail address, telephone number, information related to family and children (name, surname, personal identity number, kinship), payment card number, employer,

the country of payment of taxes,

account number, account balance, payment card number, transaction history (incoming and outgoing payments), credit obligations and other obligations.

Other types of data are determined depending on the amount of information requested in the request, claim or application, as well as on the information contained in the documents to be issued.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Credit Institution law
• Consumer Rights Protection Law

Client, including a minor

Name, surname, personal identification number, phone number, e-mail address, payment card number, transaction history (incoming and outgoing payments), signature.

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

Client, including a minor

Name, surname, personal identification number, audio recording, phone number, e-mail address, payment card number, transaction history (incoming and outgoing payments), signature.

Conclusion and performance of the contract

• Article 6, Paragraph one, point (b) of the regulation

Client, including a minor

Name, surname, personal identification number, date of birth, address, e-mail address, phone number, signature.

Other types of data are determined depending on the amount of information requested in the request, claim or application, as well as on the information contained in the documents to be issued.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Personal Data Processing Law

Client

Name, surname, phone number,

email address, date and time of the planned visit.

Legitimate interest in resolving disputes arising in connection with bookings and branch visits.

• Article 6, Paragraph one, point (f) of the regulation

Client, including a minor

Name, surname, personal identification number, date of birth, address, e-mail address, phone number, signature, audio and video recording, photo, video image, type, number, date of issue, country of issue, issuing authority, information contained in the documents to be issued, information related to the family and children (name, surname, personal identity number, kinship), payment card number, employer, the country of payment of taxes, account number, account balance, payment card number, transaction history (incoming and outgoing payments), credit obligations and other obligations, taxpayer number, place of tax residence, place of birth, country, citizenship, account number, payment card number, insolvency status, movable and immovable property owned, credit obligations and other liabilities, account number, account balance, payment card number, financial literacy information, transaction history (incoming and outgoing payments), criminal record information, PEP status, employer, type of occupation, education, information related to violations, authorization device, connection device, IP address.

Other types of data are determined depending on the amount of information requested in the request, claim or application, as well as on the information contained in the documents to be issued.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Credit Institutions Law
• State Labour Inspection Law
• Law on the Ombudsman and other legal acts

• Bank of Latvia
• The Financial Intelligence Unit of Latvia
• Court
• Promoters of criminal proceedings
• Police, Prosecutor's Office
• Corruption Prevention and Combating Bureau
• Bailiffs
• Notaries
• Orphan's courts
• Treasury
• The State Audit office of the Republic of Latvia
• Data State Inspectorate
• State Revenue Service
• Insolvency Control Service
• Information Technology Security Incident Prevention Authority
• Competition Council
• Ministry of Finance
• Consumer Rights Protection Centre
• Ombudsman
• State Labour Inspectorate
• other officials specified in the law

Reporting (whistleblowing) about possible violations in the bank and protection of whistleblowers

(You can report possible or detected violations in the bank, including potential fraud or criminal offences. We ensure appropriate protection for the whistleblower).

Client/any natural person

Name, surname, email address, phone number, addresses and content of social accounts, video recording, information related to violations.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Whistleblowing Law

Overview of transactions with persons related to the bank

(This report describes how to prepare and submit to the Bank of Latvia information on risk transactions with persons who have close ties to the bank. The report applies to transactions with shareholders of the bank who own a significant share (significant participation), spouses, parents and children of these shareholders, representatives of the bank's management - members of the board and council, responsible for internal audit, risks, compliance and internal control, spouses, parents and children of these persons, companies in which the above-mentioned persons have significant influence or participation). The bank determines the extent of the risk from each such transaction, prepares a report on these transactions and submits this report to the Bank of Latvia. This ensures that the bank operates honestly and transparently, avoiding conflicts of interest or unauthorized favour against related persons.

Persons related to the bank

Name, surname, personal identity number, position, information about the spouse, parents and children, kinship, risk transactions (significant participation) and their value.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Regulation No. 282 of the Bank of Latvia of 25.03.2024 Regulations regarding the Preparation and Submission of Supervisory Reports
• Accounting Law

Overview of major risks for submission to the European Central Bank

(The report includes information about the bank's assets, liabilities, income and transactions that occurred during a certain reporting period. The European Central Bank uses this report to assess how much risk the bank has taken. This helps to ensure that the bank works safely and responsibly and helps to protect the bank's clients and the entire financial system from possible problems if the bank takes too many risks).

Client

Name, surname, personal identity number, credit risk exposure.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012

Client

Name, surname, personal identity number, credit obligations and other obligations.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012

Client

Name, surname, personal identification number, tax number, address, account number, payment card number, transaction history (incoming and outgoing payments), IP address.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Law On Taxes and Fees
• Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax
• Council Directive (EU) 2020/284 of 18 February 2020 amending Directive 2006/112/EC as regards the introduction of certain requirements on payment service providers Council Regulation (EU) 2020/283 of 18 February 2020 amending Regulation (EU) No 904/2010 as regards measures to strengthen administrative cooperation to combat VAT fraud

• State Revenue Service
• cooperation partner that provides information about card transactions

Reporting to the Credit Register of the Bank of Latvia

(The bank must provide information to the Bank of Latvia about loans, for example, how much and to whom the bank has lent funds. The Bank of Latvia collects data and transmits it to the European Central Bank so that it has accurate information on how lending takes place throughout the euro area. It helps to monitor the financial system, understand risks and make better decisions regarding the economy.

Clients

Name, surname, personal identity number, date of birth, address, number of the identity document, date of issue, issuing country, issuing authority, status of the client, assets and liabilities, exposures, their value, presence or absence of insolvency proceedings, information on immovable property, movable property, credit obligations and other liabilities.

Statutory obligation

• Article 6, Paragraph one, point (c) of the regulation
• Credit Register Law
• Bank of Latvia Regulation No. 160 of 18.01.2018 Credit Register Regulations
• Bank of Latvia Regulation No. 226 of 24.10.2022 Regulations on electronic exchange of information with Bank of Latvia
• Regulation No. 209 of the Bank of Latvia of 13.06.2022 Regulations for the Preparation and Submission of Statistical Data on Credit Risk Transactions of Credit Institutions and the Persons Involved in Them.

• Bank of Latvia
• cooperation partner ensuring information exchange with the Bank of Latvia

10 years after the date of expiry of the commitment or the date of takeover

3 years after the end of the reporting period

Client

Name, surname, personal identity number, date of birth, identity document number, date of issue, country, document issuing authority, expiration date, account number, date of opening and closing of the account.

Statutory obligation

• Account Register Law
• Cabinet Regulation No. 186 of 28.03.2017, Procedures by which a Credit Institution, a Savings and Loan Association and a Payment Service Provider Provide Information to the Account Register, and Users of the Account Register Information Receive Information from the Account Register.

• State Revenue Service
• Information systems maintainers

Client

Name, surname, personal identification number, account balance, account turnover, cash contributions.

Statutory obligation

• Law On Taxes and Fees
• Cabinet Regulation No. 276 of 15.05.2018 Procedures by which Information on the Turnover and Balance of Accounts of a Natural Person and Cash Contributions shall be Provided to the State Revenue Service.

• State Revenue Service

• Information systems maintainers

Providing video surveillance

With the help of video surveillance, we ensure your and our safety in the bank's premises and on its territory, on the territory of the ATMs located there, as well as the protection of property.