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Industra Bank takes care of the security of personal data of its customers – in the Bank the personal data of natural persons is being handled with due respect for their interests to preserve their privacy. The principles of personal data processing and protection are being complied with in all data processing processes. The Bank maintains a high level of confidentiality of personal data and implements data protection measures, ensuring lawful, fair, and transparent data processing.
In the Bank we have a Data Protection Officer to whom you can send questions by writing to the e-mail address: dpo(abols)industra.finance or by sending a letter, marked "Attn: Data Protection Officer", to the address: Elizabetes iela 57, Rīga, Latvija, LV-1772 (the contacts in Lithuania – info_lt(abols)industra.finance, Kęstučio g.51, Vilnius, Lietuva, LT-08124). Should you not be satisfied with the response provided by the Data Protection Officer, you may contact the Data State Inspectorate (in Lithuania – the State Data Protection Inspectorate).
Personal data is any information on any medium that may help to identify a Person, directly or indirectly. In performing its duties specified in legislation, ensuring the provision of services to customers, pursuing various types of legitimate interests, and attending to the quality of customer service, Industra Bank processes various types of personal data. Examples of Personal Data processed by the Bank:
Industra Bank processes various types of Personal Data, the volume and nature of which varies due to the diverse nature of data processing purposes. The Bank does not process information that is not required for achieving a concrete, specifically set legal purpose.
Personal Data can be obtained by the Bank in various ways, for example, when:
Industra Bank may initiate processing of Personal Data only if the processing has a specific purpose (for example, conclusion of a contract, the provision of a specific service, performance of the statutory obligations, etc.) and if the processing has an appropriate legal basis.
A legal basis for processing of Personal Data may be as follows:
1. Establishment and performance of contractual obligations
In the event of this legal basis, the Bank processes the data required for concluding and performing the contract. Examples of data processing in conjunction with this legal basis:
2. Compliance with a legal obligation
This legal basis applies to the data processing when the Bank has no free choice of action - the relevant activity is governed by the provisions of applicable regulatory enactments of the EU or Latvia/Lithuania.
For example, provision of information to the State Revenue Service (in Lithuania – State Tax Inspectorate) or to the The Financial and Capital Market Commission (in Lithuania – the Bank of Lithuania) in line with the legal acts, requesting information from a potential customer for identification purposes, etc.
3. Protection of the vital interests of a Person (Data Subject) or of a third party
This legal basis is used in exceptional cases, when data processing is carried out, for example, with an effort to protect life or health of a Person.
4. Observance of public interest or exercise of official powers
This legal basis is rarely used and is similar to the compliance with a legal obligation, since the public interest or official powers of the Bank must be specified in legal acts, unlike as with a legal obligation, the Bank can have a free (or a partially free) choice of action
5. The legitimate interests of the Bank or of a third party
A frequently used legal basis. It is applied, for example:
6. The consent of a Person (Data Subject)
The consent of a Person is used as a legal basis, for example, in marketing purposes, when a Person applies for a lottery or receipt of informative materials.
A person has a free choice – to give his/her consent to data processing or not, and a Person has the right to withdraw his/her consent at any time, thus terminating the processing.
For example, if, on the basis of the consent of a Person, the Bank sends informative material about the Bank and its products to a Person, the Bank shall stop sending the information as soon as the Person has withdrawn the consent.
Industra Bank does not process, more information than it is necessary to achieve certain goals, thus observing the so-called principle of data minimization.
The Bank continuously develops information technologies in order to ensure the protection of Personal Data.
The Bank ensures that only those employees who need it for the performance of their job duties have access to Personal Data.
The Bank takes efforts to ensure that it is processing only correct and accurate data. If the Bank has doubts about the applicablity or accuracy of the information submitted by a Person, the Bank shall contact the Person to clarify the information processed. In addition, each Customer is obligated to report to the Bank in the event of changes in the information submitted to the Bank (for example, telephone number, residence address, etc.).
Personal data is processed for no longer than is necessary to achieve a certain purpose.
The Bank respects the rights of a Person, allowing the Person to control and monitor their Data Processing.
The Bank carries out, on a regular basis, training of employees, incl. on Personal Data Processing, protection, as well as on confidentiality and ethical standards.
When performing the processing of Personal Data, Industra Bank uses automated systems, but does not take individual decisions without participation of specialists of the Bank.
The Bank uses automated systems, e.g. for payment control, Customer due diligence, detection of suspicious transactions, sanctions risk management in accordance with the current legislation of Latvia and Lithuania.
When processing Personal Data, it is the priority of the Bank to keep the information confidential. Information may be transferred to third parties to the extent and in cases stipulated by the applicable regulatory enactments of Latvia/ Lithuania and of the EU, as well as in order to ensure the provision of high-quality and efficient services, or, when it is necessary for the performance of contractual obligations to the Customer.
Personal data may be transferred to:
Before transferring data to a third person, the Bank shall conclude an agreement detailing the procedure in accordance with which the business partner will process and protect the Personal Data. During the cooperation, only information required for a stipulated purpose will be transferred to the partner, and if there is such a possibility, the Bank transfers anonymized information, so that the business partner is not able to identify the particular Person. The Bank may not enter into a contract with a third party only in cases where the transfer of the relevant data is regulated by the applicable regulatory enactments of Latvia and of the EU.
Personal data of a person may be transferred to outside the EU/EEA, when doing so is necessary for ensuring the provision of a specific service, in the event when the business partner of the Bank is located outside the EU/EEA. When transferring the personal data outside the EU/EEA, the Bank ensures a data protection level compliant with General Data Protection Regulation.
Persons have the following rights regarding the processing of his or her information:
Industra Bank shall consider the Persons’ requests without undue delay and, in any case, inform the Person about the actions undertaken within a month. The Bank may extend the period of consideration of the claims for another two months on a reasonable basis (for example, large number of requests or complexity of requests).
The Bank replies to the requests of a Person, as well as carries out any other activities related to the fulfilment of the requests of Persons, free of charge (except in cases where the request is manifestly unfounded, excessive, or depending on what resources are required for handling the request). When providing a reply to a request or fulfilling a request, the Bank may charge a reasonable fee for additional costs incurred.