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SIA FIDES ACQUISITIONS Privacy Policy

The purpose of the SIA "FIDES ACQUISITIONS" Privacy Policy (hereinafter - Privacy Policy ) is to provide natural persons with information regarding the purpose, scope, protection, and duration of processing, as well as the rights of the data subject during data collection and processing.

Controller and Contact Information

You can contact the data protection specialist of FIDES ACQUISITIONS and ask questions regarding the processing of personal data at the following email address: kontakt@fidesaq.com.

Personal Data and its Collection

Personal data is any information relating to an identified or identifiable natural person (hereinafter " data subject") – potential/current/former customer, client, heir, payer, representative of these persons, contact person, or other third party involved in lending, incl. in the solvency assessment process (e.g., third-party data in documents submitted by the client).

Categories of personal data processed by FIDES ACQUISITIONS.

No.. Data Category Example
1 Personal Identification Data First name, surname, personal identity number, date of birth, ID data, passport no., image of the data subject.
2 Contact Details Actual residence address, declared residence address, phone number, email address.
3 Professional (Employment) Data Information about employer, length of service, position held.
4 Related Party Data Information on the number of dependents, heirs, and other related persons.
5 Finanzdaten Angaben zu Vermögen, Transaktionen, Verbindlichkeiten, Angaben zu Einkünften und deren Herkunft, Monatsgehalt und sonstige regelmäßige oder unregelmäßige Einkünfte, finanzielle Verpflichtungen, Einkunftsquelle.
6 Investigation Data Data obtained to prevent money laundering and terrorist financing, information on whether the customer is a politically exposed person=.
7 Creditworthiness Assessment Data External debt status, credit risk assessment, solvency status.
8 Customer Data Customer contract, application number, customer registration date, status.
9 Customer Segmentation Data Age group, language, gender, etc.
10 Service, Transaction Data Contract number, signature/approval date, type, name of service, execution or non-execution of contracts, transactions performed, concluded and expired contracts, submitted applications, requests and complaints, interest, service fees, purpose of the loan, amount of the first installment, loan amount, due date of the loan amount.
11 Billing Data Bank account number, invoice number, date, amount, type of invoice receipt, payment date, debt amount.
12 Total Liability Data Name of creditor, monthly payment, number of remaining months.
13 Data from Customer Surveys Survey name, dispatch date, response date, survey questions, and provided answers.
14 Call Recording Data Customer service call recordings, date and time.
15 Submission Data Application number, registration/resolution date, type, description.
16 Access Data for Customer Portal Personal code, password, or customer data received from the bank or Smart-ID during authorization.

The categories of processed personal data and their scope may change depending on the purpose for which they are carried out.

FIDES ACQUISITIONS receives personal data from:

  • The data subject;
  • Representatives of data subjects;
  • Cooperation partners of FIDES ACQUISITIONS (e.g., sellers of goods/services, competition organizers);
  • Creditors/assignors of data subjects;
  • From third parties related to the data subject (e.g., the data subject's relatives, spouse);
  • From other persons guaranteeing the proper fulfillment of the data subject's obligations towards FIDES ACQUISITIONS or previous creditors (e.g., guarantors);
  • Databases and public registers created in accordance with legislation on personal data processing (e.g., credit information bureaus, Bank of Latvia Credit Register, Lursoft);
  • for historical databases created in accordance with legislation on personal data processing, if the data subject has given consent (e.g., SIA ") Creditreform Latvija “);
  • Credit institutions managing settlements and/or identifying the data subject;
  • Law enforcement agencies, courts, insolvency administrators, bailiffs, notaries;
  • From publications of the official publisher of the Republic of Latvia (VSIA "Latvijas Vēstnesis") .

Purposes of Processing Personal Data

  • Receiving and processing applications and providing services;
  • Provision of services to cooperation partners by FIDES ACQUISITIONS (e.g., provision of car, home, and health insurance on behalf of the cooperation partner);
  • Preparation, processing, and execution of contracts/agreements and other documents (establishment, amendment, or termination of legal relationships);
  • Identification and due diligence of the data subject in accordance with regulatory requirements, which is a prerequisite for establishing and/or continuing a business relationship;
  • Communication with the data subject, including notification of changes regarding FIDES ACQUISITIONS services and/or information resulting from mutual contractual relationships;
  • Ensuring and improving service delivery, ensuring service quality;
  • Conducting market research, statistics;
  • Offering services to customers (for marketing purposes), organizing promotions and/or competitions;
  • Development of new services;
  • FIDES ACQUISITIONS/ advertising the services/products of the group company/cooperation partner by phone, incl. SMS, email, post, websites, mobile services, including tailoring the sent offer to the interests of the data subject;
  • Implementation of new technologies and maintenance of operations to meet regulatory requirements regarding data subject identification, prevention of illegal activities, money laundering prevention, and terrorist financing;
  • Management of settlements;
  • Organization of records;
  • Receiving and processing submissions/applications/claims etc. documents, incl. providing responses;
  • Assignment of claims;
  • Monitoring of public registers;
  • Ensuring cooperation with partners, incl. transfer/receipt of information necessary for ensuring cooperation and service provision;
  • Auditing, planning, accounting, and analysis of commercial activities;
  • Preparation and provision of business activity reports;
  • State institutions, incl. fulfilling requests from law enforcement authorities in accordance with procedures established by legal acts;
  • Assessment of the data subject's solvency, which is a prerequisite for establishing and/or continuing a business relationship, in accordance with legal requirements;
  • Assessment of the data subject's solvency before making an offer;
  • Protection of infringed or contested rights or legally protected interests, incl. exercising rights of claim, preservation of evidence in case of a possible dispute with the data subject;
  • Identification and prevention of illegal activities and reporting to competent authorities;
  • Fulfillment of obligations under legal regulations (e.g., compliance with accounting regulations, providing information to credit bureaus and the credit register);
  • Contribution to promoting responsible lending and responsible and honest borrowing.

Legal Basis for Processing Personal Data

FIDES ACQUISITIONS processes personal data based on the following legal grounds for processing personal data:

  • The voluntary and unambiguous consent given by the data subject for the processing of their personal data;
  • For the conclusion and execution of the contract or taking steps at the request of the data subject prior to entering into a contract;
  • To fulfill the legal obligations of FIDES ACQUISITIONS established in applicable regulatory laws;
  • To pursue the legitimate interests of FIDES ACQUISITIONS resulting from legal relationships or administrative orders.

The legitimate interests of FIDES ACQUISITIONS are::

  • To conduct commercial activities in accordance with legal requirements, incl. direct marketing;
  • Provision of lending services;
  • To manage settlements;
  • To perform identity verification of the data subject and customer due diligence;
  • Assessment of the data subject's solvency;
  • Transfer of claim rights to a new creditor based on a contract (assignment) and execution of this contract;
  • Ensuring the fulfillment of legal relationships and contractual obligations;
  • Avoiding inappropriate financial risks for the company (including credit risk assessment before establishing legal relationships and during their execution);
  • Contribution to promoting responsible lending and responsible and honest borrowing , promoting the creation of individuals' credit history as well as ensuring the protection of natural persons' rights so that truthful and complete information is available and used when assessing creditworthiness
  • Design and development of services;
  • To ensure and improve the quality of services and processes, including calling data subjects who started filling out an application on the FIDES ACQUISITIONS website but did not complete it, to find out the reasons;
  • Monitoring and prevention of illegal activities, incl. fraud;
  • To apply to law enforcement agencies and courts for the protection of its infringed or contested rights or legally protected interests;
  • To ensure FIDES ACQUISITIONS management, financial and business accounting, and analysis;
  • To inform the parent company about the operations of FIDES ACQUISITIONS;
  • Prevention of money laundering, terrorist financing, and proliferation;
  • To manage the credit risk of FIDES ACQUISITIONS.

Processing of Personal Data and Categories of Recipients

Personal data processing is carried out based on Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter the Regulation) and other applicable laws in the field of data protection and processing, taking into account the organizational, financial, and technical resources reasonably available to FIDES ACQUISITIONS.

Technical provision of credit services, provision of daily business activities, reporting to state authorities, candidate selection, etc. To execute processes, FIDES ACQUISITIONS may, by concluding a written contract or based on another legal act in accordance with the legislation of the European Union or a Member State, commission companies of the Marginalen Group and/or other cooperation partners (processors) to provide the necessary services.

FIDES ACQUISITIONS may disclose the data subject's personal data:

  • Entities of the FIDES ACQUISITIONS group (for administrative and marketing purposes);
  • FIDES ACQUISITIONS cooperation partners with whom FIDES ACQUISITIONS offers co-branded products and services (to provide such services and products as well as for marketing and advertising of such products);
  • To state institutions and other institutions performing tasks assigned to them by law;
  • Certified auditors, legal and financial advisors;
  • Personal data processors commissioned by FIDES ACQUISITIONS who provide support in the provision of FIDES ACQUISITIONS services and process personal data on behalf of FIDES ACQUISITIONS;
  • Credit institutions and financial institutions, credit bureaus, financial service brokers, and insurance service providers;
  • Administrators of public registers;
  • Debt collection companies, credit bureaus, credit registers, and other third parties to whom FIDES ACQUISITIONS may transfer its rights and obligations.

In certain cases, data may be transferred outside the EU/EEA, for example, if the personal data processor commissioned by FIDES ACQUISITIONS is located outside the EU/EEA and the transfer of such data is necessary to ensure the service or upon request of the data subject. Data may only be sent outside the EU/EEA if FIDES ACQUISITIONS provides appropriate safeguards in accordance with the Regulation and there is a legal basis for such transfer.

FIDES ACQUISITIONS may transfer personal data to other third parties (independent controllers) in the following cases:

  • Data processing is necessary for the conclusion of the contract, prior to the conclusion of the contract, and/or its execution;
  • Data processing is defined in the regulatory laws applicable to the operation of FIDES ACQUISITIONS;
  • The consent of the data subject is available;
  • Disclosure of data is necessary to protect the infringed or contested rights or legally protected interests of FIDES ACQUISITIONS.

Automated Individual Decision-Making, including Profiling

FIDES ACQUISITIONS may carry out automated decision-making regarding the data subject when assessing the data subject's creditworthiness before entering into contractual relationships, with the aim of assessing the data subject's ability to repay the loan and providing an initial confirmation or rejection of the loan.

FIDES ACQUISITIONS processes the following categories of personal data to assess creditworthiness using an automated individual decision:

  • Information on the potential borrower:
    • Name and surname;
    • Personal code;
    • Date of birth;
  • Loan information;
  • Information on the solvency of the potential borrower;
  • Information on credit and other payment delays;
  • Information on the customer's income and expenses;
  • Information on the customer's credit obligations.

Die betroffene Person kann der automatisierten Entscheidungsfindung im Einzelfall, einschließlich Profiling, widersprechen, jedoch können die Rechte dieser betroffenen Person gemäß den Anforderungen der Verordnung eingeschränkt werden, wenn die Entscheidung für den Abschluss oder die Erfüllung eines Vertrags zwischen der betroffenen Person erforderlich ist und FIDES ACQUISITIONS, ist dies in Übereinstimmung mit behördlichen Verordnungen erlaubt oder basiert auf der ausdrücklichen Zustimmung der betroffenen Person.

The assessment of creditworthiness via automated decision before establishing contractual relationships is necessary before concluding a contract between the data subject and FIDES ACQUISITIONS. If the data subject wishes for human involvement in the creditworthiness assessment, the data subject may contact FIDES ACQUISITIONS with a request to review the decision with human involvement. The data subject may submit such a request to FIDES ACQUISITIONS by post to 166 RUE JULES GUESDE, 92300 LEVALLOIS-PERRET or electronically ( https://www.FIDES ACQUISITIONS/contacts sends. Upon receipt of the data subject's request, signed by hand or with a secure electronic signature, FIDES ACQUISITIONS will review the automated decision.

Sending Commercial Communications

Data subjects who have submitted their personal data and expressed a wish to receive information about current offers from FIDES ACQUISITIONS – promotions, news, and other marketing activities – do not object to FIDES ACQUISITIONS representatives contacting the data subject to achieve the stated goal via publicly available electronic communication services (email, phone (calls and/or SMS)).

By consenting to the use of personal data for direct marketing purposes, the data subject has the right to object to such data processing at any time, insofar as it is related to direct marketing.

Right to Object

If the data subject does not wish/objects to being subject to fully automated decision-making, including profiling, which produces legal effects concerning the data subject or similarly significantly affects the data subject (unless the decision-making is necessary for entering into or performing a contract with the data subject, is authorized by applicable law, or is based on the data subject's explicit consent), the data subject may contact FIDES ACQUISITIONS requesting a review of the decision with human involvement on the part of FIDES ACQUISITIONS. ( The data subject may submit such a request in person, by post, or electronically ) to FIDES ACQUISITIONS . At the request of the data subject, FIDES ACQUISITIONS will review the automated decision.

If the data subject wishes to object to the automated grouping and analysis (profiling) of their personal data, the data subject must inform FIDES ACQUISITIONS at the email address kontakt@fidesaq.com.

If the data subject objects to the profiling of personal data, they should be aware that kontakt@fidesaq.com will not be able to inform the data subject about current offers and benefits of kontakt@fidesaq.com – promotions, news, and other marketing activities.

Criteria for Data Retention Period

FIDES ACQUISITIONS stores personal data as long as at least one of the following criteria is met:

  • FIDES ACQUISITIONS or the data subject can pursue their legitimate interests, e.g., file an objection or bring an action in court, file a creditor's claim, the case is not statute-barred;
  • There is a legal obligation to retain personal data;
  • Retention of supporting documents;
  • The consent for personal data processing is valid, for example, the data subject's consent to receive promotional messages.

Rights of the Data Subject

Right of Access . FIDES ACQUISITIONS provides information on the processing of personal data carried out by FIDES ACQUISITIONS to the data subject upon request in a concise, transparent, and understandable manner using clear and plain language.

Right to Rectification. Upon a justified request from the data subject, FIDES ACQUISITIONS ensures the rectification of the data subject's personal data if it is inadequate, incomplete, or incorrect.

Right to Data Portability. FIDES ACQUISITIONS offers the data subject the possibility to receive their personal data provided by the data subject, which is processed based on consent and contract performance, in written form or in one of the more common electronic formats.

Right to Erasure ('Right to be Forgotten'). The data subject has the right to request the erasure of personal data if the data subject has withdrawn consent for processing and there is no other legal basis for processing, if the data subject has objected to the processing and after re-evaluating the legitimate interests FIDES ACQUISITIONS acknowledges that there are no legal grounds for processing the data; personal data will be erased in accordance with legal requirements.

Right to Restriction of Processing. The data subject has the right to request the temporary restriction of personal data processing in accordance with legal regulations, including the Regulation, in cases where the data subject has identified inaccuracies in their personal data and FIDES ACQUISITIONS needs time to verify the accuracy of the data.

Right to Object. The data subject has the right to object to the processing of their personal data if the processing is related to profiling for direct marketing purposes or is based on the legitimate interests of FIDES ACQUISITIONS and the data subject questions this legal basis.

Right regarding Automated Individual Decision-Making . The data subject has the right not to be subject to a fully automated decision-making process, including profiling, if this decision has legal consequences or similarly significantly affects them.

Right to Withdraw Consent. The data subject has the right to withdraw the consent given to FIDES ACQUISITIONS for the processing of personal data.

Right to Receive Information about a Personal Data Breach . FIDES ACQUISITIONS will notify the data subject without delay of a data breach detected during the processing of personal data if the breach may pose a high risk to the rights and freedoms of the data subject.

The application to exercise their rights can be submitted by the data subject:

  • In person or by post as a signed submission;
  • Electronically by sending an email signed with a secure electronic signature.

FIDES ACQUISITIONS will evaluate the received request and provide a response in accordance with current legislation.

In the event of objections, FIDES ACQUISITIONS will take all reasonable and necessary measures to resolve them, otherwise - The data subject has the right to contact the supervisory authority - The Data Protection Inspectorate, contact information can be found here: http://www.dvi.gov.lv/en/.

Updating the Privacy Policy

FIDES ACQUISITIONS has the right to update and supplement the Privacy Policy. The current Privacy Policy is always available on this website.