Last updated 17 December 2024
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This privacy policy
This privacy policy explains how we collect, use and process your personal data.
LHV Bank Limited (referred to as “we”, “us” or “our” in this privacy policy) is the controller responsible for your personal data under this privacy policy. Details of the controller are outlined in below.
This privacy policy governs the retail banking products and services provided by or through us.
For other services provided by us, see the general privacy policy here.
We are committed to respecting your privacy. This privacy policy explains how we collect, use and process personal data that we receive when we interact with or provide products and services to our customers (who we refer to as "you" throughout). This may be through our website or our app, or through communications with us.
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Contacting us
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details provided in this privacy policy.
If you have any questions about this privacy policy, including any requests to exercise your legal rights (including the right to request to opt out of marketing), please contact our appointed data protection officer, who is responsible for overseeing questions in relation to this privacy policy using the details set out below:
LHV Data Protection
Address: 1 Angel Court, London, EC2R 7HJ
E-mail: dataprotection@lhv.com
Phone: +44 20 3005 0150
As noted below, you have the right to make a complaint regarding the processing of your relevant personal data with the Information Commissioner’s Office.
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What personal data do we collect?
We collect or obtain personal data: when data is provided to us; in the course of our relationship with you; when you make personal data public; when you visit our websites and app or when you use and interact with our website, app or services. We may also receive personal data about you from third parties.
We collect or obtain personal data about you from the following sources:
Data provided to us by you
We obtain personal data from you when you use our products or services (e.g., when you apply for one of our products or services, complete your KYC (know your customer) questionnaire and supply ID verification data) and where you contact us on the app or via email or telephone, or by any other means.Relationship data
We collect or obtain personal data in the ordinary course of our relationship with you (e.g., we provide a product or service to you).Website and app data
We collect or obtain personal data when you visit any of our websites or app or use any features or resources available on or through a website or app.Registration
We collect or obtain personal data when you use any of our websites, app, products or services.Content and advertising information
If you interact with any third party content or advertising provider (including third party plugins and cookies) we receive personal data from the relevant third party provider of that content or advertising.Third party information
We collect or obtain personal data from third parties who provide it to us, or from public registers (e.g., electoral roll, correspondent banks, participants in payment system (including Bacs participants, Faster Payments), Pay.UK, UK Finance, payment service providers and other business partners or from other third parties involved in a payment transaction (or from third parties who have been authorised by you to provide transaction data to us), service providers specialised in gathering data related to previous criminal convictions and offences, financial sanctions and negative news published from public and private registers, credit reference agencies, fraud prevention agencies, law enforcement authorities, KYC (know your customer) service providers, etc.)
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What personal data do we create?
We create personal data about you (e.g., records of your interactions with us).
We also create personal data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine personal data from any of our websites, apps, products or services, including where those data are collected from different devices.
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What personal data do we process?
We process: your personal details; your contact details; records of your consents; payment and transaction details; information about our websites and app; information about your interactions with our content or advertising; and any views or opinions you provide to us.
In providing our website, app and services, we may process different types of personal data about you for different processing purposes. The types of personal data we collect depends on who you are and how you use our website, app and services and includes the following:
Personal details
given name(s); preferred name; and ID verification details (information about your identity, such as a copy of your passport or alternative ID document; photograph; and a short video of yourself), residential status.Contact details
correspondence address; billing address; telephone number; email address; online messaging details; and social media details.Financial details
employment status; annual income; residential status; and PEP status.Demographic information
gender; date of birth / age; nationality; salutation; title; and language preferences.Customer service logs
details of conversations with us through email, website or app .Consent records
records of any consents you have given, together with the date and time, means of consent, and any related information (e.g., the subject matter of the consent).Purchase details
records of purchases and prices.Payment information
invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; Bacs details; SWIFT details; IBAN details; payment amount; payment date; and mobile banking authentication.Data relating to our website or app/Usage Data
This includes: device type; operating system; browser type; browser settings; IP address; cookies (if you have consented); language settings; dates and times of connecting to a website or app; mobile network; behavioural biometrics and how you use the websites or app; mobile advertising ID; and aggregate statistical information.Google Analytics and our app
We use Google Analytics to collect anonymised information about how our app is used. This data helps us monitor the app’s performance, understand user behaviour, and improve our app, products, and services. Additionally, the insights gained may be used for statistical analysis and to deliver more relevant, personalised marketing.Message history
Any information that you disclose to us through the in-app chat, in-app secure messaging and/or email.Technical data
data about users of our website, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.Employment status
where you interact with us, we will collect your employment status.Content and advertising data
records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.Views and opinions
any views and opinions that you choose to send to us or publicly post about us.
What purpose, and on which legal grounds, do we process your personal data?
We process personal data for the following purposes: providing our websites, app, products or services to you, including our banking and payment services; KYC, anti-money laundering and payment fraud monitoring and screening activities; detecting negative news; marketing and conducting surveys; communicating with you; conducting investigations where necessary; compliance with applicable law; improving our websites, app and services; risk management and fraud prevention, and the establishment, exercise and defence of legal claims.
We have set out below, in table format, a description of the types of personal data that we may collect, the ways we may process your personal data, and which of the legal bases we rely on to do so.
We have also identified what our legitimate interests are where appropriate (and in each case that they apply, to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data, subject to applicable law. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
PURPOSE OF PROCESSING
Providing our websites, app, products or services, and communicating with you in relation to those websites, app, products or services
TYPE OF PERSONAL DATA
Personal details
Contact details
Demographic information
Consent records
Visitor logs
Data relating to our websites or app
Messaging history
LEGAL BASIS FOR PROCESSING
Performance of contract with you.
Necessary for our legitimate interest to provide our websites, app or services or products.
Prior consent
PURPOSE OF PROCESSING
Providing payment products and services to you
TYPE OF PERSONAL DATA
Personal details
Contact details
Payment information and transaction data (e.g., name of payer and payee, payment information, including the sum, transaction explanations, bank account and card details)
LEGAL BASIS FOR PROCESSING
Performance of contract with you.
Necessary for our legitimate interests of performing our contract with you.
PURPOSE OF PROCESSING
Investigate, fix and manage complaints raised by you
TYPE OF PERSONAL DATA
Personal details
Contact details
Demographic information
Consent records
Data relating to our websites or app
Messaging history
LEGAL BASIS FOR PROCESSING
Performance of contract with you.
Legitimate interests of LHV to make sure accounts are well managed.
PURPOSE OF PROCESSING
KYC, anti-money laundering and payment fraud monitoring and screening (including checks for the purposes of keeping your money secure)
TYPE OF PERSONAL DATA
Personal details
Contact details
Financial details
Payment information and transaction data (e.g., name of payer and payee, payment details, including the sum, transaction explanations, bank account and card details)
LEGAL BASIS FOR PROCESSING
Necessary to comply with a legal obligation.
Legitimate interests of LHV to prevent and detect fraud.
PURPOSE OF PROCESSING
ID verification
TYPE OF PERSONAL DATA
Personal details
LEGAL BASIS FOR PROCESSING
Specific consent
PURPOSE OF PROCESSING
Telling you about products or services that are available to you (unless you have opted out of marketing, or we are prevented by law from doing so)
TYPE OF PERSONAL DATA
Personal details
Contact details
Demographic information
Consent records
LEGAL BASIS FOR PROCESSING
Legitimate interest to give you information about our products and services that you may be interested in
Prior consent where required by law in the case of electronic marketing.
PURPOSE OF PROCESSING
Engaging with you for the purposes of obtaining your views on our websites, app, our products or services
TYPE OF PERSONAL DATA
Personal details
Survey and testing data
Consent records
Views and opinions
LEGAL BASIS FOR PROCESSING
Necessary for our legitimate interests of conducting surveys, satisfaction reports and market research.
PURPOSE OF PROCESSING
Risk management, monitoring and investigating to counter fraud (e.g., payment fraud)
TYPE OF PERSONAL DATA
Usage Data
Data relating to our websites or app
LEGAL BASIS FOR PROCESSING
Legitimate interest for security risk-management, to counter fraud and resolve disputes in court or extra-judicially.
PURPOSE OF PROCESSING
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
TYPE OF PERSONAL DATA
Technical data
Usage Data
LEGAL BASIS FOR PROCESSING
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
Cookies: Legitimate interest to maintain the functionality of our website – so-called technically necessary cookies.
Prior consent – advertising and statistics cookies.
PURPOSE OF PROCESSING
To deliver relevant online and digital advertisements to you and measure or understand the effectiveness of the advertising we serve to you
TYPE OF PERSONAL DATA
(a) Personal details
(b) Demographic information
(c) Usage Data
(d) Data relating to our website or app
(e) Technical data
(f) Content and advertising data
LEGAL BASIS FOR PROCESSING
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
PURPOSE OF PROCESSING
To enable you to interact with our social media pages
TYPE OF PERSONAL DATA
Technical data
Usage Data
LEGAL BASIS FOR PROCESSING
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
Cookies -Legitimate interest to maintain the functionality of our website – so-called technically necessary cookies.
Prior consent – advertising and statistics cookies.
PURPOSE OF PROCESSING
To comply with our legal and regulatory obligations under applicable law
TYPE OF PERSONAL DATA
Personal details
Contact details
Professional details
Visitor logs
Payment information
Data relating to our websites or app
Employer details
LEGAL BASIS FOR PROCESSING
Necessary for compliance with a legal obligation.
PURPOSE OF PROCESSING
To establish, exercise and defend legal claims
TYPE OF PERSONAL DATA
Personal details
Contact details
Professional details
Survey and testing data
Demographic information
Visitor logs
Consent records
Payment information
Data relating to our websites or app
Employer details
Content and advertising data
Views and opinions
LEGAL BASIS FOR PROCESSING
Necessary for the establishment, exercise or defence of legal claims.
Legitimate interest in establishing, exercising and defending legal claims.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
In general, we do not process sensitive personal data. However, we do process information about criminal convictions and offences for the purpose of carrying out anti-money laundering and fraud prevention checks. Where we do so, our legal basis is:
Preventing or detecting unlawful acts and preventing fraud
We may process your sensitive personal data where the processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
Consent
We may process your sensitive personal data where we have, in accordance with applicable law, obtained your express consent prior to processing your sensitive personal data (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).
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Do we disclose your personal data to anybody else?
We disclose personal data to: legal and regulatory authorities; our external advisors; our processors; our third party service providers to whom we have delegated certain activities, including credit reference agencies; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our websites or app.
In order to provide payment services we need to send your data to certain trusted third party companies who provide essential payment system and payment processing services, including participants in Faster Payments and Bacs.
We may also send your data to third-party service providers to whom we have delegated certain activities e.g., cloud service providers, customer service software provider, fraud prevention and detection partners, credit reference agencies, KYC (know your customer) service providers, companies that produce debit cards, card producers and networks like Mastercard, and third party app platforms like Google and Apple. We are fully responsible for the processing of your personal data by these service providers. Your personal data will only be shared with third parties for the purposes set out in this privacy policy.
If we engage a third party processor to process your personal data, the processor will be subject to binding contractual obligations to: (i) only process the personal data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the personal data; together with any additional requirements under applicable law.
Together with the Society of Worldwide Interbank Financial Telecommunication (SWIFT) we act as joint controllers in respect of the payments messaging service provided by SWIFT, meaning that we have jointly determined the purpose and measures of this data processing. Please find the details of SWIFT’s responsibilities here and our respective responsibilities here.
Fraud Prevention Agencies
The personal information we have collected from you will be shared with Fraud Prevention Agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found here:
Fraud Prevention Agency Policy
General
Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.
The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.
Details of the personal information that will be processed include, for example: name, address, date of birth and contact details.
We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.
Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
Automated Decisions
As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more please contact us using the details in Section 2 above.
Consequences of Processing
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details in Section 2 above.
Data Transfers
Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place.
Your Rights
Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data, request that your personal data is erased or corrected, and request access to your personal data.
For more information or to exercise your data protection rights, please contact us using the contact details set in Section 2 above.
You also have a right to complain to the Information Commissioner's Office, which regulates the processing of personal data.
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Where do we process your personal data?
We transfer personal data to recipients in other countries. Where we transfer personal data from the EEA or the UK to a recipient outside the EEA or the UK (as applicable) that is not in an adequate jurisdiction, we do so on the basis of standard contractual clauses.
Sometimes, where necessary, we transfer personal data to third parties as noted in Section 7 above, in connection with the purposes set out in this privacy policy.
Most of the data processing referred to in this privacy policy is carried out in the UK.
As a general rule, we do not send your personal data outside the European Economic Area (“EEA”), or the UK, and if this is done, appropriate protection measures are applied. These measures may include the following:
ensuring that there is an adequacy decision by the UK Government in the case of transfers out of the UK, or by the European Commission in the case of transfers out of the EEA, which means that the recipient country is deemed to provide adequate protection for such personal data; or
where we have in place standard model contractual arrangements with the recipient which have been approved by the European Commission (or the UK Government for transfers out of the UK in due course). These model contractual clauses include certain safeguards to protect the personal data;
You are entitled to request further information about the safeguards used to protect your personal data using the contact details provided in Section 2 above.
In the absence of appropriate protection measures, we are entitled to forward your personal data outside the EEA or the UK in situations where forwarding the data is, for example, necessary for performing a contract between you and us or for implementing measures adopted on the basis of your application (e.g., use of correspondent banks for making foreign payments).
If the conducting of an international bank transaction involves a financial institution located in a country with insufficient level of data protection, e.g., a correspondent bank or other payment intermediary, including SWIFT, we cannot ensure that the processing of your personal data by financial institutions in such countries would have identical obligations to those of us and that the identical rights are guaranteed for you at the same level as in the EEA or the UK, as applicable, or other country with sufficient levels of data protection.
For detailed information on transferring your personal data outside the EEA or the UK (as applicable) please contact us.
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Data security
We implement appropriate technical and organisational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.
We have implemented appropriate technical and organisational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable law.
We take all reasonable precautions to safeguard the confidentiality and security of your personal information, including through the use of security measures on the app itself, for example:
Using customer electronic identity verification;
Using electronic address verification;
Carrying out fraud scoring and prevention processes; and
Using biometric authentication.
Transaction monitoring for suspicious/fraudulent activity
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it. Our practices align with recognised industry standards and security best practices to ensure the confidentiality, integrity, and availability of your data. These measures are designed to safeguard your data against unauthorised access, alteration, disclosure, or destruction.
Examples of the measures we use include:
Physical access controls to our premises to prevent unauthorised entry;
Staff training to ensure all personnel understand their responsibilities in protecting personal data;
Anti-virus software to safeguard against malware and other digital threats;
Password protection for systems access to restrict entry to authorised users only; and
Encryption of sensitive data where possible to enhance its security during storage or transmission.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any personal data that you send to us are sent securely.
Where we have given you (or where you have chosen) a password which enables you to access your online account or app, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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Data accuracy
We take every reasonable step to ensure that your personal data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.
We take every reasonable step to ensure that:
your personal data that we process is accurate and, where necessary, kept up-to-date; and
any of your personal data that we process that is inaccurate (having regard to the purposes for which they are processed) is erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your personal data.
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Data minimisation
We take every reasonable step to limit the volume of your personal data that we process to what is necessary.
We take every reasonable step to ensure that your personal data that we process is limited to the personal data reasonably necessary in connection with the purposes set out in this privacy policy.
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How long do we retain your data?
We take every reasonable step to ensure that your personal data is only retained for as long as it is needed in connection with a lawful purpose.
We take every reasonable step to ensure that your personal data is only processed for the minimum period necessary for the purposes set out in this privacy policy.
As a general rule we retain your data in a form that permits identification only for as long as we maintain an ongoing relationship with you, or as necessary in connection with the lawful purposes set out in this privacy policy for which we have a valid legal basis, and in each case, until the end of a limitation period of possible claims (including any additional periods as are necessary in connection with that claim).
During the periods relating to applicable limitation period under applicable law, we will restrict our processing of your personal data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the applicable retention periods described above is concluded, we will either permanently delete or destroy the relevant personal data, or anonymize the relevant personal data.
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Automated decision-making, profiling and artificial intelligence
Profiling refers to the automated processing of your data used for identifying risk, predicting certain outcomes and evaluating certain of your personal traits – for example, to analyse or predict your behaviour, location, movements, economic situation, personal preferences or interests. We may use profiling in the provision of our services.
We may use profiling, or other automated methods to make decisions about you that relate to the following:
Anti-money laundering and sanctions checks;
Fraud screening and monitoring process;
Identity and address checks;
Deciding whether an account is dormant;
Assessments required by our regulators and appropriate authorities to make sure we meet our regulatory obligations (e.g. making decisions about those at risk of becoming financially vulnerable.
The profiling that we carry out may result in a decision being made that your payment transaction cannot proceed or we cannot provide you product or services. We may make an automated decision about you in the following circumstances:
To help us make some of our decisions. For example, if you apply for our products or services we make base our decision about whether or not to offer you certain services based on automated processing;
To help us to identify fraud and the level of risk involved in your account activity.
Please note, there may be instances where we decide to get these decisions reviewed by a person, and you can always contact us to ask for a person to review an automated decision if you disagree with the decision. You also have the right to opt out of profiling or automated decisions for marketing purposes.
We may also use artificial intelligence models in the course of providing products and services (e.g. to assist with fraud detection and prevention) and this may include use of generative artificial intelligence models. When you interact with artificial intelligence models, we may provide you with an explanatory document to help you understand how the artificial intelligence model has processed your information and reached a specific decision.
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What are your rights in connection to your personal data?
Subject to applicable law, you may have a number of rights, including: the right not to provide your personal data to us; the right of access to your personal data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of processing, of your personal data; the right to object to the processing of your personal data; the right to have your personal data transferred to another controller; the right to withdraw consent; and the right to lodge complaints with data protection authorities. In some cases it will be necessary to provide evidence of your identity before we can give effect to these rights.
Subject to applicable law, you may have the right to:
Not provide your personal data to us
However, please note that we will be unable to provide you with the full benefit of our websites, app, products or services, if you do not provide us with your personal data – e.g., we might not be able to process your requests without the necessary details.
Request access
to, or copies of, your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you, together with information regarding the nature, processing and disclosure of that personal data, and to check that we are lawfully processing it.
Request correction
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Prohibit the further use of your contact details for sending out offers and marketing materials
We only use the contact details of our customers for such purpose and they can choose to opt-out from receiving such materials either by unsubscribing or by contacting us directly before receiving any offers.
Withdraw your consent
for processing your relevant personal data in situations where we process such data on the basis of consent. However, this will not affect the lawfulness of any processing carried out before that date on which we receive notice that you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you, and it may not prevent the processing of your personal data in reliance upon any other available legal bases. We will advise you if this is the case at the time you withdraw your consent.
Complain to a data protection authority
regarding the processing of your relevant personal data with a data protection authority which is the Information Commissioner’s Office
Request our legitimate interest assessments
Request that we stop
processing your personal data if and to the extent such processing occurs unlawfully, i.e. we lack a valid legal basis for the processing.
Request deletion of your personal data
This enables you to ask us to delete or remove personal data where there is no good reason or legitimate ground for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Request restriction of processing your personal data
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format, to the extent applicable. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Subject to applicable law, you may also have the following additional rights regarding the processing of your relevant personal data:
the right to object, on grounds relating to your particular situation, to the processing of your relevant personal data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR; and
the right to object to the processing of your relevant personal data by us or on our behalf for direct marketing purposes
This does not affect your statutory rights.
You may exercise your rights by contacting us via the contact details provided in Section 2 above. We shall respond to your queries without undue delay, and no later than one month of receiving your request. If, prior to responding, it is necessary to ascertain circumstances, ask for additional details or perform checks, we may extend the deadline for responding, notifying you thereof in advance. In some cases, it will be necessary to provide evidence of your identity before we can give effect to these rights. Where your request requires the establishment of additional facts (e.g., a determination of whether any processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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Cookies and similar technologies
We process personal data by using cookies and similar technologies. For more information, please see our Cookie Policy
When you visit a website or app, we will typically place cookies onto your device, or read cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We process personal data through cookies and similar technologies, in accordance with our Cookie Policy.
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Terms of Use
Our Terms of Use govern all use of our websites, app and our services, including terms around linking to other third-party websites.
We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
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Direct marketing
We process personal data to contact you with information regarding our websites, app, products or services that may be of interest to you. You may unsubscribe at any time.
Where we have the appropriate marketing permissions, we process personal data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding our websites, app, products or services that may be of interest to you. We also process personal data for the purposes of displaying content tailored to your use of our websites, app, products or services. If we provide our websites, app, products or services to you, we may send or display information to you regarding our websites, app, products or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send. Please note that it may take up to 2 weeks to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any websites, app, products or services you have requested.
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Details of controller
For the purposes of this privacy policy, the relevant controller is LHV Bank Limited.
Controller entity
LHV Bank Limited is registered with the UK data protection authority (the Information Commissioner’s Office or ICO) under number ZB323856
Contact details
Address: 1 Angel Court, London, EC2R 7HJ, United Kingdom
E-mail: dataprotection@lhv.com
Phone: +44 20 3005 0150
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Changes to our privacy policy or to your details
This privacy policy may be amended or updated from time to time, so please check it regularly for updates.
This privacy policy may be amended or updated from time to time to reflect changes in our practices with respect to the processing of personal data, or changes in applicable law.
Any changes we may make to this document will be posted on our website and, where appropriate and possible, notified to you by e-mail. Please check back frequently to see any updates or changes to this document.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.