INVL Logo

SB draudimas Privacy Policy

1. Purpose of the document

In this privacy policy we will inform you about the use of personal data at Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches, including what kind of personal data we process, how we use your data and what rights you have with regard to the processing of your data. You can find more detailed information in our register descriptions. You can find them by selecting below which group you belong to.

2. General Information about the Privacy Policy

As a customer of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches you trust us with your personal data. This privacy policy describes how and why we process your personal data and what kind of data we collect. This privacy policy applies to all operations of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches that involve the processing of personal data. Examples of these include the use of our online products and services, filing an insurance claim. This privacy policy covers Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches. Please see the contacts in the end of this policy.

Data protection refers to the protection of personal data and ensuring the appropriate processing of such data. Personal data means information that can be used to identify you. This privacy policy applies to the processing of personal data of natural persons. These persons include for example the private customers of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches or persons related to corporate customers of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches. Section 3 of this policy describes the categories of data subjects in more detail. You can read more about your rights in section 7 of this policy.

Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches is committed to processing your personal data in accordance with the relevant legislation, including the General Data Protection Regulation (2016/679), and other applicable regulations.

Protecting your data and your privacy and processing your data in a secure manner are very important to Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches, so whether you are a new or a long-time customer of ours, we recommend that you familiarize yourself with our practices. And in case you have any questions, do not hesitate to contact us!

You can also visit our parent’s company’s Gyvybės draudimo UAB “SB draudimas” website https://www.sb.lt/lt/apie/svarbus-dokumentai/privatumo-politika, where you can familiarize with how Gyvybės draudimo UAB “SB draudimas” process personal data in Lithuania.

Gyvybės draudimo UAB “SB draudimas” is an integral part of Šiaulių Bankas Group Companies, which also includes AB Šiaulių bankas, UAB “SB Asset Management”, UAB “SB lizingas” (hereafter in this document referred to as Group companies).

3.Whose Data Do We Process and Where Do We Collect Data From?

The privacy policy of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches applies to the following categories of data subjects:

  • Customers of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches (for example the insured persons, policyholders, beneficiaries and persons associated with corporate customers)
  • Users of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches digital services (website, customer portal(s) etc.)
  • Persons whose personal data is processed due to a statutory obligation of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches

Personal data is mainly collected from the persons themselves before and during the customer relationshipor other contractual relationship. We also receive data from employers with regard to the employer’s group insurance plans. We might receive data from high risk persons registers of insurance companies in Estonia (relevant only for Gyvybės draudimo UAB “SB draudimas” Estonian branch). We also receive data from other reliable parties and public registers maintained by authorities. For example, states population register, Commercial register and International sanctions list.

4.   How and Why We Process Personal Data?

    4.1. The Customers of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches

We process personal data for example to manage customer relationships, to comply with the requirements of law, to protect our legitimate interests, as well for developing our services. We process personal data only to the extent necessary or as required by law. The categories of data we process and the details of the processing depend on what group of persons or customers you belong to. We categorize customers into different groups, for example based on what kinds of products they have selected or based on their investment capital.  When we offer investment solutions related to our services, we assess the customer’s investing and saving needs and willingness and capability to take risk in accordance with our statutory obligations.

When we process insurance claims, we do not use personal data for making automated decisions.  We process personal data for statistical purposes in order to fulfil our statutory obligations and in order to report on our services. Individual persons or companies are not identifiable from the statistics or reports.

   4.2. More specific information

You can find more detailed descriptions of the categories of data, the purposes and legal grounds for the processing in our registers’ descriptions below, by choosing the right register and to which group you belong to.

  • Customer Register (insured persons, policyholders and beneficiaries) and their representatives. Potential and former customers. Persons related to corporate customers. Persons regarding whom the processing of personal data is related to the statutory obligation laid down for the data controller.
  • Insurance Claims Register (Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches insurance contract policyholders, the insured and insurance out payments recipients)

5. How Long Is Personal Data Retained?

We retain personal data for as long as is necessary for the purposes for which the data is collected or as long as required by law. The periods for bringing proceedings under the Estonian Law of Obligation,or Latvian Civil law, as well as storage times resulting from legislation related to the money laundering, terrorist and proliferation financing prevention and accounting regulations among other things, impact the storage times of the personal data of private customers. The maximum possible storage time is applied to data to which different storage times apply. You can find a more detailed description of the storage times for personal data in our register-specific register descriptions.

6. Is Personal Data Disclosed or Transferred to Others?

Personal data can be disclosed to parties outside Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches as allowed or required by law. Data may be disclosed e.g., to authorities (such as the Estonian or Latvian tax authorities, the Estonian insurance companies’ high risk persons registers (relevant only for Gyvybės draudimo UAB “SB draudimas” Estonian branch)), as well as, or based on the law regulating insurance activities or data subject’s consent. Personal data may be disclosed, to the extent permitted under the law, to other companies belonging to the same company’s group for the purpose of managing customer service and other customer relationship matters, as well as the conglomerate’s risk management. The processing of personal data within the group is restricted to the necessary circle of persons, and the disclosure of sensitive data is prohibited.

If we decide to sell, buy, merge or otherwise reorganize our businesses, this may involve us disclosing and/or transferring personal data to prospective or actual buyers and their advisers, or receiving personal data from sellers and their advisers.

Personal data is mainly stored and processed within the EU and the EEA. If data is transferred outside the EU and the EEA to countries for which the European Commission has not issued a decision of adequacy of data protection, we will take care of protecting the data for example by using the standard contractual clauses approved by the European Commission. Sensitive data is not transferred outside the EU and the EEA. Transferred data is processed only on behalf of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches.

7. What Rights Do You Have?

You have for example the right to access your data, the right to rectify inaccurate data and the right to erasure as described in more detail below. Please also note that Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches has statutory obligations to store some of the data and Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches may have an obligation to process or store your data even if you object to the processing or ask for the data to be erased.

You can use your rights described below by contacting our customer service.

We will respond to your request within one month of receiving the request. In special circumstances we can extend the time limit by two months as allowed by legislation, taking into account the complexity and number of the requests.

   7.1. The Right of Access by the Data Subject

You have the right to receive confirmation on whether or not Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches is processing your personal data. If your personal data is being processed, you have the right to access the data and to receive a free of charge copy of the data. The confidentiality obligations set in the legislation applicable to the insurance and finance sector (for example the act on detecting and preventing money laundering and terrorist and proliferation financing) may restrict the use of your right to access information.

  7.2. The Right to Rectification

You have the right to request that Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches rectifies any inaccurate personal data and completes any incomplete data.

  7.3. The Right to Erasure (the Right to Be Forgotten)

You have the right to request the erasure of your personal data and if the processing of your data is based on your consent, the right to withdraw your consent. If you request the erasure of your data or withdraw your consent, we will delete the data unless there are other legal grounds for the processing or unless we have a statutory obligation to store the data. In any case, we will delete your data after the retention period has ended.

  7.4. The Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data in cases where the conditions set in legislation are met. Please also note that the right to restriction of processing does not apply to the processing of personal data carried out to fulfil the statutory obligations of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches.

  7.5. The Right to Data Portability

You have the right to receive the personal data you have provided us in a structured and commonly used format and the right to have electronical data transferred to another data controller if such transfer is possible.

  7.6.The Right to Object

You have the right to object to the processing of your personal data if the processing is based on the legitimate interests of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches.

  7.7. The Right to Lodge a Complaint

If you find the processing of your personal data in conflict with the applicable legislation, you have the right to lodge a complaint with the data protection authority.

8. Marketing

We do not process personal data for marketing our services and products when managing the customer relationship in Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches.

9. Cookies

Cookies are small text files that are stored on the visitor’s computer or other device when visiting the websites of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches. Cookies are used for example to maintain the session after the user logs in to the web service and to remember the selections made by the user when moving from one page to another. We can also utilize cookies for example to individualize website visitors and to compile statistics of the visits to our websites. Both session cookies and persistent cookies set by Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches and our partners are used on Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches digital services including web site. Each Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches website has published its’ own Cookie policies.

10.  How is Personal Data Protected and What Kinds of Risks Are Involved?

We use the necessary and appropriate technological and administrative data protection methods in accordance with the best practices to protect personal and other data. These methods include the use of firewalls, strong encryption techniques and secure facilities, access controls and the limited granting of rights, training of the staff as well as the careful selection of subcontractors. The subcontractors are contractually bound to comply with the applicable legislation and the data protection principles and guidelines of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches.

The processing of personal data is only allowed for employees who need to use the data to carry out their work tasks. The systems containing personal data have individual user accounts and the use of the systems is monitored. In addition to a statutory confidentiality obligation, Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches employees processing personal data are bound by confidentiality agreement. Personal data that is no longer necessary is deleted securely.

Despite careful and appropriate security measures, data processing always includes a risk. If a data security breach that is likely to result in a high risk to your privacy or other rights takes place despite the security measures, we will contact you as soon as possible.

We also recommend that you familiarise yourself with the terms of use of Gyvybės draudimo UAB “SB draudimas” Latvian and Estonian branches online services and website, and make sure that the equipment and connections that you use are up to date with regard to data security. You can also find more information and general data security tips and instructions, for example, on the Estonian or Latvian Data Protection Inspectorate website. 

11.  Who Can I Contact?

If you have questions about data protection, you can contact our customer service in following countries and locations:

 Estonia:
Keemia 4, Tallinn, 10616, Eesti
+ 372 6 812 300
[email protected] or Data Protection Officer by contacting [email protected]

 Latvia:
Citadeles 12, Rīga, LV-1010, Latvia
+371 67503333
[email protected] or Data Protection Officer by contacting [email protected]

 Lithuania
Gynėjų 14, 01109, Vilnius, Lithuania
1813
[email protected] or Data Protection Officer by contacting [email protected]