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The purpose of personal data processing indicates the result to be achieved. The legal basis for processing indicates which GDPR-recognised legal basis underpins the collection, use or storage of your personal data.

Capitalia collects and uses personal data for the following main processes:

1.1. processing an application for financing, a loan or other Capitalia products. Your name, surname, email address and phone number will be processed to clarify details of the service you are interested in and to prepare a relevant proposal for concluding an agreement (GDPR Article 6(1)(b));

1.2. registering an investor account on the Capitalia website (GDPR Article 6(1)(a) for natural persons or Article 6(1)(f) for legal persons);

1.3. processing your or your company application for Capitalia products or investor applications to assess transaction compliance with regulations, in particular its feasibility under the Law on the Prevention of Money Laundering and Terrorist and Proliferation Financing and the Law on International and National Sanctions of the Republic of Latvia, as well as the obligation to identify beneficial owners. In such cases, additional information may be obtained from third-party registers (credit history databases, credit bureaus, public state registers, etc.) (GDPR Article 6(1)(c));

1.4. using communication with Capitalia via email or the company contact form. Your name, surname, email address, phone number, address, city, company name (if a legal person is represented by its employee) and submitted message will be used to review your enquiry and respond on the basis of consent to answer your information request about our service offerings and contract performance (GDPR Article 6(1)(a));

1.5. Capitalia calls publicly available contact phone numbers to inform about Capitalia services and marketing news also sent by email. If you consent, Capitalia records the contact details provided. Capitalia sends newsletters based on data subject consent given during a phone conversation with Capitalia (GDPR Article 6(1)(a)).

1.6. sending Capitalia marketing news in accordance with your consent (GDPR Article 6(1)(a));

1.7. In case of unjustified failure to perform contractual obligations, Capitalia may transfer personal data to third parties, debt collection service providers (GDPR Article 6(1)(f));

1.8. Capitalia may process your personal data to fulfil GDPR requirements if you have submitted a question about your data processing or wish to exercise any data subject rights under the GDPR. Personal data processed: name, surname, address, email address, and in case of electronic submission also personal identification code. Legal basis for processing: compliance with a legal obligation and legitimate interests of the controller (GDPR Article 6(1)(c) and (f));

Capitalia does not collect or process special category personal data or personal data relating to criminal convictions.

2.1. Capitalia does not provide access to its database to unauthorised persons and protects your submitted personal information. Certain personal data may be transferred to third parties only:

2.1.1. to ensure website operation and service functionality (for example, website maintenance and server hosting service providers);

2.1.2. to data processors that maintain Capitalia company data as outsourced services (SIA Pipedrive Latvia, SIA "TET", etc.);

2.1.3. to verify personal data in registers maintained by third parties (for example, credit history databases, public state registers, etc.).

2.2. Capitalia is obliged to transfer data to state institutions when a request from an authority is received in cases provided by law.

3.1. Personal data are stored and used in accordance with defined personal data processing purposes and legal bases for processing, while Capitalia fulfils at least one of the following criteria:

3.1.1. a legal obligation exists to store data for a specified period under applicable law;

3.1.2. it is necessary to pursue legitimate interests;

3.1.3. it is necessary to perform assumed contractual obligations, and for a certain period after contract performance;

3.1.4. data subject consent is in force for the relevant personal data processing.

We inform you of the rights that Capitalia provides to you as a data subject. Please note that the GDPR or law may provide restrictions on exercising these rights and each rights exercise request is assessed individually.

4.1.Right of access to your personal data
Capitalia will provide confirmation of whether Capitalia processes your personal data and will issue a summary of processed data as supplementary information in accordance with the GDPR. Capitalia may refuse to provide personal data or disclose personal data recipients where disclosure is prohibited by law, for example the Law on the Prevention of Money Laundering and Terrorist and Proliferation Financing.

4.2.Right to request rectification or supplementation of inaccurate personal data
Capitalia invites you to submit changes if they have occurred to your name, surname, delivery address, contact details or other personal data to ensure up-to-date personal data processing.
Capitalia will review a request to correct incorrect or inaccurate data and, if justified, personal data will be corrected with a notice of the decision provided to you. The right to rectify personal data does not apply to documents to be archived or in other exceptional cases.

4.3.Right to request restriction (suspension) of personal data processing
Capitalia will automatically restrict processing of your personal data (except storage) if:

• you submitted a request to correct inaccurate personal data;
• you object to the personal data processing process.

Processing is restricted for the time while a request for rectification or objection is being reviewed. In other cases you must request Capitalia to restrict personal data processing, stating the reason.

4.4.Right to object to personal data processing
You have the right to object to a specific personal data processing process where Capitalia processes data in Capitalia interests or on the basis of legitimate interests. When reviewing the request, Capitalia may fully or partially grant it. If Capitalia finds that it has compelling legitimate grounds to process your personal data, the request will not be granted.

4.5.Right to request erasure of your personal data
Capitalia will assess whether grounds under the GDPR exist to erase personal data and inform you of the decision. The right to erasure does not exist where data must be retained under legal requirements.

4.6.Right to withdraw consent
If personal data processing is based on consent, it may be withdrawn. If you consented to receive news by email, you may withdraw consent by unsubscribing as indicated in the email. Capitalia will stop processing for the purpose for which consent was given, except where personal data are retained to protect Capitalia legitimate interests.

Withdrawal of consent cannot affect processing of personal data necessary to comply with legal requirements or based on a contract, Capitalia legitimate interests or other lawful bases for processing under applicable law.

4.7. By submitting any rights request, you provide Capitalia with your personal data. In this case the purpose of processing is to decide on and respond to your request. Personal data indicated in your data subject rights request and the request itself will be stored for five years from the date Capitalia provides a response to preserve evidence of exercise of data subject rights.

4.8.You may exercise the above data subject rights by submitting a request in one of the following ways:

4.8.1. a written request signed by hand addressed to the Capitalia address indicated in this Privacy Policy;

4.8.2. a request signed with a secure electronic signature addressed to Capitalia and sent to: info@capitalia.com. For Capitalia to send a substantive response to your email address, the request signed with secure electronic signature must include your email address for the response.
Each rights exercise request will be reviewed as soon as possible, but no later than within one month.

4.9. The data subject has the right to lodge a complaint with a supervisory authority. If you have questions about personal data processing, contact Capitalia at: info@capitalia.com. If you are not satisfied with the response received, you have the right to lodge a complaint with the Data State Inspectorate: Elijas iela 17, Riga, Latvia, LV-1050.