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Privacy Policy of Altum

1.   Controller

AS "Attīstības finanšu institūcija Altum" (JSC Development Finance Institution Altum) is the personal data processing controller, registration No 50103744891, legal address: Doma laukums 4, Rīga, LV-1050; telephone: +371 67774010; altum@altum.lv

We are a state-owned development finance institution. We provide funding by means of financial instruments (loans, guarantees, investments in venture capital funds, a.o.) or grants in the areas that the state has identified as priority and eligible for support and that lack funding.

2.   Your Privacy and Trust Matter to Us

The aim of the Privacy Policy is to inform a natural person - data subject about the purpose and scale of personal data processing, data protection and processing deadline during acquisition of data and when processing personal data of the data subject.

We need to process your personal data to be able to supply you with personalised offers and services and ensure safe access to them.

Our aim is to inform you as clearly and comprehensively as possible about how and why we use your personal information.

Personal data are any information that may be used to identify an individual.

We undertake appropriate measures to ensure that your personal data are safe with us at all times and are processed in line with the effective data protection legislation, our internal policies, guidelines and procedure.

We have designated a data protection officer tasked with monitoring of our compliance with requirements of personal data protection legislation, guidelines and procedure.

The Privacy Policy lets you know what data we may obtain about you, how we will use such data and inform you about your rights and how you can contact us. At times we may have to change our Privacy Policy. All the changes will be published on this website and will be available to you at any time.

3.   Purpose of Personal Data Processing and Categories of Personal Data

3.1.     Provision of Basic Services

We have to process your personal data within the framework of implementation of the state aid and development programmes, if you want to apply for these programmes and receive support.


We process your personal data to provide our services to you. If you fail to supply us with the required personal data, you won’t be able to apply for and receive our services. For more information about our services and terms of the state aid and development programmes see www.altum.lv, section ‘services’.


In addition, we process your personal data to verify your identity, administer the state aid programmes, implement the bonds’ programme, assess viability or creditworthiness, evaluate the terms of the programme, grant state aid, monitor its use, for the purposes of statistics, questionnaires, drafting of agreements, recovery of debts, risk management, maintenance of the website, compliance with regulatory enactments as well as execution of our legal obligations.


By using our services you acknowledge that the personal data you have provided are accurate and correct and that you are at least 18 years old. We may not provide the service if you have provided inaccurate data. The obligations of the financial service and grant providers stipulated by laws are binding upon us, including the obligation to identify the client, i.e. we are obliged to make sure that you are the person that you say you are.


We process personal data for the purpose of personnel management – organisation and implementation of the personnel selection process, establishment of the labour relationships, development of the personnel (including further education and training of the employees), provision of work placement, maintenance of corporate culture and execution of other rights and obligations ensuing from the regulatory framework.


3.2.     Video Surveillance

We use video surveillance and process your personal data when you visit our regional centres or head office to guarantee your safety and safety of our employees, clients and property. Video surveillance is done in accordance with strict safety and privacy rules, using modern technologies and equipment. Video surveillance records are stored in our systems for 1 week.

3.3.     Direct Marketing

Having received your consent, we inform you about various news and current events related to our services. If you wish to receive our news, you have to indicate so in our website or fill in a form during any event of ours.

The contacts will be used to inform the current and prospective entrepreneurs, co-operation partners or population about the state aid options, providing only the information about the specific topic that you are interested in (for instance, aid for starting a business, energy efficiency of multi-apartment buildings, SME growth).

3.4.     Cookies

The cookies are small text files created and stored in your device (computer, tablet, cellular phone, etc.) when you use the Internet visiting our website. The cookies ‘remember’ your choices and basic information thus making use of our website more convenient and enhancing the possibility of acquiring the information you are interested in.


The website creates cookies that don’t contain personal data and are not used to identify a person, i.e. the information cannot be traced back to any specific person.

Use of cookies allows for processing of historic website use data, identification of problems and deficiencies in the operation of the website, collection of statistics on users’ preferences and complete and convenient use of the website’s functionality.


Should you wish to ban cookies, you may do so by changing the settings of your Internet browser, however it might disable our website. It is possible to delete the saved cookies under the settings of your device’s Internet browser where you can delete the history of the saved cookies. The cookies contain no computer viruses and neither spyware nor malware can be installed on your computer through cookies.

For more information on cookies visit our website.


3.5.     Categories of Personal Data

3.5.1.      Personal information and identification data (name, surname, personal identification number or other identification number if personal identification number has not been assigned);

3.5.2.      Contact information (residence address, e-mail address, telephone number);

3.5.3.      Biometric data (facial image) – video surveillance;

3.5.4.      Financial data, data about origin of funds;

3.5.5.      Data about education and professional experience;

3.5.6.      Communication data, correspondence;

3.5.7.      Data submitted to evaluate provision and ensuring of our services (applications, forms, contracts, etc.);

3.5.8.      Sensitive personal data (within the framework of social entrepreneurship programme);

3.5.9.      Other data, as defined by state aid rules of the respective country.


4.   Legal Basis for Processing of Personal Data

We process your personal data based on the following:

4.1.     Conclusion and execution of contract – in order to conclude a contract, based on your application, and ensure its execution;

4.2.     Compliance with regulatory enactments – in order to execute an obligation stipulated by external regulatory enactments binding on us;

4.3.     Based on your consent;

4.4.     It is necessary for exercising of our legitimate (lawful) interests.

5.   Where from we get personal data?

5.1.      You

We summarise the personal data that you submit to us prior to being provided a service, when you visit our regional centres or head office (video surveillance) and our home page (when you apply for receipt of our news), during individual meetings, also when you fill in an application for a consultation in the calculator’s template or any other specifically designed template.

5.2.     Our Co-operation Partners

We may receive your personal data from the credit institutions, financial institutions, intermediaries of financial services and third parties that you have approached, also with the aim of receiving any of our services (for instance, within the framework of the state aid and development programmes).

5.3.     Events

With your consent, we acquire personal data from you at information seminars, conferences, discussions, business forums, etc. Personal data are acquired when applying for these events through our website or when filling in registration forms or contact sheets during such events, also when organising lotteries, professional surveys.

5.4.      Public and Private Registers

6.   Who we transfer your personal data to?

6.1.      Service Providers and Co-operation Partners

In order to be able to execute the obligations delegated to us as the implementing body of the state aid and development programmes, we have to provide information about implementation progress of the state aid programmes and your personal data to the Central Finance and Contracting Agency (CFCA) and other supervisory and co-operation bodies.

We transfer your personal data to credit institutions, finance institutions, intermediaries of financial services and third parties that are involved in execution of the service you have chosen.

In addition, to meet our obligations towards you, we transfer your personal data to the companies that provide services to us, for instance in order to send direct marketing messages.

We check thoroughly all the service providers that process your personal data on your behalf and under your assignment. We assess whether co-operation partners (personal data processors) use appropriate safety measures so that processing of your personal data would be done in accordance with our assignments, directions, instructions and law. These companies are not entitled to use your personal data for any other purpose.

6.2.      Law Enforcement Authorities, Public Authorities

To comply with the law, we may transfer your personal data to the law enforcement authorities (for instance, police), also to the public authorities if requested by them. Also we may transfer your personal data to the law enforcement authorities (for instance, courts) and public authorities to protect our legitimate interests when drawing up, submitting and defending legal claims.

On certain occasions we will transfer your personal data to financial investigation authorities.

7.   Transfer of Personal Data outside European Union and European Economic Area (EU/EEA)

We always attempt to process your personal data on the territory of the European Union and European Economic Area (EU/EEA). Your personal data are not processed in a country outside EU/EEA for the purpose of providing the service you have selected.

Transfer and processing of personal data outside EU/EEA may happen if there is a legal basis for it, i.e. to execute a legal obligation, conclude or honour a contract or upon your consent and provided appropriate safety measures have been put in place.

8.       Storage Period of Personal Data

All the personal data acquired from you are kept as long as you use our services, or until you revoke your consent if your personal data are processed based on that. Longer storage period of personal data is permitted to meet the requirements of the law about minimum storage term of the documents or information or protect our legitimate interests.

When this period expires, we will erase your personal data in a safe manner or make them inaccessible (archive them) or unidentifiable so that they cannot be attributed to you anymore.

The storage period of personal data may be based on our mutual contract, our legitimate interests or applicable regulatory enactments that are binding upon us (for instance when implementing the state aid or development programmes).

9.       Protection of Personal Data

We provide, review constantly and improve the protection measures to safeguard your personal data against unauthorised access, accidental loss, disclosure or destruction. In order to achieve this, we use up-to-date technologies, technical and organisational requirements, including firewalls, software for detection and analysis of intrusion and data coding.

Nevertheless, we recommend that you comply with general computer and Internet use safety rules as well as protection and storage requirements of your private data (especially personal identification document) as we will not assume any responsibility for unauthorised access to your personal data and/or loss of data if due to your fault or negligence.

10.   Your Rights

The regulatory framework of data protection grants you certain rights with regard to processing of your personal data.

10.1.  Access to Personal Data

You are entitled to request a confirmation from us as to whether we are processing personal data concerning you and request access to the personal data that we are processing about you or information about personal data if ensuring of direct access is not envisaged.

10.2.  Rectification of Personal Data

Should you consider that information about you is incorrect or incomplete, you are entitled to request that we correct it.

10.3.  Withdrawing of Consent

As long as we process your personal data based on your consent you are entitled to withdraw your consent to processing of personal data at any time.

10.4.  Objection to Processing of Data for Direct Marketing Purposes

You are entitled to object to processing of your personal data for direct marketing purposes at any time.

10.5.  Objection to Processing Based on Legitimate Interests

You are entitled to object to processing of personal data that we process based on our legitimate interests, however we will continue to process your data even after you have filed your objection if we have compelling grounds for proceeding with processing of personal data. In order to exercise the aforementioned rights, please submit a written application to us or our data protection officer.

10.6.  Erasure

Under certain circumstances, you are entitled to request that we erase your personal data, however it does not refer to the cases when the regulatory enactments or other binding documents require us to maintain the data. In order to exercise the aforementioned rights, please submit a written application to us or our data protection officer.

10.7.  Processing Limitation

Under certain circumstances, you are entitled to limit processing of your personal data. Please, bear in mind that your request for limiting of processing of your data may affect your possibilities of receiving our services. In order to exercise the aforementioned rights, please submit a written application to us or our data protection officer.

10.8.  Data Transfer

Finally, you are entitled to receive or transfer your personal data to another data controller. Such rights refer only to those data that you have provided to us, based on your consent or contract, also in the event of automated processing. In order to exercise the aforementioned rights, please submit a written application to us or our data protection officer.

11.   Any questions?

Should you have any questions about processing of your personal data, you are welcome to contact us.

Should you not be satisfied with the reply, you are entitled to submit a claim to the Data State Inspectorate (www.dvi.gov.lv)

11.1. Contact Information of Company Responsible for Processing of Your Personal Data

AS "Attīstības finanšu institūcija Altum" (JSC Development Finance Institution Altum)
Registration No 50103744891
Address: Doma laukums 4, Rīga, LV-1050
Telephone: +371 67774010

11.2. Contact Details of Data Protection Officer

Gints Puškundzis; gints.puskundzis@altum.lv