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Data processing

Privacy policy of SIA Citadele Leasing Estonian branch

Valid from 1st of June 2022

In this policy (formerly named – Principles of Personal Data Processing*), on the website www.citadeleleasing.ee, you will find out what information we collect about you, what we do with it and in which cases we disclose it to others. We always protect your information and update this privacy policy regularly. We will notify you of any amendments to the Privacy Policy on our website, and if the amendments are substantial, we will notify you via email (if such is provided to us), giving 3 business days to familiarize with amendments before entry into force. SIA Citadele Leasing Estonian branch, registered in the Republic of Estonia under registration number: 11453650, address: Narva mnt 63/1, Tallinn 10120, Estonia, is responsible for processing of your data.

*If your agreement, document or other information contains any references to the Principles of Personal Data Processing, then it must be deemed to be a reference to this Privacy Policy.

  • 1 . How do we collect information about you?

    We collect information about you in cases where:

    • You use our website or provide personal data in the forms on it;
    • You apply for or repay leasing, loan or insurance (hereinafter collectively referred to as leasing);
    • You guarantee the leaseholder's obligations;
    • You are unable to repay your obligations.

    1.1. What is the personal data you provide:

    • Name, surname, personal identification code;
    • Postal address of residence;
    • Telephone number;
    • Employer, position, duration of employment;
    • E-mail address;
    • Monthly net income;
    • Additional income and its sources;
    • Information on other existing obligations;
    • Bank account number;
    • Bank account statement for up to the last 12 months;
    • Amount of funded pension contributions for the last 6 months;
    • Number of dependents;
    • Copy of ID or passport;
    • Relationship with politically exposed persons.

    1.2. Information we receive about you:

    1.2.1. Credit history

    According to the Creditors and Credit Intermediaries Act and Law of Obligations Act, we are obliged to assess your creditworthiness at the time we receive a leasing application. We receive information from credit information registers to assess your creditworthiness.

    1.2.2. Information provided by Citadele Group companies

    As a Citadele Group company, we may receive leasing applications from other Citadele Group companies and consider them in accordance with the terms of this Privacy Policy for the processing of your personal data. Also, by ensuring the progress of consideration of the leasing application, we can receive information from other companies of the Citadele Group that is necessary for considering and approving the leasing application.

    We may receive information from other Citadele Group companies to mitigate or prevent money laundering, terrorism and proliferation financing, violations of international and national sanctions, fraud and other risks of the Citadele Group. Also in this case, we will process your personal data in compliance with the requirements of regulatory enactments and the conditions provided for in this Privacy Policy for the processing of your personal data.

    1.2.3. Actions on our website

    In order to improve the quality of our services and speed-up the performance of our website as well as the loan granting process, we, together with our partners, collect anonymous cookies and store them for a maximum of 12 months. This information is anonymous.

    1.2.4. Information from public registers

    Information we obtain from publicly available registers in the context of the provision of leasing, for instance Population Register /Rahvastikuregister/.

  • 2 . Why do we process information about you?

    We process information about potential and existing customers, as well as guarantors for the following purposes: please see here.

  • 3 . How do we analyse your data?

    We make sure that you act in good faith and evaluate your solvency by automated means in order to grant you leasing as soon as possible. This allows us to decide whether, to what extent and on what conditions we will provide financing to you. This is beneficial for you, as we can take into account individual information about you and adjust the leasing conditions to your needs. The process described below will take approximately 2 business days. Unfortunately, if you do not agree with the automated individual decision-making procedure described below, we will not be able to assess your creditworthiness, prepare the terms of your leasing and provide you with financing.

    In the process of granting leasing and determining leasing conditions, we use an algorithm, according to which we analyse your information in accordance with the consumer financing procedure of SIA Citadele Leasing Estonian branch. If we are to refuse granting leasing to you, you can request an explanation for the refusal as set out in Section 8.

    To assess your creditworthiness, we receive information from the following credit registers or credit information registers:

    AS Creditinfo Eesti
    Narva mnt 5, Tallinn 10117, Estonia

  • 4 . Who do we disclose your information to?

    We have introduced various tools and services that facilitate our cooperation and make our communication faster. Therefore, we disclose:

    • Information about your agreement and contact information to car dealers who have submitted your leasing application to us;

    • Your name, surname, personal identity number to vehicle registration authorities, for example, Transpordiamet /Transport Administration/ and MTÜ Eesti Liikluskindlustuse Fond /Estonian Motor Insurance Bureau/;

    • Your name, surname, personal identification code, contact information to the insurance broker Smart Kindlustusmaakler AS, if you have confirmed that you want to receive an insurance offer for the leasing object or disclosure of the mentioned data for insurance purposes is required to comply with the terms of the leasing agreement. The list of insurance companies with whom Smart Kindlustusmaakler AS shares information on you for the purpose of receiving insurance offers can be found on the website of Smart Kindlustusmaakler AS;

    • Your name, surname, personal identification code, contact information, current payment information and agreement information to AS Citadele banka Estonian branch in order to provide us with remote customer service (for example, servicing your calls or electronic correspondence);

    • Your name, surname, personal identification code, date on which the debt was incurred and expired, the debt amount and information on the origin of the debt to AS Creditinfo Eesti in accordance with the Personal Data Protection Act;

    • Information about you found in the leasing documentation file to entities ensuring debtor monitoring, litigation support and debt recovery services as well as archiving service providers;

    • Your contact information to communications providers and IT service providers for leasing administration;

    • Your name, surname, personal identification code, payment information and agreement information as well as information on your debts (if any) to our parent company AS Citadele banka to ensure risk management on the Citadele Group level and reporting in conformity with prudential regulations;

    • Information on the examination of your data in accordance with the Money Laundering and Terrorist Financing Prevention Act to AS Citadele banka Estonian branch and other Citadele Group companies for the purposes of carrying out due diligence or mitigation or prevention of the identified risks;

    • Information about your requests and complaints as well as information about various types of incidents (e.g., incidents related to activities that do not comply with internal and external regulatory enactments, data breaches), if any, to AS Citadele banka to ensure risk management on the Citadele Group level and improve the quality of services and servicing of customers;

    • If you have agreed to receive advertising, we may transfer your personal data to Citadele Group companies: AS Citadele banka Estonian branch, OÜ Citadele Factoring, address: Narva mnt 63/1, Tallinn 10120, Estonia; AS Citadele banka, address: Republikas laukums 2A, Riga, Latvia, LV-1010.

    If you do not repay the leasing in accordance with the terms of the leasing agreement even having received our reminders, we will decide on necessity to hire experts to recover your debt. In this case, we will process your personal data to ensure our legitimate interest in recovering the debt. If we decide to transfer your debt to a debt recovery service company, we will provide them with your name, surname, all contact information, a copy of the leasing agreement and any annexes thereto as well as information on all previous payments and other information that may facilitate debt recovery.

  • 5 . How do we process your information when sending you individual notifications and offers?

    We or any of the Citadele Group companies will prepare the following notifications and offers, incl. personalized offers, individual offers of credit limits, and send them to you from time to time, if you have given your consent to the processing of your personal data on our website, in the leasing application or unified consent form.

    According to your consent, we will send you:

    • up-to-date information on financial services provided by Citadele Group companies, for example, account opening, payment card processing; deposit services; lending services; leasing services; insurance services; financial instruments services, etc. services and related offers, incl. personalized offers within customer loyalty programs;

    • other notices related to opportunities to participate in contests, draws, lotteries, promotions and other customer-related events; congratulations on your birthday, name day and other festivities (for example, Easter, Christmas, New Year and other celebrations); our comments on current events in the Estonian and world economy; opportunities to express our opinion about the services we provide and the quality of service by participating in customer surveys organized by us; social responsibility and support projects; our financial performance, awards, special events;

    • up-to-date information on credit limits available to you personally (for example, payment card credit limits, consumer loans, leasing offers), which will be prepared by financial consultants of AS Citadele banka/AS Citadele banka Estonian branch and/or SIA Citadele Leasing Estonian branch upon the assessment of your financial situation.


    In order to receive notifications and offers, including personalized offers and offers of individual credit limits, your personal data will be processed by the following Citadele Group companies as individual or joint controllers: SIA Citadele Leasing Estonian branch, registration number: 11453650, OÜ Citadele Factoring, registration number: 10925733, AS Citadele banka Estonian branch, registration number: 11971924, address: Narva mnt 63/1, Tallinn 10120, Estonia; AS Citadele banka, registration number: 40103303559, address: Republikas laukums 2A, Riga, LV-1010, Latvia. In order to receive a personal credit limit offer, we and AS Citadele banka Estonian branch will process your personal data.

    You have the right to withdraw your consent to receipt of notifications and offers at any time by writing to us at e-mail: privacy@citadeleleasing.ee. Upon withdrawal of consent, we will stop processing your personal data for the preparation and sending of commercial messages and offers. Withdrawal of consent (s) will not affect the lawfulness of processing of your personal data prior to withdrawal of consent.

    You can find detailed information on your rights, incl. the right of withdrawal, and processing of your personal data in the Privacy Disclaimer for Processing of Personal Data for Receipt of Notifications and Offers published on www.citadele.ee

  • 6 . How do we process your information when offering you insurance services?

    Insurance of the leasing object can be provided by several insurance service providers which cooperate with our partner – the insurance broker Smart Kindlustusmaakler AS. If we have received your consent or if it is necessary for the fulfilment of the terms of the agreement, we will transfer your personal data (name, surname, personal identity number, contact information) to the insurance broker Smart Kindlustusmaakler AS for receiving the leasing object insurance offer and processing of the leasing object insurance. The list of insurance companies with whom Smart Kindlustusmaakler AS shares information on you for the purpose of receiving insurance offers can be found on the website of Smart Kindlustusmaakler AS.

    You can withdraw your consent at any time by writing to us at e-mail: privacy@citadeleleasing.ee. Withdrawal of consent will not affect the lawfulness of processing of your personal data prior to withdrawal of consent.

  • 7 . How do we protect your information?

    We have implemented a strict policy for the use and access of IT infrastructure, which is based on the principles of "need to know" and less privileged access. We encrypt personal data, use firewalls, attack detection and prevention systems to ensure that all your personal data is confidential and secure. We regularly test our systems and review applicable policies to ensure that our IT security measures are one step ahead of all types of risks.

    We delete your personal data in accordance with the provisions of Section 2 of this Privacy Policy. If you have not reached the age of 18, but have completed the leasing application, our system will reject all information about you and will not store it.

  • 8 . What are your rights?

    We process your data, so you can find out what we do with it and how we process it. You may, upon written request, access, correct or delete your personal data, restrict processing, object to processing of such data and transfer them free of charge.

    However, if we find that your requests are recurring on a regular basis, are manifestly unreasonable or excessive, we will take into account the administrative costs associated with providing the information or communication or performing the requested action (including staff resources), we will charge you a reasonable fee for processing your request in accordance with the approved pricelist or we will refuse to fulfil your request by informing you in advance.

    In case of automated individual decisions, you have the right to request a reconsideration of such decisions by involving employees of AS Citadele banka Estonian branch and/or SIA Citadele Leasing Estonian branch in the decision-making. Such a request shall be made in writing to the Citadele Group company where you are a customer.

    SIA Citadele Leasing Estonian branch, registered in the Republic of Estonia under registration number: 11453650, address: Narva mnt 63/1, Tallinn 10120, Estonia, is responsible for your data processing. A certified personal data protection officer will answer all your questions regarding how SIA Citadele Leasing Estonian branch or other Citadele Group companies use your information. You can contact him/her by sending an e-mail to privacy@citadeleleasing.ee. Please describe the issue in as much detail as possible. You will receive an answer within 30 days.

    Our activities in the field of personal data protection are supervised by the Data Protection Inspectorate. Before you apply to the Data Protection Inspectorate for advice or a complaint, we recommend you to contact our personal data protection officer to ensure that your request is processed as soon as possible.