Terms of Use of the Online Platform SmartDeposit. AS Expobank Privacy and personal data protection policy


Terms of Use of the Online Platform SmartDeposit


1. General Conditions.


1.1 These terms of use (hereinafter – “the Terms of Use”) stipulate the procedure of use of the website www.smartdeposit.lv and the Platform available on the website (hereinafter – "the Platform”). The Platform is a technological online solution, by which Expobank performs:


1.1.1. assessment of applications for placement of term deposits with Expobank;


1.1.2. remote user identification;


1.1.3. verification of received documents and required information before signing a term deposit agreement and acceptance of funds at Expobank;


1.1.4. conclusion of distance agreements on placement of term deposit with Expobank;


1.1.5. receipt of consent for marketing activities.


1.2. AS Expobank, registration No. 40003043232, address: Krišjāņa Valdemāra iela 19, Riga, LV-1010, in these Terms of Use - Expobank, is the owner of the website smartdeposit.lv, ensures the content available on the website and provides term depositing services in accordance with the Terms of Use. Expobank holds the intellectual property rights, copyright, trade marks and other ownership rights concerning the said website or the information posted on the website. Reproduction, distribution, modification or supplementing of the information posted on smartdeposit.lv website is prohibited without receiving prior written consent of Expobank.  In case of quoting the information posted on smartdeposit.lv, a reference to Expobank as the holder of copyright is obligatory.

Expobank is entitled to suspend operation of smartdeposit.lv or separate sections of the website due to website maintenance and improvement works.


1.3. The User is an adult and legally capacitated natural person, who uses services provided on smartdeposit.lv.


1.4. If the User has registered his/her profile on smartdeposit.lv Platform, it shall be considered that the User has become acquainted with these Terms of Use and agrees to observe them. When registering his/her profile on the Platform, the User confirms that he/she has the right to register and use the term depositing services offered smartdeposit.lv.


1.5. If the User attempts to cause harm to smartdeposit.lv operation, stability, security, or otherwise fails to observe these Terms of Use, Expobank is entitled to cancel the User's registration on the Platform or otherwise restrict the User's access to the Platform.


1.6. Expobank reserves the right to amend and supplement these Terms of Use unilaterally. When the User places term deposits through the Platform, the Terms of Use that are effective at the moment of provision of the service and conclusion of the distance term deposit agreement shall apply.


1.7. Expobank reserves the right to change interest rates of term deposits. Term deposits are placed according to interest rates that are effective at the moment of conclusion of distance term deposit agreement.


1.8. While visiting smartdeposit.lv, Expobank may register the visitor's information, using cookies. The Bank may register the visitor's information regarding the date and time of visiting the website, the browser used by the visitor, the visitor's IP address and other information. More detailed information on cookies is available here.


2. Protection of personal data.


2.1. Expobank ensures the use and protection of the User's personal data in accordance with Expobank Privacy and Personal Data Protection Policy, which is available here. The User confirms that he/she has read Expobank Privacy and Personal Data Protection Policy and agrees to observe it.


 2.2. A term deposit agreement can be concluded only by registered Users. Prior to conclusion of term deposit agreement, the User shall fill in an application form and complete remote identification.


2.3. The User is fully liable for correctness of provided data. If the User has indicated inaccurate data in the registration form, Expobank does not assume any liability for inaccuracy of the data and any arising consequences, and is entitled to request compensation of direct loss from the User.


2.4. By agreeing to these Terms of Use, the User agrees that notifications necessary for conclusion and performance of term deposit agreement will be sent to the indicated e-mail address.


2.5. The User's data will be used for provision of the term deposit service and may be used for direct marketing purposes, if the User's consent is received.


2.6. Expobank undertakes not to disclose the User's personal data to third parties, except partners of Expobank, who provide services related to the User's identification and verification of data provided by the User.


3. Creation of the User's profile, filling in the registration form, User's remote identification.


3.1. A person, who wishes to use the term deposit services, shall create a User's profile (hereinafter – “the Profile”). During the Profile creation process, the User shall indicate his/her e-mail address and/or phone number, existence of which shall be confirmed by the User by using Google authenticator (Google Authenticator) (the User shall enter the confirmation code within 30 seconds).


3.2. After creation of the Profile, the User shall fill in the application form (hereinafter – “the Form”) for placing a term deposit with Expobank. If it follows from the information indicated by the User in the Form that the User has not reached the age of 18 yet, further filling in of the Form is impossible and it cannot be submitted to Expobank for examination.


3.3. For the User to be able to submit a completed Form to Expobank through the Platform, the User shall complete remote identification. For this purpose, an outsourcing solution iDenfy, created by the Lithuanian company UAB “Identifikaciniai projektai” (registration number: 304617621; legal address: Kaunas, Gričiupio g. 7-212), is integrated on the Platform through API.


3.4. The User's remote identification process on the Platform (the personal identification and verification time is approximately 60 seconds until returning of the results to the User):


3.4.1. the User shall from his/her device (smartphone, tablet PC or stationary computer), on which the Form has been filled in for submission to Expobank, by using a built-in or connected digital camera, connect to iDenfy app on the Platform;


3.4.2. on the menu, the User shall select the type of identification document (ID card or passport), which will be used for the identification and verification process. It is followed by an instruction on how the identification document should be placed in front of the camera;


3.4.3. pictures of the front and back of the identification document are taken, using iDenfy app;


3.4.4. this step is followed by an instruction on how to take a selfie;


3.4.5. after taking a selfie, photos of the identification document (both sides), accompanied by the User's selfie, are submitted to iDenfy for identification and verification of the User;


3.4.6. after receiving a positive status from iDenfy server, the User is considered an identified and verified person (the Form is submitted to Expobank).


3.5. The User's taken real-time photo of the identification document and the User's selfie are automatically encrypted and sent (streamed) to iDenfy servers for identification and verification of the person.


3.6. The biometric technology is used for the User's remote identification and verification, which compares the taken User's photo to the biometric data and other information included in the User's identification document.


3.7. The identification and verification process is carried out according to an algorithm developed by iDenfy.


3.8. For Expobank to be able to verify validity of the User's identification document, the Platform is connected to the database of the Invalid Document Register of the Republic of Latvia through API.


3.9. For Expobank to be able to verify the User's declared income, the Platform is connected to the database of the State Revenue Service (hereinafter – SRS), using API. The obtained User's data are subject to an automatic analysis according to a scenario (algorithm) integrated into the Platform, the results of which are used to determine, whether the information indicated in the Form about the User allows:


3.9.1. automatic term deposit contract conclusion process (the User is offered on the Platform to conclude a distance agreement on placement of term deposit with Expobank) or;


3.9.2. manual process (in-depth analysis of the information indicated in the Form is required before offering to the User a distance agreement on placement of term deposit with Expobank) or;


3.9.3. rejection (provision of the service to the User is rejected).


3.10. Expobank does not perform remote identification of the User, terminates it or applies other statutory measures for remote identification of the User, if:


3.10.1. any circumstances are established, which show that remote identification does not correspond to the money laundering and terrorism and proliferation financing risk inherent to the User;


3.10.2. any circumstances are established, which show insufficiency of security and suitability of the remote identification process and truthfulness of the obtained information;


3.10.3. non-conformity to the information obtained during the User's due diligence is established.


3.11. Requirements of due diligence of Customers concerning Users are fulfilled, observing the conditions of Expobank Customer Policy, the Money Laundering and Terrorism and Proliferation Financing Risk Management Policy and the Sanctions Compliance Policy.


3.12. After commencement of business relations, Expobank shall perform monitoring of customer transactions, including checks that confirm that transactions concluded during business relations are implemented in accordance with the available information on the customer, risk profile and origin of funds, and shall ensure storage, regular assessment and updating of documents, personal data and information obtained over the course of the customer's due diligence.


4. Conclusion of distance term deposit agreement.


4.1. In the instances mentioned in Paragraphs 3.9.1 and 3.9.2, the User receives in his/her Profile an offer to conclude s distance term deposit agreement (hereinafter – “the Term Deposit Agreement”), which is automatically generated by the Platform, using the data indicated in the User's Form and applying the Term Deposit Agreement conditions offered by Expobank. The Term Deposit Agreement is considered signed by Expobank at the moment, when the User receives it on the Platform with an offer by Expobank to sign it.


4.2. If the User accepts the conditions of the Term Deposit Agreement, he/she shall sign it, using the electronic tool – Google Authenticator – offered on the Platform. If Google authentication code is entered successfully, the Term Deposit Agreement shall be considered as signed. After conclusion of the Term Deposit Agreement, the User is obliged to transfer the amount of term deposit in accordance with the conditions of the Term Deposit Agreement. If the User fails to fulfil the liabilities stated in this Paragraph, the Term Deposit Agreement becomes void.


4.3. No amendments to the effective Term Deposit Agreement are allowed during the term deposit period.


5. Performance and termination of the Agreement.


5.1. During the period of the Term Deposit Agreement, Expobank shall calculate and account the interest on the term deposit pursuant to the procedure specified in the Term Deposit Agreement. After termination of the Term Deposit Agreement, Expobank shall disburse the amount of term deposit and the interest to the User, deducting the statutory taxes and transferring them into the state budget.


5.2. The User is entitled to terminate the Term Deposit Agreement, using the statutory right of withdrawal within 14 (fourteen) days from the moment of acceptance of the term deposit, filling in the Withdrawal Form on the Platform.


5.3. In case of early termination of the Term Deposit (including if the Customer exercises the right of withdrawal), no interest is disbursed to the User.



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