Principles of Personal Data Processing in AS LHV Pank User Research

Effective from: May 1, 2026

In the Principles of Personal Data Processing for User Research (hereinafter Principles), we explain how AS LHV Pank (registry code 10539549, Tartu mnt 2, 10145 Tallinn; hereinafter LHV) processes personal data as a data controller of participants in user research (hereinafter Participant).

  1. Purpose and Legal Basis for Personal Data Processing

    LHV collects the Participant’s personal data when the Participant registers to participate in user research through an LHV channel or through the market research company Norstat. By submitting data, the Participant gives consent for the processing of their personal data for the purposes and under the conditions described in these Principles.

    The processing of personal data is based on the Participant’s consent pursuant to Article 6(1)(a) of the General Data Protection Regulation (GDPR).

    The Participant has the right to withdraw their consent at any time by sending a corresponding notification to the e-mail address kasutajakogemus@lhv.ee. Consent is valid until its withdrawal, and the withdrawal of consent does not affect the lawfulness of personal data processing carried out prior to the withdrawal.

  2. Participation in User Research

    Participation in user research is voluntary, and the Participant has the right to withdraw from participation at any time. Research may include, for example, questionnaires, interviews, and testing of new prototypes or existing services. The method and format of research participation will be agreed upon separately with the Participant.

  3. Categories of Personal Data

    LHV may process the following personal data in the course of conducting user research:

    Categories of personal data Examples
    Contact data Name, e-mail address, phone number
    Demographic data Age group, preferred language of communication
    General client relationship data Information about LHV services that the Participant uses
    Device data Operating system (e.g. iOS, Android) used by the Participant
    Research content Responses, opinions, and feedback provided during research
    Research recordings Audio and screen video recordings created during research
    Technical information collected during user research Session recordings, clicks

    LHV does not collect or store special categories of personal data of the Participant in user research, except where the Participant’s special needs become apparent in audio or video recordings made during the research. In such cases, this data is processed solely for the purpose of conducting user research, including assessing the suitability of services and digital channels for persons with special needs, and it is not used for other purposes or stored in separate systems.

  4. Processing Activities and Data Retention

    Purpose Data retention period
    Selecting suitable participants and contacting them. Personal data is retained for a maximum of 18 months after the last contact or until withdrawal of consent.
    Development of services, products, and digital channels, and analysis of user experience. Audio and video recordings from research are retained for up to 18 months or until withdrawal of consent.

    Research results and summaries are prepared in anonymised form, meaning they cannot be associated with a specific individual. LHV may use anonymised data for statistical purposes indefinitely.

    The deletion of data collected during user research does not affect other retention periods arising from the nature of the client relationship between LHV and the client or from applicable legislation, whereby “client” is understood in the meaning set out in the LHV Client Data Processing Principles.

  5. Rights of the Data Subject

    The Participant has the right to receive information about the processing of their personal data and to receive copies of data, to request the correction or deletion of personal data, to restrict the processing of their personal data and to object thereto in cases provided by law, and to withdraw consent at any time. The Participant also has the right to file a complaint with the Data Protection Inspectorate.

  6. Contact Information

    For questions or to exercise rights related to personal data processing, please contact us by e-mail at kasutajakogemus@lhv.ee or by post at AS LHV Pank, Tartu mnt 2, 10145 Tallinn.

    The Participant may also contact LHV’s Data Protection Officer by e-mail at compliance@lhv.ee or by post at Tartu mnt 2, 10145 Tallinn.