Terms and conditions for the use of LHV digital pension solution

  1. GENERAL TERMS

    1. The digital pension solution (hereinafter Digital Solution) of AS LHV Pank (hereinafter LHV) is a product designed for people with pension accounts and includes both the pension section at LHV’s public online environment and a mobile application. The Digital Solution can be used by all persons who have joined Estonia’s pension system and persons who have been authorised by the client (hereinafter Users).
    2. The Digital Solution is available for free download from the App Store and from Google Play. It can also be used online.
    3. You need an ID card, mobile-ID or Smart-ID to use the Digital Solution. Users will be granted access to the Digital Solution after identification.
    4. The Digital Solution functions through an internet connection, mobile data communication or WiFi. The mobile data communication fee is determined in the contract signed between the mobile operator and the User.
    5. LHV has the right to unilaterally change the Digital Solution’s terms of use at any time. Upon changes to the terms of use, the User must renew their consent to the terms of use in order to use the Digital Solution.
    6. The Digital Solution is not a financial or other counselling service. Please read and examine the terms and conditions of financial services, the fund prospectus and basic information and if necessary, consult a specialist.
    7. By logging into the Digital Solution, the User consents to LHV making an inquiry regarding the pension account of the User from AS Pensionikeskus.
    8. By Using the Digital Solution, the User confirms that they have read, understood and accepted these terms and conditions.
  2. PERSONAL DATA

    1. LHV processes the personal data of the User in accordance with the client data processing policy of LHV.
    2. By consenting to the terms of use of the Digital Solution, the User also consents to the processing of their personal data under the terms and conditions and procedure provided for in the client data processing policy of LHV. The client data processing policy can be found at www.lhv.ee
    3. Upon updating the contact information in the Digital Solution, the corresponding data shall also automatically be updated in the environment of AS Pensionikeskus.
    4. In order to meet the obligations established on account managers, LHV must store the personal data (e.g. name, personal identification code, logins, authentications, data of optional applications) of Users for up to 10 years starting from when they log in or from their submission of a pension application.
    5. The personal data of Users which LHV is not legally obliged to store shall be stored by LHV for up to one year from the last time the service was used (last login).
    6. By filling out the free fields of the Digital Solution, the User consents to the processing of the data entered in LHV for calculating pension forecasts or for other purposes specified in the Digital Solution. LHV processes the data until the withdrawal of consent but no longer that one year from the last time the service was used (last login).
  3. INFORMATION ON USE OF DIGITAL SOLUTION

    1. Users who have joined the Estonian pension system can monitor their pension account status and pension account data which have been entered in the pensions register maintained by AS Pensionikeskus regarding their pension account.
    2. Errors may occur in the forwarding of data, which may lead to situations whereby the information seen in the Digital Solution is not up to date.
    3. Data on the status of the User’s pension account, including its balance and fund NAVs, are taken from AS Pensionikeskus with every new session. In the event the data is not updated on a daily basis, the Digital Solution shall indicate the date of submission of the data. For example, the following indicators used for comparing pension funds are shown as at the end of the previous calendar month: number of active investors, percentage of investments in Estonia and the allocation of investments. Risk and profitability indicators are updated on a daily basis.
    4. In the Digital Solution, the percentages of the pension funds in the portfolio of the User are shown as approximate percentages which have been rounded up to integers.
  4. FILING AND HANDLING OF COMPLAINTS

    1. In the event that the User identifies any shortcomings in the Digital Solution or has other complaints pertaining to the Digital Solution, we ask that the User inform LHV by sending a message to info@lhv.ee.
    2. The purpose of handling complaints is to collect feedback from Users, their legal representatives and cooperation partners for ensuring satisfaction.
    3. All written complaints shall be replied to within a reasonable time, but no longer than 15 days after the registration of the complaint.
    4. Complaints shall be processed by a person determined by LHV who involves related persons.