Privacy policy
PRIVACY POLICY
Last updated: 26 August 2026
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GENERAL INFORMATION
VAULTS1 SIA, registration number 40203621534, registered address Latgales iela 257, Riga, LV-1019, Latvia (hereinafter – VAULTS1, we, us or the Data Controller), respects the privacy of its customers and visitors of the website www.seifunoma.lv and is committed to ensuring the protection of personal data.
This Privacy Policy explains:
• what personal data we process;
• for what purposes personal data is used;
• on what legal basis we process it;
• from which sources personal data is obtained;
• to whom personal data may be disclosed;
• how long the data is retained;
• how we use website analytics and advertising technologies;
• what rights you have in relation to your personal data.
Personal data is processed in accordance with:
• Regulation (EU) 2016/679 of the European Parliament and of the Council, the General Data Protection Regulation (GDPR);
• the Personal Data Processing Law of the Republic of Latvia;
• the Information Society Services Law;
• other applicable laws and regulations of the Republic of Latvia and the European Union.
This Privacy Policy applies to persons who:
• visit www.seifunoma.lv;
• reserve or rent an individual safe deposit box;
• create or use a customer account;
• use the VAULTS1 vault facility;
• order additional services;
• participate in the VAULTS1 Partnership Programme;
• contact us by telephone, email, through the website or other channels;
• consent to receive marketing communications;
• interact with our advertisements on Google, Facebook, Instagram or other platforms.
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DATA CONTROLLER
Data Controller: VAULTS1 SIA
Registration number: 40203621534
Registered address: Latgales iela 257, Riga, LV-1019, Latvia
Vault address: Brīvības iela 39, Riga, Latvia
Email: info@seifunoma.lv
Telephone: +371 20118020
Website: www.seifunoma.lv
For questions concerning the processing of personal data or the exercise of your data protection rights, you may contact us using the contact details provided above.
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PRINCIPLES OF PERSONAL DATA PROCESSING
When processing personal data, we comply with the principles established by the GDPR.
Personal data is:
• processed lawfully, fairly and transparently;
• collected for specific, explicit and legitimate purposes;
• processed only to the extent necessary to achieve the relevant purpose;
• kept accurate and, where necessary, up to date;
• retained no longer than necessary for the relevant purpose;
• protected by appropriate technical and organisational security measures.
We are responsible for complying with these principles and for being able to demonstrate such compliance.
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WHAT PERSONAL DATA DO WE PROCESS?
Depending on how you use our services, we may process the following categories of personal data.
4.1. Contact and communication data
When you contact us, we may process:
• first and last name;
• telephone number;
• email address;
• the content of your message or enquiry;
• correspondence history;
• other information you provide to us.
Purpose of processing: to respond to your questions, provide advice, prepare an offer and provide customer service.
Legal basis: Article 6(1)(b) GDPR – steps taken at your request prior to entering into a contract or performance of a contract; where necessary, Article 6(1)(f) GDPR – our legitimate interest in providing efficient customer service.
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SAFE DEPOSIT BOX RESERVATION AND CONCLUSION OF THE RENTAL AGREEMENT
When reserving or renting an individual safe deposit box, we may process:
• first and last name;
• birth details;
• personal identification number, where necessary;
• residential or correspondence address;
• telephone number;
• email address;
• identity document details;
• where necessary, a copy of the document, if there is a lawful basis for processing it;
• selected vault location;
• selected safe deposit box size;
• rental period;
• start and end dates of the agreement;
• payment information;
• contract number and information related to performance of the agreement.
If the agreement is concluded on behalf of a legal entity, we may additionally process:
• company name and registration information;
• first and last name of the legal entity’s representative;
• contact details of the representative;
• information and documents confirming the representative’s authority.
This information is necessary to identify the customer, conclude the agreement and provide the safe deposit box rental service.
Legal basis:
• Article 6(1)(b) GDPR – conclusion and performance of the agreement;
• Article 6(1)(c) GDPR – compliance with legal obligations applicable to VAULTS1;
• in certain cases, Article 6(1)(f) GDPR – VAULTS1’s legitimate interests, including service security and protection of legal interests.
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CUSTOMER ACCOUNT
If you use a customer account on www.seifunoma.lv, we may process:
• customer identification information;
• email address;
• authentication and account security information;
• safe deposit box rental information;
• contract status;
• payment information;
• Partnership Programme information;
• partner or discount codes used;
• information about actions performed in the account.
This data is used to create and manage the customer account, provide the service and maintain account security.
Legal basis: performance of the agreement and VAULTS1’s legitimate interest in ensuring the secure and convenient operation of the customer account.
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ACCESS TO THE VAULT
The VAULTS1 vault is accessible to customers 24 hours a day.
To ensure secure access, we may process:
• customer identification information;
• system information relating to the access code assigned to the customer;
• date and time of access;
• entry and exit registration data;
• access control system events;
• information about unsuccessful access attempts;
• other security system logs.
This data is processed in order to:
• ensure that only authorised persons can access the vault;
• prevent unauthorised access;
• protect customers, employees, premises and property;
• investigate security incidents.
Legal basis: Article 6(1)(f) GDPR – the legitimate interests of VAULTS1 and its customers in ensuring a high level of vault security, as well as performance of the agreement.
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VIDEO SURVEILLANCE
For security purposes, video surveillance is carried out in the VAULTS1 vault premises and related areas.
The purposes of video surveillance are:
• protection of persons and property;
• prevention of unauthorised access;
• prevention and detection of criminal offences;
• investigation of security incidents;
• preservation of evidence in the event of legal claims.
The following data may be processed through video surveillance:
• image of a person;
• location of the person;
• date and time of the visit to the vault;
• actions of the person within the monitored area.
VAULTS1 does not carry out video surveillance in the private customer area where the customer places items into or removes items from the safe deposit box.
Video surveillance recordings are retained only for as long as necessary to achieve the security purpose. If a recording is related to a security incident, possible criminal offence, legal dispute or request from a public authority, that specific recording may be retained for a longer period until the matter has been finally resolved.
Access to video surveillance recordings is granted only to authorised persons.
Legal basis: Article 6(1)(f) GDPR – VAULTS1’s legitimate interest in protecting persons, premises and property.
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CONTENTS OF THE SAFE DEPOSIT BOX
VAULTS1 provides customers with individual safe deposit boxes.
We do not systematically inventory the contents of customers’ safe deposit boxes and generally do not know what items are placed inside an individual safe deposit box.
No video surveillance is carried out in the private customer area where items are placed into or removed from the safe deposit box.
If information about specific property or its value is necessary for the provision of a particular service, handling an insurance claim, fulfilling a legal obligation or responding to a customer request, such information is processed only to the extent necessary for the relevant purpose.
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ADDITIONAL SERVICES
If you order additional services, such as a personal assistant service, we may process:
• customer’s first and last name;
• contact information;
• selected date and time;
• information about the service ordered;
• other information necessary to provide the specific service.
Legal basis: Article 6(1)(b) GDPR – performance of the agreement.
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PAYMENTS AND ACCOUNTING
When making payments for our services, we may process:
• payer’s first and last name or company name;
• payment amount;
• payment date;
• invoice information;
• transaction identification information;
• payment status;
• bank account information to the extent available to us;
• other personal data contained in accounting documents.
If payment is made through a bank, payment card or another payment service provider, the relevant information may also be processed by that service provider in accordance with its privacy policy.
Full payment card details are not stored in our systems where payment processing is provided by an independent payment service provider.
Legal basis:
• performance of the agreement;
• compliance with VAULTS1’s legal obligations in the areas of accounting and taxation.
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PARTNERSHIP PROGRAMME
If you participate in the VAULTS1 Partnership Programme, we may process:
• your customer identification information;
• the partner code assigned to you;
• information about use of the partner code;
• the amount of discounts accumulated;
• information about the use of discounts.
The Partner is not provided with another customer’s personal data solely because that customer used the Partner’s code.
Legal basis: performance of the terms of the Partnership Programme and the agreement concluded with the customer.
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WEBSITE VISIT DATA
When you visit www.seifunoma.lv, we and the technology service providers we use may receive technical information such as:
• IP address;
• device type;
• browser type and version;
• operating system;
• approximate geographic location;
• date and time of the visit;
• pages visited;
• actions performed on the website;
• duration of the visit;
• information about the website or advertisement from which you arrived at www.seifunoma.lv;
• advertising campaign identifiers;
• cookies and other online identifiers;
• information about a booking, enquiry or other conversion action performed.
The legal basis for processing this data depends on the technology used.
For essential technologies, the legal basis may be our legitimate interest or the necessity to provide the service requested by you.
For analytics and advertising technologies that require consent under applicable legislation, the legal basis is your consent.
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COOKIES AND SIMILAR TECHNOLOGIES
www.seifunoma.lv uses cookies, pixels, tags and similar technologies.
These may include:
Strictly necessary cookies
Required for website operation, security, the booking process, the user session and saving your cookie preferences.
Consent is not required for such cookies where they are objectively necessary to provide the service requested by you.
Analytics cookies
Help us analyse website usage and improve its operation.
They are used only after obtaining your consent, where such consent is required.
Advertising and marketing cookies
May be used to measure advertising campaigns, track conversions, create advertising audiences, carry out remarketing and provide personalised advertising.
They are activated only after obtaining your consent, where such consent is required.
Detailed information about cookies is provided in our Cookie Policy and in the “Cookie Settings” section of the website.
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GOOGLE ANALYTICS AND GOOGLE ADS
We may use Google services on the website, including Google Analytics, Google Ads and Google Tag Manager.
Google Analytics may help us analyse:
• the number of website visits;
• pages visited;
• duration of visits;
• the user journey through the website;
• advertisements and other sources from which visitors arrive at the website.
Google Ads may be used for:
• evaluating advertising campaign results;
• measuring conversions;
• creating advertising audiences;
• remarketing;
• advertising personalisation, where you have consented to it.
Where a particular Google technology requires your consent, it is used only after your consent has been obtained.
Your cookie preferences may also be communicated to Google through appropriate consent status signals.
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META, FACEBOOK AND INSTAGRAM
For advertising and measuring advertising effectiveness, VAULTS1 may use Meta Platforms technologies, including Meta Pixel and Facebook and Instagram advertising tools.
After obtaining your consent, these technologies may be used for:
• evaluating advertising effectiveness;
• measuring conversions;
• determining whether a user visited our website after interacting with an advertisement;
• creating advertising audiences;
• remarketing;
• displaying more relevant advertising.
Meta may receive technical information about your device and browser, IP address, online identifiers and information about actions performed on the website.
Meta may also process this data in accordance with its own privacy policy.
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DIRECT MARKETING
If you have given consent to receive VAULTS1 news, offers or other commercial communications, we may use:
• your name;
• email address;
• telephone number;
• information about your interest in specific VAULTS1 services.
Consent to marketing is voluntary.
You may opt out of further marketing communications at any time:
• by using the unsubscribe link in an email;
• by writing to info@seifunoma.lv;
• by using another opt-out method indicated in the relevant communication.
Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
Where permitted by law, we may also send existing customers information about similar VAULTS1 services, always providing a clear opportunity to opt out of further commercial communications.
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FROM WHICH SOURCES DO WE OBTAIN PERSONAL DATA?
We may obtain personal data:
• directly from you;
• from your representative;
• from your employer or the legal entity you represent;
• from public state or company registers;
• from payment service providers;
• from our access control and security systems;
• from the website and technologies used on it;
• from advertising and analytics platforms;
• from other sources where obtaining such data is permitted by law.
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TO WHOM MAY WE DISCLOSE PERSONAL DATA?
We disclose personal data only where there is a lawful basis and where this is necessary for a specific purpose.
Recipients or processors of personal data may include:
• website and IT infrastructure maintenance providers;
• hosting and data centre service providers;
• software and customer management system providers;
• access control and security system providers;
• payment service providers and banks;
• accounting and audit service providers;
• insurance companies where involved in the provision of a service or handling of an insurance claim;
• legal service providers;
• debt collection service providers, where necessary;
• advertising and marketing service providers;
• companies within the Google group;
• companies within the Meta group;
• companies within the VAULTS1 group, where necessary for the provision of a specific service or administrative function and where there is a lawful basis;
• state and municipal authorities;
• law enforcement authorities;
• courts;
• other persons where disclosure is required by law or necessary to protect our legitimate interests.
Where a service provider processes personal data on our behalf, we impose appropriate personal data security and confidentiality requirements.
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TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
Some of the technology or other service providers we use may belong to international corporate groups, and therefore in certain cases personal data may be processed outside the European Economic Area.
In such cases, we ensure that the transfer of data is carried out in accordance with GDPR requirements, for example on the basis of:
• an adequacy decision adopted by the European Commission;
• an applicable data transfer mechanism recognised by the European Commission;
• Standard Contractual Clauses approved by the European Commission;
• other safeguards provided for under the GDPR.
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PERSONAL DATA RETENTION PERIODS
Personal data is not retained longer than necessary for the purpose for which it was obtained.
When determining the retention period, we take into account:
• the duration of the service and the agreement;
• statutory document retention periods;
• limitation periods for the protection of potential claims;
• the need to investigate security incidents;
• the specific purpose of personal data processing;
• the validity of your consent.
For example:
• customer contract data is retained during the term of the agreement and after its termination for as long as necessary to comply with legal obligations and protect potential claims;
• accounting documents are retained for the period prescribed by law;
• customer enquiries are retained for as long as necessary to process them and protect related legitimate interests;
• data relating to consent for direct marketing is retained until consent is withdrawn and for a reasonable period thereafter in order to demonstrate the fact of consent or withdrawal;
• retention periods for cookies and online identifiers are specified in the Cookie Policy or Cookie Settings;
• video surveillance recordings are retained only for the period objectively necessary for security purposes, unless a specific recording is required for the investigation of an incident or legal dispute.
After the retention period ends, the data is securely deleted or anonymised.
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PERSONAL DATA SECURITY
Given the nature of the services provided by VAULTS1, we pay particular attention to the protection of personal data and physical security.
We apply appropriate technical and organisational measures to protect personal data against:
• unauthorised access;
• unlawful use;
• unauthorised disclosure;
• accidental loss;
• alteration;
• damage;
• destruction.
Access to personal data is granted only to employees and service providers who need the relevant information to perform their duties or provide the service.
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SPECIAL CATEGORIES OF PERSONAL DATA
The provision of VAULTS1 services generally does not require the processing of special categories of personal data referred to in Article 9 GDPR, such as health information or information concerning religious beliefs, political opinions or sexual orientation.
Please do not provide us with such information unless it is necessary to resolve a specific matter.
If, in a particular situation, processing of special categories of personal data is nevertheless necessary, such processing is carried out only where an appropriate legal basis under Article 9 GDPR exists.
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AUTOMATED DECISION-MAKING AND PROFILING
Following your consent, website advertising and analytics technologies may be used for limited profiling, for example to determine a person’s possible interest in VAULTS1 services and include them in a particular advertising audience.
VAULTS1 does not make decisions based solely on automated processing of personal data that produce legal or similarly significant effects for you, unless expressly provided for and permitted by applicable legislation.
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YOUR RIGHTS
Under the GDPR, you have the following rights:
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Right to information and access to your personal data
You may request information about whether we process your personal data and obtain a copy of that data.
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Right to rectification
If your personal data is inaccurate or incomplete, you have the right to request that it be corrected or completed.
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Right to erasure
In the cases provided for by the GDPR, you have the right to request the deletion of your personal data.
This right is not absolute. For example, we cannot delete information that we are legally required to retain.
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Right to restriction of processing
In the cases provided for by the GDPR, you have the right to request restriction of personal data processing.
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Right to object to personal data processing
Where personal data is processed on the basis of our legitimate interests, you have the right to object to such processing.
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Right to object to direct marketing
You have the right to object at any time and without giving reasons to the use of your personal data for direct marketing purposes, including related profiling.
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Right to withdraw consent
Where processing is based on your consent, you may withdraw it at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
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Right to data portability
In the cases provided for by the GDPR, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and transmit it to another controller.
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Rights relating to automated decision-making
In the cases provided for by Article 22 GDPR, you have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects for you.
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HOW TO EXERCISE YOUR RIGHTS
To exercise your rights, please contact VAULTS1:
Email: info@seifunoma.lv
or in writing:
VAULTS1 SIA
Latgales iela 257
Riga, LV-1019
Latvia
To protect your personal data, before fulfilling your request we may need to verify your identity.
We will respond to your request without undue delay and generally no later than one month after receiving it.
In the case of complex or multiple requests, the GDPR allows this period to be extended by an additional two months. In such a case, we will inform you of the extension and the reasons for it.
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RIGHT TO LODGE A COMPLAINT
If you believe that your personal data is being processed improperly, we encourage you to contact us first so that we can resolve the matter.
You also have the right to lodge a complaint with the Latvian data protection supervisory authority:
Datu valsts inspekcija
Elijas iela 17
Riga, LV-1050
Latvia
Email: pasts@dvi.gov.lv
Telephone: +371 67223131
You also have the right to apply to the competent court or the data protection supervisory authority of another European Union Member State in the cases provided for by the GDPR.
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MINORS
The individual safe deposit box rental service is not intended for persons who, under applicable legislation, are not entitled to independently enter into the relevant agreement.
VAULTS1 does not knowingly collect children’s personal data for marketing purposes.
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THIRD-PARTY WEBSITES
www.seifunoma.lv may contain links to third-party websites, social networks or other services.
VAULTS1 does not control the processing of personal data carried out by such third parties.
Before using such services, we recommend reviewing the privacy policy of the relevant service provider.
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CHANGES TO THE PRIVACY POLICY
VAULTS1 may periodically update this Privacy Policy, for example where:
• our services change;
• new website functions are introduced;
• technology or service providers change;
• legal requirements change;
• our personal data processing activities change.
The current version of the Privacy Policy is always available at www.seifunoma.lv.
The date of the latest update is indicated at the beginning of the Policy.
If the changes materially affect the processing of your personal data, we will inform you in an appropriate manner.
VAULTS1 SIA
Registration No. 40203621534
Latgales iela 257, Riga, LV-1019, Latvia
Vault: Brīvības iela 39, Riga
Email: info@seifunoma.lv
Telephone: +371 20118020
www.seifunoma.lv