Information notice on the processing of personal data for the purpose of updating customer information by BT Pay

Banca Transilvania, S.A., (hereinafter also referred to as "the bank", "BT"), in its capacity as a credit institution, has a legal obligation to apply customer due diligence measures in order to prevent money laundering and terrorist financing, for the performance of a task that serves a public interest. When you become a BT customer the natural person holding an account or a representative of such a customer (legal representative, conventional representative, authorised representative on accounts) we collect from/about you information for this purpose, such as, as the case may be: name, surname, pseudonym, date and place of birth, personal numerical code or other similar unique identifier, citizenship, domicile, residence, address at which you live and its legal status, telephone number, fax number, electronic mail address (e-mail), occupation, name of employer or nature of own activity, purpose and nature of business relationship with the bank, the source of funds to be used in the business relationship, whether you are a publicly exposed person or a family member of a publicly exposed person or a person known to be a close associate of a publicly exposed person (PEP), and details and copy of your identity card.

We need to ensure that this information is kept up to date in our records throughout the course of the business relationship. Therefore, whenever any of this information changes, you need to change it at the bank. From time to time, even if the data has not changed, we will ask you to reconfirm it so that we can be sure it has not changed.

You can update all the data set we need about you for the application of customer insight measures in any BT unit. For updating some of this data, we offer online solutions, such as BT Pay.

Updating data in BT Pay is allowed for major customers who have been identified as BT account holders at the time of registration in BT Pay.

To update your data you will need to upload a copy of your ID (you will not be able to update your personal data via BT Pay if the expiry date on the ID you are inserting is older than the date you are trying to update).

To make sure that we only update/reconfirm your data and to prevent possible fraud attempts, we would apply a new technology, using so-called biometric data, to your image in the ID uploaded to BT Pay. However, we will not be able to use this data without your explicit consent. Before you decide freely whether you want to give your consent, here's what using your biometric data entails: the IT solution we use will identify the section of your uploaded ID picture that contains your face, select it and then compare it with the face in the copy of your ID that is already on file with BT Pay. The comparison is made biometrically, based on criteria such as the colour, size and slant of your eyes, the position and distance between the main features of your face such as your eyes, eyebrows, lips and nose. Following the comparison, the computer solution will give a confidence score, indicating the likelihood that the faces in the two images belong to the same person. If you do not want your biometric (facial identification) data to be processed, you can update your data at any BT unit, where your identity will be verified without the use of biometric data.

Also, if the Facial Recognition tool gives an unsatisfactory confidence score, you will be able to restart the update process in a BT unit.

If after following the above steps you convince us that it is you, you will be able to update some of your customer data online. But if you haven't passed this little test, there's no problem, you can update your data in full at any BT unit.

To help you in the updating process, some of the data in it will be automatically retrieved (through the optical character recognition process), while the rest of the data you will select from a list of values or insert yourself.

One of the details you will need to fill in is your email address. To make sure it belongs to you, you will need to confirm it. You will therefore receive a code on the email address you enter, which you will need to enter in a dedicated BT Pay field.

You will then need to check that the data is correct and amend it accordingly if necessary. If you complete the update, even though you find that the data has been taken over/ filled in incorrectly, you risk being guilty of misrepresentation and you certainly don't want that. If you fail to change the errors, quit the online flow and come into the unit.

Please note that BT Pay does not allow you to change your mailing address. So, if your home address that you update/confirm via this channel is different from the mailing address that you have declared to the bank, you will need to update your mailing address separately by contacting a BT unit or by other methods of updating your details with BT available online.

This information note is supplemented by the provisions of General information notice on the processing and protection of personal data of BT customerswhich we recommend that you consult. It is an integral part of BT Privacy PolicyPrivacy Policy, which you can find on the bank's website www.bancatransilvania.ro.

The BT Privacy Policy includes the definition of a BT Customer, as well as details about the recipients of BT Customer data, your rights in relation to the processing of your data, how you can exercise them or how to contact the BT Data Protection Officer (BT DPO).