🏦 Data controller and 👤data subjects
🏦 Data controller and 👤data subjects
Banca Transilvania S.A. ("Bank," "BT") informs you how it will process your personal data when you request, through the BT Pay mobile application ("Application" or "BT Pay"), the update of personal data ("personal data," "data") already registered with the bank.
This information note is for you if you are a BT customer who is an adult and want to update your details via the App.
🎯 Purposes and ⚖️ grounds for data processing
🎯 Purposes and ⚖️ grounds for data processing
When updating your data in BT Pay, we process your personal data for the following purposes:
(i) fraud prevention, in accordance with our legal obligations, based on legitimate interest and, where applicable, based on your explicit consent - before updating the requested data, we will verify your identity to confirm that you are the authorized BT Pay user and that the data you wish to update is yours (e.g., phone number, email address).
(ii)applying customer due diligence measures to prevent money laundering and terrorist financing - as a credit institution, BT has a legal obligation to apply customer due diligence measures. These measures involve verifying identity and processing personal data required by law, both at the time of becoming a BT customer (data collection) and throughout the entire period of customer status (data updating). Details on data processing for this purpose can be found in the dedicated information note.
🗂️ Personal data processed and what happens if you refuse their processing
🗂️ Personal data processed and what happens if you refuse their processing
In order to update data via BT Pay, we would process the following categories of personal data:
(i) a picture of your face, from the video selfie we'll ask you to take (requires access to your camera) and, if needed, from your ID, to check your identity
(ii) facial biometric data, only if you give your explicit consent (agreement) - we will ask for this agreement in BT Pay before we do any processing like this. Biometric data isobtainedby biometric comparison of the selfie image with that in the identity document already registered with the bank and, where applicable, with the DGEP (see here for details on the processing of data provided by the DGEP).
Biometric comparison is performed by analyzing relevant facial characteristics using specific computer methods to confirm that the same person appears in the images. Following the biometric comparison, the computer solution indicates the probability that the face in the compared images belongs to the same person.
(iii) data from your identity document - if you request to update your identity document registered with the bank, you will need to photograph it (this requires access to the camera). We will compare the information in it with that in the bank's records and with that in your document issued by the General Directorate for Personal Data Processing (D.G.E.P.) (see the previous point for details on the processing of data provided by D.G.E.P.).
(iv) the data you request to be updated – where applicable, identification data, image, contact details, professional data, data about BT products and services used.
You can find details about the categories and types of personal data we process for BT customers in section V of the General Information Note on the processing and protection of personal data belonging to BT customers
The data you update in BT Pay will also be updated for the services/products you use, such as sending account statements by email (if you have opted to receive them through this channel), for cards or SMS Alerts, for communicating with you (e.g., sending messages for the smooth running of the contractual relationship and, if you have given your consent, also for sending advertising messages).
If you refuse to allow us to process your data as described above, or if we are unable to verify/confirm your identity, you will not be able to update your data via BT Pay, but you can update it at any BT branch after identifying yourself with your ID.
📄 Further information about the processing of your personal data
📄 Further information about the processing of your personal data
This information note is supplemented by the provisions of the General Information Note on the processing and protection of personal data belonging to BT Customers, which we recommend you consult. It is an integral part of BT's Privacy Policy, which can be found on the bank's website www.bancatransilvania.ro, including in the Privacy Hub section of the website. The general information note also includes the definition of a BT Customer, as well as details about: the bank's identification data, all the purposes and grounds on which we process BT Customer data and the recipients and storage period of such data, automated decision-making processes, as well as your rights in relation to the processing of your data, how you can exercise them, and how you can contact the data protection officer appointed by BT (BT DPO).
