🏦 Data controller, 🎯 purpose, and ⚖️ legal basis for the processing of personal data
🏦 Data controller, 🎯 purpose, and ⚖️ legal basis for the processing of personal data
Banca Transilvania S.A. (“the Bank,” “BT”) provides customers with a chatbot (“Chatbot”) through which they can request and obtain personalized information about the products and services they have contracted with the Bank, including the ability to modify certain related information (hereinafter referred to as “personalized banking information”).
To ensure that we provide such information only to authorized individuals, we have a legal obligation and a legitimate interest in verifying the identity of those who request it.
The more sensitive the requested banking information is, the stricter our verification process will be, as explained below.
🗂️ Personal data processed and what happens if you refuse their processing
🗂️ Personal data processed and what happens if you refuse their processing
In order for us to provide you with personalized banking information , you will need to enter your personal identification number (CNP), the phone number on file with the bank, and the unique identification code (SMS-OTP) that we will send you via text message into the Chatbot. We process this information both to verify that you meet the requirements to receive personalized banking information via the Chatbot (you are a BT customer, of legal age, and a resident) and to ensure that you are who you claim to be, so that we do not provide you with the requested information if you are not entitled to receive it.
Additionally, if you are a BT Pay user and meet the eligibility requirements (e.g., you have at least one card enrolled in this app and have completed the identification process in accordance with payment services legislation, either directly in BT Pay or at a BT branch) during alive chat conversationwith a BT employee—which you can initiate by accessing the “chat with a colleague” sections in the Chatbot—for certain types of banking information , you will be able to complete the identification process in BT Pay by accessing a push notification that we will send you.
If you do not have BT Pay, do not meet the eligibility requirements, or do not wish to be identified through the app, for certain types of personalized banking information that you request via the Chatbot, you will be able to either be identified by answering additional questions or by completing a remote identification process via video, without a human operator, provided you give your consent to do so.
In this case, foridentification purposes, we would process the following types of personal data, depending on the situation: (i) the information on your ID, which you will need to photograph in certain situations (this requires access to the camera). We will compare this information with the data in the bank’s records; (ii) amoving image of your facefrom the video selfie we will ask you to take in certain cases (requires access to the camera), (iii) facial biometric data, obtained by biometrically comparing the image from the selfie with the one from the ID document photographed in the Chatbot and/or with the image already on file with the bank. We will process your biometric data only if you give your explicit consent, whichwe will request in the Chatbot before performing such processing. Thebiometric comparisonis performed by analyzing relevant facial features using specific computational methods to uniquely confirm that the same person appears in the images. Following the biometric comparison, the IT solution indicates the probability that the face in the two images belongs to the same person. To give your consent to the processing of biometric data (facial recognition), you will need to select the “I explicitly consent to the processing of my biometric data” button in the Chatbot; if you refuse to have your biometric data processed, you will select the “I do not wish for my biometric data to be used” button .
If you refuse to allow us to process your data using the methods described above, or if we are unable to verify your identity through the chatbot, we will not be able to provide you with personalized banking information via this chatbot; however, you can obtain this information at any BT branch after verifying your identity with a valid ID.
⏳Retention period for personal data in chatbot conversations
⏳Retention period for personal data in chatbot conversations
We will retain your data processed for identification purposes in the Chatbot, along with the conversation with the agent, if applicable, for a period of 3 years.
📄 Further information about the processing of your personal data
📄 Further information about the processing of your personal data
This information notice is supplemented by the provisions of General Information Note on the Processing and Protection of Personal Data Belonging to BT Customers, which we recommend you review. It is an integral part of the BT Privacy Policy, which you can find on the bank’s website www.bancatransilvania.ro, including in the Privacy Hub section of the site. The General Information Note also includes the definition of a BT Customer, as well as details regarding the bank’s identification information, the recipients of BT Customer data, the rights you have regarding the processing of your data, how you can exercise those rights, and how you can contact the Data Protection Officer (DPO) designated by BT.
