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    Information on the processing and protection of personal data in the context of the provision of the BT 24 Internet and Mobile Banking service (extract from the Terms and Conditions)

  • Chap. XI. CONFIDENTIALITY. PROCESSING AND PROTECTION OF PERSONAL DATA

    11.1 The Parties undertake to impose an obligation of confidentiality on all their employees who have access to confidential information as a result of their work. 

    11.2. The Bank shall keep confidential the information regarding the Client's accounts and the operations ordered by the Client or his authorized representatives and shall not disclose them without the Client's consent except in the cases expressly mentioned in the applicable legislation in force. 

    11.3. When you use the BT24 Internet/ Mobile Banking service, Banca Transilvania, as the operator, processes your personal data as follows:

    What data we collect to identify/authenticate BT24 users

    11.3.1 In order for individuals to be able to use BT24, it is necessary for us to verify their identity, i.e. to verify that they are authorized users of this service, in accordance with our obligations under payment services legislation and because we have a legitimate interest in preventing fraud. This identification is made on the basis of a BT24 login ID (hereinafter referred to as 'user ID') and a password. The password required for the first login is the one sent by SMS to the telephone number declared by the user to the bank. Unique codes (SMS-OTP, one time password) will be sent to this phone number for each login and for some transactions, together with messages about the transaction. If the user is using the mobile version of BT24 and logs into the app with biometric data (e.g. fingerprint, face-ID), please note that BT does not have access to this information, it is stored on the user's device. BT only obtains information as to whether or not the authentication method has been validated by the device used.

    What data we collect to ensure BT24 security

    11..3.2. In order to be able to protect your log-in data and other information in BT24, we also need to process information about your geographical location and the devices with which you access BT24 (as applicable, model, operating system and version, RAM memory, total bandwidth, type of connection used - WI-FI or mobile data, including the operator from which you use mobile data, device identifier such as device ID or IMEI depending on the device operating system and version, including the history of devices used, i.e. date of addition/deletion in BT24). We process this data both because payment services legislation obliges us to put in place monitoring mechanisms to enable us to identify unauthorized or fraudulent payment transactions and because we have a legitimate interest in preventing fraud. 

    In order to prevent fraud, as required by law and in our legitimate interest, we check the device you connect with for malware, including applications such as remote/remote login. While using the app, if you are making transactions, we also check whether the device is or has recently been used for calls, but we do not find out details of the numbers/persons you have used. If such applications/situations or other instances are identified that suggest a compromise of your user accounts in other applications offered by BT, we will block your access to use BT24 on the potentially compromised device. This blocking is an individually automated decision that we make based on legal obligations placed on us.

    Last but not least, we are required by applicable payment services legislation to monitor transactions to prevent fraud. If we detect transactions that are suspected of fraud, we may take the decision to block their processing.

    We process this data to protect the information in BT24. If you refuse processing, you will not be able to use BT24.

    What data we process when using BT24

    11.3.3 In order to provide you with the BT24 service contracted from BT and because we have a legitimate interest in sending messages in connection with that service, we use: 

    11.3.3.1 Account, card and transaction data 

    When you will use the different functionalities of BT24 we will process data related to: bank accounts (of the BT24 contracting customer and of the payees), cards attached to the accounts opened with BT, transactions ordered by accounts (payments/collections), as well as information in the nature of personal data of the BT24 contracting customer, of the user who uses the service and/or of other persons (such as payees, persons whose data is entered in BT24 fields for specific payments, e.g. data entered in transaction explanation fields, data entered in fields used to define predefined payees, data entered in messages sent via BT24 secure messaging. 

    11.3.3.2 Contact dates 

    If the SMS-OTP log-in method is used, we will use the telephone number to send messages about transactions initiated via BT24, including codes on the basis of which the user approves the transactions (where applicable). We may use the telephone number or e-mail address to inform/request further information from the customer or user about transactions initiated from BT24 or to prevent fraud attempts (e.g. phishing). We will also use the secure messaging inbox to send various informational messages related to BT and/or the bank's products and services (e.g. messages about changes to the GIP, Privacy Policy, bank unit opening hours or possible malfunctions of some of the bank's systems, non-banking working days, etc.). In case of sending documents such as account statements, proof of payment or rovinettes, we will process the e-mail address entered in the dedicated field. The e-mail address may belong to the user/customer or to third parties. BT is not responsible for the provision of incorrect addresses which may lead to the disclosure of the data contained in the banking documents to unauthorized persons, nor for the fact that the persons to whom the user has chosen to send these documents are annoyed by the receipt of the message (they believe they should not have received it). 

    11.3.3.3. Camera, geolocation and other permissions 

    The use of certain functionalities of the BT24 mobile application is allowed only after the user has accepted the permissions: Camera (access to the camera being requested only when using the option to scan the barcodes of the invoices), Location (accurately checked in the "Locations of units and ATMs" section to display the nearest Banca Transilvania units and ATMs), Contacts (their list is opened only when accessing the Email/SMS Payments to automatically fill in the beneficiaries' details), Status and Phone ID (device ID or, where applicable, IMEI is required to activate the mobile application). To use BT24 mobile functionality that requires access to the device's camera (e.g. barcode scanning for bill payments) the user will be asked if they agree to allow that access. If they do not agree, they will not be able to use that functionality. 

    11.3.3.4. Beneficiary Name Display Service (BNDS) 

    For the provision of the Payee Name Display Service (SANB) in order to prevent fraud in the case of interbank payments initiated from payment/internet banking applications, your personal data is processed as detailed in the Information Notice on the processing of personal data within the Payee Name Display Service (SANB).

    In order to prevent fraud in the case of intra-bank payments initiated from its own payment/internet banking applications, BT processes - as an independent controller - the same categories of personal data that are also used within SANB, but without the involvement of other participating banks and without the involvement of Transfond. The basis for the processing of your data is BT's legitimate interest in preventing fraud in intra-bank payments (BT-BT). Your first name (one or more, as appropriate) in full and the initial of your surname registered with BT will be displayed to other BT customers who initiate from a BT application a payment to your account. BT, whether the payment is completed or not. 

    To whom we may disclose data as a result of using BT24

    11.3.4.

    • other BT Customers who have a right and need to know:
      • BT24 users (all BT24 users are BT Customers) If the customer grants BT24 user rights to others on all or some of their BT accounts, we will disclose to them - within BT24 - the banking data (accounts, transactions, account and transaction identifiers etc) corresponding to the accounts they have been granted BT24 user rights on. 
      • BT customers to whom you order payments from BT24 When you make transactions via BT24 to the accounts of other BT customers, the details of these transactions (usually first name, surname, amount, BT account IBAN, payment explanations) will be accessible to the payees to whom you have made the payment. 
    • contractual partners (service providers) used in BT's business 

    BT24 allows you to purchase goods and services from the bank's contractual partners. If you use these functionalities, the data necessary to purchase/activate these services is disclosed to these partners (these partners are also BT Customers). Personal data processed in BT24 may also be accessed, on a need-to-know basis and only on the basis of appropriate personal data protection safeguards, by the bank's contractual partners who support us in providing the Internet/Mobile Banking service. The above list of recipients is supplemented by the list set out in the General Information Notice on the processing and protection of personal data belonging to BT Customers, section VIII. 

    How long we keep data processed in the context of accessing/using BT24

    11.3.5 Your data, as a BT customer, as well as the data relating to the operations carried out through the accounts (including through BT24) are subject to the retention regime provided for by the applicable regulatory acts, being at least 5 years from the termination of the business relationship with the bank/termination of your status as a BT customer, unless longer legal terms are applicable, which can be up to 10 years from the end of the business relationship/termination of your status as a BT customer. 

    What rights data subjects are entitled to

    11.3.6. According to the General Data Protection Regulation ("GDPR"), individuals whose personal data is processed in the context of accessing/using BT24 are guaranteed the following rights: the right to be informed (we fulfill our obligation to inform data subjects of the processing by this information notice), the right of access, the right of rectification, the right to erasure, the right to restriction of processing, the right to data portability, the right to object, the right to apply to the National Authority for the Supervision of Personal Data Processing (ANSPDCP) and to justice. Details of these rights and the ways in which they can be exercised can be found in the General Information Note on the processing and protection of personal data belonging to BT Customers, available on the website bancatransilvania.ro, including in the Privacy Hub section of the website and, on request, at any of the bank's branches. 

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    AI Search provides automatically generated answers, using GPT-4o technology, which may contain inaccurate or potentially offensive content that does not represent the views of Banca Transilvania. You are solely responsible for your use of the content generated by this service. .
    Terms and conditions

    Disclaimer

    AI Search is a pilot project - in beta - that uses GPT-4o technology to simplify the process of finding and understanding banking products.

    AI Search is trained to answer questions that are exclusively related to the banking products offered by BT, but in certain situations and depending on the questions asked, it may also answer general questions. The answers provided are automatically generated and are to be used for information purposes only. The service may sometimes provide inaccurate or potentially offensive content, which does not represent the views of Banca Transilvania. You are solely responsible for your use of the content generated by this service in any way. Do not rely on this service for financial, legal or other professional advice and do not enter personal data or other confidential information into this service.

    Use of AI Search implies acceptance of the Terms and Conditions.

    Access to and use of the service implies your unreserved acceptance of these terms and conditions. If you do not agree to them, please do not use this service. By accepting the terms and conditions to use this service provided algorithmically by an artificial intelligence model, you assume the entire risk as to the quality, safety and performance of this service.

    Banca Transilvania does not provide any guarantee in relation to the answers provided by this service.

    AI Search provides responses algorithmically and these may sometimes contain inaccurate information or potentially offensive language. This information does not express the position of Banca Transilvania and cannot engage the responsibility of the Bank for the content provided.

    AI Search does not provide answers to personalized questions, so by using it you are obligated not to provide or enter any personal data or other confidential information in your messages/questions. In case you do not comply with this obligation, by inserting personal data/confidential information in AI Search, you consent to their processing for the purpose of providing the service (answers to the questions you ask), as well as for the improvement of the algorithmic model of the robot by its developer.

    Any information provided by users during their interaction with AI Search will be treated confidentially and will only be disclosed to recipients who have a right and need to know.

    The content provided by AI Search is for information purposes only.

    Users are responsible for the questions and messages asked when using AI Search. Any abuse or inappropriate language may result in the interruption of the interaction.

    AI Search does not provide financial, legal or professional advice and is not a substitute for consulting human experts or professionals specialising in the field. Users should not rely on the information provided by AI Search in making decisions.

    The Bank reserves the right to discontinue the AI Search service at any time without prior notice.

    Terms and conditions may be revised/updated at any time.

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