Processing of personal data - natural persons

INFORMATION ON THE PROCESSING OF PERSONAL DATA

Data controllers and data subjects

Banca Transilvania S.A. (hereinafter "BT") and Idea::Bank S.A. (hereinafter "Idea"), entities of the Banca Transilvania Financial Group, jointly process personal data of you - account holder and Idea::Bank product/service holder - as well as of persons in relation with you at Idea (e.g.: persons designated with operating rights on Idea accounts, beneficial owners, representatives of any kind, co-debtors, guarantors, etc.), as we inform you below.

This processing is carried out by the two banks as associated operators, in accordance with the provisions of the General Data Protection Regulation (GDPR) and other applicable legislation in the context of the transfer to BT of certain banking contracts entered into by Idea with its customers. BT and Idea::Bank have entered into an agreement to set out the responsibilities and obligations of each with respect to the personal data processed for the purposes and by the means they have jointly determined.

Asthe processing of processed data and their source, the purposes and grounds of the processing, the retention period

Data processing is carried out for the fulfillment of common, specified and legitimate purposes established by BT and Idea, related to: the need to verify that you are a joint customer of the two banks, the preparation and transmission of BT's product/service offer and this notice, the transfer of contracts related to Idea::Bank products/services to BT, the verification of the application of know-your-customer measures to prevent money laundering and terrorist financing.

Personal data strictly necessary for these purposes has been/will be disclosed in the following period by Idea to BT and will be further processed on the following grounds: Fulfilling legal obligations to notify you of the assignment of the contract, taking steps to conclude a contract between you and BT (as a result of the assignment), fulfilling the legitimate interests of the associated operators to provide you with BT's product/service offerings corresponding to Idea's in a timely manner so that you do not experience interruptions in your use of banking services and so that you do not have to re-enter processes with BT such as designating persons with operating rights on accounts or providing/updating data necessary for know your customer.

The data is transmitted between associated operators by means that ensure adequate security and falls into the following main categories: identification data, contact data, data about the Idea products/services you have contracted and about transactions carried out through accounts opened with Idea, including data relating to account numbers, customer codes, contract numbers, data necessary for the application of know-your-customer measures to prevent money laundering and terrorist financing. At BT you have been reserved banking data and products corresponding to those in Idea (bank account IBAN codes, customer code, BT products/services), as set out in this notification.

In relation to these purposes and legal grounds, the joint processing of data by the associated controllers may only cease if you terminate the contractual relationship you have established with Idea or at the end of the joint data processing period.

The joint processing of data by Idea and BT as we inform you in this notice does not affect the processing that the Idea Bank controller carries out independently of BT as long as you are a customer of BT, and after you cease to be a customer of BT. Details of this processing can be found at https://ro.idea-bank.ro/ in the "processing of personal data" section. You can find details of the data protection provided by Idea to its customers on the same website in the section "protection of personal data".

If you do not become a BT customer as a result of the assignment, Banca Transilvania will anonymize your data received from Idea Bank and the corresponding data reserved for you in BT. In return, Idea will continue to process as a separate controller these data, either in your capacity as an Idea customer or as a former customer, for the periods mentioned in the section "processing of personal data, indicated above.

If you are already a BT customer or if you become a BT customer as a result of assignment of contract or otherwise, Banca Transilvania processes your personal data as a controller, separate from Idea::Bank, as you are informed by the General Information Notice on the processing and protection of personal data belonging to BT Customers, which you can find on the website www.bancatransilvania.ro under Privacy Policy or by directly accessing the following link: https://www.bancatransilvania.ro/Nota-informare-generala-privind-prelucrarea-si-protectia-datelor-cu-caracter-personal-clienti-BT.pdf, as well as on request at any BT establishment.

Recipients of personal data

The data processed jointly by the associated operators have access, as the case may be, to their employees who need to know them, IT service providers involved in the activity of assignment of contracts, service providers for the preparation of notifications, courier, audit, archiving, authorities and institutions entitled to know them, notaries, lawyers, insurance or valuation companies.

In addition, if your employer has an agreement with BT for salary payments, the IBAN of the account to be opened with BT - corresponding to the one at Idea - will be provided to your employer for the smooth transfer of the amounts.

At the same time, if you receive in the accounts opened with Idea amounts representing pensions or other types of social benefits (e.g. state child allowances, disability pensions, unemployment benefits, social assistance, etc.), Banca Transilvania will communicate to the paying institutions the IBAN of the account that will be opened in BT instead of the one in Idea, so that you can receive the amounts in it as from July 2022, without having to take any further steps yourself. If you don't want to receive the money in your new BT account, you will have to transfer the paying institutions account to another bank where you want the money to be paid into.

Last but not least, in case you have concluded credit agreements with Idea Bank S.A. and these are subject to the assignment of contracts to Banca Transilvania S.A., which has been brought to your attention by means of this notification, we inform you that the assignment of each credit agreement concerned will be reported to the Credit Bureau as an event occurring during the period of the credit. Details about the data processed in the Credit Bureau by Banca Transilvania S.A. during the course of a credit relationship can be found in the General Information Notice on the processing and protection of personal data belonging to BT customers or directly by accessing the following link: https://www.bancatransilvania.ro/Nota-de-informare-privind-prelucrarea-datelor-cu-caracter-personal-in-contextul-incheierii-executarii-unui-contract-de-credit-BT.pdf

We do not envisage the need for jointly processed personal data to be transferred to countries outside the EU/EEA or to international organizations. If such a need should arise, the transfer will only be made in accordance with the rules and on the basis of the safeguards premised by the GDPR.

Your rights

Each data subject is guaranteed the following rights with regard to the processing of his or her personal data by the associated controllers for the common purposes described above: the right to information (we provide you with all the information in this information notice), the right of access, the right of rectification, the right to restriction of processing, the right to erasure, the right to object to the processing, the right to data portability. You can exercise these rights by sending a request to the registered office of any of the associated controllers, to the attention of the DPO or by e-mail, as follows: for BT to dpo@btrl.ro or for Idea to dpo@idea-bank.ro. Also, if you consider that this processing violates your rights, you may lodge a complaint with the National Supervisory Authority for Personal Data Processing or go to court.

Full details about the joint processing of personal data carried out by Idea::Bank and Banca Transilvania S.A. in the context of the assignment of the contract can be found in the section on the Processing of personal data on the website https://www.bancatransilvania.ro/ideabank.