Processing of personal data - legal 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 - as a representative of a legal entity holding an account and Idea products/services - as well as of persons in a relationship with the legal entity at Idea::Bank (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. Any information about legal entities such as P.F.A., I.I., individual forms of exercising liberal professions (e.g.: individual practices of doctors, lawyers, notaries, bailiffs' offices, etc.) are also considered personal data.

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 concluded by Idea with its customers. BT and Idea have entered into an agreement to set out their respective responsibilities and obligations 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

The data processing is carried out for the fulfillment of the common, specified and legitimate purposes established by BT and Idea, related to: the need to verify whether the legal entity is a joint customer of the two banks, the preparation and transmission of BT's product/service offer and of this notification, the transfer of contracts related to Idea's 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 a contract, taking steps to conclude a contract between the legal entity 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 good time 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 are transmitted between the associated operators by means that ensure their adequate security and belong to the following main categories: identification data, contact data, data on the Idea products/services that the legal entity has contracted and on the transactions carried out through accounts opened with Idea, including data on account numbers, customer codes, contract numbers, data necessary for the application of know-your-customer measures to prevent money laundering and terrorist financing. Data and banking products corresponding to those in Idea (IBAN codes of bank accounts, customer code, BT products/services) have been reserved with BT for the legal entity as indicated 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 that the legal entity has 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 representative of a legal entity customer of Idea::Bank, and after you cease to be a representative of a legal entity customer of Idea::Bank. Details of this processing can be found at https://ro.idea-bank.ro/, in the Personal Data Processing section . You can find details of the data protection provided by Idea to its customers on the same website in the Personal Data Protection section.

If you do not become a BT customer following the assignment of the contracts concluded between Idea and the legal entity you represent, 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 a representative of an Idea legal entity customer or as a former customer/representative of a customer, for the periods mentioned in the Processing of personal data section 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, separately 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 https://www.bancatransilvania.ro/companii, under the 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 jointly processed by the associated operators have access, as appropriate, 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.

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 permitted by the GDPR.

Your rights

Each data subject is guaranteed the following rights with regard to the processing of his or her personal data carried out 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 of data, the right to data portability.

You can exercise these rights by sending a request to the registered office of any of the associated controllers, for 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 can lodge a complaint with the National Supervisory Authority for the Processing of Personal Data 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 www.bancatransilvania.ro/ideabank.