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 liberal professions (e.g. individual offices of doctors, lawyers, notaries, bailiffs' offices, etc.) are also considered personal data.
This processing is carried out by the two banks as joint controllers, in accordance with the provisions of the General Data Protection Regulation (GDPR) and other applicable legislation in this field, in the context of the assignment to BT of certain banking contracts concluded by Idea with its customers. BT and Idea have entered into an agreement to set out each other's responsibilities and obligations in relation to personal data processed for the purposes and by the means they have jointly agreed.
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 fulfilment of the common, determined 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 the BT product/service offer and of the present notification, the assignment of contracts related to Idea products/services to BT, the verification of the application of customer due diligence measures for the prevention of money laundering and terrorist financing.
Personal data strictly necessary for these purposes have been/will be disclosed in the following period by Idea to BT and will be further processed on the following grounds: fulfilling the legal obligations to notify the assignment of the 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 present you in time with the BT product/service offer corresponding to the one from Idea, so that you do not experience interruptions in the use of banking services and so that you do not have to repeat processes at BT such as those for designating persons with operating rights on accounts or for providing/updating data necessary for customer knowledge.
The data is transmitted between the associated operators by means that ensure its adequate security and are part of 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 for the prevention of money laundering and terrorist financing. At BT, data and banking products corresponding to those in Idea (IBAN codes of bank accounts, customer code, BT products/services) have been reserved to the legal entity as indicated in this notification.
With regard to these purposes and legal grounds, joint processing of data by 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 processing period.
The joint processing of data by Idea and BT as informed to you by this information 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 BT, and after the termination of this status. Details of this processing can be found on the website https://ro.idea-bank.ro/, section Processing of personal data. You can find details about the protection provided by Idea to its customers' data on the same website, in the section Protection of personal data.
If you do not become a BT customer following the transfer 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. Instead, Idea will continue to process as a separate controller this data, either in your capacity as a representative of an Idea legal entity client or as a former client/representative of a client, for the periods mentioned in the section Processing of personal data above.
If you are already or if you will become a BT customer as a result of contract assignment or otherwise, Banca Transilvania processes your personal data as a controller, separately from Idea::Bank, as you are informed by the General Information Note 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 upon request at any BT establishment.
Recipients of personal data
The data jointly processed by the associated controllers may be accessed, where appropriate, by their employees who need to know them, IT service providers involved in the assignment of contracts, service providers for the preparation of notifications, courier, audit, archiving services, authorities and institutions entitled to know them, notaries, lawyers, insurance or valuation companies.
We do not foresee the need for jointly processed personal data to be transferred to countries outside the EU/EEA or to international organisations. Should such a need arise, the transfer will only be made in accordance with the rules and based on the safeguards permitted by the GDPR.
Your rights
Every data subject is guaranteed the following rights with regard to the processing of his/her personal data carried out by the associated controllers for the common purposes outlined above: the right to information (we provide you with all the information through this information notice), the right of access, the right to rectification, the right to restriction of processing, the right to erasure of data, 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, 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.
All the details about the joint processing of personal data carried out by Idea::Bank and Banca Transilvania S.A. in the context of the contract assignment can be found in the section Processing of personal data on the website www.bancatransilvania.ro/ideabank.