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Processing of personal data - legal persons
INFORMATION ON THE PROCESSING OF PERSONAL DATA
Data controllers and data subjects
Banca Transilvania S.A. (hereinafter referred to as "BT") and Idea: Bank S.A. (hereinafter referred to as "Idea"), entities of the Banca Transilvania Financial Group, process together personal data of you – as a representative of a legal person holding an account and idea products/services – as well as of the persons in relation to the legal entity at Idea::Bank (e.g.: designated persons with operating rights on Idea accounts, real beneficiaries, represented of any kind, co-debtors, guarantors, etc.), as we inform you below. Personal data and any information about legal entities such as P.F.A., I.I., individual forms of exercise of liberal professions (e.g., individual doctors' offices, lawyers, notaries, bailiffs' offices, etc.) are 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 normative acts applicable in the field, in the context of the assignment to BT of bank contracts concluded by Idea with its customers. BT and Idea have entered into an agreement to establish their respective responsibilities and obligations with respect to personal data processed for the purposes and by means they have jointly established.
Asthe processing of processed data and their source, the purposes and grounds of the processing, the retention period
The data processing is carried out in order to fulfill 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 offer of BT products / services and of this Notice, 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.
The personal data strictly necessary for these purposes have been disclosed in the next period by Idea to BT and will continue to be processed on the following grounds: carrying out the legal obligations of notifying the assignment of the contract, taking measures for the conclusion of a contract between the legal entity and BT (as a result of the assignment), fulfilling the legitimate interests of the associated operators to present in advance the offer of BT products / services corresponding to the one in Idea, so that you do not encounter interruptions in the use of banking services and so that you do not have to resume at BT processes such as those of appointing persons with rights to operate on accounts or to provide / update the data necessary to know the customer.
The data is transmitted between the associated operators by means that ensure their adequate security and belong to the following main categories: identification data, contact data, data about the Idea products / services that the legal entity has contracted and about the transactions made through accounts opened at Idea, including data regarding 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, bank data and products corresponding to those in Idea (IBAN codes of bank accounts, customer code, BT products / services) as indicated in this notification have been reserved to the legal entity.
In relation to these legal purposes and grounds, the joint processing of data by the joint controllers may cease only if you denounce 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 through this information note does not affect the processing that the Idea operator:: Bank performs, independently of BT, as long as you are the representative of a client who is a legal person of it, as well as after the cessation of this quality. About this processing you can find details on the https://ro.idea-bank.ro/ website, section Processing of personal data. About the protection provided by The Idea of its customers' data you can find out details on the same website, in the section Protection of personal data.
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 that have been reserved for you in BT. Instead, Idea will continue to process this data as a separate operator, either in your capacity as a representative of an Idea legal entity client, either as a former customer / representative of a customer, for the periods mentioned, in the section Processing of personal data, indicated above.
If you are already or if you will become a BT customer as a result of the contract assignment or otherwise, Banca Transilvania processes your personal data as an operator, distinct from Idea::Bank, as informed by the General Information Note on the processing and protection of personal data belonging to BT Clients, which you can find on the https://www.bancatransilvania.ro/companii website, within the Privacy Policy or by accessing directly 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, in any BT unit.
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, the IT service providers involved in the activity of assignment of contracts, providers of notification preparation services, courier, audit, archiving, authorities and institutions in the right to know them, notaries, lawyers, insurance or evaluation companies.
We do not expect the need for jointly processed personal data to be transferred to countries outside the EU/EEA or to international organisations. If such a need arises, the transfer will be made only according to the rules and based on the guarantees allowed by GDPR.
Your rights
Any data subject is guaranteed the following rights with regard to the processing of his or her personal data carried out by the joint controllers for the common purposes set out above: the right to information (we provide you with all the information through this information note), the right of access, the right to rectification, the right to restriction of processing, the right to delete the data, the right to object to data processing, the right to data portability.
You can exercise these rights by sending a request to the registered office of any of the joint controllers, to the attention of the DPO or by e-mail, as follows: for BT, at dpo@btrl.ro or for Idea, at dpo@idea-bank.ro. Also, if you consider that this processing violates your rights, you can file a complaint with the National Supervisory Authority for Personal Data Processing or contact the 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 www.bancatransilvania.ro/ideabank website.