1. Who is the data controller and what is the purpose of the processing?
Banca Transilvania S.A. ("the Bank", "BT") has a legal obligation to verify the identity of customers who request personalised information about the products/services contracted with the Bank, including the modification of certain information related thereto ("personalised banking information"), in order to ensure that it is provided only to authorised persons. The more sensitive the banking information requested, the higher the level of identification we will need to apply.
When we receive such requests, we want to accommodate them as quickly as possible. That's why we provide customers with personalised banking information via the Ino chatbot (hereinafter "Ino") after they have successfully completed the identification process.
The general questions and answers (FAQ) section of Ino can be accessed by anyone without having to identify them.
2. What personal data is processed for identity verification in Ino and what happens if you refuse its processing
In order to be able to provide you with personalised banking information, you will need to enter your personal identification number (CNP), the telephone number you have declared in your relationship with your bank and the unique identification code (SMS-OTP) that we will send you via SMS. We process this information both to check that you qualify for personalised banking information through Ino (you are a BT customer, a major and a resident) and to make sure you are who you say you are, so we don't provide you with the information requested if you are not entitled to receive it.
Additionally, if you are a BT Pay user and meet the eligibility requirements (e.g. you have at least one card enrolled in BT Pay and have gone through the identification process under payment services legislation, either directly in BT Pay or in a BT unit) during the live chat conversation with a BT employee, which you will enter by accessing the "chat with a colleague" sections of Ino, for some types of banking information you will be able to complete the identification process in BT Pay by accessing a push notification we will send you.
If you do not have BT Pay, do not meet the eligibility requirements or do not wish to be identified through the app, for some types of personalised banking information you request through Ino, you will be able to either be identified by asking additional questions or by going through a remote identification flow by video means, without a human operator, if you agree to this and explicitly consent to the processing of your biometric data, according to the following steps:
- you present the image of the ID card ("IC") to the camera (requires access to the device's camera) - we take the data from the IC using optical character recognition, ORC-ization, (a process that allows the automatic extraction of letters and numbers from the loaded IC) and compare them with those already in the bank's records to make sure they match.
- you move in front of the camera - we record your moving image and use it to make sure you're a real person.
- To confirm your unique identification, we want to apply a technology to your image (face) that uses so-called biometric data (comparing the characteristics of your face from two photos).
We will not use biometric data without your explicit consent. Before you decide freely whether you wish to express it, here is how we would use it:
- the software solution we use identifies your face in the CI and in the video we record when you move in front of the camera, selects it and compares it with the face in the copy of the CI that is already recorded in BT's records
- the comparison is made biometrically, based on criteria such as: colour, size and slant of the eyes, position and distance between the main facial features such as eyes, eyebrows, lips and nose.
Following the biometric comparison, the software solution indicates the probability that the face in the two images belongs to the same person. To consent to the processing of your biometric data (facial recognition), you will have to select the "I explicitly consent to the processing of my biometric data" button in Ino and if you refuse to have your biometric data processed, you will select the "I do not want my biometric data to be used" button.
If you refuse to have your data processed by the above means or we fail to identify you in Ino, we will not be able to provide you with your personalised banking information within this chatbot, but you can obtain it at any BT unit after identification with your ID.
3. How long do we keep the data from conversations through Ino?
We will keep your data processed for identification in Ino, where applicable together with the discussion with the agent, for a period of 3 years.
This information note is supplemented by the provisions General information notice on the processing and protection of personal data of BT customerswhich we recommend that you consult. It is an integral part of BT Privacy PolicyPrivacy Policy, which you can find on the bank's website www.bancatransilvania.roincluding in the Privacy Hub section of the website. The general information notice includes the definition of a BT Customer, as well as details about the recipients of BT Customer data, your rights in relation to the processing of your data, how you can exercise them or how to contact the BT Data Protection Officer (BT DPO).
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