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  • Information note on the processing of personal data cash deposit occasional customers BT

Information note on the processing of personal data by Banca Transilvania S.A. in the context of cash deposit banking operations

Version applicable from 11.06.2021

Banca Transilvania, S.A., (hereinafter also referred to as "the bank", "BT", "we", "us"), hereby informs you of how it intends to process your data when you deposit, as a BT occasional customer, cash amounts in accounts opened with BT on which you have no capacity (including the bank's regular customers - BT customers - who deposit such amounts in accounts on which they have no capacity will be occasional customers).

This information note is supplemented by the provisions of BT Privacy Policy (the "Policy"), which we encourage you to review. The Policy includes the definition of "BT Occasional Customer", as well as further details on the processing of data relating to this category of data subject, in particular in section C of this Policy, which can be found on the BT website www.bancatransilvania.ro.

When you act in relation with us as a BT occasional customer, in order to deposit a cash amount at our counters - in BT accounts on which you are not an account holder, authorised representative or cash deposit agent - it is necessary to identify you on the basis of a valid identity document and to process in our records the following personal data concerning you - name, surname, ID number and series, CNP, address, details of the amount deposited and explanation of the nature of the payment (what the payment represents).

In some cases provided for by law, we may need to make and retain a copy of your ID.

We process this data, as appropriate, for the main purposes relating to:

  • to verify your identity in order to prevent money laundering and terrorism financing; For the occasional transactions initiated over the counter in BT units, for your identity to be verified you will have to present your original, valid ID document, and, in the case of banking operations you initiate throughBT equipment your identity shall be verified via other information existing in the bank’s evidence.
  • applying the know your customer (KYC) rules in order to prevent money laundering and financing of terrorism, including risk-based verification;
  • concluding and signing the agreements related to occasional transactions;
  • evaluating and monitoring the financial-commercial behaviour to detect unusual and suspicious transactions, according to the legal KYC obligations in order to prevent money laundering and terrorism financing;
  • settlement of bank transactions;

as well as, depending on the situation, for other purposes closely related to the main ones, i.e. for:

  • the preparation and submission of reports to the competent authorities, authorized to receive them in accordance with the legal provisions governing BT’s activity (e.g. payment incident reports to the Office of Payment Incidents within the National Bank of Romania-NBR, declaring the transactions that exceed the amount established by the National Office for Prevention and Control of Money Laundering);
  • conducting analyses and the keeping of records for the bank’s economic, financial and/or administrative management;
  • management within the internal departments of the services and products provided by the bank;
  • defending the bank’s rights and interests in court, the resolution of disputes, investigations or any other petitions/ complaints/requests in which the bank is involved;
  • performance or risk controls regarding the bank’s processes and procedures, as well as the performance of audit activities or investigations;
  • monitoring/security of persons, premises and/or property of the bank or visitors to its premises;
  • taking measures/providing information or answers to the requests/claims/complaints of any nature addressed to the bank by any person or by legal authorities or institutions, including electronic communication and internet requests;
  • performance of internal analysis (including statistics);
  • archiving of documents both in physical and electronic format and security back-up;
  • the performance of registration and secretary services regarding the correspondence addressed to the bank and/or sent by it, as well as for carrying out courier activities;
  • ensuring the security of the IT systems used by BT and the physical premises where the bank operates;
  • fraud prevention;

We process this data mainly pursuant to our legal obligations to perform a task established in the public interest and for the conclusion/execution of the contract related to the occasional transaction.

Refusal to have this data processed for the purposes indicated may make it impossible to process the requested transaction.

In order to reduce waiting times at bank counters, we justify the legitimate interest to use this data also for any cash deposit transactions you may request in the future. In case of cancellation of the transaction, we will need to contact you in order to refund the amount deposited. If we already have your contact details in our records, we will use them for this purpose (e.g. if you are also a regular customer of the bank - BT customer - we have your contact details that you provided us for the purpose of that regular contractual relationship).

However, if you have not declared your contact details to the bank, by filling in any such details (telephone number, e-mail address) in the information form given to you at the time of cash deposits initiated at the counters, you consent to their use for the purpose of contacting you for the return of the amount, including future cash deposits, until such time as you request us to stop processing your contact details for this purpose and/or to change them.

In the BT Privacy Policy you will also find details of your rights in relation to the processing of your data for the purposes indicated, how you can exercise these rights or how you can contact the BT Data Protection Officer (BT DPO).