Information note on the processing of personal data for the purpose of analysing a loan application submitted to Banca Transilvania S.A.

1. Identification data of the controllers

Banca Transilvania S.A . , headquartered in mun. Calea Dorobantilor, nr. 30-36, Cluj-Napoca, jud. Cluj and Societatea Biroul de Credit S.A., a Romanian legal entity with registered office in Bucharest, str. Sfanta Vineri, nr. 29, etaj 4, sector 3, as associated operators, process your personal data in good faith, fairly and transparently, for specified and legitimate purposes, in accordance with the provisions of Regulation (EU) No 679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (Regulation).

Credit Bureau SA is the private law entity that manages the Credit Bureau System, in which personal data are processed in connection with the lending activity carried out by the Participants.

The participants in the Credit Bureau System are credit institutions, non-banking financial institutions, insurance companies and debt collection companies, which have signed a Participation Agreement with the Credit Bureau.

2. Legal basis and purpose of the processing

Banca Transilvania S.A. and the Credit Bureau process your personal data on the basis of the legitimate interest of the Participants and the Credit Bureau to carry out a responsible lending activity, under the conditions of protecting, facilitating access to credit and preventing excessive indebtedness of the data subjects, complying with the legal framework regarding creditworthiness assessment and credit risk reduction, as well as preventing the use of the financial-banking system to carry out unlawful activities.

Banca Transilvania S.A. is obliged, in accordance with the legal regulations in force, to assess your ability to repay the credit before concluding a credit agreement and during its term. For this purpose, Banca Transilvania S.A. processes the information indicated in point (4), registered in your name in its records, and forwards it to the Credit Bureau for processing by this institution and for consultation by any Participant, for the purpose of initiating or carrying out a credit relationship, as well as providing credit products.

3. Obligation to provide data and consequences of non-compliance

The provision of your personal data is necessary for the purpose mentioned in point (2). Refusal to provide your personal data, necessary for the purpose mentioned above, will make it impossible for Banca Transilvania S.A. to fulfil its legal obligations in connection with the granting of credit.

4. Categories of personal data processed in the Credit Bureau System

• identification data of the data subject: name, surname, personal identification number or CUI for authorized natural persons or CIF for natural persons carrying out liberal professions or country code and passport series / number for non-resident persons, home address / residence, telephone number, date of birth;
• employer data:employer address, date of registration of this information, CUI;
• data regarding the credit products requested/granted:the type and name of the Participant, the type of product, the status of the product/account, the date of granting, the duration of the account, the amounts granted, the amounts due, the date of update, currency, the frequency of payments, the amount paid, the monthly installment, the outstanding amounts, the number of days of delay, the date of the outstanding premium, the category of delay, the date of the last payment;
• data on events occurring during the period of the credit product,such as those relating to restructuring/refinancing, giving into payment, assignment of the credit agreement, assignment of the claim;
• data regarding the relations with other accounts:information regarding credit products in which the data subject has the capacity of co-debtor and /or guarantor;
• insolvency data:information relating to data subjects against whom insolvency proceedings have been opened;
• Number of queries: indicates the number of Credit Reports issued by the Credit Bureau at the request of one or more Participants;

In the process of analysing your credit application, Banca Transilvania S.A. will ask the Credit Bureau to issue a Credit Report, with or without FICO® Score, to check whether you are within the debt level established by law and whether you have the capacity to repay the loan. In order to obtain the Credit Report, Banca Transilvania S.A. will send the Credit Bureau your name, surname and personal number.

After granting the loan, Banca Transilvania S.A. will send to the Credit Bureau your personal data provided for in points a)-f). This information shall be shared with the other Participants within the Credit Bureau System and shall be used for the purpose referred to in point 2.

Your ability to repay debts when due can be checked periodically after credit is granted, including by obtaining Credit Reports or using the Alert Service.*.

If, during the term of the credit granted, you are more than 30 calendar days late in paying your instalments, Banca Transilvania S.A. will send to the Credit Bureau information on the outstanding amounts, the category of arrears, the date of the first arrears and/or, if applicable, information on the opening of the payment procedure, only after you have notified us, at least 15 calendar days in advance, in writing, by telephone, SMS, e-mail or other electronic means of communication.

* The Alerts service is used by the Participants to identify and/or reduce the credit risk in a timely manner, by generating an alert to a Participant when an event is registered for a debtor (opening/closing an account, entering/exiting from arrears, account correction, registering/deleting the status of guarantor/co-debtor, account query, changing the employer name/phone number) to another Participant.

5. FICO® Score from credit bureau

The personal data referred to in point (4) may be processed by the Credit Bureau, including to calculate, at the request of the Participants, fico® score from the Credit Bureau.

Participants can use FICO® Score from the Credit Bureau in order to reduce the credit risk associated with a debtor/potential borrower.

The FICO® Score from the Credit Bureau is a number between 300 and 850, obtained from the statistical process that processes the information recorded by the Participants in the Credit Bureau System and indicates the probability that the data subject will pay his installments in the future on time. The main causes that caused the decrease of fico® score from the Credit Bureau are displayed in the form of reason codes.

FICO® Score from the Credit Bureau takes into account the following elements that confer predictability: payment history, current debt, duration of the credit account(s) (average number of months since the loans were granted), the application for new loans (the number of queries and loans granted in the last 6 months), the credit mix (types of loans granted), the age of the person concerned. The influence of these items on the value of fico® score from the Credit Bureau may vary depending on the information recorded with the Credit Bureau for each person concerned.

FICO® Score from the Credit Bureau is a highly predictable analysis tool that, in line with the data from the Credit Report and the information obtained by the Participants from other sources, competes in the correct assessment of the creditworthiness of the data subject in order to conclude / carry out the credit agreement.

6. Recipients of the data

Personal data recorded in the Credit Bureau System shall be disclosed to Participants, upon request, for the purpose referred to in point (2).

The personal data processed in the Credit Bureau System will not be disclosed to third parties, except for public authorities and institutions, according to their competences and applicable legislation, such as the National Supervisory Authority for Personal Data Processing, the National Bank of Romania, the National Integrity Authority, the courts, notaries public, bailiffs, criminal investigation bodies.

7. Storage period

Personal data is stored at the Credit Bureau and disclosed to Participants for 4 years from the date of update, with the exception of data of credit applicants who have withdrawn their credit application or who have not been granted credit, which is stored and disclosed to Participants for a period of 6 months.

8. Rights of data subjects regarding the processing of personal data

As a data subject, you can exercise your rights under the Regulation as follows:

a) the right of access to data may be exercised:

• by a written request, signed, sent by post to the Credit Bureau, or
• by securely accessing the Credit Bureau's website, or
• personally or electronically, to the Participant who holds the status of creditor/potential creditor of you.

At the same time, you have the right to obtain, upon request, at the time of the communication of the credit decision, a copy of the Credit Report issued by the Credit Bureau, which was used by Banca Transilvania S.A. in the analysis of the credit application.

b) the right to rectify the data,

c) the right to delete the data,

d) the right to restriction of data,

e) the right to oppose the processing,including the individual automated decision-making process, 

may be exercised: 

• by securely accessing the Credit Bureau's website, or
• personally or electronically, to the Participant who holds the capacity of creditor/potential creditor of the data subject.

f) the right to address to the National Authority for the Supervision of Personal Data Processing and justice.

9. The contact details of the Data Protection Officers are:

• For Banca Transilvania S.A.– e-mail address dpo@btrl.ro 
• For the Credit Bureau - e-mail address: rpd@birouldecredit.ro

This is a specific information notice on the processing of personal data for the purpose of pre-offer and, where applicable, credit application analysis to BT. The provisions of this notice are complemented by the General Information Notice on the processing and protection of personal data of BT Customers, in which all other purposes for which data are processed are detailed. The General Information Notice is an integral part of the BT Privacy Policy, which is available on the website of Banca Transilvania and can be obtained on request at any BT branch.

1. Identity of the operator

Banca Transilvania S.A . with registered office in mun. Calea Dorobantilor, 30-36, Cluj-Napoca, jud. Cluj processes your personal data in its capacity as data controller for the purpose of pre-offer and, where applicable, the analysis of the credit application.

2. Legal basis and purpose of the processing

For the purpose of pre-offer and, where applicable, the analysis of the credit application made, in accordance with the need to carry out a responsible lending activity, in addition to the processing of your personal data in the system of the Credit Bureau S.A. - of which you have been informed under item. I. of this information - Banca Transilvania S.A. processes such data in its own records, pursuant to the legal obligations it must comply with, the conclusion of the credit agreement and on the basis of its legitimate interest.

The bank will process any of the contact details provided within the formulated loan application, for the purpose of notifying the loan applicant in written form of the decision to approve / reject it, in accordance with the applicable legal provisions. If the applicant wishes to use another form for the communication of the decision, he/she may address an express request to the bank to that effect.

3. Obligation to provide data and consequences of non-compliance

The provision of your personal data is necessary for the purpose mentioned in point I.(2). Refusal to provide your personal data, necessary for the purpose mentioned above, will make it impossible for Banca Transilvania S.A. to fulfil its legal obligations in connection with the granting of the credit, and the credit application cannot be considered.

4. Categories of personal data processed within Banca Transilvania S.A.

The personal data referred to in this information notice under point. I. (4), II.(5), as well as other categories of such data collected in the credit application fields are processed by Banca Transilvania S.A. within the process of analysing the credit application submitted, both in the system of the Credit Bureau S.A. and in its own records, and are also checked (name, surname and/or CNP) - if applicable - in public databases such as websites - court portal, ONRC, etc.

5. Existence of an automated decision-making process, including the creation of profiles made through the BT scoring application

For the purpose of objectively verifying that you meet the eligibility conditions for pre-offer and, where applicable, for analysing your credit application, BT processes your personal data in an automated system of its own ("BT scoring application") in order to carry out the necessary steps to conclude the credit agreement at your request, and on the basis of our legitimate interest to effectively manage the credit risk.

In the BT scoring application, some of the personal data that we have requested from you in the credit application/application, together with information resulting from checks carried out in the bank's own records or in those of the Credit Bureau S.A., such as (for information purposes but not limited to them) as the case may be - information related to your BT customer status, income level, information of a professional and personal nature, level of monthly payment obligations, payment history on other loans. Following the analysis of all the information and the result of the consultation of the records of the Credit Bureau S.A., the BT scoring application issues a score which establishes a profile of the borrower/potential borrower based on the information presented in the previous lines, which will be taken into account in the analysis process and which takes into account the probability of payment of the monthly payment obligations.

On the basis of the score issued by the BT scoring application, together with the result of the verification of the applicant's situation in public databases such as websites - court portal, ONRC etc. - Banca Transilvania S.A. determines whether the eligibility conditions set by its internal regulations are met and will take the decision to admit or reject the credit application, based on the analysis carried out by the Bank's employees (human intervention).

As an exception, we will make the decision to approve/reject a credit application by exclusively automated means only in specific cases, when the application is made online and it is essential to provide you with a response within a very short period of time. In such cases, the decision is taken by such means in order to be able to analyse the application quickly and, if necessary, to conclude the credit agreement. However, you are guaranteed the right to request human intervention, i.e. to have your credit application examined by a bank employee, to express your point of view and to appeal against the decision.

6. Recipients of the data

In addition to the recipients mentioned in pt. I.(6) of this notice, the personal data processed for the purposes indicated in point I.(7) of this notice shall be processed for the purposes indicated in point I.(8) of this notice. II.(2) are disclosed, as appropriate, to the following recipients: ANAF (for consultation of the Ministry of Finance's database, if you have given your consent to this on the dedicated form), your employer (if you have opted to provide proof of income with an income statement from your employer), the Credit Bureau S.A. (in order to consult your situation in the records of this institution), insurance companies, appraisers (in the case of loans for which a valuation of the goods provided as collateral is carried out), FNGCIMM (in the case of Prima Casă, Nouă Casă or Prima Mașînă loans), providers of the BT scoring application or other services used by Banca Transilvania S.A. in the credit application analysis process and/or in other processes specific to its activity.

7. Storage period

The personal data filled in in the loan application are kept in the records of Banca Transilvania for limited periods established legally (e.g. according to the legislation in the financial accounting field) or internally.

8. Rights of data subjects regarding the processing of personal data

In order to exercise your rights (right of access to data, right to rectify data, right to erase data, right to restrict data, right to object to processing) provided for by the Regulation in relation to the processing of your personal data in the system of Credit Bureau S.A. in relation to Banca Transilvania S.A., you may use any of the methods indicated in point. I.(8).

If you wish to exercise these rights with Banca Transilvania S.A. (both for the processing of personal data in the system of Credit Bureau S.A. and within Banca Transilvania S.A.), you may address your written request to the address in Mun. Calea Dorobantilor, 30-36, Cluj-Napoca, jud. Cluj, with the mention - "for the attention of the Data Protection Officer (DPO)" or by e-mail to dpo@btrl.ro. You also have the right to address the National Authority for the Supervision of Personal Data Processing and Justice.