Information on the processing of personal data in the context of occasional transactions

Version 1 as of 18.12.2024

Data controller and data subjects

Banca Transilvania S.A. ("the bank", "BT") processes the personal data of individuals who carry out occasional transactions (e.g. cash deposits in BT accounts on which they have no capacity, currency exchanges, money transfers via Western Union, payments to utility suppliers, withdrawals of amounts representing dividends), also called occasional customers, in the bank's establishments or through BT equipment, as well as, where applicable, the data of the actual beneficiaries of occasional customers (together "data subjects").

Purposes of processing personal data

Personal data is processed in the context of occasional transactions for the following main purposes:

the application of know your customer measures to prevent money laundering and terrorist financing (including identity verification and identification).
conclusion and execution of the contract for occasional transactions (including processing/settlement of this transaction);

Categories of personal data processed and their source

In the context of occasional transactions, BT processes the following categories of personal data as appropriate:

identification data: data contained in the identity card or passport with which you identify yourself, including a copy of this document, when we are required by law, signature, country of tax residence;
financial data about the occasional transaction (e.g. amount, currency, payee, explanations/ transaction details, transaction reference/ transaction identifier) and the history of occasional transactions with BT;
contact details: telephone number, e-mail address;
other personal data required by law, depending on the specifics of the transaction;

We collect data directly from occasional customers. In the case of their beneficial owners, we collect the data from the occasional customers who provide it to us.

What are the legal grounds for processing personal data and what happens if you refuse processing

The Bank processes personal data pursuant to the legal obligations applicable to it (e.g. know-your-customer legislation to prevent money laundering and terrorist financing, payment services legislation), as well as for the conclusion and performance of the contract related to the requested occasional transaction. If you refuse to process this personal data, we will not be able to process the occasional transaction.

Also, in order to reduce waiting times at bank counters, we have a legitimate interest to use the data processed in the context of a one-off transaction or, where appropriate, personal data we hold about you from the perspective of a regular customer of the bank and for possible future one-off transactions.

How long we keep personal data

Personal data is kept for 5 years from the date of the occasional transaction, a period which may be extended under the conditions of the specific legislation. Upon expiry of the legal retention period, the bank will erase/anonymize the data, unless there are other legal provisions requiring their continued retention (e.g.: the Fiscal Procedure Code requires data to be retained for 10 years from the date of the occasional transaction).

To whom we disclose personal data

The categories of recipients to whom we disclose personal data, where applicable, are:

other Customers (the BT customer who is the beneficiary of the amounts subject to the occasional transaction)
contractual partners (service providers) used in BT's business
public authorities and institutions to which we have a legal obligation (e.g. ANAF and ONPCSB) or, where applicable, a legitimate interest (e.g. courts of law) to disclose personal data processed in the context of occasional transactions.

This information notice is complemented by the Policy of Banca Transilvania S.A. on the processing and protection of personal data in the framework of banking activities ("Privacy Policy"), in particular with the provisions of section C, paragraph 2 thereof. The Privacy Policy can be found on the website www.bancatransilvania.ro or, upon request, at any branch of the Bank. The Privacy Policy includes the rights that can be exercised by the data subjects and the means of exercising them, as well as the contact details of the Data Protection Officer (BT DPO).

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Information on the processing of personal data in the context of occasional transactions

Data controller and data subjects

Purposes of processing personal data

Categories of personal data processed and their source

What are the legal grounds for processing personal data and what happens if you refuse processing

How long we keep personal data

To whom we disclose personal data

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Information on the processing of personal data in the context of occasional transactions

Data controller and data subjects

Purposes of processing personal data

Categories of personal data processed and their source

What are the legal grounds for processing personal data and what happens if you refuse processing

How long we keep personal data

To whom we disclose personal data