Information notice on the processing of personal data for the purpose of online updating of customer information (chatbot Ino

Banca Transilvania S.A. ("the Bank", "BT"), as a credit institution, has a legal obligation to apply know-your-customer measures for the purpose of preventing money laundering and terrorist financing in order to perform a task that serves a public interest. When you become an individual customer holding an account with BT or a representative of such a customer (legal representative, conventional representative, account representative, proxy) we collect from/about you information for this purpose, such as, as appropriate: your name, surname, pseudonym, date and place of birth, personal identification number or other similar unique identifier, nationality, domicile, residence, address where you live and its legal status, telephone number, fax number, e-mail address, occupation, name of employer or nature of your business, the purpose and nature of the business relationship with the bank, the source of the funds to be used in the business relationship, whether you are a publicly exposed person or a family member of a publicly exposed person or a person known to be a close associate of a publicly exposed person (PEP), and details and copy of your identity card.

We need to make sure that as long as you have such a quality, this information is up to date in our records. Therefore, whenever any of this information changes, you need to change it at the bank as well. From time to time, even if the details have not changed, we will ask you to reconfirm them so that we can be sure they have not changed.

You can update all the data set we need about you for the application of customer insight measures in any BT unit. To update some of this data, we offer you online solutions, such as this Ino chatbot.

To ensure that we only update/reconfirm your details and to prevent possible fraud attempts, we need to verify your identity. As you know, in our bank branches, we verify your identity on the basis of your original ID. Online we do things a little differently. Here's how we do it:

• we will verify your identity and your status as a BT customer on the basis of the personal identification number (CNP) and the telephone number you have declared in the bank's records. A unique code (SMS-OTP) will be sent to this phone number via SMS, which you will need to enter in the dedicated chatbot field. If you no longer use the phone number you registered with the bank, you will first need to update it in a BT unit or by calling the call centre service.
• then you will need to upload a picture of your ID to Ino. We would then apply a new technology to your image in this photo, which uses so-called biometric data. However, we will not be able to use this data without your explicit consent. Before you decide freely whether you want to express your consent, here is what the use of your biometric data entails: the IT solution we use will identify the section of your ID picture uploaded by you that contains your face, select it and then compare it with the face in the copy of your ID that is already on file with BT. The comparison is made biometrically, based on criteria such as the colour, size and slant of your eyes, the position and distance between the main features of your face such as your eyes, eyebrows, lips and nose. Following the comparison, the computer solution will give a confidence score, indicating the likelihood that the faces in the two images belong to the same person.

If you do not wish to have your biometric (facial identification) data processed, you can update your data at any BT unit, where your identity will be verified without the use of such data.

Also, if the Facial Recognition tool gives an unsatisfactory confidence score, you will be able to restart the update process in a BT unit.

If after following the above steps you convince us that it is you, you will be able to update some of your customer data online. But if you haven't passed this little test, there's no problem, you can update your data in full at any BT unit.

To help you in the update process, some of your data from your ID will be automatically taken (through the optical character recognition process) when you upload your photo, while the rest of your data will be selected from a list of values or inserted by you. Please check that the data is correct and modify it if necessary. If you complete the update, even though you find that the data has been taken over/ filled in wrongly, you risk being guilty of misrepresentation and you certainly don't want that. If you fail to change the errors, quit the online flow and come into the unit.

Please note that when you update your details via Ino, the home address from the ID you upload will also be taken/updated as your correspondence address with the bank. If you wish to declare a different correspondence address to BT than your home address, you will need to update it separately at a BT unit.

Your home address will also be taken as your residence address if you have confirmed to us in Ino that you do not have a valid residence/floating visa on the back of your ID. If you do have a valid visa, your residence address is different from your home address. In this case, you need to update it at a BT unit.

This information note is supplemented by the provisions General Information Note on processing and protection of personal data of BT customerswhich we recommend that you consult. It is an integral part of BT Privacy Policy. Both can be found on the bank's website www.bancatransilvania.roincluding in the Privacy Hubsection, or, on request, in any BT branch. The general information note 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).