Information note on the processing of personal data for obtaining / increasing the credit line related to a BT credit card, exclusively online
Who is the controller of personal data?
BANCA TRANSILVANIA S.A. (hereinafter the "bank" or "BT") credit institution, a legal person Romanian, with the identification and contact data presented in Section III of the General Information Note on the processing and protection of personal data belonging to BT Clients, offers its individual customers the possibility to obtain a BT credit card / increase the credit line related to a BT credit card, exclusively online.
In the general note indicated above, which forms an integral part of the BT Privacy Policy website, which can also be found separately in the Privacy Hub section of this website, you can find detailed information about your rights in relation to the processing of your personal data, how you can exercise them or how you can contact the BT Data Protection Officer (BT DPO).
If you want to apply for obtaining or, as the case may be, for the increase of the credit line related to a BT credit card exclusively online, we will process your personal data for several purposes and legal grounds; we alone, as the exclusive data controller or, where appropriate, together with other operators associated with us.
In this information note, when we refer to the processing of personal data for the application for / obtaining / contracting a BT credit card, the information is also valid for the processing of the data that is carried out when you request the increase of the credit line related to a BT credit card that you have previously obtained (regardless of whether you contracted it in a BT unit or online).
Also, when we refer to the processing of personal data for the conclusion and execution of the credit card contract, the information is also valid for the processing of personal data for the conclusion / execution of an addendum to the credit agreement. This addendum will be concluded between you and the bank if you are approved the increase of the credit line related to a card that you have previously obtained (regardless of whether you contracted it in a BT unit or online).
On what grounds do we process the data and what happens if you refuse to process it?
The processing of personal data carried out by BT in the context of applying and, where appropriate, contracting an exclusively online credit card are based on the following grounds:
- the legal obligations to which BT is subject by various normative acts,
- concluding/executing the credit card contract or taking the necessary steps in order to conclude it,
- our legitimate interest and/or that of third parties, (e.g. interest in fraud prevention or legitimate interest in consulting your situation in the records of the Credit Bureau SA for the assessment of your creditworthiness, legitimate interest in contacting you for the resolution of situations that may arise when you apply for obtaining/increasing the credit line related to the card),
- your consent, such as the one for consulting your income in the ANAF database or for verifying your identity and quality as a BT customer based on biometric data.
For what purposes do we process personal data, what is the data, for what period do we keep it and to whom can we disclose it?
In the following lines we present you separately the purposes for which we would process personal data so that you can apply and, where appropriate, contract a BT credit card exclusively online.
Depending on the purpose of the processing, you will have presented information about the storage period of your data, the categories of data recipients, the existence of automated decision-making processes, as well as the rights you benefit from in relation to the processing of your data.
A. Personal data processed for the purposes of verifying your identity, for the prevention of fraud, money laundering and terrorist financing, for confirming your status as a BT Customer, and for contacting you for the purposes of providing support or assessing the quality of this BT service.
The law that applies to us obliges us to verify the identity of the persons with whom we conclude different contracts. We also have a legitimate interest in ensuring that we prevent attempts at fraud through identity theft online.
When a person requests a credit card in a BT unit, their identity is verified based on the original ID. In the online environment we do not have this possibility, so we will do things a little differently. We have chosen a method that assures us who is the client of BT applying, so that we can prevent possible fraud attempts. This method uses the latest technologies, processing so-called biometric data. However, we will not be able to use this data without your explicit consent. Before you decide freely if you want to express it, here's what the use of your biometric data entails:
- You'll need to photograph your ID card ("ID"), which also contains your image (requires access to the camera).
- the computer solution we use will identify in the CI's photo the section that contains your face, select it and then compare it with the face from the copy of your identity card that is already recorded in the records of BT. Comparison is made biometrically, based on criteria such as: color, size and inclination of the eyes, position and distance between the main elements of the face such as the eyes, eyebrows, lips and nose. Following the comparison, the computer solution will issue a trust score, indicating the probability that the face of the two images will belong to the same person.
If you do not want your biometric data (facial identification) to be processed, you can apply for your credit card in any BT unit, where your identity will be verified without the use of such data.
Also, if the facial identification tool issues an unsatisfactory confidence score, you will be able to resume the application process in a BT unit.
B. Personal data processed for credit application analysis, including automated decision-making processes based on profiling
In order to analyze the application by which you apply for a BT card exclusively online, we process information that concerns you both in our internal records and in the records of the Credit Bureau, in which we consult your situation. All the information related to this processing can be found in point (a) and (b). I and II below.
Because it is essential to be able to provide you with a quick response to your credit card application addressed online, we will decide to grant the credit or, as the case may be, to reject this request based on the exclusively automatic processing of the data, a decision about which you can find details below, in point II (5).
C. Information on the processing of personal data on the occasion of the conclusion and during the performance of a credit agreement concluded with BT
D. Information on the processing of personal data for the purpose of issuing and managing the Qualified Digital Certificate issued to the User by Alfatrust Certification S.A. for signing the documentation in relation to BT
If you want to obtain a BT credit card exclusively online, you will need to sign the credit documentation with a qualified electronic signature. The issuance and use for signing of the digital certificate does not involve costs for you, but it is necessary for BT and Alfatrust to process together, as joint operators, personal data concerning you for the issuance of this electronic signature.