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    Information notice on the processing of personal data for obtaining a BT personal loan 100% online

    Who is the controller of personal data?

    BANCA TRANSILVANIA S.A. (hereinafter "the bank" or "BT") credit institution, Romanian legal entity, with the identification and contact details set out in section III of General Information Notice on the processing and protection of personal data belonging to BT Customers, offers its individual customers who are current account holders the possibility to obtain a 100% online personal loan (hereinafter also referred to as "BT 100% online loan").

    In the general notice indicated above, which is an integral part of the BT Privacy Policy on the www.bancatransilvania.ro website , also found separately in the Privacy Hub section, you will find the definition of BT Customer, detailed information about your rights in relation to the processing of your personal data and how you can exercise them, and the possibility to contact the BT Data Protection Officer (BT DPO).

    When you apply for a 100% online BT loan, we process your personal data for a number of purposes and lawful bases, either as the sole data controller or, where applicable, together with other associated data controllers, as set out below.

    Also, if you choose a credit with attached insurance, the insurer Metropolitan Life is the controller of your personal data processed for the issuance and management of the insurance policy, and the bank acts only as the authorized person of the insurer for this processing. Metropolitan Life's personal data processing policy can be accessed from the website https://www.metropolitanlife.ro/ https://www.metropolitanlife.ro/ or directly at the following link: MetLife_Politica_de_processing_data_clienti_Life_si_NonLife_aug2019.pdf (metropolitanlife.ro).

    On what grounds do we process the data and what happens if you refuse processing?

    When you apply for and, where applicable, enter into a contract for a BT 100% online credit, we process your personal data on the following legal grounds:

    • the legal obligations to which BT is subject by various normative acts,
    • the conclusion/execution of the credit agreement or the steps necessary for its conclusion,
    • our legitimate interest and/or the legitimate interest of third parties, (e.g. the legitimate interest of fraud prevention or the legitimate interest of consulting your situation in the Credit Bureau SA's records for the assessment of your creditworthiness, the legitimate interest of contacting you to provide you with support for the completion of your online application and to ask your opinion about the application process),
    • your consent, such as to consult your income in the ANAF database or to verify your identity based on biometric data.
    If you do not want your data to be processed as we inform you in this information notice, you will not be able to get the requested BT loan 100% online, but you can apply for it at a bank branch. Find out more.

    Where we are obliged by law to process personal data or where it is necessary for the conclusion of the credit agreement, if you refuse processing, we will not be able to consider your request.

    For processing based on the legitimate interest of BT or third parties, refusing to have your data processed may make it impossible to process your application or obtain BT 100% online credit.

    For data processing for which your consent is required, we will ask for your consent at the appropriate time on the online application flow. If you refuse to give this consent, you cannot get the 100% online credit, but you can apply for it at a BT branch, where you will have to prove your income to us in some other way (e.g. proof of income from your employer) and your identity will be verified without the processing of 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 will set out separately the purposes for which we would process your personal data in order for you to apply for and, where applicable, take out a BT 100% online loan. Depending on the purpose of the processing, we will provide you with information about the period of data storage, the categories of data recipients, the existence of automated decision-making processes, and the rights you have...

    A. Personal data processed for the purposes of identity verification, to prevent fraud, money laundering and terrorist financing, and to contact you for the purposes of providing support or assessing the quality of this BT service

    Applicable law obliges us to verify the identity of persons with whom we are about to enter into contracts. At the same time, we have a legitimate interest in preventing fraud attempts through online identity theft.

    In BT branches we verify the identity of loan applicants on the basis of their original ID. Online we don't have this possibility, so we do things a little differently. We've chosen a method that assures us who the BT customer is who is applying, so we can prevent potential fraud attempts. This method uses the latest technology, processing so-called biometric data. We will only use such data with your explicit consent. Before you freely decide if you wish to give your consent, here is what the use of your biometric data entails:

    • take a video selfie (requires access to your device's camera);
    • The IT solution used compares your face in the selfie video biometrically with the face on the copy of your ID already on BT's records.

    The biometric comparison uses criteria such as: color, size and slant of the eyes, position and distance between the main facial features such as eyes, eyebrows, lips and nose. Following the comparison, the computer solution outputs a confidence score, indicating the probability that the face in the two images belongs to the same person. If the confidence score is satisfactory, we will further check whether your ID data in our records is still valid. If they're not, you'll need to update your details on BT records and restart the application process. We will use the details taken from your ID to complete the documentation for the loan you apply for.  

    We will also check your contact details - phone number and e-mail address - to make sure they belong to you. We will also use them to let you know and remind you that you can sign your documentation electronically and to send you your credit documentation. Also, if you have not completed the application flow, we may contact you for support and to get your feedback on the application flow.

    B. Personal data processed for credit application analysis, including automated profiling-based decision-making processes

    In order to process your application for a 100% online BT loan, we process your data in BT's internal records and in the Credit Bureau's records, where we consult your situation. You can find all the information about this processing below, in pts. I and II of this section B.

    As it is essential for us to provide you with a quick response to your online credit application, we will take the decision to approve/reject your application by processing your personal data by exclusively automated means. Details of this decision can be found in point. II (5) below.

    I. Information on the processing of personal data in the Credit Bureau System. See details.

    1. Identification data of the controllers

    Banca Transilvania S.A. and Societatea Biroul de Credit S.A., a Romanian legal entity based in Bucharest, str. Sfânta Vineri, nr. 29, 4th floor, 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 April 27, 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" or "GDPR").

    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 the assessment of creditworthiness and credit risk reduction, as well as preventing the use of the financial-banking system for activities against the law.

    Banca Transilvania S.A. has the obligation, according to the legal regulations in force, to assess your ability to repay the loan, before concluding a credit agreement and during its performance. For this purpose, Banca Transilvania S.A. processes the information indicated in point (4), registered on your name in its own records and transmits them to the Credit Bureau for processing by this institution and consulting them by any Participant, in order to initiate or carry out a credit relationship, as well as to ensure 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). The refusal to provide your personal data, necessary to achieve the purpose mentioned above, will lead to the impossibility of Banca Transilvania S.A. to fulfill its legal obligations in connection with the granting of the loan.


    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 analyzing your credit application, Banca Transilvania S.A. will ask the Credit Bureau to issue a Credit Report, without FICO® Score, in order to verify whether you fall within the debt ratio established by law and whether you have the ability to repay the loan. In order to obtain the Credit Report, Banca Transilvania S.A. will send to the Credit Bureau your name, surname and personal identification 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 your debts when they fall due can be checked periodically after the credit has been granted, including by obtaining Credit Reports or by using the Alert Service*.

    If, during the loan period, you will delay the payment of the installments more than 30 calendar days from the due date, Banca Transilvania S.A. will send to the Credit Bureau information on the outstanding amounts, the category of delay, given to the first arrears and/or, as the case may be, information regarding the opening of the procedure of giving in payment, only after your notification, at least 15 calendar days before, made in writing, by phone, SMS, e-mail or other means of electronic communication.

    *TheAlert Serviceis used by Participants to identify and/or mitigate credit risk in a timely manner, by generating an alert to a Participant when an event (opening/closing account, entering/closing arrears, account correction, registering/deleting guarantor/co-debtor status, account inquiry, change of employer name/ telephone number) is registered for one of its own debtors at 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, except for the data of credit seekers who have waived their credit application or who have not been granted credit, which are protected 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 the rights provided by 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 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 loan 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 the National Supervisory Authority for Personal Data Processing and Justice.


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

    II. Information on the processing of personal data in BT for the purpose of analyzing your credit application. See details.

    This is a specific information note on the processing of personal data for the purpose of analyzing the credit application submitted to Banca Transilvania S.A. The provisions of this note are supplemented by General Information Notice on the processing and protection of personal data belonging to BT Customers.


    1. Identity of the operator

    Banca Transilvania S.A. processes your personal data as an operator for the purpose of pre-offer and, where appropriate, to analyze your credit application.


    2. Legal basis and purpose of the processing

    For the purpose of pre-offer and, where appropriate, 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 in pct. I. of this information - BT processes such data in its own records, pursuant to its legal obligations, the conclusion of the credit agreement and on the basis of its legitimate interest.


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

    The provision of personal data is necessary for the purpose referred to in point II (2). Refusal to provide the personal data necessary for this purpose would prevent the bank from fulfilling its legal obligations in relation to the granting of the credit, so that the credit application cannot be considered.


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

    The categories of personal data referred to in this information at pct. I. (4) and II. (5), as well as other data collected in the credit application, are processed by BT for pre-offer and application analysis purposes respectively.


    5. Automated decision-making process, including profiling, realized through the bank's own system and queries of external records

    In order to objectively verify whether you meet the eligibility conditions for the credit requested, we process your personal data in our own automated system, in order to take the necessary steps to conclude the credit agreement at your request, and in the legitimate interest of effectively managing credit risk. The Bank does not use the FICO® Score from the Credit Bureau to analyze your credit application.

    In the bank's own system used for analyzing your credit application, personal data collected from you during the application process are automatically processed, together with information resulting from checks carried out in the bank's own records or those of the Credit Bureau SA. We process data such as, but not limited to: identification, professional, family, economic and financial data, data about any BT products and services you already use. After analyzing all the information and as a result of consulting the records of the Credit Bureau SA, our analysis system establishes a profile of you as a borrower/potential borrower to help us determine whether you fit the credit conditions set by BT.

    On the basis of the agreement requested on a separate form, we will interrogate your data and ANAF records in order to obtain the statement of income you realize in order to verify the degree of indebtedness established by law. By way of exception, we will not ask for your consent for this consultation if you have already given your consent on the same day. If you refuse to have your data queried by ANAF, you cannot obtain your personal loan 100% online.

    To the information obtained by automatic data processing in our own analysis system, we will add the information obtained by querying the Credit Bureau and ANAF and the result of checking your situation in public databases such as the websites of the courts portal, ONRC, etc.

    We will take the decision to approve/reject your credit application by 100% automated means because the application is made online and it is essential that we respond to it in a very short time. In such situations, the decision by such means is necessary in order to be able to analyze the application quickly and, where appropriate, to conclude the credit agreement. However, you are guaranteed the right to ask for human intervention, i.e. to have your credit application examined by a bank employee, to express your point of view and to contest the decision.


    6. Recipients of the data

    In addition to the recipients mentioned in pct. I. (6) of this Notice, the personal data processed for the purposes indicated in pt. II (2) are disclosed, where applicable, to the following recipients: ANAF (in order to consult the database of the Ministry of Public Finance, if you have given your consent), Biroul de Credit S.A. (in order to consult your situation in the records of this institution), insurance companies (if you opt to take out insurance in connection with the credit), providers of various services used by the bank in the process of analyzing your credit application.


    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 the rights (right of access to data, right to rectification of data, right to erasure of data, right to restriction of data, right to object to processing) provided for by the Regulation in relation to the processing of personal data in the system of the Credit Bureau S.A. in relation with Banca Transilvania S.A. you may use any of the methods indicated in point. I.(8).

    If you exercise these rights at BT (both for the processing of personal data in the system of Bureau de Credit S.A. and within the bank) or if you wish to withdraw your consent (for the processing of personal data based on this ground), you can send a written request to the address in mun. Cluj-Napoca, Calea Dorobanților, nr. 30-36, 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 contact the National Supervisory Authority for Personal Data Processing.

    III. Information on the processing of personal data for the purpose of the constitution of the debtor's group

    Banca Transilvania S.A., as a credit institution, is subject to legal obligations to determine and analyze its exposure to groups of connected customers as part of its credit risk analysis. For this purpose it is required to collect from you, as a credit applicant and, where appropriate, from other public or internal sources, information about persons with whom you form the same debtor group, as you are related customers. Your spouse is always a connected person. If you are married, you will need to provide us with his or her full name and Social Security number.

    In addition to your spouse, there may be other natural or legal persons with whom you are part of the same debtor group. Find out more.

    In order to check whether and with whom you are in such a relationship, we will query our internal and public records (e.g. ONRC) for your details. To understand which categories of people are considered to be in a relationship with you, we recommend that you study the details available in the BT Privacy Policy on our website www.bancatransilvania.ro, in section C point 3 or at the following link: https://www.bancatransilvania.ro/Informare-Apartenenta-la-Grupuri-Credit-Online.pdf. People who are connected with you can also find information about how we process their data for this purpose from the same section of the BT Privacy Policy.

    As a reporting person, BT has a legal obligation to report these exposures and the composition of related debtor groups of customers to the NBR, the Credit Risk Center (only where applicable) and, based on its legitimate interest, may also disclose this data to entities of the Banca Transilvania Financial Group and service providers used by BT in the credit application review process. Your refusal to have this data processed may make it impossible for BT to consider your application and/or approve the credit.

    The retention period of these individuals' data on BT's records is equal to the existence of the group(s) of connected customers of which they are part, plus non-excessive storage periods.

    IV. Information about consulting your income in the anaf records - if you express your consent for this consultation

    When analyzing your credit application we have a legal obligation and a legitimate interest to establish your degree of indebtedness and your ability to repay the credit requested. This requires that we know your exact income situation. To make things go quickly, when you apply for a 100% online BT loan, we want to find out your income from your National Revenue records.

    But we will only consult them on the basis of your express consent, which we will ask for separately during the application process. See details.

    If you give your consent, we will be able to carry out the consultation for a maximum of 5 working days from the date of consent. We will usually keep the form on which you give your consent or refusal for 8 years, so that we can prove that we have fulfilled our obligation to inform you properly and to seek your consent.

    The personal data indicated below, registered in your name in the records of the Ministry of Finance, National Agency for Fiscal Administration (ANAF) would be consulted for the purposes of (i) initiating or carrying out the contractual relations in accordance with the prudential requirements applicable to BT as a credit institution and (ii) streamlining the operational lending process, as a result of the simplification of the documentation we request from you:

    • identification data of the natural person/natural person exercising an authorized activity: name and surname, domicile/residence address, personal numeric code/unique identification code, series and number of identity card, in case of non-resident persons;
    • the name of the form of exercising the profession / of achieving income, the tax identification code of the form of exercising the profession / of income realization, the address / headquarters of the form of exercising the profession / of achieving income;
    • identification data of the natural person, legal representative of the legal entity: name and surname, personal numeric code/unique identification code;
    • the nature, source and amount of income, for the period covering the last two completed tax years, including, where possible, the period between the last completed tax year and the date of application;
    • other financial information (in case of legal entity customer);

    You have the right to withdraw your consent to the processing of your personal data at any time, as indicated in the General Information Notice, referred to above. In this case, we will cease processing your data based on your consent, unless there is another legal basis for doing so. The withdrawal of consent does not, however, affect the lawfulness of data processing carried out prior to the withdrawal of consent.

    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

    If your BT credit application is approved, we will inform you below how we will process your data during the conclusion (electronic signature) and during the course of the credit agreement.

    This is a specific information notice concerning the processing of personal data for the purpose of concluding and carrying out a credit agreement. The provisions of this notice are supplemented by the General Information Notice on the processing and protection of BT Customers' personal data, which details all other purposes for which your data is processed as a BT customer.


    1. Identity of the operator

    Banca Transilvania S.A processes as operator your personal data for the conclusion and performance of the credit agreement concluded with the bank and, as the case may be, of the guarantee contract - accessory of the credit agreement.


    2. Legal basis and purpose of the processing

    For the conclusion and performance of credit agreements and, where appropriate, of the guarantee contracts related to them, the Bank processes the categories of personal data mentioned in this section in point (4), on the basis of its legal obligations, the conclusion and execution of the contract and on the basis of its legitimate interest.

    The Bank shall use any of the contact details provided by the borrower for the purposes of the contractual relationship with the Bank for the purpose of informing the borrower of the due date of each instalment and, where applicable, for the purpose of sending notifications of the expiry of insurance policies, for the recovery of debts on the credit taken out and for other events occurring in connection therewith.


    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). The refusal to have the personal data necessary to achieve the mentioned purpose processed will lead to the impossibility of the bank to provide you with the requested credit.


    4. Categories of personal data processed

    The personal data processed by the bank for the purposes referred to in point (2) are those that you are aware are processed during the pre-offer/analysis stage of the credit application (detailed in lit. B pct. I, II and III of this section of this information notice) plus other such data received from you on the occasion of/for the conclusion of the credit agreement, together with the ancillary data. When the agreement is concluded, you will be allocated an IBAN code for the credit facility, through which the payments relating to the credit facility will be made.

    We will also use the e-mail address we have requested from you, which we have verified during the application process that you use, to send you the credit agreement.


    5. Recipients of the data

    Personal data processed for the purposes referred to in paragraph (2) shall be disclosed or transferred in accordance with the applicable legal grounds, as appropriate and only under conditions that ensure full confidentiality and data security, to the following categories of recipients - Bureau de Credit S.A. and the Participants to this system, insurance companies, valuation companies, service providers used by the Bank in the credit process, debt recovery companies, the Cadastre and Real Estate Publicity Office (OCPI), the National Registry of Real Estate Publicity (RNPM), public authorities and institutions, notaries public, lawyers, bailiffs, Central Credit Risk Office*, companies (funds) guaranteeing various types of credit products.

    *The Bankhas the legal obligation to report to the Central Credit Register (CRC) the credit risk information for each borrower that fulfills the condition to be reported (it includes the identification data of a borrower, individual or non-bank legal entity, and the operations in lei and in foreign currency through which the Bank is exposed to risk with respect to that borrower), respectively to have registered an individual risk with respect to that borrower, as well as information on card frauds detected.

    **The Bankhas a legitimate interest to report in the Credit Bureau System, to which other Participants (mainly credit institutions and non-banking financial institutions) have access, your personal data in case you are at least 30 days late in the payment of your credit, after having notified you at least 15 days prior to the reporting date.


    6. Duration of storage of personal data

    Personal data processed for the purposes indicated in paragraph (2) shall be stored in the bank's records for the longest of the legally established periods or, in the absence of legal time limits, for internally established periods. Those personal data that are processed in the Credit Bureau system and disclosed to the Participants of this system shall be stored in the records of this institution for 4 years from the date of each update. In the records of the Credit Risk Center the data reported under the Bank's legal obligation, namely credit risk information and card fraud information, are maintained for a period of 7 years from the date of registration.


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

    As a data subject, you can exercise your rights under EU Regulation 679/2016 - General Data Protection Regulation: the right of access, the right to rectification of data, the right to erasure of data, the right to restriction of data, the right to object to processing.

    These rights may be exercised as follows:

    • to the Bank, by sending a written request to the bank's address in Mun. Cluj-Napoca, str. Calea Dorobanților, nr. 30-36, jud. Cluj, with the mention - "for the attention of the Data Protection Officer (DPO)" or by e-mail to dpo@btrl.ro.
    • by accessing the Credit Bureau's websitein a secure manner, in the case of data processed in the Credit Bureau System, as well as the right to address the National Authority for the Supervision of Personal Data Processing and justice.

    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 100% online BT loan, you will be required to sign your loan documentation with a qualified electronic signature. There is no cost to you to issue and use the digital certificate for signing, but BT will need to

    Detailed information about the processing of your data for this purpose can be found below.


    1. Controllers of personal data

    Pursuant to Articles 13-14 of the EU Regulation 679/2016 - General Data Protection Regulation ("GDPR"), Alfatrust Certification S.A. ("Alfatrust") and Banca Transilvania S.A. ("BT"), inform you about the processing of your personal data, as a User ("data subject"), that they carry out as associated operators for the purposes mentioned in letter b of this information.


    2. Purpose and basis of the processing of personal data

    The purpose for which the associated operators process the User's data is to issue and manage the Qualified Digital Certificate (the "Certificate").

    BT is the operator that identifies the User, respectively collects from him the personal data necessary for the issuance of the Qualified Digital Certificate, and transmits them to Alfatrust for this operator to issue the certificate.

    The data that BT collects from Users are those processed by BT in its own records, in the context of the business relationship that is already established between the User and BT at the time of transmitting the data to Alfatrust.

    During the period of validity of the certificate, personal data are processed by the associated controllers, as the case may be, as well as in situations where users request the suspension or revocation of the certificate in the ways detailed in the Terms and Conditions of Service Provision.

    The grounds for the processing of personal data for the defined purpose are the legal obligation (Art. 6 para. 1 lit.c GDPR), the conclusion / execution of the contract (Art. 6 para. 1 lit.b GDPR) and the legitimate interest of the associated operators (Art.6 para. 1 lit. f GDPR).

    As far as the legal obligation is concerned, both BT - as a credit institution with which the User has an established business relationship, and Alfatrust - as an accredited certification service provider from which the User wishes to obtain a certificate, are subject to the applicable legal provisions in the field of prevention of money laundering and terrorist financing, according to which they must collect from their customers a series of personal data. These data are also necessary for the conclusion/execution of the contract on the basis of which the User is required to use the certificate to sign the documentation in relation with BT.

    In order to support users who wish to make a request for suspension or withdrawal of the certificate, the joint operators justify a legitimate interest in offering them (who are also customers of BT) the possibility to submit these requests not only directly to Alfatrust, but also through BT. The settlement of these requests involves the exchange of the Personal Data of the Users between the two joint controllers.

    Contact details - telephone number, and home address will be processed by any of the associated operators, whenever it will be necessary to contact the end-user for the proper development of the contractual relationship related to the qualified digital certificate.


    3. Categories of personal data and persons whose personal data are processed

    The personal data processed in order to fulfill the above-mentioned purpose are those required by law to be collected by a credit institution, respectively by a certification service provider for the prevention of money laundering and terrorism, namely: name, surname, CNP, home/residence address, date of validity of the identity card, and telephone number, copy of the identity card. All this data, as provided by the User to BT, will be transmitted to Alfatrust in order to issue and manage the Qualified Digital Certificate.

    The processing of these personal data is necessary for the generation of the Qualified Digital Certificate. The User's refusal to have this data processed leads to the impossibility of issuing the Qualified Digital Certificate.

    The data subjects of this processing are only the Users as defined in the Alfatrust Terms and Conditions of Use.


    4. Recipients of personal data

    With the exception of the associated controllers between whom an exchange of the personal data processed to fulfill the purpose of the processing will be carried out, the data shall be disclosed, where appropriate, to the providers of IT services, audit services, authorities and institutions entitled to know them.


    5. Period of processing of personal data

    Information on a Qualified Digital Certificate (including personal data) is processed by Alfatrust for a period of 10 years from the date of its termination of validity, in accordance with legally established deadlines.

    At the BT level, the remote electronic signature, applied on the basis of the Qualified Digital Certificate issued by Alfatrust on the documentation signed in relation to BT, is kept for the entire period during which a business relationship is carried out between the User and BT, to which are added the terms established in the applicable legislation.


    6. Rights of data subjects for the processing of their personal data

    Any User, in his capacity as a data subject, is guaranteed the exercise of the following rights with regard to the processing of his personal data, to any of the joint controllers: the right of access, the right to rectification, the right to restriction of processing, the right to delete data, the right to object to data processing, the right to data portability.

    Users can exercise these rights or contact the data protection officers for any questions / requests regarding the processing of your personal data, as follows:

    • Banca Transilvania S.A. - by e-mail to dpo@btrl.ro or by a request sent to the bank's address in Mun. Cluj-Napoca, str. Cale Dorobanților nr. 30-36, jud. Cluj, with the mention "for the attention of the Data Protection Officer (DPO)"
    • at Alfatrust Certification S.A. - by message sent to the e-mail address suport@alfasign.ro or by a request sent to alfatrust headquarters, with the mention "to the attention of the data protection officer (DPO)"

    Users also have the right to lodge a complaint with the supervisory authority - the National Supervisory Authority for Personal Data Processing (ANSPDCP), with headquarters in Bucharest, sector 1, Bd. G-ral Gh. Magheru nr. 28-30.

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    AI Search is trained to answer questions that are exclusively related to the banking products offered by BT, but in certain situations and depending on the questions asked, it may also answer general questions. The answers provided are automatically generated and are to be used for information purposes only. The service may sometimes provide inaccurate or potentially offensive content, which does not represent the views of Banca Transilvania. You are solely responsible for your use of the content generated by this service in any way. Do not rely on this service for financial, legal or other professional advice and do not enter personal data or other confidential information into this service.

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