Information note on the processing of personal data for obtaining / increasing an overdraft exclusively online, 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 customers natural persons who are holders of debit cards the possibility to obtain / increase the credit line in the current account to which this debit card is attached, exclusively online. This type of credit is hereinafter referred to as the 'overdraft'.
In the general note indicated above, which forms an integral part of the BT Privacy Policywebsite, 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 an overdraft 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 an overdraft, the information is also valid for the data processing that is carried out when you request the increase of an overdraft that you have previously obtained (regardless of whether you have contracted it in a BT unit or online).
Also, when referring to the processing of personal data for the conclusion and performance of the credit agreement, 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 to increase the credit line of a card you have previously obtained (regardless of whether you took it out in a BT establishment or online).
On what grounds do we process data and what happens if you refuse to process it?
The processing of personal data carried out by BT in the context of the application and, where appropriate, the contracting of an exclusively online overdraft are based on the following grounds:
- the legal obligations to which BT is subject by various normative acts,
- the conclusion/execution of the overdraft contract or the completion of 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 to assess your creditworthiness, legitimate interest in contacting you to resolve situations that may arise when you apply for obtaining/increasing your overdraft line of credit),
- 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 separately the purposes for which we would process your personal data so that you can apply and, as the case may be, contract an overdraft 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 purpose of providing support or evaluating 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 an overdraft in a BT unit, his or her identity is verified on the basis of the identity document presented in the original. 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 BT client 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 freely decide whether you want to express it, here's what the use of your biometric data involves:
- 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 picture of the CI the section that comprises your face, select it and then compare it with the face from the copy of your identity document that is already recorded in the BT records. The comparison is made biometrically, based on criteria such as: the color, size and inclination of the eyes, the position and the distance between the main elements of the face such as the eyes, eyebrows, lips and nose. Following the comparison, the IT solution will issue a confidence score, indicating the probability that the face in the two images belongs to the same person.
If you do not want your biometric data (facial identification) to be processed, you can apply for overdraft 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 the analysis of the credit application, including automated decision-making processes based on the creation of profiles
In order to analyze the application by which you apply for an overdraft 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. I and II below.
Because it is essential to be able to provide you with a quick response to your online overdraft request, we will decide to grant the credit or, as the case may be, to reject this request based on exclusively automatic data processing, 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 get an overdraft exclusively online, you will need to sign the credit documentation with a qualified electronic signature. Issuing and using the digital certificate for signing does not entail costs for you, but it is necessary for BT and Alfatrust to process together, as joint controllers, personal data concerning you for the issuance of this electronic signature.