Privacy Policy

Performing any operation, requested at the counters of the BT units by the clients ordinary or occasional, presupposes that the Bank will go through the stage of identification of the to these people. In this regard, BT employees will ask people to present their valid id. In some cases required by law, it will also be necessary performing and retaining by BT the copy of the identity document, for the period provided by law.

Cases in which BT has the obligation to apply the standard measures of knowledge of the clients, and including to perform and withhold the copy of the identity document are Following:

• when establishing a business relationship;
• when performing occasional transactions worth at least EUR 15,000 or equivalent, whether the transaction is carried out in a single operation, or several operations that seem to have a connection between them;
• where there is a suspicion that the operation in question is aimed at money laundering, or terrorist financing, regardless of the incidence of the derogatory provisions from the the obligation to apply the standard customer-knowledge measures set out in the this law and the value of the operation;
• if there are doubts as to the veracity or relevance of the information of identification already held about the customer;

Under the legal obligation to apply standard measures of customer knowledge, which any Romanian credit institution has according to the provisions of the Regulation BNR nr. ANGEFLY NO. 9/2008 on customer knowledge in order to prevent and combat money laundering, of Law 656/2002 on preventing and combating money laundering and financing terrorism and HGR 594/2008 for the application of Law 656/2002 on combating money laundering and terrorist financing, at the time of establishing a business relationships, it is necessary to collect and keep in the records of BT at least the following categories of personal data: name, surname, date and place of birth, personal identification number or other similar unique identifier, domicile, telephone number, fax, e-mail address, citizenship and, if the case, pseudonym, address of residence, occupation, name of the employer or nature own activity, important public office held, name of the real beneficiary.

The same information is collected if a client is represented in the relationship with the bank of another person, acting as empowered, curator, guardian or in any other capacity and, in addition, data relating to the nature and limits Empowerment.

In case of establishing and carrying out the business relationship with a legal person client, it is will collect the data mentioned in the paragraphs above in order to identify the persons which, according to the articles of incorporation and/or the decision of the statutory bodies, are invested with the power to direct and represent the entity and their powers of employment of the entity, as well as for the identification of the person acting on behalf of the and information to establish that it is authorized/empowered in These data, the bank has the obligation to verify them including in the registers Public.

Under the same legal obligations, the data of identity of the beneficial owner.

The verification of the collected data will be done on the basis of identity documents, but also through verification of other sources.

Performing and retaining the copy of the deed of the identity of all these persons is also mandatory for the bank.

In the process of knowing the clientele, the bank has the legal obligation to collect including information related to the quality of the politically exposed person of the clients with whom enter into a business relationship. For this purpose only, BT will process information that falls into the category of political opinions - personal data of a special character.

Also, in accordance with the legal obligations incumbent on him in this matter, in the stage of enrollment and opening of account BT will classify customers by degrees of risk, in the basis of criteria such as nationality, residence, finding, functions or positions important owned.

In the process of knowing the clientele, based on the legal obligations of GEO no. ANAe no. 202/2008 on the implementation of international sanctions and the Regulation No. ANNThen. 28/2009 on the supervision of the implementation of sanctions international, as well as on the basis of his legitimate interest in not entering into relations of business with persons accused or suspected of non-compliance with the law, the bank processes information regarding fraudulent / potentially fraudulent activity (data on charges and convictions related to crimes such as fraud, laundering money and financing of terrorist acts) 

BT has an obligation to ensure that all such data is updated in its records throughout the business relationship with customers, meaning that it will request to update the data provided at the initiation of the business relationship, or by as many times as necessary, being able to even update them on their own initiative, from sources externally secure, public or private, accessed directly or through third parties suppliers.

All these data are kept in the bank's records according to the established legal term, which is at least 5 years after the termination of the client's business relationship with BT.

If the request for initiation of the business relationship is filled in online, in the sections available on the BT website, the applicants will have to provide the same data imposed by the aforementioned legal provisions, following that the enrollment process (establishing the relationship of afceri) to be completed only after signing the documentation in a unit of the bank. If, within 60 days from the completion of the application online opening of the business relationship the applicant does not show up in a BT unit for signing, respectively completing the enrollment process, its data will be deleted from the bank's records.

Lending is one of the main activities carried out by a credit institution. Concluding and carrying out a credit agreement with a natural or legal person, involves going through several stages in which character data is processed personnel under the legal obligations of the Bank, on the basis of the conclusion and execution credit/guarantee/evaluation contract, based on the legitimate interest that the Bank it justifies it, as well as, in some concrete situations, based on the consent data subjects of the processing.

BT allocates to each of its clients a client id (Client Id) based on which it is identified in the bank's records, as well as an IBAN code for each account (current, card, savings, etc.) opened in the name of the customer at Bank.

At the same time, for each of the cards issued by BT to its customers, it is allocates a unique number (PAN), which BT registers on the card together with the expiry date its name and surname, the name and surname of the card holder and the CVV basket (back). Based on agreement of the cardholders, there is the possibility of registering on the card including the IBAN code.

Banca Transilvania is constantly preoccupied with offering its clients with whom it concludes a business relationship such online services and products be – the internet banking service – with the variants BT24, mobile BT24 or BT24 Invoices - digital wallet payment application - BT Pay, chat both "Livia from BT" accessible via Facebook, the self serv service callable by phone. For the use of these services is necessary for the processing by the bank of certain categories of personal data in order to identify individuals as BT clients and, subsequently, as users of the services. These data are usually - name, surname, date of birth, customer code, phone number.

Some of the BT applications, which are accessible with the help of mobile equipment (example: BT24 mobile, BT Pay), may require their users either at the time of installation, or during their use, access to certain data with personal character supplementing such as, but not limited to: camera (by example for the option to scan the barcodes of the invoices), location (in certain sections of applications, for displaying units and ATMs BT located nearby or for indicating the shops of the merchants registered in the Star BT loyalty program), contacts (only when accessing the option of payments by Email / SMS / P2P for the automatic filling in of the beneficiaries' details), SMS (for the automatic completion of the SMS-OPT codes required within the various sections of applications), phone status and identity (e.g. IMEI's phone is required to activate the mbt24 mobile internet banking application), information related to the existence or non-existence of a method of securing the phone used in the Applications.

Also, when using online services, to ensure security the transactions made will be processed in some situations the IP address of the device on that you use. These data are requested and used strictly for insurance purposes the security of the transactions and processed only for the strictly necessary period.

In order to provide certain banking services, such as, but not limited to, internet and mobile banking - with the variants of BT24, mobile BT24 or BT24 Invoices- SMS Alert, BT Alert, the bank will process the phone number communicated by the clients in order to provide the respective services.

Also, the phone number, e-mail address or domicile/residence/correspondence provided by the clients for the development of the relationship of business, will be processed by the bank in order to inform clients about to issues of interest related to the functioning of the services / products contracted by the BT,as well, but not limited to interruptions in the operation of some services, institution of garnishing on bank accounts, warnings on expiry bank cards issued by BT or identity documents, but also for contacting them in the activity of debt collection.

In the case of "apply online" services for various BT products/services/contests/events, available in the form of forms on BT's website and on other websites controlled by the bank, we usually request filling in the following personal data: name, surname, telephone number and address e-mail, in order to contact the applicants to provide them with an answer/information in connection with these requests.

Depending on the specifics of the product / service for which it is applied online, there are situations when it is necessary to provide additional data, either of those imposed by legal provisions, either of those processed by BT on the basis of the legitimate interest to identify the persons in order to be able to provide them / provide them with the products / services / information Requested.

The data filled in in these forms are processed by the bank for the purpose of providing products / services / information requested, for the period necessary to fulfill these goals, according to the bank's retention policies elaborated in accordance with the the principles and obligations established by the applicable laws in the field of processing and protection of personal data.

BT will not collect or store the personal data of those who have it completed online, if they have not completed their registration.

Any person has the right to deposit cash amounts in accounts opened with BT, if the holders of these accounts have allowed such deposits to be made by third parties.

In order to make such a deposit, the bank has the legal obligation to identify payers based on their identity documents, and respectively also to process a series of their personal data - name, surname, series and number of the act of identity, personal identification number, address, details of the deposited amount and explanations on the nature of the payment (what is the payment).

In the cases provided by law, mentioned in point. I of this section, for making cash deposit The bank will have to perform and keep in his records the copy of the identity document belonging to the occasional Clinet who make deposit

If certain occasional Clients repeatedly present themselves in the units bank to make deposits of cash amounts in the accounts opened with BT, for to streamline the bank's activity, respectively to reduce the waiting time in units, the bank has a legitimate interest to use their data collected on the occasion of previous deposits, and they will be prefilled in the receipt form cash deposit. The data of external depositors will not be processed for other purposes, will be accessed only by the staff who has the need to know and keep them only for the periods stipulated in the internal retention policies and within the acts norms containing provisions on this aspect.

Any person has the opportunity to address the bank's requests, to request the provision of information / taking measures or can send him complaints / complaints, on various channels such as – by sending/submitting legal complaints at the bank's headquarters or of its territorial units, by calling the phone number of the call center BT or any other phone number assigned to BT units, by sending messages on e-mail addresses made available to customers or on the addresses of e-mail of the bank's employees, by sending electronic messages in the framework of the secure internet banking platform BT24, by filling in some forms dedicated on the BT website or on other websites controlled by the bank - for the list all BT websites enter here.

To identify the requesting persons, to analyze the reported situation and to to respond to these requests for information / notifications / complaints, the bank processes a series of personal data - name, surname, telephone number, address of electronic mail or correspondence from which the request was received, other personal data provided within the messages or that is required to be processed in order to formulate answers / provide the requested information.

In order to prove that these complaints / complaints / requests for information/measures, as well as for quality control answers/information/actions transmitted/taken by the bank, as well as for purposes of quality control of the support services, the received messages will be kept in the records BT both in the format in which they were received, as well as in electronic format, and phone calls will be recorded and kept during the business relationship for BT clients, respectively for a period necessary to fulfill the purpose in which have been processed (formulating the answer/providing the information), plus a period of 3 years - the legal term of prescription if the data do not belong to persons with which bank has established a business relationship.

According to the provisions of Law nr. 333/2003 on the security of objectives, goods, values and the protection of persons, with subsequent amendments and completions and of the Decision No. 301 of April 11, 2012 for the approval of the Methodological Norms of Law no. 333/2003 regarding the security of objectives, goods, values and the protection of persons, BT has the legal obligation to video surveillance the ATM area, as well as the areas of the horses access, hallways and other high-risk areas.

Based on its legitimate interest, the bank understands to supervise video and other areas accessible to the public that presents a potential security risk for persons/spaces or goods.

The video surveillance activity involves the processing of the image of the persons, and the places where the cameras are located are properly marked, by a specific and prominent notice accompanied by the icon.

The video surveillance system is not used for any purpose other than the one mentioned, not uses to monitor the activity of the public, employees or timekeeping. Of Nor is the system a means of investigating or obtaining information for internal investigations or disciplinary proceedings, except where a physical security incident occurs or criminal behavior is observed (in exceptional circumstances the images may be transferred to the investigating bodies in the framework of a disciplinary or criminal investigation).

The system can record any movement detected by the cameras installed in the area supervised, along with date, time and location. All rooms are functional 24 hours, 7 days a week. When necessary, the quality of the images allows recognition of people passing through the action zone of the cameras. Records video are stored in the internal records of the bank.

In addition to image processing in the framework of the video surveillance activity, to allows visitors' access to some spaces where the bank operates, the personnel with security attributions will identify the visiting persons based on the documents their identity, and the name, surname, series and number of the identity document of the these persons are to be registered in special registers and kept in the format letric for the legally established period.

BT wants to inform interested persons about the products /services/ events offered/organized by the bank, the entities of the BT Financial Group or by the their partners, meaning that they process the personal data of these persons, if they have expressed their consent to receive such advertising messages by filling in the dedicated form, accessible in any unit of the bank and on website.

The data processed by BT for the purpose of transmitting advertising messages are usually name, surname, telephone number and/or e-mail address or correspondence provided by persons interested in receiving advertising mesae. To ensure that the advertising messages transmitted are relevant to its customers, The bank will process other information it finds out about the client, in the context in which they use BT's services/products (e.g. transaction data, age, location, income range, etc.), on which he will automatically study (profiling) to create an opinion related to the products/services/events that would be appropriate.

The personal data will be processed by the Bank until the termination of the relationship business with the data subjects or, as the case may be, until the withdrawal of their agreement to receive such messages.

Advertising messages will be transmitted mainly on SMS channels, phone call, e-mail address, postal correspondence address.

In some cases, for the transmission of advertising messages on these channels, BT will contract service providers, who will process the personal data of persons in the name and for BT, only for the transmission of advertising messages established in compliance with the instructions of BT and being under the close supervision of the Bank.

Willing people can choose to receive advertising messages from several categories, including: products and services of BT, products and services of the BT subsidiaries, events organized by BT, products/services of partners, which are related to products/services of BT or BT subsidiaries and events organized by BT partners.

BT subsidiaries whose products/services and events are intended to be promoted in the framework of advertising messages sent to persons who have opted for this purpose  are the following entities in within the Banca Transilvania Financial Group 

• BT Microfinance IFN SA ("BT Mic")
• BT Asset Management S.A.I. S.A. ( "BTAM")
• BT Leasing Transilvania IFN S.A. ("BTL")
• BT Direct IFN S.A. ("BTD")
• BT Capital Partners S.S.I.F. S.A.("BTCP")
• other entitsthat can be ofthis group in the future

The list of current categories of partners of BT and/or subsidiaries of BT is accessible at the https://www.bancatransilvania.ro//Sites_portofoliu_BT_25.05.2018-14.08.2019_versiunea_1.pdf link and https://www.bancatransilvania.ro//Parteneri_BT_Politica_Confidentialitate_31.07.2019-prezent_Versiunea_2.pdf or in any BT or BT subsidiary establishment.

If you have opted to receive advertising messages about products/services of events offered/organized by BT subsidiaries or by partners, these entities will process the personal data for the purpose of transmitting these messages, under close supervision and coordination of the Bank. For any possible processing of personal data carried out by BT partners / subsidiaries of BT  outside or adjacent to the transmission of advertising messages, such as, for example, in order to conclude contracts related to their products / services that have been promoted, these partners are going to act as operators of the processed personal data.

Consent to receive advertising messages may be withdrawn or modified by several modalities, indicated separately on the form for expressing the consent to the processing of personal data for advertising purposes.

In some concrete cases, with strict respect for rights and freedoms to individuals, Banca Transilvania will process personal data for the purpose of transmission of advertising messages based on its legitimate interest in promoting the products and services they offer.

BT is one of the companies with the largest number of employees in Romania, and ads about various vacancies in the bank are posted on recruitment sites. People who access these sites and apply for specific positions available in BT or the "careers" section of the www.bancatransilvania.rowebsite, will be directed to the platform secure recruitment used by Banca Transilvania.

Within this platform, either they will want to apply only for a certain post, or that will prefer that the bank can contact them for different positions available in the company, candidates will be asked to create an account, entering their name, first name, a phone number and an e-mail address where it can be contact for recruitment purposes and upload at least their CV.

If it will apply only for a certain post accessed, the personal data of the the candidate will be processed by the bank only within the recruitment process for that post, following that they and the account created in the platform to be deleted at completing the recruitment process for the respective position.

If, instead, the candidate will choose to be contacted generally for vacancies in the BT, it will be necessary to select a series of predefined criteria in the platform, in the basis of which will be announced about the availability of posts that are Fit. In this case, the candidate's data will be kept for recruitment purposes for a period of 1 year from the moment of registration of this option.

The same retention period applies if the CVs were handed over /transmitted to the Bank by the candidates on any other channels.

After the expiry of the mentioned term, BT will anonymize the personal data collected for recruitment purposes, and they will be used only for the generation of statistical reports for the internal use of the bank. Once these records become anonymous, they can no longer identify the person to whom they belong.

In the recruitment process, references from employers can become relevant previous candidates. If the bank needs them, it will contact the candidate to ask for his consent to obtain them on his behalf. If the candidate does not will express his consent in this regard, it will be necessary to obtain these himself references, if he wants to continue the recruitment process.

The candidate has the option to delete at any time the account created within the BT's recruitment platform, which will equate to the withdrawal of consent or as the bank to process his personal data for recruitment purposes. From the moment deleting the account in the platform, only the candidate will be able to access his/her data registered, not BT.

If the bank will receive CVs or job applications on other channels than the recruitment platform indicated above, will keep these data for the same periods of time mentioned above, respectively until the end of the recruitment process for the chosen post, or, as the case may be, for a period of 6 months, which can be extended at the request of the candidate, if he/she wants to apply for various positions available in the company.

In addition to the purposes detailed in the previous sections, the Bank Transylvania also processes personal data for other purposes, such as:

• performing analyses and keeping economic and financial management records and/or administrative in the Bank;
• administration within the internal departments of the services and products offered by the bank;
• evaluating and monitoring the financial-commercial behavior of the Clients on the during the business relationship with the Bank; 
• creating or analyzing profiles to improve BT products/services or of the entities in the BT Group;
• analyzing the behavior of website users through the use of cookies, both of BT and of third parties, in order to provide general content or customized, offers tailored to the interests of users (details in  Cookie Policy);
• conducting internal analysis (including statistics), both on products / services, as well as with regard to the client portfolio, for the improvement of and the development of products/services, as well as the performance of studies and analyses of the market regarding the Bank's products/services;
• calculation of the commissions to which the employees acting within the the sales force of BT;
• archiving both in physical and electronic format of documents, making correspondence registry services addressed to and dispatched by BT, as well as carrying out courier activities; 
• settlement of disputes, investigations or any other petitions/complaints/requests in which BT is involved; 
• performing risk controls over BT's procedures and processes, as well as carrying out audit or investigation activities;
• making and transmitting reports to the competent institutions to them receive in accordance with the legal provisions applicable to BT (eg reports about the payment incidents at the Payment Incidents Central within the NBR, declaring transactions that exceed the amount established by law to the Office National Prevention and Control of Money Laundering);
• for monitoring the clients' activity in order to detect transactions unusual and suspicious transactions;