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    • Personal data processing and protection policy - previous versions - 15082019-30092019

    Privacy Policy

    Policy of Banca Transilvania S.A. on the processing and protection of personal data personal data protection within the framework of banking activities ("Policy" or "BT Privacy Policy")

    At Banca Transilvania S.A. (hereinafter referred to as "BT", "the Bank" or "we") we are concerned with that the personal data of all individuals with whom we interact are processed in full compliance with the applicable legal provisions and with the highest standards of security and confidentiality.

    To guide and support us in our work in the field of data processing and data protection with personal data, we have appointed a data protection officer (DPO), who can be contacted by any person about any issues relating to the way BT processes data data by sending a complaint to:

    • BT headquarters in mun. Cluj-Napoca, str. G. Barițiu, nr. 8, jud. Cluj, with the mention "to the attention of the Data Protection Officer" or of a message to
    • the e-mail address dpo@btrl.ro

    The following is our policy in this very important area, which we are committed to to review it from time to time with a view to continuous improvement.

    By this Policy we intend to comply with all categories of individuals whose data personal data we process in the course of our banking business ("data subjects"), we are obliged to information in accordance with the provisions of Articles 13 -14 of EU Regulation No 679/2016 or Regulation General Data Protection Regulation ("GDPR").

    Whenever we have the objective possibility of directly informing certain categories of people data subjects about the processing of their data, we undertake to do so.

    In some cases, however, either we do not have the objective possibility or it would involve a disproportionate effort to bank to fulfil this obligation directly. For all these situations, we fulfil our obligation to information through this Privacy Policy.

    If you are a regular customer of the bank - BT Client - and you want to consult only the section on the processing of data of this category of data subjects, you can access:   General information note on the processing and protection of personal data belonging to BT Customers, which is an integral part of this Policy.

    This Policy is not addressed to employees of Banca Transilvania, this category of persons concerned being informed about the personal data that BT processes as an employer through a separate document.

    We will present below what categories of personal data we process in the framework of our activity who the data subjects are, for what purposes we use the personal data, and for what purposes we use them. to whom we disclose or transfer it, how long we keep it, how we ensure the security of personal data, and how we use it. their security, as well as what rights data subjects can exercise in relation to their personal data. such processing.

    If you are not familiar with the meaning of the various specialist terms used in the GDPR or applicable banking legislation, we recommend that you first study the section on:

    The terms defined in this section shall have the following meanings where when used in this Policy:

    • 'personal data' means any information relating to a natural person identified or identifiable natural person ("data subject"); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifiable identification, such as a name, an identification number, location data, an online identifier, or one or more specific elements specific to his or her identity physical, physiological, genetic, mental, economic, cultural or social identity
    • "Processing of personal data" or "data processing" means any operation or set of operations which is performed upon personal data or upon sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or making available otherwise made available, aligning or combining, restricting, deleting or destruction
    • "GDPR" means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to processing of personal data and on the free movement of such data, and of repealing Directive 95/46/EC;
    • "BT Financial Group"- The Bank together with entities controlled by it such as, BT Microfinance IFN SA ("BT Mic") , BT Asset Management S.A.A.I. S.A., ( "BTAM") , BT Leasing Transilvania IFN S.A. S.A. ("BTL") , BT Direct IFN S.A. ("BTD") , BT Capital Partners S.S.I.F. S.A.("BTCP") , The Romanian Entrepreneur's Club Foundation, Clujul are Suflet Foundation and other entities that may join this group in the future;
    • "Operator" means a legal person, which alone or jointly with others determines the purposes and means of the processing of personal data;
    • "data subject" means the natural person whose personal data are processed;
    • "Recipient" means the natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not it is a third party;
    • "Third party" means a natural or legal person, public authority, agency or other body, other than the Targeted Person, the Operator, the Authorised Person and which, under the direct authority of the Operator or the Authorised Person is authorised to process Personal Data;
    • "Supervisory Authority" means an independent public authority established by a Member State, responsible for monitoring the application of the GDPR. In Romania the supervisory authority is the National Supervisory Authority for the Processing of Personal Data. National Authority for Personal Data Processing - "ANSPDCP";
    • "Biometric data" means personal data resulting from specific processing techniques relating to physical, physiological or chemical characteristics behavioural characteristics of a natural person which enable or confirm the unique identification of that person, such as facial images or dactyloscopic data;
    • "Health data" means personal data relating to health physical or mental health of an individual, including the provision of healthcare services, which reveals information about his or her state of health;
    • "Specimen Signature" means the Client's handwritten signature on the documents used in the Customer's relationship with the Bank and/or the Customer's signature captured by the Device electronic signature (SignaturePad) provided to the Bank as a specimen signature;
    • "Beneficial owner" as defined in Art. 4 para. 1 of Law no. 129/2019 for the prevention and combating of money laundering and terrorist financing and for amending and supplementing certain legal acts, is any natural person who owns or ultimately controls the customer and/or the natural person on whose behalf the transaction, operation or activity is carried out and includes at least the categories of natural persons referred to in Article 4(4). 2 of this normative act;
    • "Publicly exposed person" as defined in Article 3 para. 1 of Law no. 129/2019 on preventing and combating money laundering and terrorist financing, and for amending and supplementing certain regulatory acts, are natural persons who exercise or have exercised important public functions and includes at least the categories of natural persons referred to in Article 3(3). 2 of this normative act.

    BANCA TRANSILVANIA S.A.   is a credit institution, legal person Romanian, registered at the Cluj Trade Register Office under the number J12/4155/1993, having the unique registration code no. RO5022670 and the following contact details: registered office address George Barițiu Street Nr. 8, postal code 400027, Cluj-Napoca, Cluj County, Romania Tel: 0801 01 01 0128 (BT) - callable from Romtelecom network, 0264 30 8028 (BT) - callable from any network, including international, *8028 (BT) - callable from Vodafone and Orange networks, e-mail address:   contact@bancatransilvania.ro, website   www.bancatransilvania.ro.

    BT has more than 500 units - branches, agencies, outlets, operating in Romania, as well as units through which it conducts its banking business in Italy.

    Our official website is www.bancatransilvania.ro (hereinafter referred to as "the website"). BT WEBSITE").

    The Bank also manages other internet pages, the updated list of which you can consult here: https://www.bancatransilvania.ro//site-uri-bt.pdf

    Banca Transilvania S.A. is the parent company of Banca Transilvania Financial Group (referred to in hereinafter referred to as the "BT Group"), which also comprises the following subsidiaries of Bank: BT Microfinanțare 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")

    C. What personal data BT processes, to whom it belongs and for what purposes use?

    Within the framework of its banking activity, Banca Transilvania processes various categories of data personal data, depending on the capacity of the data subjects in relation to BT. The purposes in which we process data are also directly dependent on the way in which the different categories of data subjects enter into a relationship with us.

    With regard to your relationship with the bank in a particular context, we present you separately below how we will process your personal data:

    a. Who is a BT customer?

    "BT Customer" or "Customer" means an individual who is a member of any of the following categories of data subjects:

    • residents or non-residents who hold at least one account with the Bank (also referred to as "natural person customer account holder") or who complete the dedicated forms to acquire this status;
    • the legal or contractual representatives of the natural or legal person clients of account, including Customers of the type of authorised natural persons;
    • authorised representatives with operating rights on the accounts of natural or legal persons account holders;
    • the beneficial owners of the Customers who are natural or legal persons holding open accounts with BT;
    • persons with the right to make bank deposits, withdraw bank statements and/or deposit sums of money in the name and on behalf of natural or legal person customers account holders (also known as "delegates");
    • any other individual users of a bank product/service who have not the status of Customer account holder, legal representative, authorised representative, delegate or beneficiary such as, but not limited to: additional card users, users of the Bank's internet/mobile banking services, users of mobile payment applications offered by bank, managers with collateral management accounts opened with the bank, users of BT meal vouchers);
    • guarantors of any kind of payment obligations undertaken by the Customers natural persons or legal account holders;
    • persons who apply to the bank for the opening of a contractual relationship and/or the contracting of a a certain product/service of the bank, even if this request is rejected;
    • the legal or conventional successors of the aforementioned.

    We remind you that complete details, in printable format, about the processing by BT of the data of its regular customers – BT Customers – can also be found in   the General Information Note on the processing and protection of personal data belonging to BT Customers

    b. Purposes for which we process personal data of BT customers

    Upon case, if you are a BT customer, we shall process your personal data as follows:

    • identity verification to prevent money laundering and terrorist financing, as well as to confirm BT customer status;

    Identity verification is carried out when establishing and during the course of a relationship of business relationship, when ordering any transaction or when requesting information or to carry out transactions such as, but not limited to: account information, filing/transmitting any requests/submissions, surrendering cards, tokens, expressing any options, contracting any of the bank's products/services, accessing any of the bank's services already services already contracted, as well as on the occasion of telephone calls initiated by Customers or by bank.

    In the bank's branches, identity is verified on the basis of identity documents within the which must be presented in original, and in the online environment and during calls telephone calls initiated by the Customer or by the bank, by requesting the provision and validation of information already in the bank's records about the Customer;

    • Know Your Customer for the prevention of money laundering and terrorist financing, including risk-based verification, by applying Know Your Customer measures involving both identity verification and the processing of certain personal data personal data required by law, both at the time of acquisition by an individual of the quality of Customer (data collection), throughout the period during which this quality is (updating of data), as well as after that moment, for the period of time legally established after the moment when the Client ceases to be a Client (data storage and processing for the purposes permitted by law);
    • assessing creditworthiness, reducing credit risk, determining the degree of of clients interested in personalised offers in relation to credit products. products or the contracting of these types of products (credit risk analysis). risk analysis);
    • the conclusion and execution of contracts between the bank and its customers relating to products and services offered by it on its own behalf (such as, but not limited to: cards, deposits, loans, internet and mobile banking, SMS Alert);
    • For details on the processing of personal data within the service Self Service Livia from BT, please visit the following link: https://www.bancatransilvania.ro/files/self-service-livia-de-la-bt/nota_informare_prelucrare_date_caracter_personal_serviciu_livia_de_la_bt.pdf
    • >For details on the processing of personal data within the   BT Visual Help   service, please access the following link: https://www.bancatransilvania.ro//Nota-de-informare-privind-prelucrarea-datelor-cu-caracter-personal-in-cadrul-BT-VISUAL-HELP.pdf
    • the conclusion and performance of contracts relating to occasional transactions, such as but not limited to but not limited to: cash deposits made by Customers at counters or with the help of bank's machines, where the amounts are deposited in bank accounts on which the said Customers do not have operating rights (are not account holders, authorised representative, delegate on those accounts), money transfer services, foreign exchange;
    • settlement of transactions;
    • the establishment of attachments, the recording of the amounts attached at the disposal of creditors and the provision of replies thereto to enforcement bodies and/or authorities authorities, in accordance with the bank's legal obligations;
    • monitoring the security of persons, premises and/or property of the bank or the visitors to its premises;
    • the production and transmission of reports to the institutions competent to receive them, in in accordance with the legal provisions applicable to the bank (such as, but not limited to: reports on payment incidents to the NBR's Payment Incident Centre, reporting of transactions exceeding the amount established by law to the National Bank of Greece's Prevention and Combating Money Laundering);
    • carrying out analyses and keeping records of economic, financial and/or administrative management of the bank;
    • administration within internal departments of the services and products offered by bank;
    • assessing and monitoring the financial and commercial behaviour of Clients during business relationship with the bank, in order to detect unusual transactions and suspicious transactions, in accordance with the legal obligations to know the Customer established in the bank's responsibility for the prevention of money laundering and terrorist financing; 
    • debit collection and recovery of receivables registered by the customers;
    • preventing persons with a valid identity card from acquiring or regaining the status of Client. inappropriate behaviour which is likely to prevent the performance of an activity prudent banking activities in accordance with the bank's legal obligations;
    • the legal defence of the bank's rights and interests, the settlement of disputes, investigations or any other petitions/complaints/applications in which the bank is involved. involved; 
    • performing risk controls on bank procedures and processes, and carrying out audits or investigations;
    • taking action/providing information or responding to requests/complaints/complaints of any nature addressed to the bank by any person and/or by authorities or institutions, on any channel, including via electronic communications services and the Internet;
    • proof of claims/agreements/options on certain issues requested/discussed/agreed in telephone calls initiated by the Customer or the bank, by recording the matters discussed and, where appropriate, the audio recording of telephone calls or, where appropriate, audio-video;
    • informing Customers about the products/services they hold at the bank, in the proper performance of contracts (such as, but not limited to, statements of account or information on the opening hours of the bank's offices, information on the bank's services, information on of account attachments, notifications of unauthorised debits or about overdue instalments, information about the approaching deadline for the of a particular product/service owned, information about improvements or new facilities offered in connection with the product/service owned);
    • sending of advertising messages, according to the consent expressed by Customers on forms available in the bank's branches, on its website or within the services offered online;
    • collecting customers' opinions on the quality of BT's services/products/employees (service quality assessment);
    • the Customers’ financial education;
    • conducting internal analyses (including statistical), both on products/services, and on the portfolio and profile of customers, for the improvement and development of of products/services, as well as carrying out studies, market analyses, opinion analyses Customers on the Bank's products/services/employees;
    • archiving - both in physical and electronic format - of documents, making copies of documents back-up;
    • providing registry and secretarial services for correspondence addressed to and/or dispatched by the bank, as well as for carrying out the bank's courier activities; 
    • ensuring the security of the IT systems used by BT and the physical premises in which bank carries out its activities;
    • fraud prevention;
    • calculation of the fees to which certain categories of bank employees are entitled to.

    c. Categories of personal data belonging to BT Customers, processed upon case

    • identification data: name, surname, pseudonym (if applicable), date and place of birth, personal identification number (CNP) or similar unique identifier such as CUI for authorised natural persons or CIF for natural persons carrying out professions (e.g. another unique identifier is allocated by the bank to customers in category "non-residents" and this is represented by a code consisting of a sequence of year, month, date of birth and identity card number, either in full or in truncated), the series and the national or international identity card/passport number, as well as a copy of the passport, home address and residence;
    • contact details: mailing address (if applicable), telephone number, fax number, e-mail address;
    • citizenship;
    • information about the purpose and the nature of the business relationship;
    • financial data (such as, but not limited to, transaction data, including the amount of expected transactions);
    • fiscal data (country of fiscal residence);
    • profession, occupation, name of employer or nature of own activity (if applicable) if applicable),
    • information on important public office held - if any - and political opinions (exclusively in the context of obtaining information related to the exposed person's public - PEP);
    • the capacity, holdings and, where applicable, powers of representation held in legal persons;
    • information on family situation (including marital status, number of children, children in dependent children, etc.);
    • information on the economic and financial situation (including data on income, data transactions and their history, data on assets owned/leased in the country of residence, and ownership, and payment behaviour data);
    • image (contained in ID documents or captured by video surveillance cameras installed in the bank's premises, on BT's equipment, as well as in recordings audio and/or video recordings, as appropriate);
    • voice, in telephone or audio/video calls and recordings (initiated by Customers or the bank);
    • age, to check eligibility to contract certain products/services/offers of bank (e.g. loan products, products for minors, etc.);
    • opinions, expressed in the context of complaints/appeals/conversations, including by telephone, in in connection with the bank's products/services/employees;
    • signature (including within signature samples);
    • biometric data (such as, but not limited to, the situation of card-not-knowing persons or visually impaired persons who may be fingerprinted);
    • identifiers, including identifiers allocated by Banca Transilvania or other institutions financial-banking or non-banking institutions, necessary for the provision of certain services, such as, but not limited to limited to: BT Customer Code (BT CIF), transaction identifiers, IBAN codes codes attached to bank accounts, debit/credit card numbers, card expiry dates, contract numbers, codes and operating system type of mobile phones or other devices used to access mobile banking services/applications payment applications, as well as the IP address of the device used to access these services. services. Mobile phone codes, operating system type and IP addresses shall be processed exclusively for the purpose of ensuring security measures for the transactions carried out through these services in order to prevent fraud;
    • health data, only if the processing of such data it is necessary for the purpose of proving to the Customer that he/she is in distress or their family members, in particular for the purpose of granting facilities or in the context of the provision/delivery of insurance products/services intermediated by the bank;
    • for credit products: type of product, term of grant, date of grant, date maturity, amounts and credits granted, amounts due, account status, date of closure currency of credit, frequency of payments, amount paid, monthly rate, name and address of employer, amounts due, amounts outstanding, number of instalments outstanding, date due date of arrears, number of days in arrears in repayment of credit. These data shall be processed both in the bank's own records and - where applicable - in the system of the Credit Bureau and/or other such records/systems;
    • information on fraudulent/potentially fraudulent activity, consisting of data relating to allegations and convictions in relation to offences such as fraud, money laundering and terrorist financing;
    • information relating to the commission of offences or contraventions in the field of financial-banking offences, in direct relation with Banca Transilvania S.A., ascertained by decisions final or irrevocable judgments, as the case may be, or by administrative acts uncontested;
    • information on the location of certain transactions (by default, in the case of operations on BT equipment belonging to Banca Transilvania);
    • data and information related to products and services offered by the bank or its collaborators which the data subjects use (such as, but not limited to, products credit, deposit, insurance products);
    • any other personal data belonging to the Customers which are brought to our attention in various contexts by other Customers or any other persons.

    a. Who is/what are the situations in which we process your data as an Occasional Customer BT?

    "BT occasional customer" is the natural person who orders at the counter or through BT's equipment transactions of the following types:

    • cash deposits to BT accounts on which they have no standing (including BT customers depositing sums into bank accounts on which they have no standing will act in this quality);
    • FX exchange;
    • Western Union (WU) money transfers;
    • payment of utility bills;
    • payment of different instalments of insurance premiums;
    • cashing dividends or other types of cash amounts;
    • cash withdrawals from BT machines with cards issued by other banking institutions or by payment cards etc).

    The specific information notice on the processing of personal data for the purpose of cash deposits can be found here https://www.bancatransilvania.ro//Politica-privind-prelucrarea-si-protectia-datelor-cu-caracter-personal-versiune-valabila-in-perioada-15-08-2019-30-09-2019.pdf

    We process your data as an occasional BT customer whenever you carry out transactions of transactions, even if you are also a regular customer of the bank.

    b. Purposes for which we process personal data of BT walk-in clients

    When you act in relation to BT as a casual customer, you are processed data, as appropriate, for the following purposes:

    • identity verification to prevent money laundering and terrorist financing; In the case of occasional transactions carried out through bank units, identity shall be verified in valid identity documents, which must be presented in the bank's original, and in the case of the use of BT's equipment through other information on payer in the bank's records;
    • Know your customer to prevent money laundering and terrorist financing, including risk-based verification through the application of know-your-customer measures;
    • assessing and monitoring financial and commercial behaviour to detect unusual transactions and suspicious transactions, in accordance with the legal obligations to the bank's customer due diligence obligations for the prevention of money laundering and terrorist financing;
    • concluding and signing the agreements related to occasional transactions;
    • settlement of transactions;
    • the production and transmission of reports to the institutions competent to receive them, in in accordance with the legal provisions applicable to the bank (such as, but not limited to: reports on payment incidents to the NBR's Payment Incident Centre, reporting of transactions exceeding the amount established by law to the National Bank of Greece's Prevention and Combating Money Laundering);
    • carrying out analyses and keeping economic, financial and/or management records administrative management of the bank;
    • administration within internal departments of the services and products offered by bank;
    • the legal defence of the bank's rights and interests, the settlement of disputes, investigations or any other petitions/complaints/applications in which the bank is involved. involved; 
    • performing risk controls on bank procedures and processes, and carrying out audits or investigations;
    • monitoring/security of persons, premises and/or property of the bank or the visitors to its premises;
    • taking action/providing information or responding to requests/complaints/complaints of any nature addressed to the Bank by any person and/or by authorities or institutions, on any channel, including via electronic communications services and the Internet;
    • performance of internal analysis (including statistics);
    • archiving - both in physical and electronic format - of documents, making copies of back-up;
    • providing registry and secretarial services for correspondence addressed to and/or dispatched by the bank, as well as for carrying out the bank's courier activities; 
    • ensuring the security of the IT systems used by BT and the physical premises in which bank carries out its activities;
    • prevention of fraud.

    c. Categories of personal data belonging to BT walk-in clients, processed upon case

    We process the following categories of data for BT's occasional customers as appropriate personal data:

    • identification data - name, surname, series and number of national identity card or passport, personal identification number (CNP) or other unique identifier similar identification number, such as CUI for authorised natural persons or CIF for persons individuals carrying out liberal professions (e.g. another unique identifier is allocated by the bank to customers in the "non-resident" category and this is represented by a code consisting of a sequence of digits relating to the year, month, day of birth and number of identity card (whole or truncated), home address and - in some cases including a copy of the identity card (usually when depositing money in a bank). currency exchange, money transfer services above a certain amount or which suspicious);
    • details of the amount involved in the transaction and an explanation of the nature of the payment (what represents payment);
    • the transaction identifier;
    • signature;
    • contact details - telephone number and/or e-mail address in the case of depositors of amounts in who are not BT customers and who wish to provide us with them in order to be notified in the event of the transaction is cancelled);
    • the image (from the ID card, if a copy of the ID card needs to be retained) or, where appropriate, captured by video surveillance cameras);
    • information on the location of certain transactions (by default, in the case of transactions on LV equipment);

    a. Who is a natural person related to the applicant for credit BT CREDIT?

    Are natural persons connected with the applicant for credit* (also referred to as "applicant" or "borrower") and form the same group with the latter, any of those indicated in the table below:

    *The loan applicant is a natural or legal person who applies to BT for a credit application.
    A credit applicant includes the spouse/partner of spouse/life partner/co-debtor/guarantor of the main credit applicant.

    • The applicant's spouse/life partner together with the companies over which the applicant controls or manages
    • Other close members of the applicant's family together with the companies over which they control or manage, to the extent that between them and the applicant for credit applicant or between the companies they control/manage a relationship of: direct or indirect control/dominant influence/dependence economic
    • The legal entities where the loan applicant exercises direct or indirect control through any of the following:
      • Holding at least 50% of the shares/ shares;
        and/or
      • Ability to get a majority of votes in the AGA
        and/or
      • Ability to appoint/revoke the majority of the members of the governing bodies, administrative or supervisory bodies
    • The legal entities where the loan applicant is a director
    • Entities in which the applicant is the managing director or the head in the case of foundations/associations/public bodies
    • Parent companies/subsidiaries of the companies listed in points 3 and 4;
      Companies controlled by the companies listed under 3 and 4.
    • Directors and persons directly or indirectly exercising control in 3, 4 and 6 except those mentioned above
    • The natural and/or legal person who guarantees with his assets (including income in case of co-obligor/guarantor) of the applicant's credit, if the enforcement of such guarantees would affect it in such a way that it would jeopardise its ability to pay

    b. The purposes for which we process data belonging to individuals in a group BT debtor

    If you are such a person, BT processes your data, upon case, for the following main purpose:

    • assessing creditworthiness, reducing credit risk, determining the degree of of clients interested in personalised offers in relation to credit products. products or the contracting of these types of products (credit risk analysis). credit risk analysis);

    In the context of the examination of a credit application of a natural or legal person, the Bank shall Transilvania S.A. also processes your personal data, if you include any of the categories of natural persons indicated in the table above (which part of the borrower's group), as the bank is subject to legal obligations to establish and analyse its exposure to related customer groups as part of the analysis credit risk analysis.
    Also, as a reporting person, the bank will report these exposures and the composition of the related customer groups to the NBR, Credit Risk Centre (only where applicable).
    These data of yours are necessary for the bank to proceed with the analysis of the credit application/application, and the refusal of the credit applicant (or of you) to provide them or to be processed may make it impossible for the bank to analyse and/or approve the credit.

    Your personal data shall be transmitted/disclosed, as appropriate, to the Central Credit Risk Centre of the NBR, as well as, with respect to the need-to-know principle, to entities within the BT Financial Group and/or to service providers used by the Bank in the credit application analysis process.

    The period of retention of your data in the bank's records is equal to the period of existence of of a group/groups of connected customers to which you belong.

    Other purposes related to the main purpose indicated above for which we process your data are, as appropriate, the following:

    • verification of identity, including confirmation/confirmation of your status as BT customer;
    • the production and transmission of reports to the institutions competent to receive them, in in accordance with the legal provisions applicable to the bank (such as, but not limited to: Credit Risk Centre of the NBR);
    • carrying out analyses and keeping economic, financial and/or management records administrative management of the bank;
    • administration within internal departments of the services and products offered by bank;
    • the legal defence of the bank's rights and interests, the settlement of disputes, investigations or any other petitions/complaints/applications in which the bank is involved. involved; 
    • performing risk controls on bank procedures and processes, and carrying out audits or investigations;
    • taking action/providing information or responding to requests/complaints/complaints of any nature addressed to the Bank by any person and/or by authorities or institutions, on any channel, including via electronic communications services and the Internet;
    • performance of internal analysis (including statistics);
    • archiving - both in physical and electronic format - of documents, making copies of back-up;
    • providing registry and secretarial services for correspondence addressed to and/or dispatched by the bank, as well as for carrying out the bank's courier activities; 
    • ensuring the security of the IT systems used by BT and the physical premises in which bank carries out its activities;
    • prevention of fraud.

    c. Categories of personal data processed on individuals in a group BT debtor

    • identity detail - name, surname, personal identification number (romanian cod numeric personal CNP/NIN);
    • position, capacity, holdings and, where applicable, powers of representation held in the legal entities in the debtor's group;
    • where appropriate, other data in the bank's records or publicly available, which are necessary for the main purpose of credit risk analysis.

    a. Who is the signatory/contact person on behalf of the contracting partners? BT?

    • Signatories are usually legal representatives or other persons designated by the contracting partners to sign contracts with the bank (irrespective of whether the counterparties are BT corporate customers who are account holders or service providers, collaborators, suppliers of goods contracted by the bank);
    • Contact persons are persons designated by the contractual partner and the bank in order to maintain contact for the smooth running of the contract. contract, whether or not their details are mentioned in the contract.

    b. The purposes for which we process data of signatories/contact persons from BT contract partners

    If you are a signatory/contact person from any of the bank's contractual partners, we process your data, where applicable, for:

    • the conclusion and proper performance of the contract with the contractual partner (usually your employer), and for other purposes, in close cooperation with the the conclusion and performance of the contract:
    • the production and transmission of reports to the institutions competent to receive them, in in accordance with the legal provisions applicable to the bank;
    • carrying out analyses and keeping economic, financial and/or management records administrative management of the bank;
    • the legal defence of the bank's rights and interests, the settlement of disputes, investigations or any other petitions/complaints/applications in which the bank is involved. involved; 
    • performing risk controls on bank procedures and processes, and carrying out audits or investigations;
    • taking action/providing information or responding to requests/complaints/complaints of any nature addressed to the bank by you or by authorities or institutions, on any channel, including via electronic communications services and the Internet;
    • performance of internal analysis (including statistics);
    • archiving - both in physical and electronic format - of documents, making copies of back-up;
    • providing registry and secretarial services for correspondence addressed to and/or dispatched by the bank, as well as for carrying out the bank's courier activities; 
    • ensuring the security of the IT systems used by BT and the physical premises in which bank carries out its activities;
    • fraud prevention;

    Categories of personal data processed on behalf of signatories/contact persons contractual partners

    As a rule, we process the following categories of personal data concerning you, as follows where applicable:

    For signatories:

    • identity details - name and surname;
    • position held within the BT contractual partner;
    • signature.

    For the contact persons:

    • identity details - name and surname;
    • contact details - telephone number (work number) and/or e-mail address (work e-mail address);
    • position held within the BT contractual partner.

    Information note for signatories and contacts acting on behalf of BT's contractual partners can be found here: https://www.bancatransilvania.ro//Nota-de-informare-privind-prelucrarea-datelor-cu-caracter-personal-semnatari-persoane-de-contact-pentru-partener-contractual-BT.pdf

    a. Who is a BT shareholder/obligor or person whose data we process in relation to with those of our shareholders/obligors?

    • BT shareholder - you are a BT shareholder if you own as a person individual or legal entity shares issued by Banca Transilvania S.A.;
    • BT bondholder - you are a BT bondholder if you own as a person individual or legal entity, if you hold bonds issued by Banca Transilvania S.A.;
    • Natural persons whose data we process, as a rule, in relation to with those of BT's shareholders/bondholders - legal representatives or of BT shareholders/bondholders, persons who co-own shares/bonds with BT shareholders/bondsholders, successors of BT shareholders/bondsholders.

    b. The purposes for which we process the data of BT shareholders/obligors or other persons in connection with those of BT shareholders/bondholders

    If you are a BT shareholder and/or bondholder or an individual whose data we process in in relation to those of shareholders/bondholders, we will use your data, as appropriate, in the following ways purposes:

    • verification of identity in order to confirm/confirm shareholder/bondholder status of the bank, other status in relation to BT shareholders/obligors;
    • the fulfilment of specific legal obligations and activities deriving from the status of BT's issuer status (e.g. organisation of AGMs, shareholder services, specific communications for investors);
    • the establishment of attachments, the recording of the amounts attached at the disposal of creditors and the provision of replies thereto to enforcement bodies and/or authorities authorities, in accordance with the bank's legal obligations;
    • the production and transmission of reports to the institutions competent to receive them, in in accordance with the legal provisions applicable to the bank;
    • carrying out analyses and keeping economic, financial and/or management records administrative management of the bank;
    • administration within internal departments of the services and products offered by bank;
    • the legal defence of the bank's rights and interests, the settlement of disputes, investigations or any other petitions/complaints/applications in which the bank is involved. involved; 
    • performing risk controls on bank procedures and processes, and carrying out audits or investigations;
    • taking action/providing information or responding to requests/complaints/complaints of any nature addressed to the bank by any person, as well as to those addressed by the authorities or institutions in relation to BT's shareholders/obligors, through any channel, including through via electronic communications services and the internet;
    • proof of claims/agreements/opinions on certain issues requested/discussed/agreed, including in telephone calls initiated by you or the bank, by recording the issues discussed and, where appropriate, audio recording of telephone calls or, where appropriate, audio video;
    • performance of internal analysis (including statistics);
    • archiving - both in physical and electronic format - of documents, making copies of back-up;
    • providing registry and secretarial services for correspondence addressed to and/or dispatched by the bank, as well as for carrying out the bank's courier activities; 
    • ensuring the security of the IT systems used by BT and the physical premises in which bank carries out its activities;
    • prevention of fraud.

    c. Categories of personal data processed of BT/other shareholders/obligors persons in relation to their data

    If you are a BT shareholder and/or bondholder, another person related to them, you we usually process the following categories of personal data:

    • identification data - name, surname, national identification number or other unique identifier, serial number and national or international identity card/passport number, postal address and, where applicable, a copy of the identity card (for identification of shareholders in the case of shareholder or bondholder certificate or shareholder history shares/bonds held with BT);
    • citizenship;
    • fiscal data (country of fiscal residence);
    • information on the economic and financial situation, relating to assets held - number of BT shares and/or bonds, including the history of holdings of these assets;
    • the capacity, holdings and, where applicable, powers of representation held in legal persons;
    • signature (on the bank’s applications);
    • phone number, e-mail address, mailing address, depending on the channel of communication channel selected in the applications to the bank.

    a. Who is a visitor to the BT premises and/or user/visitor of the equipment BT EQUIPMENT?

    • A visitor to BT premises is any natural person who visits the bank's premises (including its administrative buildings), regardless of whether whether or not they carry out banking transactions;
    • Any natural person who using or standing in front of such equipment (ATMs, BT Express, BT Express Plus etc.), regardless of whether such equipment is placed inside BT premises or in other locations, regardless of whether the user is a BT Customer, BT Occasional Customer or any other third party, whether or not they initiate banking transactions via BT equipment, whether or not they complete the banking transaction initiated through BT equipment.

    b. The purposes for which we process the data of visitors to the BT units and/or the users/visitors of LV equipment

    The bank processes your personal data, as appropriate, for:

    as well as for other related purposes related to the main purposes indicated above, respectively:

    • Identity verification, if necessary for identification purposes at request of the competent authorities or when the bank has a legitimate interest;
    • performing risk controls on bank procedures and processes, and carrying out audits or investigations;
    • performance of internal analysis (including statistics);
    • archiving - both in physical and electronic format - of documents, making copies of documents back-up;
    • ensuring the security of the IT systems used by BT and the physical premises in which bank carries out its activities;
    • prevention of fraud.

    On video surveillance, as well as on data processing for access to some establishments BT, data subjects are informed, including by specific pictograms and/or information displayed at the entrance to the bank's premises and on BT equipment respectively.

    c. Categories of personal data processed on visitors to the establishments and/or users/visitors of BT equipment

    If you visit the bank's premises (including its administrative buildings) and/or use or stand in front of BT equipment we will process you as appropriate:

    • your image, as it is captured by the video surveillance cameras installed;
    • any data necessary for the execution of transactions ordered through BT's equipment or other related purposes mentioned above (e.g. time spent in the units/on the equipment). BT EQUIPMENT).

    At the same time, to allow you access to some of the establishments where the bank operates, security personnel will identify you on the basis of your identity papers and will enter in special registers provided for by law, the following data concerning you:

    • identification data - name, surname, series and number of national identity card or passport.

    a. Who is a visitor of the BT websites/social media pages?

    Any natural person accessing any of the websites of BT portfolio and/or its social media pages.

    b. The purposes for which we process the data of visitors to websites/social media pages BT media

    Through cookies or similar technologies we process your data in as a visitor to the BT websites for the purposes described at length in the policies the cookie policies for each of the websites and briefly in the banners and centres cookie settings.

    For the www.bancatransilvania.ro website, the Cookie Policy includes by accessing the following link: https://www.bancatransilvania.ro/politica-de-utilizare-a-cookie-urilor/

    If you enter your details on BT websites in requests/complaints, applications for bank products/services/campaigns, subscriptions to newsletters in various fields, we process the data entered in these forms as appropriate, for:

    • taking action/providing information or responding to requests/complaints/complaints of any nature addressed to the bank by any person, as well as to those addressed by the authorities or institutions in relation to BT's shareholders/obligors, through any channel, including through via electronic communications services and the internet;
    • proof of claims/agreements/opinions on certain issues requested/discussed/agreed, including in telephone calls initiated by you or the bank, by recording the issues discussed and, where appropriate, audio-recording of telephone calls or, where appropriate, audio-video;
    • collecting your opinion on the quality of services/products/employees BT (service quality assessment);
    • performance of internal analysis (including statistics);
    • performing risk controls on bank procedures and processes, and carrying out audits or investigations;
    • archiving - both in physical and electronic format - of documents, making copies of documents back-up;
    • providing registry and secretarial services for correspondence addressed to and/or dispatched by the bank, as well as for carrying out the bank's courier activities; 
    • ensuring the security of the IT systems used by BT and the physical premises in which bank carries out its activities;
    • prevention of fraud.

    Please note that subscribing or unsubscribing any e-mail address entered by in forms/fields such as/named "newsletter" available on BT websites to receive information in various areas of interest is managed by via the respective online forms (subscription) and unsubscribe links respectively in the content of the messages received following subscription (unsubscription).

    We also inform you that subscribing/unsubscribing to/from "newsletters" for which you opt-in on BT websites, does not influence your choices regarding the processing of your data for the purpose of advertising data filled in on the Bank's forms available in the branches or on the BT website (the online form found at the following link: https://www.bancatransilvania.ro/gdpr/ is only available to Customers BT customers to express marketing choices in the context of the contractual relationship conducted by with the bank).

    c. Categories of personal data processed on visitors BT websites/social media pages

    If you visit a BT website we will collect the following categories of data with personal data:

    • data processed through cookies;
    • IP Address:
    • data about the equipment used to access the website.

    Also, in the documents available on websites the bank collects, as appropriate:

    • identification data - name, surname, and in some cases with the consent of the individuals personal identification number;
    • contact details-e-mail address and/or telephone number.

    Please note that BT websites may contain links to websites whose privacy/processing of personal data is different from that of BT. Individuals submitting personal data to any of these websites should be aware that they are subject to the privacy/processing policy of personal data processing policy of those websites, which we recommend reading. BT Policy policy on the processing and protection of personal data does not apply to information provided on those websites, BT has no control over the processing of personal data provided on those websites. that the providers of these websites carry out for their own purposes and assumes no responsibility for such processing.

    If you use BT's social media pages and insert comments, images, opinions and/or likes on our posts, we will usually process them:

    • your user name on the respective ocial media platform;
    • the opinions you insert;
    • images you insert.

    In some cases it is possible - usually as a result of your participation in various or the insertion of comments in which we are asked to comment on your comments. you raise complaints about BT's work or ask us about any issues related to BT's work. our work - to ask you to provide us with other information to enable us to identify you and/or the situation you have raised and to provide a response to to this. This will usually include:

    • details on the situation that you bring to our attention;
    • identity details – usually name, surname;
    • identifiers: upon case, BT client ID (CIF BT), IBAN;
    • contact details: upon case, e-mail address and/or telephone number.

    If you provide us with this personal data within the social media platform media, we will process them for the purposes mentioned above in this section. For protection of your data, please do not submit personal data to us in within posts that are public on our social media platforms.

    Please note that in cases where you insert images that are personal data personal data of yourself or others, or when you tag various other people in within the Bank's social media pages, you consent to the use of such data by the bank, i.e. you assure us that you have obtained consent of the people to whom this data belongs.

    Last but not least, please be advised that any personal data that you BT's social media pages are also processed by the providers of those pages. social media platforms and are subject to the privacy policies of respective platforms. BT has no control over the processing of personal data on that the providers of these platforms carry out for their own purposes and does not assume any responsibility for such processing.

    a. Who is a BT prospect?

    You can be a BT prospectus holder if you have applied in the bank's branches via websites in its portfolio or via BT's contractual partners information about BT products/services, you have initiated their contracting without completing this or signed up for various campaigns organised by the bank.

    b. Purposes for processing personal data belonging to BT prospects

    If you are a BT prospect, we process your data, upon case, for the following purposes:

    • verifying your identity, in order to confirm/infirm your quality of BT customer;
    • taking action/providing information or responding to requests/complaints/complaints of any nature addressed to the bank by any person, as well as to those addressed by the authorities or institutions through any channel, including communications services electronic and internet services;
    • proof of claims/agreements/options on certain issues requested/discussed/agreed, including in telephone calls initiated by you or the bank, by recording the issues discussed and, where appropriate, audio-recording of telephone calls or, where appropriate, audio-video;
    • collecting your opinion on the quality of services/products/employees BT (service quality assessment);
    • performance of internal analysis (including statistics);
    • performing risk controls on bank procedures and processes, and carrying out audits or investigations;
    • archiving - both in physical and electronic format - of documents, making copies of documents back-up;
    • providing registry and secretarial services for correspondence addressed to and/or dispatched by the bank, as well as for carrying out the bank's courier activities; 
    • ensuring the security of the IT systems used by BT;
    • fraud prevention;
    • calculation of the fees to which certain categories of bank employees are entitled.

    c. Categories of personal data belonging to BT prospects, processed upon case

    If you are a BT prospect, as the case may be, the bank usually processes the following personal data concerning you:

    • identification data - name, surname, and in some cases only with consent your consent or if we justify a legitimate interest, your personal identification number (CNP);
    • contact details-e-mail address and/or telephone number.

    a. Who is a BT candidate?

    Are you a candidate for available positions at BT or for internships organised by BT if you have sent us or if we have received your CV for use for recruitment, directly from you or through/by others, or if you have otherwise made it known that you are interested in filling positions BT/participating in BT internships.

    b. Purposes for which we process personal data of BT candidates

    The bank processes your personal data, as appropriate, for:

    • recruiting for the post(s) or, where appropriate, the traineeship you want to occupy/traineeship within the Bank, as well as for purposes closely related to this activity, such as:
    • taking action/providing information or responding to requests/complaints/complaints of any nature addressed to the bank by any person, as well as to those addressed by the authorities or institutions, through any channel, including communications services electronic and Internet services;
    • proof of claims/agreements/opinions on certain issues requested/discussed/agreed, including in telephone calls initiated by you or the bank, by recording the issues discussed and, where appropriate, audio-recording of telephone calls or, where appropriate, audio-video;
    • performance of internal analysis (including statistics);
    • performing risk controls on bank procedures and processes, and carrying out audits or investigations;
    • archiving - both in physical and electronic format - of documents, making copies of documents back-up;
    • providing registry and secretarial services for correspondence addressed to and/or dispatched by the bank, as well as for carrying out the bank's courier activities; 
    • ensuring the security of the IT systems used by BT;
    • prevention of fraud.

    If you will only apply for a specific post/internship, your details personal data will only be processed by the bank for the recruitment process for the post/internship and will be deleted after the end of the the respective recruitment process.

    If, instead, you choose to be contacted generally for vacancies/internship positions within BT, we will keep your details and use them for recruitment purposes. for a period of 1 year, which can be extended with your consent.

    References from previous employers may become relevant in the recruitment process, or from teachers. If the bank needs these, it will contact you to request your agreement to obtain these references on your behalf. If you do not consent, you will need to obtain these references yourself. references if you wish to continue the recruitment process.

    c. Categories of personal data belonging to BT candidates

    BT candidates are usually processed the following categories of personal data, as follows as indicated in the CV submitted to/transmitted to the bank:

    • identity details- name, surname;
    • your age, to check your eligibility to become an employee or, if applicable, to participate in certain BT traineeships;
    • contact data: e-mail address, phone number;
    • data on studies and professional experience;
    • any other relevant data from the CV.

    a. Who is/when do we process your personal data as a BT petitioner?

    You are such a person if you make any request to BT, through any channel, whether you you are a BT customer, BT occasional customer or any other category of individuals.

    b. Purposes for which we process personal of BT petitioners

    Depending on your specific situation and quality of your relationship with the bank, when we you submit a request, we process your personal data for the following purposes:

    • verifying your identity, including in order to confirm/infirm your quality of BT customer;
    • taking action/providing information or responding to requests/complaints/complaints of any nature addressed to the bank by any person, as well as to those addressed by the authorities or institutions, through any channel, including communications services electronic and Internet services;
    • proof of claims/agreements/options on certain issues requested/discussed/agreed in telephone calls initiated by you or by the bank, by recording the matters discussed and, where appropriate, the audio recording of telephone calls;
    • collecting your opinion on the quality of services/products/employees BT (service quality assessment);
    • performing risk controls on bank procedures and processes, and carrying out audits or investigations;
    • performance of internal analysis (including statistics);
    • archiving - both in physical and electronic format - of documents, making copies of documents back-up;
    • providing registry and secretarial services for correspondence addressed to and/or dispatched by the bank, as well as for carrying out the bank's courier activities; 
    • ensuring the security of the IT systems used by BT;
    • fraud prevention;
    • calculation of the fees to which certain categories of bank employees are entitled.

    c. Categories of personal data belonging to BT petitioners, processed upon case

    To record, acknowledge receipt of, analyse, formulate and transmit reply to any requests/complaints/complaints you send to us, we process the following categories of data personal data:

    • identification data: name, surname and other data in this category that we personal data that you provide or personal data that BT is required to process for identify the BT petitioner to prevent disclosure of confidential information (including personal data) to recipients who are not entitled to receive it. to whom it is addressed;
    • contact details – correspondence address, e-mail address, phone number;
    • voice, in calls and recordings of telephone conversations (initiated by petitioners or the bank);
    • where applicable, any other information of which the bank is aware and which is necessary for the analysis of the applications.

    a. Who is/when do we process your personal data as a BT third party?

    You are included in this category of data subjects if any personal data which is disclosed/transferred to us by BT customers, BT occasional customers in the context of their relationship with us or by any other person. Your data will processed in this context as a BT third party, even if you have other direct relationships with BT. us (e.g. a BT credit applicant provides us with the sale-purchase agreement of the property in which you are listed as the seller. In this case, the data in this contract we will process it in your capacity as a third party, even if you are in fact also a BT customer and we also process your data for other purposes specific to your contractual relationship established with the bank).

    Thus, by way of example, we process your data in your capacity as a BT third party if you belong to any of the following categories of natural persons:

    • family members of a BT customer or BT employee - it is possible that, in certain circumstances, Customers may disclose to us details of members of their family members, particularly in the context of formulating and considering a loan application or the processing of a credit agreement.
      At the same time, BT employees may also provide data about family members in various contexts related to their relationship (e.g. minor children of employees, other family members of BT employees);
    • Non-customer payers: individuals who are customers of other institutions offering payment services and who order transfers of amounts to the accounts of customers' accounts with BT (interbank transfers ordered by customers of other payment institutions). payment institutions to BT customers who are account holders) - we need to process the data of these individuals for the provision of payment services and in accordance with our legal obligations;
    • beneficiaries of non-customer payments: individuals who are customers of other institutions offering payment services, to whose accounts BT Customers order transfers of amounts (interbank transfers ordered to customers of other by BT Customers)- it is necessary to process the data of this category of persons to provide payment services and in accordance with legal obligations;
    • natural persons referred to in the details/explanations of payment in a payment order submitted/transmitted/received at BT -completion of related fields explanation/details of a payment is mandatory according to the legal provisions in the field of prevention of money laundering and terrorist financing. According to the principle of reduction to data, only personal data should be inserted in these fields when absolutely necessary and only data that are strictly necessary;
    • authorised persons (other than authorised representatives or delegates on accounts) natural persons nominated to order/initiate transactions on behalf of a BT Customer - banking or non-banking - through the channels offered by BT (e.g. payment instructions telephone instructions);
    • natural persons whose details are mentioned on various documents made available to bank - if a BT customer, BT occasional customer or any other person with whom the bank interacts submits various documents to the bank, in various situations (e.g. statements or documents of any kind containing data with personal data of the signatories or, as the case may be, other persons mentioned in the the bank will process these data in view of the need to keep these data in a safe place. even though it may not need to process the data in another Member State. form other than storage;
    • persons in relation to whom the bank receives requests/requests for information from various institutions and/or public authorities, notaries, lawyers, bailiffs, etc;
    • participants in various social responsibility events or actions organised by the bank, the details of which must be process in order to ensure the logistics of the events;
    • any other categories of natural persons whose personal data are made available to us by any person with whom we interact or who comes into in any other way.

    b. Purposes for which we process personal data of BT third parties

    We process your data as a BT third party for the purpose for which it is necessary in the relationship our relationship with the person who provided it to us, and for the following related purposes:

    • performance of the employment relationship with BT employees, where applicable;
    • performing risk controls on bank procedures and processes, and carrying out audits or investigations;
    • performance of internal analysis (including statistics);
    • archiving - both in physical and electronic format - of documents, making copies of documents back-up;
    • providing registry and secretarial services for correspondence addressed to and/or dispatched by the bank, as well as for carrying out the bank's courier activities; 
    • ensuring the security of the IT systems used by BT;
    • prevention of fraud.

    c. Categories of personal data belonging to BT third parties, processed upon case

    The most common categories of personal data that we process if you are a BT third party, by way of example:

    • identity details: - name, surname, personal identification number (romanian cod numeric personal- CNP);
    • relationship between you and a BT customer or employee, upon case;
    • position held within a legal entity;
    • signature;
    • any other data made available to us by anyone we interact with in our business.

    a. Who may be the persons who have expressed their choices to BT about data processing for advertising purposes (as appropriate, consent or refusal)

    They are currently considered to be persons who have given BT their consent to be personal data processed for advertising purposes in any of the following categories data subjects:

    • BT customers, BT occasional customers or any BT third parties who have given their consent on BT's dedicated form used in BT's establishments from 12.03.2018 and on BT website www.bancatransilvania.ro (online form within this link: https://www.bancatransilvania.ro/gdpr/ is only available to BT customers) since May 2018;
    • BT customers, BT occasional customers or any third parties who have expressed this consent on forms used in the bank's business prior to 12.03.2018 and have not changed/withdrawn this consent in the meantime, nor following the information that the bank has May 2018 about this possibility, nor on their own initiative.

    There are currently individuals who have expressed their refusal to have their data processed BT customers, BT occasional customers or any BT third parties who have have expressed from the outset their refusal to have their data processed for this purpose, as well as individuals who have initially given their consent to their data being processed for advertising purposes, have subsequently withdrawn their consent.

    b. The purposes for which we process the data of individuals who have expressed their choices to BT on the processing of their data for advertising purposes (where applicable, consent or refusal)

    If you have given your consent for your data to be processed for advertising purposes, we will process it as follows:

    • transmission of advertising messages, in accordance with the given consent (advertising purpose);
    • verification of the identity of persons in order to confirm/confirm their status as BT customer;
    • proof of claims/agreements/options on issues related to options advertising, by recording the issues discussed and, where appropriate, audio recording of the telephone calls (initiated by the bank or by you);
    • performance of internal analysis (including statistics);
    • archiving - both in physical and electronic format - of documents, making copies of documents back-up;
    • providing registry and secretarial services for correspondence addressed to and/or dispatched by the bank, as well as for carrying out the bank's courier activities; 
    • ensuring the security of the IT systems used by BT;
    • prevention of fraud.

    If you have refused the processing of your personal data for the purpose of advertising we will process your data for all the above purposes except for the for the transmission of advertising messages.
    *BTwishes to inform interested persons about the products/services/events offered/organised by the bank, the entities of the BT Financial Group or their partners, in which sense it processes data personal data of such persons, if they have given their consent to receive messages advertising messages.
    The form dedicated to the expression/collection of marketing options used in currently used by BT, is available in any of the bank's branches and on the website www.bancatransilvania.ro, or directly at the following link: https://www.bancatransilvania.ro/gdpr/
    The online form is available to BT customers only and can be used by them not only to express initial expression of marketing options, but also to change previously expressed options. and, where appropriate, for withdrawing consent to receive marketing communications. advertising messages.

    c. Categories of personal data processed on individuals who have expressed their consent to BT consent to the processing of their data for advertising purposes, their recipients, and the period of their processing

    The data processed by BT for sending marketing messages are usually:

    • identity data: name, surname;
    • contact details: telephone number and/or e-mail or mailing address provided by persons interested in receiving advertising messages or, where appropriate, those declared in the bank's records for the purpose of knowing the customer (relationship contractual relationship) in the case of BT Customers;
    • in the case of BT Customers: other information we learn about customers in the context of they use BT's services/products (e.g. transaction data, age, location, income range, etc.), which we will automatically study (profiling) to create an opinion about the products/services/events that would suit them (advertising personalised advertising).

    Personal data will be processed by the bank for sending advertising messages until the termination of the contractual relationship with BT Customers or, as the case may be, until the time of withdrawal of their consent to receive such messages (the latter including in the case of any other categories of persons who are not BT Customers).

    In some cases, for the delivery of advertising messages, BT will contract with suppliers of service providers, who will process the personal data of data subjects on behalf of and for BT, only for the purpose of delivering the advertising messages set out in strict compliance with BT's instructions and under the Bank's close supervision.

    Interested parties can choose to receive advertising messages in several categories, including including: products and services of BT and BT subsidiaries, events organised by BT, products/services of partners, which are related to BT's or BT subsidiaries' products/services. BT subsidiaries and events organised by BT partners.

    BT Subsidiaries whose products/services and events are to be promoted in the advertising messages to opt-in persons are as follows entities within the Financial Group BT: 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 entities that may be join the BT Group in the future.

    List of BT's current partners and/or BT subsidiaries whose products/services and events are to be promoted in advertising messages to persons who who have opted in can be accessed at the link: https://www.bancatransilvania.ro/parteneri.

    If you have opted to receive advertising messages about products/services events offered/organised by BT subsidiaries or partners, these entities will process your personal data for the purpose of sending these messages, under the supervision and coordination of the Bank and, where appropriate, together with the Bank. For any possible processing of personal data carried out by BT partners/BT subsidiaries in outside or adjacent to the transmission of advertising messages, such as, for example, for the purpose of the conclusion of contracts relating to their products/services that have been promoted, these partners are to act as controllers of personal data processed.

    The agreement to be contacted for advertising purposes can be withdrawn or modified at any time by several ways, indicated separately on the form dedicated to the expression of consent to data processing for advertising purposes.
    Withdrawal of consent only operates for future and does not affect the lawfulness of the data processing carried out before the time of consent. withdrawal.

    Please note that subscribing or unsubscribing any e-mail address entered by in forms/fields such as/named "newsletter" available on BT websites to receive information in various areas of interest, is managed by via the respective online forms (subscription) and unsubscribe links respectively in the content of the messages received following subscription (unsubscription).
    We also inform you that subscribing/unsubscribing to/from "newsletters" that you opt-in to on BT websites, do not influence the choices regarding the processing of your data for advertising purposes completed on the Bank's forms available in the branches or on the BT website.

    As a rule, the personal data of the data subjects whose data we process are collected by us directly from them on various occasions and in various ways, such as:

    • upon the establishment and during the performance of the business relationship with BT;
    • on the occasion of the conclusion and performance of contracts for products/services offered by the bank, in on its own behalf or on behalf of third parties;
    • by filling in forms available on the BT website, on other websites owned by bank or other Group entities;
    • by entering/participating in various competitions/campaigns organised by BT in its units, on the BT website or on the bank's social media pages;
    • when we are asked for information/receive enquiries/complaints on the telephone numbers of e-mail addresses, via messages sent to the bank's web pages, via the bank's social media pages or received by letter in BT units;
    • when applying for available positions in the bank (online, by sending/submitting CVs in BT branches or on various e-mail addresses, at career fairs or other events);
    • when accessing websites/social media platforms of BT.

    However, there are situations when the data are collected from other sources, such as:

    • from other natural or legal person account-holding customers in situations such as, but not limited to limited to: the empowerment of other Customers on their accounts opened with the bank, the contracting of products/services of the bank by a Client on behalf of another Client who has given him power of attorney for this purpose, the contracting by employers who are corporate customers of BT of products/services of the bank for/on behalf of their employees (e.g. meal vouchers, benefits at of salary income on accounts opened with BT, guarantee accounts, management etc);
    • from payers - natural or legal persons, whether or not they are Customers BT- in the context of transferring/depositing amounts to the accounts of individual customers account holders;
    • from public authorities or institutions (e.g. courts, public prosecutors, bailiffs, etc.). courts, NBR, ANPC, ANSPDCP etc.), notaries, lawyers in the context that they are send us referrals or requests;
    • from/through Transfond, SWIFT, international payment organizations, etc.;
    • from credit institutions with which Banca Transilvania S.A. has merged (Volksbank Romania S.A. and Bancpost S.A.);
    • from partner banks and correspondent banks, banks or financial institutions participating in syndicated loans;
    • from international payment organisations;
    • from other entities of Banca Transilvania Financial Group etc.;
    • from public sources, such as but not limited to: the Trade Office Register, the Register of National Register of Real Estate Publicity, the Cadastre and Real Estate Publicity Office, the portal courts, Official Gazette, social media, internet, etc.;
    • from records such as Credit Bureau, Credit Risk Centre, if any a legal basis and a determined and legitimate purpose for consulting them;
    • from private database providers - e.g. entities authorised to administer databases with persons accused of financing terrorism and politically exposed persons;
    • from entities in the BT Financial Group for use for specified purposes, and legitimate purposes, in general for the proper conduct of the joint economic activity carried out by them together with the other entities of the BT Group and for the fulfilment of related legal requirements supervision on a consolidated basis of BT Financial Group;
    • from the contractual partners of the bank in various fields;
    • from debt collection/recovery companies (e.g. we can find out the new dates of contact details of customers from companies that support us in our debt collection activities, data that the latter obtain based on their own interactions with them or with persons close to them);
    • from assessment companies;
    • from insurance companies;
    • management companies of pension and investment funds
    • from Depozitarul Central S.A., for the data of the bank’s shareholders;
    • from any other natural or legal person who sends us a complaint/request containing data personal data (e.g. persons notifying us that some BT customers no longer have the same data contact details they have declared in the bank's records).

    The bases on which BT processes personal data are, as appropriate:

    • the need to process the data for the performance of a task which serves an interest public interest;
    • the bank’s legal obligation;
    • conclusion/performance of the agreements concluded with the data subject;
    • the legitimate interest of the bank and/or third parties;
    • the data subject’s consent.

    Except where personal data are processed on the basis of consent of the data subjects, and in some cases where the basis for processing is legitimate interest, the refusal of individuals to have their data processed by BT will make it impossible to provide requested services or the resolution of their requests.

    Personal data of the Bank's Customers and, where applicable, other categories of persons mentioned in this Policy, are disclosed by BT or, where applicable, transferred, in in accordance with GDPR principles, based on the applicable legal grounds depending on the situation and only under conditions that ensure full confidentiality and security of the data, to categories of recipients, such as, but not limited to:

    • other Customers who have the right and need to know them;
    • entities within the BT Financial Group;
    • assignees;
    • contractual partners (service providers) used by the bank in the performance of its banking activity, such as but not limited to: IT services (maintenance, development software), physical and/or electronic archiving, courier services, auditing, issuance-related services and enrolment in platforms, market research/surveys, transmission of information, etc. advertising messages, monitoring of user traffic and behaviour online tools, marketing services via social media resources, etc.);
    • inter-bank payment processing companies and transmission of information on transactions (e.g. Transfond SA, Society for Worldwide Interbank Financial Telecommunication- SWIFT);
    • bank partners from various fields, whose products/services/events we can promote BT customers on the basis of their consent. The updated list of the Bank's partners is here: https://www.bancatransilvania.ro/parteneri;
    • international payment organisations (e.g. Visa, Mastercard);
    • payments processors;
    • financial-banking entities participating in payment and communication schemes/systems such as SWIFT, SEPA, ReGIS, financial/banking institutions to which we confirm or ask them to confirm signatures and/or certain information that may be contained in the letters of good standing, bank guarantee letters, other addresses issued by the Bank's Clients in favour of their business partners, other entities (such as banks or institutions financial institutions) in the context of the sale or restructuring of the Bank's portfolios. and/or other rights of the Bank arising from legal relationships with Clients;
    • partner banks and correspondent banks, banks or financial institutions participating in syndicated loans;
    • public authorities and institutions, such as, but not limited to: the National Bank of Romania (NBR), the National Tax Administration Agency (ANAF)*, the Ministry of Justice, the Ministry of Administration and Interior, the National Office for Preventing and Combating Money Laundering (ONPCSB)**, the National Agency for Cadastre and Real Estate Publicity (ANCPI), the National Registry of Real Estate Publicity (RNPM), the Financial Supervisory Authority (ASF), including, after where applicable, their territorial units;
    • companies (funds) guaranteeing various types of loan/deposit products (e.g. FNGCIMM, FGDB etc.);
    • public notaries, lawyers, bailiffs;
    • Central Credit Register***;
    • The Credit Bureau and the Participants in the Credit Bureau system****;
    • insurance companies;
    • assessment companies;
    • companies collecting outstanding debts or receivables;
    • pension fund management companies and investment fund management entities to which the Bank has outsourced the provision of financial-banking services;
    • banking institutions or state authorities, including from outside the European Economic Area - in international SWIFT transfers or as a result of processing carried out in for the purposes of FATCA and CRS legislation;
    • providers of social media.

    *According to the provisions of the Fiscal Procedure Code (Law 207/2015), as an institution of institution, BT has the legal obligation to communicate daily to the central tax authority - A.N.A.F. - the list of of the holders, whether natural persons, legal entities or any other entities without legal personality, who open or close accounts, as well as the identification data of the persons holding the right to sign for accounts opened with them, the list of persons who rent safe deposit boxes, and termination of the rental contract. A.N.A.F. may communicate these data to tax authorities authorities or to other central and local public authorities, under the terms of the law.

    **If the conditions for the transmission by BT of data with personal data to the National Office for Preventing and Combating Money Laundering, according to the Law no. 129/2019 for the prevention and combating of money laundering and terrorist financing, as well as for the amendment and completion of some normative acts, they shall be transmitted simultaneously and in the same format to the A.N.A.F.

    ***The bank is legally obliged to report to the Credit Risk Centre (CRC) the information of risk for each borrower that qualifies to be reported (includes the data identification of a borrower, whether an individual or a non-bank legal entity, and the transactions in RON and foreign currency whereby the Bank is exposed to risk vis-à-vis that borrower), i.e. to be registered an individual risk against it, as well as information on card fraud detected.
    ****The Bank has a legitimate interest in reporting in the Credit Bureau System, to which other Participants (mainly credit institutions and financial institutions) have access to it. institutions (mainly credit institutions and non-banking financial institutions) the personal data of borrowers who are overdue for credit payments of at least at least 30 days, after giving at least 15 days' prior notice to the persons concerned days before the reporting date.

    Where it is necessary for the performance of the objects of contracts concluded with BT Customers or BT Occasional Customers, and only in specific situations or on the basis of guarantees appropriate safeguards, the Bank will transfer personal data abroad, as appropriate, including to countries that do not ensure an adequate level of protection of personal data. States that do not ensure an adequate level of protection are States outside the European Union/European Economic Area, with the exception of States which have been recognised by the European Commission as having an adequate level of protection, namely: Andorra, Argentina, Canada (commercial companies only), Faroe Islands, Guernsey, Israel, Switzerland, Israel, Faroe Islands, Iceland, Liechtenstein, Liechtenstein, Liechtenstein, Norway, Norway, Sweden Man, Jersey, New Zealand, Uruguay, Japan, United States of America - only within the limit of protection provided by the EU-US Privacy Shield - (to the extent that no decision to the contrary is issued in respect of any of these countries).

    If BT Customers or BT Occasional Customers order transactions through the bank within where the recipients of the payments are located in countries that do not ensure an adequate level of protection of personal data, the transfer of data to those states shall be based on the provisions of the General Data Protection Regulation relating to: transfer that is necessary for the performance of a contract between the Bank and the Customer or for the application of measures adopted at the request of the Client, as the case may be, transfer which is necessary for the the conclusion of a contract or the performance of a contract concluded in the interest of the individual concerned.
    Where it is necessary to transfer personal data to countries third countries/international organisations and in other circumstances, the Bank will only do so with the safeguards provided by law for such transfers.

    In some circumstances, only with compliance with the GDPR, in banking automated decision-making processes are used, including as a result of the creation of the profiles. These are decisions made by the bank as appropriate, with or without the intervention of a factor human decision, and may produce legal effects and/or affect data subjects in a similar way, in a significant extent.

    Such situations, presented by way of example, are the following:

    • for the application of customer awareness measures to prevent and combat money laundering and terrorist financing, checks will be carried out in the databases of persons accused of financing terrorist acts or, where appropriate, high-risk persons of fraud and, if Customers are found to be included in these records, the Bank reserves the right to to refuse to enter into a business relationship with them or to terminate the contractual relationship;
    • to protect BT customers and occasional customers against fraud, and to the bank adequately fulfils its know-your-customer obligations, monitors their transactions and, if it identifies suspicious transactions (such as unusual payments as frequency, amount, including in relation to the source of funds declared by account holders or the purpose and nature of the business relationship, transactions initiated from different locations at short intervals of time, which did not allow travel between those locations), adopted in accordingly, measures to block transactions, account cards, taking these decisions on purely automatic basis;
    • according to legal provisions, the granting of credit products is conditional on the existence of a certain degree of indebtedness of the applicants. To determine eligibility for borrowing product in relation to the degree of indebtedness, this will be determined on the basis of based on automatic criteria, starting from the level of income and expenditure they the applicant;
    • for the purpose of objectively verifying the fulfilment of the eligibility conditions for the pre-offer and, where appropriate, to consider an application for credit made to BT by an applicant, in the majority of cases cases, a bank scoring application will be used which will analyse the data filled in the application form. credit application, information resulting from checks carried out in the bank's own records, and and/or Credit Bureau S.A.'s records and will issue a score that determines the risk and the likelihood of future timely payment of instalments. To the score issued shall be added the result of other checks on the applicant's situation, which will be analysed by the bank employees to determine whether the eligibility conditions set out in the internal regulations. The final decision to approve or reject the credit application is based, however, on the analysis carried out by Bank employees (human intervention);
    • where BT Customers have given their consent on the dedicated form for their data to be personal data to be processed for advertising purposes for the transmission of messages personalised messages, these are based on a profile drawn up on the basis of various criteria, such as, but not limited to not limited to data on transactions, age, location, income range, which the bank will automatically study in order to form an opinion about products/services/events that would suit the Customer. In some cases, this profile made will only result in the promotion of a particular product/service to specific individuals as fulfilling the profile conditions, and at other times it will cause only people who meet the the profile criteria to contract/benefit from certain promotional offers.

    Personal data processed by the bank for the purpose of customer knowledge for theprevention of money laundering and terrorist financing, including data transactions carried out through accounts opened with the bank, will be kept by the bank at least at least 5 years from the date of termination of the business relationship with the Customer natural person or person account holder, in accordance with the legal retention period established for the bank.

    Also, if the business relationship is not open, the data in the application will be stored at BT for at least 5 years from the date of refusal. bank to establish the contractual relationship.

    Personal data completed in a credit application are stored in BT's records for a period of 3 years from the date of signature of the credit application, if is rejected, and for a period of 5 years from the date of the date of termination of the business relationship with the bank of the borrowing customer, if the a credit agreement is concluded following approval of the credit application.
    As regards As regards the data processed in the framework of BT's activity in the Credit Bureau system, they are stored at the level of this institution and disclosed to Participants for for 4 years from the date of the last update, except for data of applicants credit applicants who have withdrawn their application for credit or who have not been granted credit, which are stored and disclosed to Participants for a period of 6 months.

    Personal data for which BT is legally obliged to report to the Credit Risk Centre (CRC) will be kept in the CRC's records for a period of 7 years from date of their registration.
    For data processed on the basis of consent data subjects for the purpose of sending advertising messages, they will be processed until the termination of the business/contractual relationship with the bank or, where applicable, until the withdrawal such consent.

    For the purpose of proving that complaints/requests/requests for information/measures have been received and that replies to them have been formulated and transmitted, the data related to these petitions will be kept in BT's records (together with personal data contained therein) in both paper and electronic format for the duration of the relationship. business relationship for BT's customers, i.e. for a period necessary to fulfil the purpose for which they were processed (the formulation of the response/provision of information), plus a period of 3 years- the legal limitation period if the data do not belong to BT customers.

    Personal data processed by BT candidates will be kept until the end of the recruitment process for the vacancy or, if the candidates have been interested in being contacted for more than one post that would suit them, the data in the CVs and other documents they have provided to BT for this purpose will be kept for a period of one year. maximum 1 year, unless they are requested to be deleted from the database within this period. the Bank's records. This period may be extended with the consent of the candidate.

    Storage duration of data obtained through the video surveillance system is proportionate to the purpose for which the data is processed, i.e. not exceeds 30 days, after which time the recordings shall be deleted by the procedure automatically in the order in which they were recorded. In the event of a security incident (including a personal data security breach), the retention period of relevant footage may exceed normal limits depending on the time required for investigation further investigation of the security incident.

    Any other personal data processed by BT for other purposes will be kept for the period necessary to fulfil the purposes for which it was collected for which it may be non-excessive time limits set in accordance with applicable legal obligations in this area, including but not limited to without limitation to archiving provisions.

    Any data subject whose data are processed by the bank, is guaranteed and can benefit from the rights provided by the GDPR, respectively:

    • right of access: data subjects can obtain confirmation from BT that they are being personal data are processed, as well as information on the specifics of the processing such as such as: purpose, categories of personal data processed, recipients of the data, the period for which the data are kept, the existence of the right of rectification, erasure or restriction of processing. This right allows data subjects to obtain, free of charge, a copy of the personal data processed, as well as any additional copies for a fee;
    • the right to rectification of data: data subjects may request BT to amend incorrect data relating to them or, where appropriate, complete data which are incomplete;
    • the right to delete the data: data subjects may request the deletion of their data with personal data when:
      • they are no longer needed for the purposes for which we collected and process;
      • consent to the processing of personal data has been withdrawn and BT can no longer process them on other grounds;
      • the personal data are processed against the law;
      • the personal data must be deleted in accordance with the relevant legislation;
    • the right to withdraw consent: data subjects may withdraw consent to the processing of personal data processed on the basis of the data subject's consent. Withdrawal of consent does not affect the lawfulness of the processing carried out prior to that moment.
    • the right to object: data subjects may object at any time to processing in marketing purposes, as well as processing based on the legitimate interest of BT, on grounds that their specific situation;
    • the right to restriction of processing:: data subjects may request restrict the processing of their personal data if:
      • disputes the accuracy of personal data, for a period that allows us to verify the accuracy of the data concerned;
      • the processing is unlawful and the data subject objects to the erasure of the data personal data and instead requests the restriction of their use;
      • data are no longer necessary for processing, but the data subject requests them from us for a legal action;
      •  if the data subject has objected to the processing, for the period during which it is verified whether the legitimate rights of BT as controller prevail over the the rights of the data subject.
    • the right to data portability: data subjects may request, in the bank to provide them with certain personal data in a form that is structured, frequently used and machine-readable form. If individuals data subjects request, BT may transmit those data to another entity, if possible from the technically possible.
    • the right to lodge a complaint with the National Data Protection Supervisory Authority Personal Data Processing: data subjects have the right to lodge a complaint to the National Supervisory Authority for Personal Data Processing if they consider that their rights have been violated: The National Supervisory Authority Processing of Personal Data, B-dul G-ral. Gheorghe Magheru 28-30 Sector 1, cod. 010336 Bucharest, Romania anspdcp@dataprotection.ro
      In order to exercise those rights a) to g) above, or for any questions about the processing of personal data personal data processing carried out by BT, data subjects may use the contact details of the Data Protection Officer designated by BT by sending the request:
      • by post, at the address in mun. Cluj-Napoca, str. G. Bariţiu, nr. 8, jud. Cluj, with the mention "to the attention of the data protection officer"
      • at the following email addressdpo@btrl.ro.

    BT prepares an internal framework of standards and policies to ensure the security of the personal data. They are regularly updated in line with the legal regulations applicable to BT and the highest standards in the field.

    Specifically and according to the law, the Bank adopts and applies appropriate technical and organizational measures (policies and procedures, IT security, etc.) to ensure the confidentiality and integrity of personal data and the way in which they are processed.
    BT employees have the obligation to maintain confidentiality and cannot illegally disclose the personal data they process in the course of their business.
    The Bank makes sure that its contractual partners that have access to personal data are contractually bound in accordance with the legal provisions and checks their compliance with the assumed obligations. 
    The contractual partners who act as the bank's authorized person will
    process the personal data on behalf of and for the bank, only in accordance with the instructions received from the bank and only in compliance with the security and confidentiality requirements within the limits imposed.
    We warrant that BT does not sell the personal data it collects from the data subjects and does not transmit such data to entities, other than the ones that are entitled to know them, in line with the legally established principles and obligations.

    This policy is regularly reviewed in order to make sure that the rights of the data subjects are guaranted and to improve the ways in which personal data are processed and protected.

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    AI Search is a pilot project - in beta - that uses GPT4 technology to simplify the process of finding and understanding banking products.

    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.

    Use of AI Search implies acceptance of the Terms and Conditions.

    Access to and use of the service implies your unreserved acceptance of these terms and conditions. If you do not agree to them, please do not use this service. By accepting the terms and conditions to use this service provided algorithmically by an artificial intelligence model, you assume the entire risk as to the quality, safety and performance of this service.

    Banca Transilvania does not provide any guarantee in relation to the answers provided by this service.

    AI Search provides responses algorithmically and these may sometimes contain inaccurate information or potentially offensive language. This information does not express the position of Banca Transilvania and cannot engage the responsibility of the Bank for the content provided.

    AI Search does not provide answers to personalized questions, so by using it you are obligated not to provide or enter any personal data or other confidential information in your messages/questions. In case you do not comply with this obligation, by inserting personal data/confidential information in AI Search, you consent to their processing for the purpose of providing the service (answers to the questions you ask), as well as for the improvement of the algorithmic model of the robot by its developer.

    Any information provided by users during their interaction with AI Search will be treated confidentially and will only be disclosed to recipients who have a right and need to know.

    The content provided by AI Search is for information purposes only.

    Users are responsible for the questions and messages asked when using AI Search. Any abuse or inappropriate language may result in the interruption of the interaction.

    AI Search does not provide financial, legal or professional advice and is not a substitute for consulting human experts or professionals specialising in the field. Users should not rely on the information provided by AI Search in making decisions.

    The Bank reserves the right to discontinue the AI Search service at any time without prior notice.

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