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  • Information note on the processing of personal data within the BT Pay mobile application

Information note on the processing of personal data within the BT Pay mobile application

Version updated on 14 June 2024

General provisions

Banca Transilvania, S.A., a credit institution established in Romania, with registered office in Cluj-Napoca, Calea Dorobantilor, no. 30-36, Cluj county, registered with the Trade Register under no. J12/4155/1993, unique code RO 5022670, (hereinafter referred to as "BT"), hereby informs you how it will process, as controller, personal data concerning you if you use the mobile application - BT Pay (hereinafter referred to as "BT Pay" or "the application"). The cases in which, by way of exception, BT is not the controller of the personal data processed in BT Pay are set out separately in this information notice.

This information notice relates exclusively to the processing of personal data belonging to BT Pay users who are at least 18 years old ("mature users"). 

Minors over 14 years of age who have an account with BT who wish to use/use the BT Pay functionalities available for this age group with their own card attached to this account, as well as the parents/guardians/legal representatives ("parent") of these minors should read the Information Notice on the processing in BT Pay of personal data of users under 14 years of age who have a BT account, including the provisions on minors' personal data in the Information Notice on the processing of personal data for identification purposes in BT Pay, for information on the processing of personal data of minors in this age group in BT Pay.

Minors aged 8 - 18 who wish to use/use the BT Pay functionalities available for this age group with their own card attached to a parent's account should read the Information Notice on the processing in BT Pay of personal data of minor users attached to the parent's account for information on the processing of personal data of minors in this age group in BT Pay. If minors are under 14 years of age, we recommend that they read this notice with their parents/guardians/legal representatives ("parent").

BT Pay is an application offered to BT customers, under the conditions set out in the BT Pay Terms and Conditions of Use, which we recommend you to consult.

In BT Pay, users can use several distinct services. Some of these involve the processing of personal data for specific purposes and grounds of processing, users can find details in the specific information notes, as follows:

Also, adult resident individuals who do not yet have a current account with BT can open a business relationship with Banca Transilvania from BT Pay, without having to go to a bank branch. In this context, we process personal data as detailed in Information note on the processing of personal data for opening a business relationship with Banca Transilvania through BT Pay, which is displayed separately when the process of opening the business relationship via the application is initiated.

BT may revise this information note from time to time, but it will not create any less favourable conditions for users of the application in terms of processing and protection of personal data. We will inform you of such changes to the information note within the BT Pay application. The updated version of the information note and the date from which it applies will be available to users at any time. All users will be subject to the provisions of the information note in force. If, at any time, you consider that the manner in which BT processes and / or protects the personal data does not comply with your legal provisions and / or requirements, you can notify us of this aspect at the contact addresses: dpo@btrl.ro and / or stop using BT Pay.

What types of personal data do we process, as the case may be, within the BT Pay application?

Information we check when you apply to open a business relationship with Banca Transilvania through BT Pay

When you apply to open a business relationship with BT via the BT Pay application, we use a remote video identification service, which involves the processing of personal data in accordance with applicable legislation in this field (e.g. personal data from your ID card, contact data, as well as so-called biometric data), we collect personal data required by applicable legislation in the field of customer knowledge for the prevention of money laundering and terrorist financing and data necessary for contracting the bank's transactional services/products, as well as data to collect your marketing options, as set out in Information note on the processing of personal data for opening a business relationship with Banca Transilvania through BT Pay.

Information we check prior to registration with BT Pay

Before registering with BT Pay, you will need to confirm that you agree to the terms and conditions of use, which is your acceptance to conclude with BT the contract allowing you to use the services offered through BT Pay. We recommend that you read these Terms carefully and save them. Optionally, you can send them to an email address.

If you have entered your e-mail address regardless of whether you have completed the registration or not, we will keep it in the records of the application, because we have a legitimate interest in proving that we have transmitted the terms and conditions to it, as requested.

To ensure the security of BT Pay, in order to register the cards in the application, we also verify at this stage the identity of the phone (e.g. device ID, device model, type and version of the device's operating system, including its history), as well as the fact that the phone used is secured by password, fingerprint or other security method, as required by law. The bank will only verify the existence of the security, but will not have access to the password, fingerprint or other security methods used, which will remain stored in the user's device memory.

In order to protect your transaction data and other information available in BT Pay, we have a legitimate interest and, where applicable, a legal obligation, to collect and use the IP address(es) of the devices with which you connect to BT Pay, including the geographic location from which you make the transaction through the App.

At the same time, when you start the App, we use a tool that scans the app list of the mobile device you're connecting with for malware, including remote/remote apps. Depending on the situation, the bank may take the following measures as appropriate: blocking the app until uninstalling third-party apps that may compromise the privacy of BT Pay information or contacting the bank.

We process this data to protect the information in BT Pay. If you refuse their processing, you will not be able to use the App. 

Information we process in order to register with BT Pay

In order to use BT Pay it is first necessary for us to apply a strict authentication procedure to you, as required by the applicable payment services legislation. For this purpose, we use some or all of the following categories of personal data about you as appropriate: telephone number, date of birth, other data from your identity document and a copy of it (the identity document can be an identity card issued by the Romanian authorities in the case of residents or, as the case may be, a passport or national identity card for non-residents), PIN (security code) set for BT PAY following the identification process in BT Pay, facial biometric data (only on the basis of your explicit consent, which you will be able to express on the basis of the details in the separate information note, which will be displayed to you in BT Pay, respectively: Information notice on the processing of personal data for identification purposes in BT Pay).

In the registration process it is also necessary to provide the card data that is requested from you.

Also at this stage, we will ask you to choose a nickname, which will correspond to your BT PAY account and will not be used for identification purposes.

The registration of the cards in BT Pay will be finalized only after it will be confirmed by entering the SMS-OTP code sent to the phone number declared to BT by the cardholder (hereinafter referred to as the "phone number declared to BT"). 

We inform you that the application will read from the device used the SMS with codes transmitted by BT including during the activation of the various functionalities of the application, codes that it will precomplete in various fields where necessary, to support you, respectively to make it easier for you to go through the steps necessary for activations. BT doesn't have access to other SMS from the device you're using.

You have the possibility to enter into BT Pay and cards issued in your name. by other financial institutions in Romania (hereinafter referred to as "non-BT cards"). In this case we will process information related to these cards, which are, as the case may be, personal data: card number, expiration date, CVV code and the name and surname on the card, name entered by you that will be displayed in the SMS sent automatically when initiating a transfer. The name entered will also appear on the image of the non-BT card in the application, which can be changed from the settings menu of the card.

You will only be able to complete the registration of a non-BT card in the application after completing the card registration steps according to the 3D Secure standards applied by the card issuer. Banca Transilvania does not know the method or the personal data used by the card issuer to perform this verification.

After registering the non-BT card in BT Pay, the user has the possibility to access certain financial information of the card by activating for a period of up to 90 days the Open Banking option.

In case of activating this functionality, BT Pay will have access to the following information that is, as the case may be, personal data of the client or other persons to / from whom he has transferred amounts through accounts from other financial institutions: the balance of the card, the selected IBAN account related to the respective non-BT card and the history of transactions in the selected payment accounts, including those made through the BT Pay app.

You can also enter into BT Pay your cards issued by BT Direct IFN SA (hereinafter referred to as " BT Direct cards"). In this case, we will process the following personal data from them: card number, expiration date, CVV code and the name and surname on the card.

You will be able to complete the registration of a BT Direct card in the application only after entering the SMS code received on the phone number registered in the records of the issuing institution.

Information about you that we process, as appropriate, when using BT Pay

For setting/resetting/unlocking PIN (security code), authentication in BT Pay

To enable you to perform these actions, we process personal data for identification purposes as set out in the Information Notice on the processing of personal data for identification purposes in BT Pay.

For payments to merchants

If you own a device with Android operating system and built-in NFC technology, with BT Pay you can pay merchants with the BT cards in the app. In this case, we will indirectly obtain data about you such as the checks you were asked to perform the operation (e.g. entering the phone unlock password), data about the transactions you made, the card data with which you made the transaction, the account attached to the card, including data related to the date, time and amount paid, data related to the location where you paid and those inserted in the payment description.

To pay to merchants with BT Pay installed on Android devices, nfc (Near Field Comunication) is required to be enabled. If this is not enabled, BT Pay will have access to this feature to direct you to your NFC settings. 

In the case of installing the BT Pay application on devices with Android operating system that do not have the NFC function available, the BT Pay application will not be able to be used for payment at merchants, but its other functionalities are available.

If you wish to register your card with Google Pay, this is subject to the Google Pay Terms and Conditions. The processing of your personal data in the context of the use of Google Pay services is also subject to the provisions of the privacy policy of the provider of these services, which is Google.

To make it easier for you to enroll in Google Pay the cards already registered in BT Pay, the app will check if you are using the Android operating system and, if so, if a card you have registered in the app is not enrolled in Google Pay, it will display a button that will allow you to enroll it in Google Pay. If you opt for this type of registration, the following your card data will be processed, including being transmitted by Banca Tranilvania to the Google Pay solution provider in a secure way: card number (PAN), card expiry date, first and last name on the card, BT customer code (CIF BT), Device ID, Wallet ID.

If you are using an iOS device, you will need to enroll your card in Apple Pay in order to use it to pay merchants via NFC. The use of cards in Apple Pay is subject to the Apple Pay Terms and Conditions which can be found at the following link: Apple Pay Terms and Conditions.

To make it easier for you to enroll cards already registered in BT Pay in Apple Pay, the app will check that you are using the IOS operating system and, if so, if a card you have registered in the app is not enrolled in Apple Pay, it will display next to it a button that will allow it to be enrolled in Apple Pay faster. If you opt for this type of fast enrollment, the following data related to your card will be processed, including transmitted by Tranilvania Bank to the Apple Pay provider in a secure way: card number (PAN), card expiration date, cardholder name, first 6 digits of the card number (BIN), card type (debit or credit).

For "Pay With BT Pay" users who choose "BT Pay" as their payment method on the merchant's website, they will be able to authorise the transaction using the BT PAY application by choosing the card with which they wish to make the transaction and confirming it.


For transfers

With BT Pay, you can make transfers between a BT card and any other BT card in the app or send or request money to/from people in your contact list as well as to/from any other BT Pay users, provided that the transfer amount is accepted on a BT card or you can choose a primary/preferred card for cashing. To operate such transfers (hereinafter referred to as "P2P transfers") to users of the app from your phonebook, BT Pay will request access to your phone's contact list. If you choose not to grant this access or if you do not have the phone number of the BT Pay user to whom you want to initiate a P2P transfer in your phonebook, you will need to enter this number. If you choose a preferred card for cashing P2P transfers, we will use the details of the chosen card for cashing and send you notification of the cashing.

In order to facilitate transfers of type P2P through the phone number, the BT Pay application will display at the time of initiating such a transfer if the chosen phone number (whether it belongs to a person from the contact list or not) the BT Pay application is installed. Thus, if the phone number on which you have the BT Pay application installed is selected or entered by any BT Pay user in order to make a P2P transfer, that user will find out that the BT Pay application is installed on that phone number.

Also, with BT Pay you will be able to initiate BT cards transfers based on IBAN code.

In the case of transfers, data related to the transaction (amount, explanations, date, etc.) will also be processed, as well as those of the recipient of the transfer - to whom you have sent an amount of money (name, surname, IBAN of the account in which or from which the payment is made).

You can provide proof of initiation of the transfer to an email address entered in a dedicated field, which we will keep to prove that we have submitted proof of payment as requested by you.

For P2P transfers initiated from a non-BT card to a BT card, the authentication of the transactions will be performed according to the 3D Secure standards applied by the institution issuing the non-BT card.

For the Accounts service:

When accessing the Accounts functionality, Banca Transilvania will process, as appropriate, the following information/personal data about you: IBANs related to the added accounts, cards attached to each account, transaction history related to the last 30 days, accounts currency, recurring payment balance and predefined beneficiaries set in BT Pay or retrieved from BT24 and NeoBT.

In the case of transfers, the transaction data (amount, explanation, date, etc.) as well as the data of the recipient of the transfer - to whom you have sent a sum of money (name, surname, IBAN of the account to which you wish to make the payment, telephone number - if you initiate/make a transfer to an account via Alias Pay) will also be processed. In the case of currency exchanges and payments, the currencies between which you are exchanging and the exchange rate, i.e. the currency in which you are making the payment, will be additionally processed as appropriate.

You can send proof of initiation of the transfer to an email address entered in a dedicated field, which we will keep to prove that we have sent proof of payment as requested.


For cash withdrawal from atm BT based on code

From BT Pay you can generate for cards issued per individual a code with which you can withdraw cash from the ATM. The code will have a reduced validity in time and will be sent by the bank to the phone number selected from the phonebook of the user BT Pay or entered manually by him. In order to send the code, it is necessary for the bank to process the phone number of the recipient.


For cash withdrawal contactless from BT ATM

With BT Pay, the user can withdraw contactless cash from the ATM. This operation will only be possible by entering the PIN code of the respective card.  


For setting trading limits and/or blocking cards

From BT Pay, you can set trading limits on BT cards registered in the app, block - temporarily or permanently - these cards, and request the release of temporarily blocked cards.

Access to these settings is allowed only after validation of the user's right to access them. In this regard, for each desired card, the use of these functionalities will be available (both for the card in digital and physical format) only after the SMS-OTP confirmation sent to the phone number declared to BT.


To display card details in the app

Through the BT Pay application, it will be possible to view and copy your card details – card number and CVV code (the 3-digit code displayed on the back of the card) in order to facilitate its use for online payments.

In some cases, access to this functionality is only allowed after validation of the user's right to use it. In this regard, for each desired card, an SMS-OTP will be sent to the phone number declared to BT. By entering the code received by SMS on this phone number, it is allowed to obtain this information for the respective card until the moment when it will be deleted from the BT Pay application.


For authentication / confirmation of online payments through BT Pay

Online payments (payments made on merchants' websites) initiated with BT cards registered in BT Pay and 3D secure will be able to be authenticated, respectively rejected, exclusively through the application.

The message related to the authentication / rejection of such an online payment will be sent within the application where the respective BT card is enrolled, on the "general" channel. Authentication / rejection of the online payment will be possible to be done from any of these devices.

Failure to enable notifications sent on the "general" channel will be able to make it impossible to receive the message necessary for authenticating / rejecting the online payment.

In the case of phones with Android operating system, with the user's permission, the payment confirmation screen can be automatically displayed, without the need to access the notification or the application, the user being able to confirm or cancel the payment by method of unlocking the phone. This permission we will request after the first confirmation of an online payment or it can be set from the advanced settings of the phone – the applications section – the BT Pay application.

Within the authentication / rejection message of the user's payment, the following information will be displayed: the card from which the transaction was initiated (the image of the card and the last 4 digits in the card, as they appear within the application), the name of the merchant to whom the payment is to be made, the transaction amount, the maximum time required to authenticate the transaction and the status of the authentication of the transaction . If the card has been enrolled to authenticate online payments in multiple devices, all these devices will receive the mentioned information. If the transaction was approved / rejected from one of the devices, when accessing the application from any other device, the status of the transaction will be viewed.

Upon receipt of the message related to the initiated online payment, BT Pay will save the transaction identifier to the phone device, in order to be able to display the message at the next opening of BT Pay, in order to authenticate / reject it. The transaction identifier remains stored in the phone used until the online payment is authenticated or rejected, as the case may be.

We also process the data related to the phone unlocking method of your choice to ensure the proper security of the transactions in accordance with the legal provisions applicable in the field of payment services. The data related to the unlocking method of the phone you have chosen (e.g. fingerprint, facial identification, model, PIN, password, etc.) is not in the bank's possession, but BT only finds out the result of the verification (accepted / rejected) by comparison, of the data used to authorize each payment operation with the corresponding blank data stored in your phone.


For identification via BT Pay if you are on a call in a call centre or BT unit

If you choose to be identified in BT Pay in case of a call in a BT call centre or, in specific situations, in a BT unit, we will process personal information/data according to which you are a BT customer, a natural person using the Application, the phone number on which you have BT Pay installed, the activation of the phone unlocking method, data on the version of the application installed.


To update personal data in BT through the BT Pay app

In case of accessing this functionality, you will have the possibility to update some of the personal data necessary for the bank to apply the customer knowledge measures in the BT Pay application. In connection with the processing of your personal data for this purpose, you will be shown a separate information note, specific to this functionality, which can be accessed following the link displayed in the "general provisions" section of this information note.


To activate and use the Invoice Payments service

Within this service, personal data will be processed by BT as informed by a separate information note specific to this functionality, which can be accessed by following the link displayed in the "general provisions" section of this information note.


For enrollment in Open Banking

In case of accessing the Open Banking functionality in the case of non-BT cards added to BT Pay, BT will have access to the following information which is, as the case may be, personal data of the customer or of other persons to / from whom he has transferred / received amounts through accounts from the financial institutions from which he has integrated his accounts in BT Pay:

  • The balance of the selected non-BT card / account
  • IBAN account for the selected card
  • List of transaction history of the selected open payment accounts, including the following details: transaction date, transaction amount, transaction details (transaction details and transaction authorisation code, person from whom amounts were debited to the account or, if applicable, person to whom amounts were transferred to the account).


For debit card issue/ reissue functionality

When accessing the Debit Card Issuance or Re-issuance functionalities, BT will process, as appropriate, the following information/personal data of yours: data related to the card issued/re-issued, IBAN of the account to which it will be attached, delivery address of the card.


To issue a Virtual Card

When accessing this functionality you will be able to request the issuance of a virtual debit card from the BT Pay application, BT will process, as appropriate, the following information/personal data of you: data related to the card issued, IBAN of the account to which it will be attached.

For BT Pay Kiddo functionality - for minors over 14 years old

If you access the BT Pay Kiddo section - the section for minors over 14 - and try to connect a minor in this age group, we will need to check that you meet the conditions set out in the BT Pay Kiddo Terms for minors who have a BT account. To do this, based on your personal data consisting of name, surname, ID, age, we will check whether you are the authorised representative on the account of the minor for whom you provide us with data in BT Pay (ID and phone number), to grant him/her the right to access/use BT Pay for minors. In addition, we will implicitly also process personal data consisting of the relationship between you and that minor.

The provisions in this paragraph only relate to the processing of your data as the parent of the minor. The processing of the minor's personal data is carried out in accordance with the Information Notice on the processing in BT Pay of personal data of users under the age of 14 who have a BT account, including the provisions relating to the personal data of minors in the Information Notice on the processing of personal data for identification purposes in BT Pay, which you are kindly requested to read before completing the connection process with the minor in this age group through BT Pay Kiddo. 

For BT Pay Kiddo functionality - for minors between 8 and 18 years old attached to the parent's account

If you access BT Pay Kiddo - the section for minors attached to a parent's account and you try to connect a minor between the ages of 8 and 18 years old to use BT Pay with their own card attached to your account, we will need to check that you meet the conditions set out in the BT Pay Kiddo Terms for minors attached to a parent's account.

For this purpose, we will process your personal data consisting of your name, surname, CNP, age andimplicitly personal data consisting of the relationship between you and that minor.

The provisions in this paragraph only relate to the processing of your data as the parent of the minor. The processing of personal data of a minor aged 8 - 18 without a BT account is carried out in accordance with the Information Notice on the processing in BT Pay of personal data of minor users attached to the parent account, which we ask you to read before completing the login process with the minor in this age group through BT Pay Kiddo.

For offering, issuing and managing MTPL insurance

Through the 'MTPL Insurance' section of BT Pay you can get MTPL Insurance quotes from different insurers or take out MTPL Insurance policies. In order to display insurance offers in the BT Pay application, several pieces of information are required, some of which are personal data. Unlike the other functionalities available in BT Pay, please note that for the personal data processed in this section Banca Transilvania is only a processor. The processing of personal data in this section is subject to the provisions of The Processing Policy of Timesafe SRL ("the Company") and Renomia - SRBA Insurance Broker SRL ("the Broker") of Personal Data within the "MTPL Insurance" section of the BT Pay App.which is provided to you separately by the data controllers and which you will find in the menu of this section available in BT Pay.  

For the functionality of Round Up

In case of accessing the Round Up functionality, BT will process, as appropriate, the following information/personal data of yours: the amount related to the round up service, the multiple of the selected amount, the data of the account for which the activation of the service is desired and of the account to which the amounts related to the round up service are transferred.

For Savings functionality in BT Pay

When accessing the Savings functionality, the Bank will process - if applicable - the following information/personal data: the IBAN of the current account from which the deposit is made, the balance of the current account, the IBAN of the deposit account or - if applicable - of the savings account set up, the amount of the deposit, the start and end date of the deposit, the date chosen for recurring transfers, set for savings accounts.

For the "Move your money to BT" option

When you use this functionality we process personal data such as: the amounts you transfer to the account to which the BT card is attached and the frequency with which you transfer them, the data of the cards involved in the recurring transfer and the bank from which you transfer the amounts.

For the Loans functionality in BT Pay

When accessing the Loans functionality, the Bank will process - as appropriate - the following information / personal data of you, as a BT Pay user:the IBAN of the credit account and of the current account from which the monthly instalment is withheld, the balance of the non-card credit account, the amount of the contracted credit, the start and end date of the credit, the amount of the monthly instalment, any arrears.

For the Account statements option

To use this option you will be able to preview or download the account statements of the accounts opened and added in the BT Pay application, BT will process, as appropriate, the following information/personal data of yours: transaction data, account IBAN, account balance, transactions, rates on credit products and points available for credit card accounts held with BT.

For the Card Reload option

When you use this option, we usually process the following: the phone number for which you are recharging, the card details, the balance of the account from which you are recharging.

For the Rovinieta option

To use this option you will have the possibility to purchase or renew from BT Pay a vignette for the territory of Romania. BT will process, as appropriate, the following information / personal data: information relating to the vehicle for which the road tax ticket will be issued, the balance and the card used to pay the road tax ticket.

For Investment functionality

When accessing this feature you will be able to view the investment accounts held at BT Asset Management SAI. Banca Transilvania will process, as the person empowered by the BTAM operator, as the case may be, the following personal information/data concerning you: name, surname, CNP, BTAM client ID, investment account number, transaction history, BTAM balance.

For offering, issuing and managing Travel Insurance

Through the "Travel Insurance" section of BT Pay you can get Travel Insurance offers from the insurer Groupama Asigurari S.A. . In order to display the insurance offer in the BT Pay application and to conclude the insurance policy, several personal data are required. Unlike the other functionalities available in BT Pay, please note that for the personal data processed in this section, Banca Transilvania is only the authorized person of the operator Groupama Asigurari S.A. . The processing of personal data in this section is subject to the provisions of the Information Notice on the Processing of Personal Data from Groupama (an integral part of the Groupama S.A. Privacy Policy), which is made available to you separately in BT Pay from this operator, when you request a travel insurance offer. You will also find this information note in the Travel Insurance section menu of BT Pay.

To provide the Beneficiary Name Display Service (BNDS) for the purpose of fraud prevention for interbank payments initiated from payment/internet banking applications.

Personal data are processed by BT together with other associated operators, as detailed in the Information Notice on the processing of personal data within the Beneficiary Name Display Service (BNDS).

For the prevention of fraud in the case of intrabank payments initiated from its own payment/internet banking applications, BT processes - as an independent controller - the same categories of personal data that are also used within SANB, but without the involvement of other participating banks and without the involvement of Transfond. The basis for the processing of your data is BT's legitimate interest in preventing fraud in the case of intra-bank payments (BT-BT). Your full first name (one or more, as the case may be) and the initial of your surname registered with BT will be displayed to other BT customers who initiate from a bank application a payment to your BT account, whether the payment is completed or not.


For communication with BT Pay users

The app will send a series of notifications regarding the following aspects:

  • Notifications confirming / invalidating the payments made through the cards registered in the application;
  • Specific notifications, dedicated to the users of the service Pay Invoices;
  • Notifications for identification via BT Pay;
  • Notifications for transfers, related to the acceptance of transfers by the beneficiary / payer, the successful execution of the transaction, the rejection of the transaction by the payer;
  • Notifications of offers, the user being informed of the new offers added to the list of offers, as well as if he has unlocked an offer in the section Offers - prizes on the move
  • Notifications for authentication / rejection of online payments initiated with BT cards enrolled in the application and in 3DSecure
  • General notifications, where the user is notified of other relevant information related to the BT Pay app, other than those related to the above functionalities
  • Notifications of particular interest, by which the user is informed about important issues related to his/her contractual relationship with the bank (e.g. changes to the bank's General Terms and Conditions of Business, changes to fees, changes to the General Information Notice on the processing and protection of personal data of BT customers, notifications about the need to update the data concerning money, notifications for identification through BT Pay, following a call to the BT call centre or, where applicable, following certain types of requests/transactions in BT units)


If you don't want to receive some or all of these notifications, you can turn them off in the app's Settings menu. If you do not have notifications set to "on" you will not receive push notifications, but will find them in the Notifications section of the app.

If it is necessary to communicate with you in relation to important aspects related to the use or operation of BT Pay, in order to ensure that these communications reach your attention, we reserve the right to use the phone number and / or e-mail address declared by you in the records of Banca Transilvania.

In order to inform you about the latest versions of the application available in the official Google Store stores, Huawei App Gallery / App Store, for you to use all the functionalities of BT Pay, we will notify you at the time of accessing the BT Pay application. These notifications will be displayed up to 2 times in the case of each application update and will not block access to the use of the BT Pay application.

In order to display personalized offers, BT Pay will request permission to access the location of the device on which the application is installed, in order to automatically display the offers of STAR partners (for STAR credit card owners), but also of the BT offers that are addressed specifically to a locality. You will be able to choose not to grant access to the location of the device, in this case you will be able to manually select the desired locality. At the same time, the application will offer users the possibility to view the partner locations related to the published offer, on the map, in this case being necessary to activate the GPS functionality in the device settings.

By accessing the "offers" section of the app, you agree that BT will collect information about the offers accessed (saved, activated or to which you have applied), in order to present in the future other offers that may be of interest to you and to the application of preferential conditions for the offers activated or to which you have applied.


To display the categories of expenses grouped by category of traders

Through the application you will be able to view the expenses made with BT cards at merchants, grouped by categories of expenses. The categories of expenses are displayed according to the category of merchants to which you make payments with that card are classified and do not involve any analysis or evaluation of your payment behavior.

In order to be able to compile statistics that allow the measurement of the performance of BT Pay services in order to improve the performance of this application, it is necessary to collect the following information about the devices on which it is installed - phone identification (Device ID), phone type, operating system, operating system version, device name, device settings, accesses necessary to have internet connection.


Retention period of the data provided / collected within the BT Pay application

Except for the situations expressly mentioned in the presence of information notes, your data, as a BT customer, as well as the data regarding the transactions carried out through BT Pay will be kept for a period of 5 years from the termination of your business relationship with the bank, according to the applicable legal provisions, except for the data that must be kept for a period of 10 years, according to the legal provisions in the financial accounting and fiscal field.


To whom we may disclose information provided by BT Pay users or collected by the bank

The data provided directly by the users of the application or of which the Bank can become aware, as mentioned in the previous section, may be disclosed by Banca Transilvania to the service providers who assist us in providing the application, to the Apple Pay solution, if you have opted to quickly enroll your card from BT Pay, to public authorities / institutions authorized in accordance with the applicable legal provisions, at the latter's request.

In accordance with the aspects mentioned in the presence of the information note, certain information will be implicitly disclosed to other BT Pay users.

In addition, in the case of certain competitions, certain data necessary for partner merchants will have to be communicated to you in order to deliver your prizes.

Banca Transilvania will be able to use the personal data provided by users / collected by the Bank within BT Pay to prevent and identify frauds, as well as for other legitimate purposes.

The categories of recipients to whom personal data are disclosed in the context of the new registration method in BT Pay as well as the separate services Alias Pay BT, Bill Payments, Overdraft, Credit Card and online credit line increase are mentioned in the specific information notes for the processing of personal data within these services.


Security

The bank guarantees that it has implemented appropriate technical and organizational measures to ensure the security of personal data in the application. Despite these precautions, the Bank cannot guarantee that unauthorized persons will not gain access to personal data, especially if such access is due to the fault of the customer.

You are solely responsible for maintaining the confidentiality and keeping your phone safe, in particular the phone unlock password (password, fingerprint or other security method offered by the phone), as well as login data in third-party applications, for example: physical activity monitoring applications. Moreover, you are responsible for activities of any kind that take place in your account, such as if it is found that you have not done the necessary diligence to maintain the security of the device where the application is installed or if you have provided to persons, intentionally or through fault, SMS-OTP codes or other details available in the application, that have allowed them or other third parties to have access to your cards/accounts.

You must notify us immediately of security breaches or unauthorized use of your mobile phone. We will not be liable for your losses caused by unauthorized use of your account, such as cases where it turns out that you have not done the necessary diligence to maintain the security of the device where the application is installed and / or the information available in the application (e.g.: disclosing the method of unlocking the phone, knowingly accessing suspicious content, intentionally or by faulty access to links, images and any other suspicious content that has led to the disclosure of the data of your cards / accounts available in the application, etc.).

If, through your fault. or for any other reason, unauthorized persons will access the information that will belong to you and that is available in / through BT Pay, the bank, as soon as it is notified or establishes the occurrence of such a situation, will take all necessary measures to limit any future unauthorized access and will make all necessary efforts to limit any negative effects already produced.


Links and third-party applications

The application contains links to the websites belonging to the partner merchants.

At the same time, the application offers users the possibility to access third-party applications - to monitor physical activity - by logging in with the account data from that application through the BT Pay application, in order to unlock preferential offers from the Moving Prizes section of BT Pay.

The application also offers users through the Offers section the option of accessing personalized links from partner merchants to access that third parties will be able to know that the person has accessed from BT Pay, so implicitly the fact that it is a BT customer.

The Bank does not manage or control in any way the information that the owners of the websites of the partner merchants or the providers of the third-party applications process in relation to the users, so it cannot guarantee that it is processed and / or protected in accordance with the applicable legal provisions in the field of processing and protection of personal data, as well as, but not limited to, the General Data Protection Regulation ("GDPR"), Law 506 / 2004, Law 190 / 2018. Also, the bank cannot know and / or guarantee the timeliness or accuracy of the information that these sites / applications hold about you.

Because the bank wants to encourage an active life, within BT Pay it has developed the Awards section on the move, by accessing which users can unlock offers at preferential prices offered by partner merchants with whom the bank collaborates, as well as offers of the Bank.

For this purpose, by accessing a physical activity monitoring application through BT Pay, the Bank will request permission to access certain information related to the activity carried out by the user in the third application. This data will be visible to the user who accessed the respective application through BT Pay in the Moving Prizes section. Of these, the bank will use to allow the unblocking of offers only information related to the number of steps taken, the number of kilometers traveled and / or the number of active minutes ("physical activity data"), as defined in the third-party physical activity monitoring application. In order to verify the user's eligibility to benefit from the offer published in The Moving Prizes and to correctly allocate the prizes, the Bank will store the data on the user's physical activity strictly for the period necessary to fulfill these purposes.

The offers will be able to be unlocked according to one or more of this information, to which will be added, as the case may be, other parameters related to the activity with the card, the sticker, the BT Pay application from a certain period, all these parameters being specifically mentioned in each offer.

You are not obliged to access and use the Moving Prizes section of the BT Pay app. Failure to access this section does not affect in any way the possibility of using BT Pay's services. If you have granted access to the BT Pay application to the information in the motion monitoring application you are using, you can revoke this access at any time from the settings of the third-party application / from the phone settings, the permissions granted to the BT Pay application for taking over the physical activity. In this case, until you have a possible new grant of access, you will no longer be eligible for offers in this category.

Each site and third-party application accessed through the application has its own rules regarding the processing of personal data, so please refer to the policy of each site / application to ensure that it does not contravene your interests.


The rights you can exercise in connection with the processing of your personal data

The processing of your personal data in the context of carrying out banking transactions with cards enrolled in BT Pay is subject to the provisions of the General Information Note on the processing and protection of personal data belonging to BT customers, an integral part of the BT Privacy Policy, which you can find on the website www.bancatransilvania.ro, in the Privacy Hub section or on request in any of the bank's offices.

In the general information note mentioned above you can also find the rights you can exercise in connection with the processing of your personal data, the ways in which you can exercise them, as well as the contact details of the Data Protection Officer (DPO) and the way in which you can contact him/ her.