🏦 Data controller and 👤data subjects
🏦 Data controller and 👤data subjects
Banca Transilvania S.A. ("Bank", "BT") informs you how it will process your personal data when you request, through the BT Pay mobile application ("Application" or "BT Pay"), the update of personal data ("personal data", "data") already registered with the bank.
This information note is for you if you are an adult individual BT client and want to update your data through the Application.
🎯 Purposes and ⚖️ legal bases of data processing
🎯 Purposes and ⚖️ legal bases of data processing
In the process of updating data in BT Pay, we process your personal data for:
(i) fraud prevention, according to our legal obligations, based on legitimate interest and, where applicable, based on your explicit consent - before updating the requested data, we will verify your identity to confirm that you are the entitled BT Pay user and that the data you wish to update is yours (e.g.: phone number, e-mail).
(ii)the application of measures regarding customer due diligence for the prevention of money laundering and terrorist financing - as a credit institution, BT has the legal obligation to apply measures regarding customer knowledge. These measures involve verifying identity and processing certain personal data required by law, both at the time of acquiring the status of BT client (data collection) and throughout the entire period this status is held (data updating). Details about data processing for this purpose can be found in information note dedicated.
🗂️ Processed personal data and what happens if you refuse their processing
🗂️ Processed personal data and what happens if you refuse their processing
In order to update the data through BT Pay, we would process the following categories of personal data:
(i) the image faces, from the selfie video that we will ask you to make (requires access to the photo camera) and, if applicable, from the identity document, to verify your identity
(ii) the biometric data of the face, only if you explicitly express your consent (agreement) - we will request this agreement in BT Pay before carrying out such processing . Biometric data are obtained by biometric comparison of the selfie image with that in the identity document already registered at the bank and, if applicable, at the DGEP (see here details about the processing of data provided by D.G.E.P.).
Biometric comparison is carried out by analyzing relevant facial features, using specific IT methods, to uniquely confirm that the same person appears in the images. Following the biometric comparison, the IT solution indicates the probability that the face in the compared images belongs to the same person.
(iii) the data from the identity document - if you request to update your identity document registered at the bank, it will be necessary to photograph it (requires access to the camera). We will compare the information from this with that existing in the bank's records and with that from your document issued by the General Directorate for Personal Records G.D.P.R. (see the previous point for a link with details about the processing of data provided by G.D.P.R.).
(iv) the data whose update you request – as applicable, identification data, image, contact details, professional data, information about the BT products and services used.
You can find details about the categories and types of personal data we process for BT clients in section V of General information note concerning the processing and protection of personal data belonging to BT Clients
The data you update in BT Pay will also be updated for services/products you use, such as for sending account statements by email (if you have opted to receive them through this channel), for cards or SMS Alert, for communication with you (e.g. sending messages for the smooth conduct of the contractual relationship and, if you have given your consent, also for sending advertising messages).
If you refuse to let us process your data as we have informed you above or if we fail to verify/confirm your identity, you will not be able to update your data through BT Pay, but you can update them at any BT branch, after identification based on the identity document.
📄 Other information about the processing of your personal data
📄 Other information about the processing of your personal data
This information note is completed with the provisions General information notes regarding the processing and protection of personal data belonging to BT Customers, which we recommend you consult. It is an integral part of BT Privacy Policies, pe care o regăsești pe site-ul bancii www.bancatransilvania.ro, including in the section Privacy Hub from the site. Within the general information note, you will find including the definition of the BT Client, as well as details about: the bank's identification data, all purposes and grounds on which we process BT Clients' data, and about the recipients and the storage period of these data, about automated decision-making processes, as well as about the rights you benefit from in connection with the processing of your data, about the ways in which you can exercise them and about how you can contact the person responsible for data protection appointed by BT (BT DPO).
