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    Information note regarding the processing of personal data for identification in Chatbot in order to provide personalized banking information

    Version updated on November 24, 2025

  • 🏦 The data controller, 🎯 the purpose and ⚖️ the legal basis for processing personal data

    Banca Transilvania S.A. ("Bank", "BT") provides customers with a chatbot ("Chatbot") through which they can request and obtain personalized information about the products/services contracted from the bank, including being able to modify some information related to them (hereinafter referred to as "personalized banking information").

    To ensure that we provide such information only to authorized persons, we have the legal obligation and legitimate interest to verify the identity of those who request it.

    The more sensitive the requested banking information is, the stricter the level of identification we will apply, as we inform you below.

    🗂️ Processed personal data and what happens if you refuse their processing

    To be able to provide you with personalized bank information you will need to enter in the Chatbot personal numeric code (CNP), telephone number declared in relation to the bank and the unique identification code (SMS-OTP) that we will send you via SMS. We process this information both to verify whether you meet the conditions to obtain personalized banking information through the Chatbot (you are a BT client, adult, and resident) and to ensure that you are who you claim to be, so that we do not provide you with the requested information if you are not entitled to receive it.

    Additionally, if you are a BT Pay user and meet the eligibility conditions (e.g. you have at least one card enrolled in this application and have completed the identification process according to legislation of payment services, either directly in BT Pay, or in a BT unit) during live chat type conversation with a BT employee, which you will enter by accessing the "talk to a colleague" sections from the Chatbot, for some types of banking information you will be able to complete the identification process in BT Pay, by accessing a push notification that we will send you.

    If you do not have BT Pay, do not meet the eligibility requirements, or do not wish to be identified through the application, for some types of personalized banking information that you request through the Chatbot you may either be identified by answering additional questions, or by completing a remote identification process through video means, without a human operator, if you express your consent in this regard.

    In this case, for identification, the following types of personal data would be processed, depending on the situation: (i) the data from the identity document, pe care va fi necesar să îl fotografiezi în anumite situații (acest lucru implică acces la camera foto). Vom compara aceste informații cu cele existente în evidențele băncii; (ii) the image faces in motion, from the selfie video that we will ask you to make in certain cases (requires access to the camera), (iii) the biometric data of the face, obtained by biometric comparison of the selfie image with the one from the identity document photographed in the Chatbot and/or with the image already existing in the bank's records. We will process your biometric data only if you give your explicit consent, which we will request from you in Chatbot before carrying out such processing. Biometric comparison is performed by analyzing relevant facial characteristics, 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 two images belongs to the same person. To express your consent for the processing of biometric data (facial recognition), you will need to select the button in the Chatbot „I explicitly consent to my biometric data being processed” and if you refuse to have your biometric data processed, you will select the button „I do not wish my biometric data to be used”.

    If you refuse to allow us to process your data through the means indicated above or we fail to identify you in the Chatbot, we will not be able to provide you with personalized banking information within this chatbot, but you can obtain it at any BT branch, after identification based on the identity document.

    ⏳The period of retention of personal data in conversations held through Chatbot

    We will keep your processed data for identification in the Chatbot, if applicable, together with the discussion with the agent, for a period of 3 years.

    📄 Other information about the processing of your personal data

    This information note is supplemented with the provisions General information notes regarding the processing and protection of personal data belonging to BT Clients, which we recommend you consult. It is an integral part of BT Privacy Policies, which you can find on the bank's website 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, about the recipients of BT Clients' data, about the rights you benefit from in connection with the processing of your data, about the ways you can exercise them, and about how you can contact the data protection officer designated by BT (BT DPO).