Processing of personal data - natural persons
INFORMATION REGARDING THE PROCESSING OF PERSONAL DATA
Data controllers and data subjects
Banca Transilvania S.A. (hereinafter "BT") and Idea::Bank S.A. (hereinafter "Idea"), entities of the Banca Transilvania Financial Group, jointly process your personal data - account holder and of Idea::Bank products/services - as well as of persons related to you at Idea (e.g., persons designated with operating rights on Idea accounts, real beneficiaries, representatives of any kind, co-debtors, guarantors, etc.), as we inform you below.
This processing is carried out by the two banks as joint controllers, in accordance with the provisions of the General Data Protection Regulation (GDPR) and other applicable legal acts in the field, in the context of the assignment to BT of certain banking contracts concluded by Idea with its clients. BT and Idea::Bank have concluded an agreement to establish the responsibilities and obligations of each regarding the personal data processed for the purposes and by the means they have jointly determined.
Yescategories of data processed and their source, purposes and grounds of processing, retention period
Data processing is carried out to fulfill the common, determined, and legitimate purposes established by BT and Idea, related to: the need to verify if you are a common client of the two banks, the preparation and transmission of the BT product/service offer and this notification, the assignment of contracts related to Idea::Bank products/services to BT, the verification of the application of customer due diligence measures to prevent money laundering and terrorist financing.
Strictly necessary personal data for these purposes have been disclosed/will be disclosed in the following period by Idea to BT and will continue to be processed on the following grounds: fulfilling legal obligations to notify the assignment of the contract, taking measures to conclude a contract between you and BT (as a result of the assignment), fulfilling the legitimate interests of the associated operators to present to you in advance the BT product/service offer corresponding to that from Idea, so that you do not experience interruptions in the use of banking services and so that you are not required to repeat at BT processes such as the designation of persons with account operating rights or providing/updating data necessary for client identification.
The data is transmitted between the associated operators by means that ensure their adequate security and are part of the following main categories: identification data, contact data, data about the Idea products/services you have contracted and about transactions made through accounts opened at Idea, including data related to account numbers, client codes, contract numbers, data necessary for the application of client knowledge measures to prevent money laundering and terrorist financing. At BT, banking data and products corresponding to those from Idea have been reserved for you (IBAN codes of bank accounts, client code, BT products/services), as indicated in this notification.
Reported to these objectives and legal grounds, the joint processing of data by the associated operators can only cease in the event that you terminate the contractual relationship you have established with Idea or at the end of the joint data processing period.
The joint processing of data by Idea and BT, as we inform you through this privacy notice, does not affect the processing carried out by the operator Idea Bank independently of BT, as long as you are a client of the former, as well as after the termination of this status. You can find details about this processing on the website https://ro.idea-bank.ro/ at the section "personal data processing". About the protection ensured by Idea for its clients' data you can find details on the same website, at the section "personal data protection".
If you do not become a BT client following the assignment of the contract, Banca Transilvania will anonymize your data received from Idea Bank and the corresponding data that was reserved for you at BT. However, Idea will continue to process these data as a separate operator, either in your capacity as an Idea client or as a former client, for the periods mentioned in the “personal data processing” section indicated above.
In case you are already or if you will become a BT client as a result of the contract assignment or otherwise, Banca Transilvania processes your personal data as a controller, distinct from Idea::Bank, as you are informed through General privacy notice on the processing and protection of BT Clients' personal data, which you can find on the website www.bancatransilvania.ro within Privacy Policies or by accessing the following link directly: https://www.bancatransilvania.ro/Nota-informare-generala-privind-prelucrarea-si-protectia-datelor-cu-caracter-personal-clienti-BT.pdf, as well as on request, in any BT unit.
Recipients of personal data
The data processed jointly by the associated operators are accessible, as appropriate, to their employees who need to know them, IT service providers involved in the activity of contract transfer, service providers for preparing notifications, courier services, auditing, archiving, authorities and institutions entitled to know them, notaries, lawyers, insurance or evaluation companies.
Also, if the employer has concluded an agreement with BT regarding salary-related collections, the IBAN of the account to be opened at BT - corresponding to the one at Idea - will be provided to your employer, for the optimal transfer of funds.
At the same time, if you are receiving into the accounts opened at Idea amounts representing pensions or other types of social benefits (e.g., state allowances for children, disability pensions, unemployment benefits, social assistance, etc.), Banca Transilvania will communicate to the paying institutions the IBAN of the account which will be opened in BT instead of the one at Idea, so that you receive the amounts into this from July 2022, without you having to take any further steps. If you do not wish to receive the amounts in the new account opened at BT, you will have to provide the paying institutions with the account opened at another bank where you want the amounts to be transferred.
Last but not least, if you have concluded loan agreements with Idea Bank S.A. and these are subject to assignment to Banca Transilvania S.A., which has been communicated to you through this notification, we inform you that the assignment of each relevant loan agreement will be reported, as an event occurring during the loan term, to the Credit Bureau. Details about the data processed at the Credit Bureau by Banca Transilvania S.A. during the course of a credit relationship can be found in the general privacy notice regarding the processing and protection of personal data belonging to BT clients or by directly accessing the following link: https://www.bancatransilvania.ro/Information-note-regarding-the-processing-of-personal-data-in-the-context-of-conclusion-and-execution-of-a-BT-credit-agreement.pdf
We do not foresee the necessity for personal data processed jointly to be transferred to countries outside the EU/EEA or to international organizations. If such a need arises, the transfer will be carried out only according to the rules and based on the guarantees provided by the GDPR.
Rights you benefit from
Any data subject is guaranteed the following rights regarding the processing of their personal data carried out by the associated operators for the common purposes presented above: the right to information (we provide you with all the information through this privacy notice), the right of access, the right to rectification, the right to restriction of processing, the right to erasure of data, the right to object to data processing, the right to data portability. You can exercise these rights by sending a request to the registered office of any of the associated operators, addressed to the DPO or by e-mail, as follows: for BT at dpo@btrl.ro or for Idea at dpo@idea-bank.ro. Also, if you consider that this processing violates your rights, you can file a complaint with the National Authority for the Supervision of Personal Data Processing or address the court.
All details about the joint processing of personal data carried out by Idea::Bank and Banca Transilvania S.A. in the context of the contract assignment can be found in the Personal Data Processing section on the website https://www.bancatransilvania.ro/ideabank.