Processing of personal data - legal entities

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 – as a representative of a legal entity holding an account and Idea products/services – as well as the data of persons related to the legal entity at Idea::Bank (e.g.: persons designated with account operation rights on Idea accounts, beneficial owners, representatives of any kind, co-debtors, guarantors, etc.), as we inform you below. Personal data also include any information about legal entities such as P.F.A., I.I., individual forms of practicing liberal professions (e.g.: individual medical offices, lawyers, notaries, bailiff offices, etc.)

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 BT's assignment of certain banking contracts concluded by Idea with its clients. BT and Idea have concluded an agreement to establish the responsibilities and obligations of each regarding the personal data processed for the purposes and by 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 necessity to verify whether the legal entity is a common client of the two banks, the preparation and transmission of the offer of BT products/services and this notification, the assignment of contracts related to Idea's products/services to BT, the verification of the application of customer due diligence measures for the prevention of money laundering and terrorist financing.

Strictly necessary personal data for these purposes have been disclosed/will be disclosed in the next period by Idea to BT and will be further processed on the following grounds: fulfilling the legal obligations of notifying the assignment of the contract, taking measures for concluding a contract between the legal entity and BT (as a result of the assignment), fulfilling the legitimate interests of the associated operators to present you in advance with the offer of BT products/services corresponding to those from Idea, so that you do not encounter interruptions in the use of banking services and so that you are not required to repeat processes at BT such as appointing persons with rights to operate accounts or providing/updating data necessary for customer identification.

Data are 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 that the legal entity has contracted and about the transactions carried out through accounts opened at Idea, including data related to account numbers, client codes, contract numbers, data necessary for applying customer due diligence measures to prevent money laundering and terrorist financing. At BT, data and banking products corresponding to those from Idea (IBAN codes of bank accounts, client code, BT products/services) have been reserved for the legal entity as indicated in this notification.

Reported to these purposes and legal grounds, the joint processing of data by the associated operators can only cease in the event that you terminate the contractual relationship that the legal entity has established with Idea or at the end of the joint data processing period.

Joint data processing by Idea and BT as we inform you through this information note does not affect the processing carried out independently by the operator Idea:: Bank, separate from BT, as long as you have the status of representative of a legal entity client of the latter, as well as after the termination of this status. You can find details about this processing on the website https://ro.idea-bank.ro/, the section Personal data processing. About the protection ensured by Idea of its clients' data you can find details on the same website, in the section Personal data protection.

If you do not become a BT client following the assignment of contracts concluded between Idea and the legal entity you represent, Banca Transilvania will anonymize your data received from Idea Bank and the corresponding data reserved for you in BT. However, Idea will continue to process this data as a separate operator, either in your capacity as a representative of an Idea legal entity client, or as a former client/representative of a 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 information note regarding the processing and protection of personal data belonging to BT Clients, which you find on the website https://www.bancatransilvania.ro/companies, within Privacy Policy 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.

We do not anticipate the need for jointly processed personal data to be transferred to countries outside the EU/EEA or to international organizations. If such a need arises, the transfer will only be carried out in accordance with the rules and based on the guarantees permitted 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 operators associated for the common purposes previously presented: 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 data erasure, 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 Supervisory Authority for 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 www.bancatransilvania.ro/ideabank.