Banca Transilvania, S.A., (hereinafter also referred to as "the bank", "BT", "we"), hereby informs you through this specific information note how it intends to process your data when you deposit, as an occasional BT client, cash amounts into accounts opened at BT over which you have no capacity (including the bank's regular clients – BT clients – who deposit such amounts into accounts over which they have no capacity will be occasional clients).
This information note is completed with the provisions BT Privacy Policies (hereinafter also referred to as the “Policy”), which we recommend you consult. Within the Policy, you will also find the definition of the “BT occasional client,” as well as other details regarding the processing of data of this category of data subjects, especially in section C of this Policy, found on the BT website www.bancatransilvania.ro.
When you act in relation to us as an occasional BT client, for depositing cash at the counters of our units into BT accounts for which you do not have the status of account holder, authorized person, delegate with rights to deposit cash sums - it is necessary to identify you based on a valid identity document and to process in our records the following personal data concerning you - name, surname, series and number of the identity document, Personal Numeric Code (CNP), domicile, details regarding the deposited amount and explanations concerning the nature of the payment (what the payment represents).
In some cases provided by law, it will be necessary to make and keep a copy of your identity document.
We process this data for you, as applicable, for the main purposes related to:
- identity verification, in order to prevent money laundering and terrorist financing; In the case of occasional transactions carried out through the bank's units, identity is verified based on valid identity documents, which must be presented in original, and in the case of using BT equipment through other information about the payer held in the bank's records;
- client knowledge for the prevention of money laundering and terrorist financing, including risk-based verification, through the application of customer knowledge measures;
- conclusion and execution of the contract related to the occasional transaction;
- evaluation and monitoring of financial-commercial behavior in order to detect unusual transactions and suspicious transactions, in accordance with the legal obligations of customer due diligence imposed on the bank for the prevention of money laundering and terrorist financing;
- reimbursement of bank transactions;
as well as, depending on the situation, for other purposes closely related to the main ones, namely for:
- preparation and submission of reports to the competent institutions to receive them, in accordance with the legal provisions applicable to the bank (such as, but not limited to: reports on payment incidents to the Payment Incident Center within the National Bank of Romania, declaration of transactions exceeding the amount established by law to the National Office for Prevention and Control of Money Laundering);
- carrying out analyses and keeping records of the bank's economic, financial and/or administrative management;
- administration within the internal departments of the services and products offered by the bank;
- the legal defense of the bank's rights and interests, the resolution of disputes, investigations or any other petitions/complaints/requests in which the bank is involved;
- carrying out risk controls on the bank's procedures and processes, as well as performing audit or investigation activities;
- monitoring/security of persons, spaces and/or assets of the bank or its unit visitors;
- taking measures/providing information or responses to requests/notifications/complaints of any nature addressed to the bank by any person and/or by authorities or institutions, through any channel, including via electronic communication services and the internet;
- carrying out internal analyses (including statistical);
- archiving - both in physical and electronic format - of documents, making backup copies;
- provision of registry and secretarial services regarding correspondence addressed to and/or sent by the bank, as well as for carrying out courier activities;
- ensuring the security of the IT systems used by BT and the physical spaces where the bank operates;
- fraud prevention;
We mainly process this data on the basis of our legal obligations in order to fulfill a task carried out in the public interest, as well as for the conclusion/performance of the contract related to the occasional transaction.
Refusing to have this data processed for the indicated purposes may make it impossible to carry out the requested transaction.
To reduce waiting times at the bank counters, we justify the legitimate interest in using this data also for any cash deposit transactions you may request in the future. In case of transaction cancellation, we will need to contact you for the purpose of returning the deposited amount. If we already have your contact details on record, we will use them for this purpose (e.g., if you also have the status of a regular bank client – BT client – we have your contact details that you provided us for carrying out that usual contractual relationship).
If you have not declared contact details to the bank, by filling in any such data (phone number, e-mail address) in the information form handed to you on the occasion of cash deposits initiated at the counters, you express your consent for their use in order to contact you for the return of the amount, including future cash deposits, until the moment you request the cessation of the processing of contact data for this purpose and/or their modification.
In the BT Privacy Policy you will also find details about the rights you benefit from in connection with the processing of your data for the indicated purposes, about the ways in which you can exercise these rights or about how you can contact the data protection officer designated by BT (BT DPO).
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