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 in which you have no capacity (including Regular clients of the bank – BT clients – who deposit such amounts into accounts in 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 “occasional BT customer”, as well as other details about 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 a cash amount at the counters of our units - into BT accounts for which you are not the account holder, authorized person, or delegate with rights to deposit cash amounts - 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, first name, series and number of the identity document, personal numerical 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 appropriate, for the main purposes relating 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, the 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 available in the bank's records;
- knowledge of the clientele for the prevention of money laundering and terrorist financing, including risk-based verification, through the application of customer due diligence measures;
- the conclusion and execution of the contract related to the occasional transaction;
- evaluation and monitoring of financial-commercial behavior with a view to detecting unusual transactions and suspicious transactions, according to the legal obligations of customer due diligence imposed on the bank for the prevention of money laundering and terrorist financing;
- settlement of bank transactions;
as well as, depending on the situation, for other purposes closely related to the main ones, namely for:
- the preparation and transmission 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 Incidents Central within the NBR, declaring transactions exceeding the amount established by law to the National Office for the Prevention and Control of Money Laundering);
- performing 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 settlement of disputes, investigations or any other petitions/complaints/requests in which the bank is involved;
- carrying out risk checks on the bank's procedures and processes, as well as performing audit or investigation activities;
- monitoring/security of persons, spaces and/or the bank's or its units' visitors' goods;
- taking measures/providing information or responses to requests/notifications/complaints of any kind addressed to the bank by any person and/or by authorities or institutions, through any channel, including via electronic communication services and the internet;
- conducting internal analyses (including statistical);
- archiving - both in physical format and electronic - of documents, creating backup copies;
- providing 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 BT's information systems and the physical spaces where the bank carries out its activity;
- fraud prevention;
We process this data mainly on the basis of our legal obligations in order to fulfill a task established in the public interest, as well as for the conclusion/performance of the contract related to the occasional transaction.
Refusal to process these data for the indicated purposes may render 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 to return the deposited amount. If we already have your contact details in our records, we will use them for this purpose (e.g., if you are also a regular bank client – BT client – we have your contact details that you provided us for conducting the respective regular contractual relationship).
If you have not declared contact details to the bank, by completing 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 to contact you for the refund of the amount, including for future cash deposits, until the moment when you request us to stop processing the contact data for this purpose and/or to modify them.
In the BT Privacy Policy you will also find details about the rights you have regarding the processing of your data for the indicated purposes, about the ways you can exercise these rights or about how you can contact the data protection officer designated by BT (BT DPO).
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