1. General provisions
1. General provisions
Banca Transilvania, S.A., 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, as a BT Client, for the main purpose of customer due diligence for the prevention of money laundering and terrorist financing.
This information note is completed with the provisions General information notes regarding the processing and protection of personal data belonging to BT Clients (also hereinafter referred to as "the BT general information note" or "the Note"), which we recommend you consult. Within the note you will also find the definition of the BT Client, the actual beneficiary, the politically exposed person, as well as definitions of other specialized terms.
Primary legislation that establishes the obligation for BT to apply customer due diligence measures is primarily represented by Law no. 129/2019 for the prevention and combating of money laundering and terrorist financing, as well as for the amendment and completion of certain normative acts.
Knowing the clientele for the prevention of money laundering and terrorism financing, including risk-based verification, is carried out by BT through the application of customer due diligence measures that involve both identity verification and the processing of personal data required by law, both at the time a certain individual acquires the status of BT Client (data collection), throughout the entire period this status is held (data updating), as well as after this moment, for the legally determined period following the termination of the BT Client status (data storage and processing for purposes permitted by law).
As long as you have the status of BT Client, you are obliged to update in the bank's records the data collected/provided for the purpose of customer knowledge, whenever they change.
2. Personal data that we process for the purpose of customer knowledge
2. Personal data that we process for the purpose of customer knowledge
Thus, for the opening and carrying out of the contractual relationship with most categories of BT Clients, the bank has the legal obligation to collect from/about the BT Clients, for the fulfillment of a task serving a public interest, as appropriate, at least the following categories of personal data: name, surname, date and place of birth, personal numeric code (CNP) or another similar unique identification element, domicile, residence, telephone number, fax, email address, occupation, employer’s name or nature of own activity, important public function held or status of politically exposed person (PEP), information about the purpose and nature of the business relationship and the source of funds, as well as a copy of the identity document.
Applying customer knowledge measures also involves using collected data for:
- the 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 for declaring transactions exceeding the amount established by law to the National Office for the Prevention and Control of Money Laundering);
- evaluation and monitoring of the financial-commercial behavior of BT Clients during the course of the business relationship with the bank, in order to detect unusual transactions and suspicious transactions, according to the legal obligations of knowing the clientele imposed on the bank for the prevention of money laundering and terrorist financing;
3. The retention period of personal data processed for the purpose of client knowledge
3. The retention period of personal data processed for the purpose of client knowledge
The collected data and, as the case may be, updated, together with the records of all financial operations arising from the conduct of the business relationship with BT, will be stored in the bank's records for a minimum period of 5 years from the date of termination of the business relationship, according to the legally provided retention period (in Law 129/2019).
If the business relationship is not opened, your data will be stored by BT for at least 5 years from the date of the bank's refusal to open the business relationship.
In case BT Clients refuse to provide/ to update/ to have these data processed, their contractual relationship with the bank cannot be opened or, as the case may be, may be terminated at BT's initiative.
Data processed for understanding the clientele may be subject, as the case may be, to automated decision-making processes, such as:
- for the application of client knowledge measures in order to prevent and combat money laundering and terrorist financing, checks will be carried out in databases with persons accused of financing acts of terrorism or, as appropriate, with persons at high risk of fraud and, if BT Clients are found registered in these records, the bank reserves the right to refuse entering into a business relationship with them or to terminate the contractual relationship;
- to protect Clients against fraud, as well as for the bank to properly fulfill its Customer Due Diligence obligations, it monitors their transactions and, if it identifies suspicious operations (such as unusual payments in terms of frequency, value, also reported relative to the source of funds declared by the account holding Clients or to the purpose and nature of the business relationship, transactions initiated from different localities at short intervals of time, which did not allow travel between these locations), it accordingly adopts measures to block transactions, account cards, making these decisions on an exclusively automated basis;
4. Rights of the data subject
4. Rights of the data subject
The data processed for the purpose of customer knowledge may be disclosed/transferred by BT, as appropriate, to the categories of recipients mentioned in General information note of BT. In this general note you will also find details about the rights you benefit from in relation to the processing of your data for the indicated purpose, about the ways in which you can exercise them or about how you can contact the data protection officer appointed by BT (DPO BT).
