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 client identification 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 Customers (hereinafter also referred to as the “General BT Information Note” or the “Note”), which we recommend you consult. Within the note you will also find the definition of the BT Client, the real beneficiary, the politically exposed person, as well as definitions of other specialized terms.
Primary legislation that imposes on BT the obligation 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.
Customer knowledge for the prevention of money laundering and terrorist financing, including risk-based verification, is carried out by BT through the application of customer knowledge measures that involve both identity verification and 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 established time 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 knowing the clientele, whenever they change.
2. Personal data that we process for the purpose of knowing the clientele
2. Personal data that we process for the purpose of knowing the clientele
Thus, for the opening and conduct of the contractual relationship with most categories of BT Clients, the bank has the legal obligation to collect from/about BT Clients, for the fulfillment of a task serving a public interest, as the case may be, at least the following categories of personal data: first name, last name, date and place of birth, personal numeric code (CNP) or another similar unique identification element, domicile, residence, phone number, fax, email address, occupation, employer's name or nature of own activity, important public function held or status as a 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.
The application of client knowledge measures also involves the use of collected data for:
- the preparation and submission of reports to the competent institutions authorized 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 Prevention and Control of Money Laundering);
- evaluation and monitoring of the financial-commercial behavior of BT Clients throughout the business relationship with the bank, in order to detect unusual transactions and suspicious transactions, according to the legal obligations of customer due diligence imposed on the bank to prevent money laundering and terrorism financing;
3. The retention period of personal data processed for the purpose of customer knowledge
3. The retention period of personal data processed for the purpose of customer knowledge
The collected data and, where applicable, 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, in accordance with the legally prescribed 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 the bank refuses to open the business relationship.
In case of BT Clients' refusal to provide/ update/ have these data processed, their contractual relationship with the bank will not be able to be opened or, as the case may be, may be terminated at BT's initiative.
Data processed for the purpose of customer knowledge 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 terrorism financing, checks will be carried out in the databases with persons accused of financing acts of terrorism or, as the case may be, with persons at high risk of fraud and, if BT Clients are found registered in these records, the bank reserves the right to refuse to enter into a business relationship with them or to terminate the contractual relationship;
- to protect Customers against fraud, as well as for the bank to adequately fulfill its Know Your Customer obligations, it monitors their transactions and, if it identifies suspicious operations (such as payments unusual in frequency, value, including relative to the source of funds declared by Account holder Customers 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 those locations), it accordingly adopts measures to block transactions, cards, accounts, making these decisions on an exclusively automatic basis;
4. The rights of the data subject
4. The rights of the data subject
Data processed for the purpose of knowing the clientele may be disclosed/transferred by BT, as the case may be, 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 connection with 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).
