Who is the personal data operator?
BANCA TRANSILVANIA S.A. (hereinafter also "the bank", "BT", "we") brings to your attention through this specific informative note how it intends to process your data, with the main purpose of analyzing a credit application submitted to Banca Transilvania S.A..
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 “BT General Information Note” or “Note”), which we recommend you consult. Also, during the analysis stage of a loan application submitted to BT, we process personal data belonging to individuals connected with the BT loan applicant (also referred to as “individual from the debtor group”). Details about the processing of personal data belonging to individuals from the debtor group can be found in BT Privacy Policy, especially in section C, point 3 thereof. If you are an individual in the debtor's group, we recommend that you consult this section of our Privacy Policy, found on the BT website bancatransilvania.ro.
1. Identification data of operators
Banca Transilvania S.A. , headquartered in Cluj-Napoca city, Calea Dorobantilor street, no. 30-36, Cluj county and the company Biroul de Credit S.A., a Romanian legal entity headquartered in Bucharest, Sfanta Vineri street, no. 29, 4th floor, sector 3, as associated operators, process your personal data in good faith, fairly and transparently, for determined and legitimate purposes, in accordance with the provisions of Regulation (EU) no. 679 of April 27, 2016 concerning the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (the Regulation).
Credit Bureau SA is the private law entity that manages the Credit Bureau System, in which personal data related to lending activities carried out by Participants is processed.
Participants in the Credit Bureau System are credit institutions, non-bank financial institutions, insurance companies, and debt collection companies, which have signed a Participation Agreement with the Credit Bureau.
2. The legal basis and purpose of processing
Banca Transilvania S.A. and the Credit Bureau processes your personal data based on the legitimate interest of the Participants and the Credit Bureau for conducting responsible lending activities, under conditions of protecting, facilitating access to credit, and preventing excessive indebtedness of the persons concerned, complying with the legal framework related to creditworthiness assessment and risk reduction, as well as preventing the use of the financial-banking system for conducting activities contrary to the law.
Banca Transilvania S.A. are the obligation, according to the legal regulations in force, to evaluate your credit repayment capacity before concluding a credit agreement and during its term. For this purpose, Banca Transilvania S.A. processes the information indicated at point (4), registered in your name in its own records, and transmits them to the Credit Bureau for processing by this institution and for consultation by any Participant, for the purpose of initiating or conducting a credit relationship, as well as for securing credit-type products.
3. The obligation to provide data and the consequences of non-compliance with it
Providing your personal data is necessary for the purpose mentioned in point (2). Refusal to provide your personal data, required for achieving the above-mentioned purpose, will lead to the impossibility Banca Transilvania S.A. to fulfill its legal obligations in connection with granting the credit.
4. Categories of personal data processed in the Credit Bureau System
- identification data of the data subject: name, first name, personal numeric code or CUI for authorized natural persons or CIF for natural persons carrying out liberal professions or country code and series/number of passport for non-resident persons, home/residence address, phone number, date of birth;
- information regarding the employer: employer's address, date of registration of this information, VAT number;
- data related to requested/granted credit type products: the type and name of the Participant, type of product, the state of the product/account, granting date, account duration, amounts granted, amounts owed, update date, currency, payment frequency, amount paid, monthly rate, outstanding amounts, number of days of delay, date of first outstanding payment, delay category, date of last payment;
- data related to events occurring during the term of the credit-type product, such as those related to restructuring/refinancing, payment in kind, assignment of the loan agreement, assignment of the debt;
- data related to relationships with other accounts: information regarding credit-type products for which the data subject has the status of co-debtor and/or guarantor;
- data related to insolvency: information regarding the data subjects against whom an insolvency procedure has been opened;
- number of queries: indicates the number of Credit Reports issued by the Credit Bureau, at the request of one or more Participants;
In the process of analyzing your credit application, Banca Transilvania S.A. will request from the Credit Bureau the issuance of a Credit Report, with or without FICO® Score, to verify if you fit within the indebtedness level established by law and if you have the capacity to repay the credit. For obtaining the Credit Report, Banca Transilvania S.A. will send to the Credit Bureau the first name, last name, and personal numeric code.
After granting the credit, Transilvania Bank S.A. will transmit your personal data provided at points a)-f) to the Credit Bureau. This information is shared with other Participants, within the Credit Bureau System, and is used for the purpose mentioned in point 2.
Your ability to repay debts on time may be periodically verified after the credit is granted, including by obtaining Credit Reports or by using the Alert Service*.
In the event that, during the term of the granted loan, you delay the payment of installments by more than 30 calendar days from the due date, Banca Transilvania S.A. will send to the Credit Bureau information regarding the outstanding amounts, the delay category, the date of the first outstanding installment and/or, as the case may be, information regarding the initiation of the payment assignment procedure, only after notifying you, at least 15 calendar days in advance, in writing, by phone, SMS, e-mail or by other electronic communication means.
*The Alert Service is used by Participants to identify and/or reduce credit risk in a timely manner, by generating an alert to a Participant when an event (account opening/closing, entry/exit from delinquency, account correction, registration/deletion of surety/co-debtor status, account inquiry, change of employer name/phone number) is recorded for their own debtor at another Participant.
5. FICO® Score from the Credit Bureau
Personal data provided at point (4) may be processed by the Credit Bureau, including to calculate, at the request of Participants, the FICO® Score from the Credit Bureau.
Participants can use the FICO® Score from the Credit Bureau in order to reduce the credit risk associated with a debtor/potential debtor.
FICO® Score from the Credit Bureau is a number between 300 and 850, obtained following the statistical process that processes the information recorded by Participants in the Credit Bureau System and indicates the probability that the targeted person will pay their installments on time in the future. The main causes that led to the decrease of the FICO® Score from the Credit Bureau are displayed in the form of reason-codes.
FICO® Score from the Credit Bureau takes into account the following elements that provide predictability: payment history, current debt, account(s) duration (average number of months since the credits were granted), new credit requests (number of inquiries and credits granted in the last 6 months), credit mix (types of credits granted), age of the person concerned. The influence of these elements on the value of the FICO® Score from the Credit Bureau may vary depending on the information recorded at the Credit Bureau for each person concerned.
FICO® Score from the Credit Bureau represents a highly predictive analysis tool which, together with the data from the Credit Report and information obtained by Participants from other sources, contributes to the correct evaluation of the creditworthiness of the targeted person for the purpose of concluding/executing the credit agreement.
6. Recipients of the data
The personal data recorded in the Credit Bureau System are disclosed to Participants, upon request, for the purpose mentioned in point (2).
Personal data processed in the Credit Bureau System will not be disclosed to third parties, except authorities and public institutions, according to their competences and applicable legislation, such as the National Authority for the Supervision of Personal Data Processing, the National Bank of Romania, the National Integrity Authority, courts of law, public notaries, judicial executors, criminal investigation bodies.
7. Storage period
Personal data is stored at the Credit Bureau and disclosed to Participants for 4 years from the update date, except for the data of credit applicants who have withdrawn their credit application or who were not granted the credit, which are stored and disclosed to Participants for a period of 6 months.
8. Rights of the data subjects regarding the processing of personal data
As a data subject, you can exercise your rights provided by the Regulation, as follows:
a) the right of access to data can be exercised:
- by a written, signed request, sent by mail to the Credit Bureau, or
- by securely accessing Credit Bureau website, or
- personal or electronically, to the Participant who holds the status of creditor/potential creditor of yours.
At the same time, you have the right to obtain, upon request, at the time of communication of the credit decision, a copy of the Credit Report issued by the Credit Bureau, which was used by Banca Transilvania S.A. in the analysis of the credit application.
b) the right to rectify data,
c) the right to erase data,
d) the right to data restriction ,
e) the right to object to processing, including the automated individual decision-making process,
can be exercised:
- by securely accessing Credit Bureau website, or
- personal or electronically, to the Participant who holds the status of creditor/potential creditor of the data subject.
f) the right to address the National Authority for the Supervision of Personal Data Processing and the judiciary.
9. The contact details of the data protection officers are:
- For Banca Transilvania S.A.– e-mail address dpo@btrl.ro
- For the Credit Bureau - e-mail address: rpd@birouldecredit.ro
This is a specific information note regarding the processing of personal data for the purpose of pre-offering and, where applicable, the analysis of the credit application addressed to BT. The provisions of this note are supplemented by General information note concerning the processing and protection of personal data belonging to BT Clients, in which you can find all the other purposes for which the data is also processed, presented in detail. The general information note is an integral part of the BT Privacy Policies, found on website of Transilvania Bank and can be obtained on request at any BT unit.
1. Operator's identity
Banca Transilvania S.A. with headquarters in Cluj-Napoca city, Calea Dorobanților street, no. 30-36, Cluj county processes your personal data as an operator for the purpose of pre-offering and, if applicable, analyzing the submitted credit application.
2. The legal basis and purpose of processing
For the purpose of pre-offering and, where appropriate, analyzing the credit request made, in accordance with the need to carry out responsible credit activities, in addition to processing your personal data in the system of Credit Bureau S.A. - about which you were informed at point I. of this notice - Transilvania Bank S.A. processes such data in its own records, based on the legal obligations it must comply with, the conclusion of the credit contract and based on its legitimate interest.
The bank will process any of the contact details provided within the credit application, for the purpose of notifying the credit applicant in writing regarding the approval/rejection decision, in accordance with the applicable legal provisions. In case the applicant wishes to use another form for communicating the decision, they may submit an express request to the bank in this regard.
3. The obligation to provide data and the consequences of non-compliance with it
Your provision of your personal data is necessary for the purpose mentioned in point II.(2). Refusal to provide your personal data, necessary to achieve the purpose mentioned above, will lead to the impossibility of Banca Transilvania S.A. to fulfill its legal obligations in connection with granting the loan, so that the loan application cannot be analyzed.
4. Categories of personal data processed within Banca Transilvania S.A.
Personal data mentioned in this notice at point I. (4), II.(5), as well as other categories of such data collected in the credit application fields are processed by Banca Transilvania S.A. within the credit application analysis process, both in the Credit Bureau S.A. system and in own records, being also verified (name, first name and/or personal numeric code) - as the case may be - in public databases such as websites - court portal, National Trade Register Office etc.
5. The existence of an automated decision-making process, including profiling created through the BT scoring application
In order to objectively verify the fulfillment of eligibility conditions for pre-offering and, as the case may be, for analyzing the credit application, BT processes your personal data in its own automated system ("BT scoring application"), for carrying out the necessary steps to conclude the credit contract at your request, as well as based on our legitimate interest to efficiently manage credit risk.
In the BT scoring application, some of the personal data that we requested from you within the credit application/request are entered and processed automatically, along with information resulting from verifications carried out in the bank's own records or those of Credit Bureau S.A., such as (by way of information but not limited to) as appropriate - information related to BT client status, income level, professional and personal information, the amount of monthly payment obligations, payment history on other loans. After analyzing all the information and the result of consulting the records of Credit Bureau S.A., the BT scoring application issues a score that establishes a profile of the debtor/potential debtor based on the information presented in the previous lines, which will be considered in the analysis process and takes into account the probability of paying the monthly payment obligations.
Based on the score issued by the BT scoring application, to which is added the result of checking the applicant's situation in public databases such as websites - the courts' portal, ONRC etc - Banca Transilvania S.A. determines whether the eligibility conditions established by its internal regulations are met and will make the decision to approve or reject the credit application, a decision which is based on the analysis carried out by the Bank's employees (human intervention).
By exception, we will take the decision to approve/reject the credit application exclusively by automated means only in specific cases, when the application is made online and it is essential to provide you with a response to it within a very short time. In such situations, making the decision by such means is necessary in order to quickly analyze the application and, if applicable, to conclude the credit agreement. However, you are guaranteed the right to request human intervention, that is, the analysis of the credit application by a bank employee, to express your point of view, and to contest the decision.
6. Recipients of the data
In addition to the recipients mentioned in point I.(6) of this notice, the personal data processed for the purpose indicated in point II.(2) are disclosed, as appropriate, to the following recipients: ANAF (for consulting the database of the Ministry of Finance, in case you have given your consent in this regard on the dedicated form), your employer (if you have chosen to prove your income with an income certificate from the employer), Credit Bureau S.A. (to check your situation in the records of this institution), insurance companies, appraisers (in the case of loans for which an evaluation of the collateral assets is performed), FNGCIMM (in the case of Prima Casă, Nouă Casă or Prima Mașină loans), providers of the BT scoring application or other services used by Banca Transilvania S.A. within the loan application analysis process and/or within other processes specific to its field of activity.
7. Storage period
Personal data filled in the credit application are kept in the records of Banca Transilvania for legally established limited periods (e.g. according to the financial accounting legislation) or internally.
8. Rights of the data subjects regarding the processing of personal data
For the exercise of rights (the right of access to data, the right to rectification of data, the right to deletion of data, the right to restriction of data, the right to object to processing) provided by the Regulation in connection with the processing of your personal data in the system of Credit Bureau S.A. in relation to Banca Transilvania S.A., you can use any of the methods indicated at point I.(8).
In case you wish to exercise these rights at Banca Transilvania S.A. (both for the processing of personal data in the Credit Bureau system S.A., and within Banca Transilvania S.A.), you can submit your written request to the address in Cluj-Napoca City, Calea Dorobanților Street, no. 30-36, Cluj County, mentioning – "to the attention of the data protection officer (DPO)" or electronically at the e-mail address dpo@btrl.ro. You also have the right to address the National Authority for the Supervision of Personal Data Processing and justice.
