Who is the personal data operator?
BANCA TRANSILVANIA S.A. (hereinafter also "the bank," "BT," "we") hereby informs you through this specific information 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 Clients (hereinafter also referred to as the "BT General Information Note" or the "Note"), which we recommend you consult. Also, during the analysis phase of a loan application submitted to BT, we process personal data belonging to individuals related to the BT loan applicant (also referred to as "individual in the debtor's group"). Details about the processing of personal data belonging to individuals in the debtor's group can be found in BT Privacy Policy, especially in section C, point 3 thereof. If you are an individual from 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 municipality, Calea Dorobantilor street, no. 30-36, Cluj county, and the Credit Bureau S.A. Company, 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 specific and legitimate purposes, in accordance with the provisions of Regulation (EU) no. 679 of April 27, 2016, on 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, where personal data related to lending activities carried out by Participants are processed.
Participants in the Credit Bureau System are credit institutions, non-banking financial institutions, insurance companies, and debt collection companies that have signed a Participation Contract with the Credit Bureau.
2. The legal basis and the 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 lending and preventing excessive indebtedness of the targeted persons, complying with the legal framework regarding creditworthiness assessment and risk reduction, as well as preventing the use of the financial-banking system for carrying out activities contrary to the law.
Banca Transilvania S.A. are the obligation, according to the legal regulations in force, to assess your credit repayment capacity before concluding a credit agreement and throughout its duration. For this purpose, Banca Transilvania S.A. processes the information indicated at point (4), recorded 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 ensuring credit-type products.
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 (2). Refusal to provide your personal data, necessary for achieving the purpose mentioned above, will lead to the impossibility Transilvania Bank 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: the last name, first name, personal numeric code or CUI for authorized natural persons or CIF for natural persons who carry out liberal professions or country code and passport series/number for non-resident persons, home/residence address, telephone number, date of birth;
- data relating to the employer: employer's address, date of registration of this information, VAT number;
- data related to the requested/granted credit-type products: the type and name of the Participant, type of product, product/account status, date of granting, account duration, granted amounts, amounts owed, date of update, currency, payment frequency, amount paid, monthly rate, outstanding amounts, number of days of delay, date of first outstanding, delay category, date of last payment;
- data relating to events occurring during the term of the credit-type product, such as those relating to restructuring/refinancing, handing over in payment, assignment of the credit contract, assignment of the claim;
- data regarding relationships with other accounts: information regarding credit-type products for which the data subject has the status of co-debtor and/or guarantor;
- data regarding insolvency: information regarding the targeted persons against whom an insolvency procedure has been initiated;
- 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. requests from the Credit Bureau the issuance of a Credit Report, with or without FICO® Score, to verify if you fit within the debt-to-income ratio established by law and if you have the capacity to repay the credit. To obtain the Credit Report, Banca Transilvania S.A. will send to the Credit Bureau your first name, last name, and personal numeric code.
After granting the credit, Banca Transilvania S.A. will send your personal data specified in 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 granting the loan, including by obtaining Credit Reports or by using the Alerts Service*.
In case, during the period of the granted credit, you delay the payment of installments for 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 overdue installment and/or, as the case may be, information regarding the opening of the payment surrender procedure, only after notifying you, at least 15 calendar days in advance, made in writing, by phone, SMS, e-mail or by other means of electronic communication.
*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 is recorded for their own debtor (account opening/closing, entry/exit from delinquency, account correction, registration/deletion of guarantor/co-debtor status, account inquiry, employer name/phone number change) at another Participant.
5. FICO® Score from the Credit Bureau
Personal data provided in point (4) may be processed by the Credit Bureau, including to calculate, at the request of the Participants, the FICO® Score from the Credit Bureau.
Participants can use the FICO® Score from the Credit Bureau for the purpose of reducing the credit risk associated with a debtor/potential debtor.
FICO® Score from the Credit Bureau is a number between 300 and 850, obtained through 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/accounts duration (average number of months since the credits were granted), new credit inquiries (number of inquiries and credits granted in the last 6 months), credit mix (types of credits granted), age of the concerned person. 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 concerned person.
FICO® Score from the Credit Bureau represents a highly predictive analytical tool which, combined with data from the Credit Report and information obtained by Participants from other sources, contributes to the accurate assessment of the creditworthiness of the targeted person in order to conclude/execute the credit agreement.
6. Data recipients
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 for 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, judicial courts, notaries public, judicial executors, criminal investigation bodies.
7. Storage period
Personal data are stored at the Credit Bureau and disclosed to Participants for 4 years from the update date, except for the data of loan applicants who have withdrawn their loan application or who have not been granted the loan, which are stored and disclosed to Participants for a period of 6 months.
8. The rights of the data subjects regarding the processing of personal data
As a data subject, you can exercise your rights under 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 the 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 rectification of data,
c) the right to erasure of data,
d) the right to restrict data,
e) the right to object to processing, including the automated individual decision-making process,
can be exercised:
- by securely accessing the 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 appropriate, analyzing the credit application addressed to BT. The provisions of this note are supplemented by General information note regarding the processing and protection of personal data belonging to BT Clients, in which you can find detailed presentation of all other purposes for which the data is also processed. The general information note is an integral part of the BT Privacy Policies, found on the website of Banca Transilvania and can be obtained upon request at any BT unit.
1. The identity of the operator
Banca Transilvania S.A. with headquarters in Cluj-Napoca city, Calea Dorobanților street, no. 30-36, Cluj county processes your personal data as a data operator for the purpose of pre-offering and, where appropriate, analyzing the submitted credit application.
2. The legal basis and the purpose of processing
For the purpose of pre-offering and, where applicable, analyzing the formulated credit request, in accordance with the need to conduct a responsible lending activity, in addition to processing your personal data in the Credit Bureau S.A. system - about which you have been 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 on the basis of its legitimate interest.
The bank will process any of the contact details provided within the credit application submitted, for the purpose of notifying the credit applicant in writing regarding the approval/rejection decision thereof, in accordance with the applicable legal provisions. In case the applicant wishes to use another form for communicating the decision, they may address the bank with an explicit request 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 for achieving the aforementioned purpose, will lead to the inability of Banca Transilvania S.A. to fulfill its legal obligations related to granting the credit, and the credit application will not be analyzed.
4. Categories of personal data processed within Transilvania Bank S.A.
Personal data mentioned in this information notice in section 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 process of analyzing the submitted credit application, both in the system of Biroului de Credit S.A. and in its own records, being also verified (name, first name and/or personal identification number) - as applicable - in public databases such as websites - the courts portal, ONRC etc.
5. The existence of an automated decision-making process, including profiling created through the BT scoring application
For the purpose of objectively verifying the fulfillment of the eligibility conditions for pre-offering and, if applicable, 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 in efficiently managing credit risk.
In the BT scoring application, some of the personal data you provided in the credit application/request are entered and processed automatically, along with information resulting from checks carried out in the bank's own records or those of Credit Bureau S.A., such as (for informational purposes but not limited to them) as applicable - information related to BT client status, income level, professional and personal information, the level 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 taken into account in the analysis process and which considers 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 verifying the applicant's situation in public databases such as websites - the courts' portal, ONRC etc. - Banca Transilvania S.A. establishes whether the eligibility conditions set 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 loan application by exclusively automated means only in specific cases, when the application is made online and it is essential to provide you with a response 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 loan contract. However, you are guaranteed the right to request human intervention, that is, the analysis of the loan application by a bank employee, to express your point of view and to contest the decision.
6. Data recipients
Besides 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 the case may be, to the following recipients: ANAF (for consulting the database of the Ministry of Finance, if you have given your consent in this regard on the dedicated form), your employer (if you opted 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, evaluators (in the case of loans for which an evaluation of the collateral assets is performed), FNGCIMM (in the case of First House, New House or First Car loans), providers of the BT scoring application or other services used by Banca Transilvania S.A. within the process of analyzing the credit application and/or in other specific processes related to its object or activity.
7. Storage period
The personal data filled in the credit application are kept in the records of Transilvania Bank for legally established limited periods (e.g. according to financial accounting legislation) or internal periods.
8. The rights of the data subjects regarding the processing of personal data
For exercising the rights (the right of access to data, the right to rectification of data, the right to data deletion, 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 with Transilvania Bank S.A. you can use any of the methods indicated at point I.(8).
In case you decide to exercise these rights at Banca Transilvania S.A. (both for the processing of personal data in the system of Biroul de Credit S.A., and within Banca Transilvania S.A.), you may submit your written request at the address in Cluj-Napoca City, Calea Dorobanților Street, no. 30-36, Cluj County, with the mention – "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 the justice system.
