1. Who processes personal data within the Bill Payments service?
1. Who processes personal data within the Bill Payments service?
Banca Transilvania S.A.(“BT”, “bank”) offers you the service of Bill Payments, under the conditions presented in The terms and conditions of use of this service. Before you decide whether you want to become a user of this service, it is important to know how we process personal data if you use it. We present the necessary information within this specific information note.
To avoid any doubt, the processing of your data carried out by Banca Transilvania in the context of your status as a BT client is subject to the provisionsGeneral information notes regarding the processing and protection of personal data belonging to BT Customers.
2. The purposes of processing, the categories of data processed and their recipients
2. The purposes of processing, the categories of data processed and their recipients
a. for activating the Bill Payments service
To use the Bill Payments service you must be a BT Pay user identified as a BT client. To ensure that you meet this condition, we verify the phone number registered in the bank's records, the date of birth, and if you have at least one BT card enrolled in the application.
b. for connecting suppliers in BT Pay
After selecting the providers to which you want to make payments from BT Pay, you will be able to connect in our application the account from each provider, by entering the login data requested by them. The categories of data required for connection are established by each provider individually and are communicated to us through our partner Timesafe SRL (the Pago application provider). Both the providers and Timesafe process this data as operators, for purposes and by means that they have established separately from BT, according to their own personal data processing policies.
The bank processes this data only to allow you to connect the respective supplier account in BT Pay, so you can use the Bill Payment service. As a rule, the login data are: the username(s) and the password(s) you use to log in to the account created on the respective supplier's website. You can connect multiple user accounts from the same supplier in BT Pay.
You enter this data into BT Pay, we forward it to Timesafe, along with an identifier allocated to you so that the bank and Timesafe can recognize your future login attempts. If necessary, based on this identifier, BT and Timesafe will carry out the necessary data exchanges to resolve the notifications/complaints you may have regarding the use of the Bill Payments service. Timesafe then sends the username and password entered by you in BT Pay to each respective provider. If this data matches that of the provider, the connection in BT Pay of the account you have created with that provider will be successful.
In order not to have to reconnect your account from each provider in case of reinstallation of the BT Pay application, we will keep a record of the providers you have connected to before and we will automatically display them after reinstallation, as long as you still use the same credentials to connect to their accounts.
c. for viewing invoices and history of paid invoices
Once the account from a provider is successfully connected, we will process the payment amount from the invoices from that provider, the provider to whom this amount is owed, the customer codes allocated by that provider, as well as various other information, depending on the type of provider (e.g. phone numbers, addresses, customer codes, contract numbers in relation to that provider, any other personal data, as they appear on the invoices). We carry out this processing in order to be able to display the payment amounts related to those invoices, as well as the payment history made in the provider accounts that are found in the provider account.
The period for which the payment history for a certain supplier will be displayed is set by the respective supplier. BT will only be able to see the payment history available at the time of each of your logins from BT Pay to the respective supplier's account.
d. for connecting the account in the Pago application
If you are a user of the Pago application, you have the possibility to import into BT Pay the providers you already have integrated in Pago, without needing to connect each of them separately in BT Pay. For this purpose, you will need to enter in BT Pay the email address of the Pago user account and a unique code that will be displayed in the Pago application.
After importing the data from Pago, we will process in BT Pay the same data indicated at lit. c, which you have available in the accounts of the suppliers connected in Pago and, where appropriate, other data as you have defined them in the account in the Pago application (e.g. type of consumption place related to a supplier, such as: parents' house, holiday house, domicile).
e. for invoice scanning
For certain providers, you will be able to pay the invoice by scanning the barcode. To use this feature, the BT Pay app needs access to the camera. If you have previously granted the app access to the camera when using other features of the app (e.g. updating data through BT Pay), it is possible that this access will no longer be requested, as it is already allowed. Please note that access to the camera may be requested differently depending on the operating system of the phone you are using or the version of this system. Depending on those same elements, camera access granted in BT Pay may remain active or be disabled when you no longer use the BT Pay feature that requires this access. Please check your phone's privacy settings to manage camera access for the BT Pay app.
p. for bill payment and, where appropriate, for subscribing and withholding the value of the Facturi Plus or Facturi Nelimitate option
We will process the data necessary for the payment: payer's first and last name, amount, currency, payment date, payment beneficiary (the supplier to whom you make the payment), transaction reference, IBAN of the account from which the payment is made, card number attached to the account from which the payment is made, payment explanations (as required by the supplier and entered by you or taken by scanning the barcode, e.g. client code at the respective supplier), number of invoice payments made, IBAN of the account from which the option value is charged.
g. for the confirmation of payment operations
We process the data related to the phone unlocking method chosen by you to ensure the adequate security of transactions in accordance with the applicable legal provisions in the field of payment services. The data related to the phone unlocking method you have chosen (e.g., fingerprint, facial identification, pattern, PIN, password, etc.) are not in the possession of the bank, but BT only finds out the verification result (accepted/rejected) by comparing the data used to authorize each payment operation with the corresponding reference data stored on your phone.
h. for transmitting to suppliers the status of payments related to invoices
In order for the utility providers to whom you have made payments to be able to reconcile them in their systems, we transmit to them, through Timesafe SRL (the Pago application provider), the necessary information for this purpose: the amount, currency, payment date, payment beneficiary (the provider to whom you make the payment), transaction reference, payment explanations (as required by the provider and entered by you or captured by scanning the barcode e.g. client code at the respective provider, invoice code, etc.).
i. for sending notifications within the application related to this service
When a supplier you have connected issues a new invoice, 3 days before the due date of an already issued invoice or about the cards set at the time of activation of the Plus Invoices or Unlimited Invoices options, you will receive notifications in BT Pay. You can disable these notifications from the application's settings menu. Please note that in this case you will not receive any other general notifications regarding BT Pay;
3. The basis for processing personal data and the consequences of refusing to have them processed
3. The basis for processing personal data and the consequences of refusing to have them processed
The processing operations presented in the previous lines are, as the case may be, necessary for BT to provide you with the Bill Payments service or are carried out by the bank based on its legitimate interest to offer you the same experience and complete picture of the information as that displayed in the account of a provider you have connected in BT Pay. If you do not want BT to process this data, you will not be able to use this service, but your right to use other functionalities of the BT Pay application or other BT services/products is not affected.
4. Source of data and categories of recipients of personal data within the Bill Payments service
4. Source of data and categories of recipients of personal data within the Bill Payments service
We receive and simultaneously transmit, as the case may be, the data mentioned at item points b-d and h above from/to our partner Timesafe SRL, provider of the Pago application. They process it as the operator, according to the provisions Timesafe Data Processing Policies for Personal Data.
When you pay bills from the BT account linked to the selected card in BT Pay, the transaction data is disclosed to the supplier to whom you make the payment and, if applicable, to the credit institution where this supplier's account is opened.
Other categories of recipients of your data processed as a BT client are those provided in General information note concerning the processing and protection of personal data belonging to BT Clients.
5. Period of storage of personal data in the context of using the Bill Payment service
5. Period of storage of personal data in the context of using the Bill Payment service
The personal data mentioned in letters b-d are processed by BT only as long as you use the Bill Payment Service and have at least one supplier account connected to BT Pay. The other categories of data indicated in this information note are processed, as the case may be, for other functionalities of BT Pay (the camera mentioned in letter e, payment confirmation through the phone unlocking method indicated in letter g), while the data related to payments and those necessary for activating the service are subject to the retention periods from General information note concerning the processing and protection of personal data belonging to BT Clients, being closely related to your status as a BT client.
6. The rights that are guaranteed to you
6. The rights that are guaranteed to you
As a BT customer, you are guaranteed the rights stipulated by the General Data Protection Regulation (GDPR), as detailed in General information note regarding the processing and protection of personal data belonging to BT Clients, with the provisions of which this specific information note is completed. You will find the general information note at the BT website, as an integral part of BT Privacy Policy, both as well as distinctly. You can also request it at any BT unit.
