1. General provisions
1. General provisions
Banca Transilvania, S.A. with registered office in Cluj-Napoca, Calea Dorobanților street, no. 30-36, Cluj county, registered at the Trade Register under no. J1993004155124, unique code RO 5022670, contact phone: 02648028 (hereinafter referred to as “BT”) provides its clients with the payment solution – BT POS App (hereinafter referred to as “BT POS App”).
We hereby inform you which personal data will be used to identify/authenticate users (identity verification), for the security of this payment solution in order to prevent fraud, as well as in the context of using the BT POS App functionalities, for what purpose and on what basis we use this data, to whom we disclose it, how long we keep it, how we protect it, and what rights the data subjects have.
This information is supplemented by the provisions General information notes regarding the processing and protection of personal data belonging to BT Clientswhich is an integral part of BT Privacy Policies which you can find on the website www.bancatransilvania.ro or by accessing the following link https://www.bancatransilvania.ro/politica-prelucrare-si-protectie-date-personale/.
This information notice may be revised by BT at certain intervals. Users will be notified if such changes occur through the website www.btepos.ro.
2. What data do we collect for BT POS App user authentication
2. What data do we collect for BT POS App user authentication
To be able to use the BT POS App solution that you have contracted from BT, it is necessary to authenticate yourself as an authorized user. This authentication is performed based on merchant ID, terminal ID and a password. The credentials are sent by BT via SMS to the phone number of the legal representative declared in the contract.
3. What data do we collect to ensure the security of the BT POS App
3. What data do we collect to ensure the security of the BT POS App
To be able to protect your transactions carried out through the BT POS App and the information within this platform, we will collect and use Advertising ID on the phone on which you have the BT POS App mobile application installed, other security identifiers of the phone (ex. Instance ID/ Device Identifier) and the generated tokens, the model, the phone manufacturer and its operating system type, the application version, to verify that at each login you still use the same phone with which you registered to use the BT POS App. Also, we process address/ IP addresses of the phone and, if applicable, of the tablet or PAD with which you connect to the BT POS App.
4. What data do we process when you use BT POS App
4. What data do we process when you use BT POS App
To fulfill the legal obligations we have, to provide you with the BT POS App solution you have contracted for your company, and, where applicable, because we have a legitimate interest in preventing fraud and communicating with BT POS App users to provide them with support and to request their evaluation of the quality of the BT POS App solution, we use:
Data related to cards and transactions
When you use the BT POS App, we will have implicit access to information regarding: transactions carried out by your customers with the card, the PAN related to these cards, the transaction IDs (RRN), the amounts collected in the company's accounts, including information mentioned in the payment explanations. Although this solution is dedicated exclusively to legal entity clients of Transilvania Bank, and information about legal entities is generally not considered personal data, if you have an entity of the type P.F.A., I.I., an individual form of exercising certain liberal professions (e.g., individual law offices, notaries, bailiff offices, etc.) you should know that information about these entities is treated as personal data and the bank will handle it in compliance with the legal provisions applicable in this field. Also, we process your and/or your clients' personal data, such as the beneficiaries of collections, natural persons or authorized natural persons (P.F.A.), individual enterprises (I.I.), individual forms of practicing liberal professions.
Contact data
Based on the BT POS App solution purchase contract we will use phone numberof the legal representative for sending the validation SMS of the phone number and login data, and email address for sending you various reports regarding the transactions carried out through the solution.
Because we have the legitimate interest to provide you support in using the BT POS App (support) and because we want to find out your opinion about this solution (service quality evaluation) we will use contact details which you have declared to the bank in your capacity as a client in order to contact you for this purpose. You have the right to object to such contact. For details, read the section regarding the rights you have in connection with the processing of your personal data.
Data collected for the purpose of identifying and correcting errors
When you use the application and technical errors occur, to identify and fix them we will capture the following data: device, operating system, operating system version, type and description of the error.
Permissions requested in the context of application usage
When you install the app, you will be asked for permission to access files and media the device in the situation where you want to upload a profile picture, respectively want to download the receipts locally in pdf format.
In case you want to upload a profile picture, the application will access the location where your images are stored, but only to give you the option to choose the desired photo. Regarding the other functionality, after making the payment you will have the option to save locally (on your device) a copy of the receipt proving the payment, and for you to be able to benefit from this option, the application requires access to the location where it will save the receipt. The saving operation does not involve processing the data already stored in that location.
If you refuse to grant access to files and media you will not be able to use the BT POS App application, because the inherent functionalities of the application require access to this location. We reiterate that by granting access your personal data from files and media will be processed exclusively for the purpose of uploading a profile picture or saving a receipt.
Other permissions required for the use and operation of the application, as established by the operating system provider of the device you are using and for which explicit user consent is not required, are detailed in the "Permissions" section of the Play Store/Apple Store for the BT POS App application (e.g., permissions to notify you when you do not have an Internet connection).
5. To whom can we disclose the data as a result of using the BT POS App solution
5. To whom can we disclose the data as a result of using the BT POS App solution
When transactions are made through BT POS App, the data related to them (usually, PAN, amount, payment explanations), will be accessible to the payers who made the payment and, implicitly, to the credit/payment institutions where they have the respective accounts opened.
Your data processed in the BT POS App may be accessed, according to the need to know and only based on some guarantees of protection of personal data, by the bank's contractual partners who support us in offering the BT POS App solution.
The list of recipients is completed with the one provided within General information notes regarding the processing and protection of personal data belonging to BT Clients, section VIII.
6. How long do we keep the processed data in the context of providing the BT POS App solution
6. How long do we keep the processed data in the context of providing the BT POS App solution
Your data, as a BT client, as well as data regarding operations carried out through the BT POS App are subject to the retention regime provided by the applicable regulations in the field of anti-money laundering and counter-terrorism financing, in the field of payment services or in the accounting and financial - fiscal field.
7. How do we ensure the protection of personal data in the BT POS App solution
7. How do we ensure the protection of personal data in the BT POS App solution
Banca Transilvania takes all necessary technical and organizational measures to protect personal data within the BT POS App solution.
Despite these precautions, the Bank cannot guarantee that unauthorized persons will not obtain access to your personal data through the terminals you use to access the BT POS App, in case they are unprotected or improperly protected.
You are solely responsible for maintaining the confidentiality and keeping secure the terminal used to access the BT POS App (phone, tablet, PAD) and especially the login ID and/or login passwords (password, fingerprint, or another security method provided by the phone/ tablet/ PAD).
8. What are the rights that users of the BT POS App solution benefit from
8. What are the rights that users of the BT POS App solution benefit from
In accordance with the provisions of the General Data Protection Regulation (“GDPR”), as a data subject regarding the processing of personal data in the context of using the BT POS App, you are guaranteed the following rights: the right to be informed (we fulfill our obligation to inform you through this document), the right of access, the right to rectification, the right to erasure of data, the right to restriction of processing, the right to data portability, the right to object, the right to withdraw consent (for processing based on this legal ground), the right to address the National Authority for the Supervision of Personal Data Processing (ANSPDCP) and the judiciary. You can find these rights detailed also in the provisions General information notes regarding the processing and protection of personal data belonging to BT Clients.
You can exercise these rights at BT or you can contact the BT Data Protection Officer (DPO), by sending a request by mail to the previously indicated BT headquarters - with the mention - "attention 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 (ANSPDCP)- (plangere@dataprotection.ro).
