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 for the identification/authentication of users (identity verification), for the security of this payment solution to prevent fraud, as well as in the context of using the functionalities of BT POS App, for what and on what legal 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 completed with the provisions General information notes regarding the processing and protection of personal data belonging to BT Customerswhich 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 can be revised by BT at certain time intervals. Users will be notified if such changes occur through the website www.btepos.ro.
2. What data do we collect for the authentication of BT POS App users
2. What data do we collect for the authentication of BT POS App users
In order to use the BT POS App solution that you 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
In order to protect your transactions conducted through 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 the type of its operating system, the application version, to verify that at each login you still use the same phone that you registered with to use the BT POS App application. Also, we process address/ IP addressesof the phone and, where appropriate, of the tablet or PAD with which you connect to the BT POS App.
4. What data do we process when you use the BT POS App
4. What data do we process when you use the BT POS App
In order to fulfill the legal obligations we have, to provide you with the BT POS App solution you have contracted for your company and, where appropriate, because we have a legitimate interest in preventing fraud and communicating with BT POS App users to provide support and to request their assessment 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 made by your clients with the card, the PAN related to these cards, the transaction ID (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., individual practice form of certain liberal professions (e.g. individual law offices, notaries, bailiff offices, etc.) you must know that information about these entities is subject to personal data regulations and the bank will treat them in compliance with the legal provisions applicable in this field. Also, we process your personal data and/ or those of your clients, such as the recipients of collections individuals or P.F.A., I.I., individual forms of practicing liberal professions.
Contact details
Based on the purchase contract for the BT POS App solution we will use phone numberof the legal representative for sending the SMS to validate 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 a legitimate interest in providing 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 declared to the bank in your capacity as a client 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 mediaof the device in the situation in which you want to upload a profile picture, respectively you want to download locally the receipts 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 offer you the possibility to choose the desired photo. Regarding the other functionality, after making the payment you will have the possibility to save locally (on your device) a copy of the receipt that proves the payment was made, 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 in 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 the user's explicit consent is not required, are detailed in the "Permissions" section of the Play Store/Apple Store for the BT POS App (e.g., permissions to notify you when you have no 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 the BT POS App, the data related to them (usually, PAN, amount, payment explanations), will also be accessible to the payers who made the payment and, implicitly, to the credit/payment institutions where they have the respective accounts opened.
Your processed data in the BT POS App may be accessed, according to the need to know and only based on personal data protection guarantees, by the bank's contractual partners who support us in providing 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 Customers, 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 transactions conducted through the BT POS App, are subject to the retention regime provided by the normative acts applicable 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 gain 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 security of the terminal used to access the BT POS App (phone, tablet, PAD) and especially the login ID and/or login passwords (password, fingerprint, or any other security method provided by the phone/tablet/PAD).
8. What are the rights enjoyed by the users of the BT POS App solution
8. What are the rights enjoyed by the users of the BT POS App solution
In accordance with the provisions of the General Data Protection Regulation (“GDPR”), as a data subject of 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 Customers.
You can exercise these rights at BT or 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).
