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    Information note regarding the processing of personal data for the purpose of online updating of some information for customer knowledge (chatbot Ino)

    Transilvania Bank S.A. ("Bank", "BT"), in its capacity as a credit institution, has the legal obligation to apply customer due diligence measures, for the purpose of preventing money laundering and terrorist financing, in order to fulfill a task serving a public interest. When you become an individual account holder client at BT or a representative of such a client (legal representative, conventional representative, authorized person on accounts, delegate) we collect from/about you information for this purpose, such as, as the case may be: name, first name, pseudonym, date and place of birth, personal numeric code or another similar unique identification element, citizenship, domicile, residence, the address where you live and its legal status, phone number, fax, email address, occupation, employer's name or the nature of own activity, purpose and nature of the business relationship with the bank, source of the funds to be used in carrying out the business relationship, classification as a politically exposed person or holding the status of a family member of a politically exposed person or known as a close associate of a politically exposed person (PEP), as well as the details and copy of the identity document.

    We must ensure that, as long as you have such a quality, this information is updated in our records. That is why, whenever one of this information is changed, it is necessary to modify them at the bank as well. From time to time, even if the data have not changed, we will ask you to reconfirm them, so that we are sure they have not been modified.

    Can you update your entire set of data that we need about you for the application of customer knowledge measures in any BT unit. For updating part of this data, we offer you online solutions, such as the one from this Ino chatbot.

    To make sure we update/ reconfirm only your data and to prevent possible fraud attempts, we need to verify your identity. As you know, in bank branches, we verify your identity based on the original identity document. Online, we will do things a little differently. Here is how we will proceed:

    • we will verify your identity and your status as a BT client based on the personal numeric code (CNP) and the phone number you declared in the bank's records. To this phone number, a unique code (SMS-OTP) will be sent via SMS, which you will need to enter in the dedicated field of the chatbot. If you no longer use the phone number declared at the bank, you will first need to update it at a BT branch or by calling the call center service
    • then you will have to upload to Ino also a photo of your identity document. We would apply a new technology to your image from this photo, which uses so-called biometric data. However, we will not be able to use this data without your explicit consent. Before freely deciding whether you want to give it, here is what the use of your biometric data entails: the IT solution we use will identify in the photo of the identity document uploaded by you the section that includes your face, will select it and then compare it with the face in the copy of your identity document that is already recorded in BT's records. The comparison is done biometrically, based on criteria such as: the color, size and tilt of the eyes, the position and distance between the main elements of the face such as the eyes, eyebrows, lips and nose. Following the comparison, the IT solution will issue a confidence score, indicating the probability that the face in the two images belongs to the same person.

    If you do not want your biometric data (facial identification) to be processed, you can update your data at any BT unit, where your identity will be verified without using such data.

    Also, in the event that the facial identification tool issues an unsatisfactory confidence score, you will be able to restart the update process at a BT unit.

    If after following the steps above you convince us that you are you, you will be able to update some of your Know Your Customer data online. However, if you did not pass this small test, there is no problem, you can update your data in full at any BT unit.

    To help you in the update process, some of your identity card data will be automatically extracted (through the optical character recognition process) when you upload its photo, while the rest of the data you will select from a list of values or you will enter yourself. Please check if the data is correct and modify it accordingly, if necessary. If you complete the update, even though you find that the data was incorrectly extracted/filled in, you risk being guilty of making false statements and of course you don't want that. If you can't fix the errors, abandon the online flow and come to the unit.

    Please note that, when you update your data through Ino, the residential address from the identity document you upload will be taken/updated also as the correspondence address in relation to the bank. If you wish to declare a correspondence address to BT different from the residential address, you will need to separately update it at a BT branch.

    The home address will also be taken as the residence address if you have confirmed in Ino that you do not have a valid floating residence permit/visa on the back of your identity document. If you have a valid floating visa, the residence address is different from the home address. In this case, you need to update it at a BT unit.

    This information note is supplemented with the provisions General information notes regarding the processing and protection of personal data belonging to BT Clients, which we recommend you consult. It is an integral part of BT Privacy Policies. You can find them both on the bank's website www.bancatransilvania.ro, including in the section Privacy Hub, or, upon request, at any BT unit. In the general information note, you will also find the definition of the BT Client, as well as details about the recipients of BT Clients' data, about the rights you have in relation to processing your data, about the ways you can exercise them, or about how you can contact the person responsible for data protection appointed by BT (BT DPO).

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