Personal data operator
Personal data operator
Banca Transilvania S.A., headquartered in Cluj-Napoca, Calea Dorobanților no. 30-36, registered at the Trade Register under no. J1993004155124, VAT number RO5022670 (hereinafter „BT”), informs you how it will process, as an operator, the personal data in the BT Pay mobile application („Application” or ”BT Pay”). The situations in which BT is not the operator of the processed data are specifically presented in this note.
BT Pay is offered to BT customers, according to Terms and conditions of use of the BT Pay mobile application.
The targeted persons
The targeted persons
This information note refers exclusively to the processing of personal data belonging to BT Pay users who are at least 18 years old (“major users”).
👦 Informing minor users:
Minors over 14 years old, with own BT card and account:
Minors aged at least 14 years who have an account opened at BT and use BT Pay with their own card, as well as their parents/ guardians/ legal representatives (“parent”), are invited to consult:
- Information note regarding the processing in BT Pay of the personal data of minor users over 14 years old who have a BT account,
Minors, with own BT card ataparent account sat:
Minors aged between 8 and 18 years who use BT Pay with their own card attached to a parent's account are invited to consult:
For minors under 14 years old, it is recommended that this information be read together with the parent/ guardian/legal representative (“parent”).
Specific announcements
Specific announcements
BT Pay offers various products/ services that involve, as the case may be, the processing of personal data for specific purposes and legal grounds. Complete details are available in the following information notes:
- for EnPay -> Information note regarding the processing of personal data within RoPay
- for obtaining or increasing the credit card limit -> Information note on the processing of personal data for obtaining a BT credit card exclusively online.
- for obtaining or increasing an overdraft -> Information note regarding the processing of personal data for obtaining an overdraft exclusively online .
- for obkeepinga personal loan -> Information note regarding the processing of personal data for obtaining a BT personal needs loan 100% online
- for update of personal data through BT Pay -> Information note regarding the processing of personal data for updating through BT Pay the data registered with BT
- for Bill Payments Service, in Information note regarding the processing of personal data within the Bill Payment service
- For SANB Service -fraud prevention in the case of interbank transactions -> Information note regarding the processing of personal data within the Beneficiary Name Display Service (SANB).
BT will periodically update this information note, without imposing less favorable conditions regarding data processing and protection. The changes will be communicated in the BT Pay application, and the updated version will be available at any time for consultation in BT Pay and also on the BT website, in the section Privacy Hub.
BT Pay users are always subject to the current version of this information.
If you have any questions or complaints regarding how BT processes personal data, you can contact us at dpo@btrl.ro.
Personal data processed in BT Pay, the purposes and legal grounds for processing
Personal data processed in BT Pay, the purposes and legal grounds for processing
🛡️1. For ensuring security in BT Pay/ fraud prevention
For the security of data in BT Pay and to prevent fraud, when you register or use BT Pay, we process, based on legal obligations and legitimate interest, the following types of data:
📱data about the device: such as, but not limited to: device ID and name, model, operating system type/version, existence of a security method (e.g. password, fingerprint - BT does not have access to these methods, only checks if they exist), information regarding recent use of the device for calls/conversations (without access to their content or to the phone numbers called/calling), including the presence of potentially dangerous applications (e.g. malware, remote control applications) - we check the device to detect if such applications are installed and, if so, which ones they are. without having information or access to other installed/used applications on the device.
📡IP address and location based on IP
🔑necessary data for: setting/resetting/unblocking PIN, authentication in the application, transaction authorization, as presented in Information note regarding the processing of personal data for the purpose of identification in BT Pay
Depending on the fraud risks, based on the processing of these data, the bank may take measures, including automatically, such as: blocking the application until unsafe third-party applications are removed or, as the case may be, until you assume the risks associated with their use on a device on which you use BT Pay, blocking suspicious transactions, contacting the user.
These data are essential for the security of the application. If you refuse to process them, usually, you will not be able to use BT Pay
🆕 2. For the registration in BT Pay of new BT clients holding a current account
At the opening of a business relationship through BT Pay, we use remote identification via video means, which involves processing data from the identity document, contact data, and biometric data (facial recognition), in accordance with applicable legislation. The details are presented in Information note regarding the processing of personal data for opening the business relationship with Banca Transilvania through BT Pay.
💳 3. For the registration in BT PAY of existing BT customers
If you already have a relationship with BT and want to register for BT Pay, it is necessary to identify you through a strong authentication process, according to the legislation regarding payment services. For this purpose, we process personal data, according to the details in Information note regarding the processing of personal data for the purpose of identification in BT Pay accessible from the “Specific Information” section of this information note.
For registration in BT Pay, based on the conclusion/ execution of the contract related to the Application, we process your a username (nickname), an Application identifier (wallet ID), card data/ card data(the card number, expiration date, CVV/CVC code, and the name on the card) that you hold at BT or that you register in BT Pay (cards issued by BT, BT Direct or non-BT cards), declared phone number at BT, respectively at BT Direct and, for non-BT cards the confirmation of 3D Secure verificationby the issuing institution (BT does not have access to the data used in this verification, does not know the method nor the personal data used for verification by the issuing institution of the card).
🧭4. For using BT Pay
For the execution of the contract related to BT Pay of which you are a party, for fulfilling the bank's legal obligations, based on our legitimate interest and, where applicable, based on your consent, we process personal data as follows:
I. "Cards" Functionality
1. Card payments at merchants
With devices Android with NFC activated, you can pay with BT cards from BT Pay. In this case, we process data such as: device dates (the system and system version of the operating system, whether it has the NFC function and whether it is activated), required authentication (ex. unlocking the phone), details about transactions (amount, date, location), card and account dataused.
For card enrollment in Google Pay, the application will display the option if you use Android and have unregistered BT cards. In this case, BT transmits securely to Google card data (its number, expiration date, name), BT client code (BT CIF), Device ID, and Wallet ID.
On devices iOS, for NFC payments, card enrollment is necessary in Apple Pay, according to Apple terms. BT Pay will display the quick enrollment option and will process device dates (system and operating system version), card data (PAN, expiration date, name, BIN and card type) on which transmit securely to Apple.
To authorize online payments with „Pay with BT Pay”, we process selected card data and authorization method.
For online payments through "Click to Pay", users need to create a Click to Pay profile from the application. If e-mail and phone numberregistered at the bank match those used at the merchant, the transaction can be authorized without manually entering the card details. Details regarding the processing of personal data are păsesc in the dedicated section of Terms and conditions of use of the functionality„Click to Pay” from BT Pay.
2. Transfers based on phone number (P2P) or IBAN
With BT Pay you can: send/request money to/from contacts or other BT Pay users, via phone number (P2P); make transfers based on IBAN; make transfers between your own cards registered in BT Pay.
For P2P transfers, the application can access (only with your consent)phone agenda for making the transfer. If you do not allow access, you will have to manually enter the recipient's number.
During the initiation of a P2P, the application will show if the entered phone number is associated with a BT accountPay. Thus, if the phone number on which the BT Pay application is installed is selected or entered by any BT Pay user în in order to carry out a P2P transfer, that user will find out that the BT Pay application is installed on that phone number.
For the execution of P2P transfers we process: card details (including the preferred card for receiving P2P transfers, if you have chosen one), the transaction data (the amount, the date, the explanation, the IBAN and the name of the payer/ beneficiary of the transfer), phone number (yours and the other BT Pay user's).
For transfers based on IBAN code, we process card and account details you,the transaction data (like a P2P transfer), the beneficiary's transfer details (name, surname, IBAN).
Can you send proof of the transfer P2P or via IBAN to a email address.
For transfers between own cards registered in BT Pay we process card data between which you make the transfer and accountsBT to which these are attached and transaction data.
Within the “Cards” functionality, BT Pay allows users to perform other banking operations as well, such as cash withdrawals (with code or contactless), setting limits and blocking cards, viewing card details, authenticating online payments, paying bills, enrolling in Open Banking, issuing cards (including for additional users), transferring money to BT, and saving cards with merchants, viewing information about the credit limit/line and about payments made with the card broken down by the merchant category where they were made, for credit cards. For each functionality, Banca Transilvania processes relevant personal data (e.g., card data, phone number, transactions) .
3. Cash withdrawal from BT ATM based on code
From BT Pay you can generate a temporary code for cash withdrawal from the ATM (valid only for cards issued to individuals). We process phone number (selected from the agenda/ entered by you) for sending the code, card and account data, transaction data.
4. Contactless cash withdrawal from BT ATM
With BT Pay the user can withdraw cash contactless from the ATM. This operation will be possible only by entering PIN code pertaining to the respective card.
5. Setting trading limits and/or blocking cards
From BT Pay, transaction limits can be set on BT cards registered in the application, these cards can be blocked - temporarily or permanently - and the unlocking of temporarily blocked cards can be requested. We process information about the set limits, the status and card data, as well as the phone number declared at BT (these operations being allowed only based on the OTP code sent via SMS).
6. Displaying card details in the application
Through the BT Pay application, it will be possible to view card data – card number and CVV/CVC code în in order to facilitate its use for online payments, as well as PIN code set for the card. We process this data and, where appropriate, the phone number declared at BT (when display is allowed only based on the OTP code sent via SMS).
7. Authentication/ confirmation of online payments through BT Pay
Online payments (payments made on merchants' websites) initiated with BT cards registered in BT Pay, including in 3D secure, can be authenticated/ declined exclusively through the application. We process card details, transaction details (including the name of the merchant to whom the payment is to be made and the transaction identifier, which will be stored in the device you use, from the initiation of the payment, until the online payment is authenticated or rejected, as the case may be).
Notification regarding the authentication/ rejection of such an online payment will be transmitted on the "general" channel in the Application. Not activating notifications sent on the "general" channel will prevent receiving the notification for authentication/rejection of the online payment. On Android phones, with your consent, BT Pay can automatically display the payment confirmation screen, without you having to manually open the application or the notification. Permission is requested after the first online payment or can be activated from the phone settings, applications section – BT Pay.
8. Activation and use of the Bill Payment service
The personal data for the activation and use of this service are processed according to the specific information notice, accessible from the "Specific Information" section of this information notice.
9. Enrollment in Open Banking
For the use of the Open Banking functionality (available for non-BT cards added in BT Pay), BT processes the following information which are, as the case may be, personal data : The IBAN, the balance of the non-BT card/account, and the history/data of transactions from non-BT accounts (date, amount, transaction details, counterparty of the transaction carried out in the non-BT account).
10. Issuance/reissuance of a card
From BT Pay you will be able to request the issuance/reissuance of a card for yourself (including a virtual card) or for a person you designate as an additional card user. In this case, we process, as appropriate, your personal data and/or those of the additional card user: date of the issued/reissued card, the IBAN of the account to which it will be linked, the delivery address of the card, the personal numeric code and phone number of the additional card user. If the supplementary card user is not yet identified in BT Pay at the time of his designation, we will also process his personal data for identification in BT Pay, as provided in Information note regarding the processing of personal data for the purpose of identification in BT Pay, accessible from the "Specific Information" section of this information note.
11. Option “Move your money to BT”
When you use this functionality we process personal data as follows: transaction data (amounts, transfer recurrence, the banking institution from which you make the transfer), card and account data,
12. Option “Card saved at merchants”
When you use this option we process you: name, first name, e-mail address, card details, information about active subscriptions, details about recurring payments (amount, frequency, date) and websites where the card data was saved.
13. Credit information and expense grouping
For credit cards, you can also view information about the credit line/limit, the minimum payment obligation and the amount paid, possible insurances of the credit line, transactions posted in installments, the number of accumulated Star points, to activate/ deactivate the monthly automatic payment and the amount of this payment, and to see the grouping of expenses according to the category of merchants at which the payments were made (does not involve analysis or assessment of payment behavior). We process this personal data to help you manage your financial resources (purpose of financial education)
II. The "Accounts" functionalities and "Savings"
For viewing, using and managing in BT Pay a current accounts, credit card accounts, savings accounts, deposits and associated services (such as Round Up, extracts, transfers or payments), BT processes the following categories of personal data related to these accounts, as applicable: IBANs, balances, currencies, cards attached to accounts, data regarding transactions (amount, explanations, date, exchange rate, data of payment recipients - name, first name, account number, transaction history), recurring payments, predefined beneficiaries, amounts and settings related to the Round Up service, data regarding the establishment and administration of deposits and savings accounts (amounts, start/end dates, transfer frequency), information regarding interests and related taxes.
In case of sending the proof of payment by e-mail, it will also be processed and address entered by user.
III. "Credits" Functionality
In case of accessing the “Credits” functionality, the Bank will process personal data aboutthe products that you have to BT (IBAN and the balance of the credit account, of the current account from which the monthly installment is withheld or of the account you select to make an early repayment on a non-card loan, număthe credit contract rule, the contracted loan amount, the start and end date of the loan, the amount related to the monthly installment, any arrears, the repayment schedule, insurances related to the loans and their status).
IV. “Investments” Functionality
Products in this BT Pay section are offered by subsidiaries of the bank (member entities of the BT Financial Group). In this case, Banca Transilvania processes your data as an authorized person, and the subsidiary is the operator. Your data from the bank's records necessary for concluding/performing the contract you conclude with the subsidiary is sent to the respective subsidiary, which will process it according to the provisions of its own Privacy Policy. You can find more details below:
For the purchase and management of units at the funds managed by the bank's subsidiary - BT Asset Management SAI (BTAM) - from BT Pay you can become an investor in the funds managed by BTAM by signing the brokerage contract with BT, to buy/sell and manage fund units (UF) in the fund you choose. Your personal data such as will be processed by the BTAM operator: name, first name, CNP, BTAM client ID, investment account number, transaction history, balance held in investment funds managed by BTAM, information regarding gain/ loss and withholding tax. You will become a BTAM client. Details about the processing of personal data carried out by the BTAM operator can be found in the BTAM Privacy Policy, available on the website www.btassetmanagement.ro.
To become a participant and view the accumulated amounts in the optional pension funds managed by subsidiary băncii - BT Pensii SAFPF S.A. (BT Pensii) - by signing the adhesion act to a voluntary pension fund (pillar III) administered by BT Pensions, you become a participant in this fund (BT Pensions client). You will be able to set and manage the contribution to the fund, including expressing your preferences regarding BT Pensions' communication with you. Details about the processing of personal data carried out by the BT Pensions operator can be found in the BT Pensions Privacy Policy, available on the website www.btpensii.ro
To view the amounts accumulated in your pension managed privately by the bank's subsidiary – BT Our Pension SAFPP S.A. – if you have a private pension (pillar II) at BT Pensia Noastră, you can view the accumulated amount in BT Pay. Details about the processing of personal data carried out by the operator BT Our Pension can be found on the website https://btpensianoastra.ro/
V. Functionality "Kiddo"
1. BT Pay Kiddo – for minors aged 14 and over, with own BT card and account
Dacă inițiați, ca părinte, o conectare a unui minor din această secțiune din BT Pay Kiddo , vom verifica dacă îndepliniți condițiile prevăzute în BT Pay Kiddo Terms. In this regard, we will process the following personal data: name, first name, CNP, age,the quality of being a parent of the minor and of aauthorized on his account.
2. BT Pay Kiddo – for minors with own BT card attached at the parent's account:
Dacă inițiați, ca părinte, o conectare a unui minor din această secțiune din BT Pay Kiddo, vom verifica dacă îndepliniți condițiile prevăzute în BT Pay Kiddo terms for minors attached to the parent's account. For this purpose, we will process the following personal data: name, first name, Personal Numeric Code (CNP), age șand implicit personal data consisting of the relationship between you and the respective minor.
VI. Other BT Pay functionalities
1. Identification through BT Pay in calls or in BT units
If you choose identification through BT Pay during a call with a BT call center agent or at a BT unit, we will process your personal data: the status of BT client BT Pay user, phone number, authentication method (PIN, biometrics, phone unlocking) and application version.
2. Beneficiary Name Display Service (SANB) for the purpose of fraud prevention
We have the legal obligation and legitimate interest to prevent banking fraud. To protect you in case of interbank transactions (payments to accounts from other banks), BT together with other associated operators, processes your personal data according to the details in Information note on the processing of personal data within the Beneficiary Name Display Service (SANB) , din secțiunea “Specific Information” from this information note. In case intrabank transfers (payments to BT accounts), BT processes the same categories of personal data on its own that are also used within SANB. The legal basis for processing your data is BT's legitimate interest in preventing fraud in the case of intrabank payments (BT-BT). The first name(s) (one or more, as applicable) in full and the initial of your registered surname at BT will be displayed to other BT clients who initiate a payment to your BT account from a bank application, regardless of whether the payment is completed or not.
3. Updating personal data
Through this functionality, you can update some personal data at the bank. Details about the processing of personal data can be found in the specific information note in the "specific notifications" section of this information note.
4. Management of authorized representatives
If you have received/have access in BT Pay to the accounts of other BT individual clients, adults or minors, on which you are designated with operating rights (proxy), we process data about your status as a proxy on those accounts, about the transactions and any actions you perform on those accounts. Also, we process your data if these clients revoke your status as a proxy from BT Pay on their accounts.
If you grant access in BT Pay to other BT clients, natural adult persons, designated with operating rights (authorized person) on your accounts, we process data about your status as an account holder who has designated an authorized person(s) with access rights in BT Pay. Also, if the authorized persons perform transactions and any actions on your accounts, we process the necessary data (name, first name, accounts, transactions, balance, etc)
5. Current account subscription management
Through this functionality, you can activate and deactivate current account subscriptions and view details about the subscription you have active. For the execution of the contracts related to each of the products and services offered by BT that are part of these subscriptions, we process your necessary personal data, as provided in General informative note regarding the processing and protection of personal data belonging to BT customers . For insurance products that are included in some of the subscriptions, the operator of your personal data for concluding and executing the insurance policy is the Insurer.
6. RCA Insurance
Through the "RCA Insurance" section in BT Pay you can obtain quotes or conclude RCA policies. For displaying the offers, personal data is processed by Timesafe SRL and Renomia-SRBA, according to the data processing policies of these companies, available in the application. BT processes the data as an authorized person of the operator.
7. Travel insurance
Through BT Pay you can obtain insurance offers and conclude travel insurance from Groupama Asigurări. For this functionality, BT processes personal data as an authorized representative of Groupama. Details regarding the processing of personal data carried out by Groupama are accessible directly from the application, in the "Travel Insurance" section.
8. Home insurance
Through BT Pay you can obtain the insurance offer and conclude a voluntary home insurance from Groupama Asigurari and a PAD insurance. For this functionality, BT processes personal data as an authorized person of Groupama. Details regarding the processing of personal data carried out by Groupama are accessible directly from the application, in the "Home Insurance" section.
9. Recharge phone card
When you use this option, we process: phone number for which the recharge is made, card details, account balance from which you make the loading.
10. Purchasesyou eSIM
When you use this option and purchase an eSIM data plan from our partner – Timesafe SRL (Pago) who offers this service in BT Pay, BT will process, including disclose to Pago, your data consisting of: name, first name, unique identifier (BT client code – BT CIF), data regarding the transaction through which you purchased the eSIM (payment transaction reference, payment status, information regarding the payment method used for eSIM purchase - bank card).
In the context of using the eSIM functionality from BT Pay, Pago processes your data as an independent operator, as provided in the Timesafe SRL Privacy Policy for eSIM in BT Pay, which you can access from the relevant eSIM section.
11. Vignette purchase
When purchasing or renewing the road toll vignette for Romania from BT Pay, BT will process: data about the vehicle, the card used and the available balance
🔊 5. For communication with BT Pay users through the application
a. Notifications
Through BT Pay we send you several types of notifications:
- Notifications related to card payments: confirmation/ denial of payments made with the cards registered in the application, authentication/rejection of online payments initiated with BT cards enrolled in the application and in 3D Secure.
- Transfer notifications: acceptance/ rejection of the transaction initiated via P2P; confirmation of successful completion of the transaction;
- Notifications regarding partial early repayments of the non-card loan:information regarding the status of the request for partial early repayment of the non-card loan.
- Notifications for identification via BT Pay: identification requests in the application (in call with BT call center agent or for identification with BT Pay in units).
- Notifications for Bill Payments Service: messages dedicated to the users of this service.
- Notifications/ messages of general interest: relevant information about the BT Pay application, other than those related to the above functionalities.
- Notifications/ messages of particular interest: ex. changes to the Bank's General Business Conditions, changes in commissions, updates to information notes regarding personal data processing; notifications of updates to data in the bank's records.
- Advertising messages,if you have given your consent at BT for us to process your data for advertising purposes, through the dedicated form (available in branches, on the BT website, in BT Pay Web or in the process of opening the business relationship with the bank for BT Pay for individuals or through BT Go for legal entities).
- Notifications about "Offers" from BT Pay: information about new offers added in the application; Notifications about unlocked offers in the "Offers – rewards in motion" section. By accessing the "Offers" section in the app, you express your consent for BT to collect information about: the offers accessed (saved, activated, or applied for), with the purpose of presenting relevant offers in the future and applying the preferential conditions related to the activated or accessed offers.
🏃♀️ Prizes în Mișwhich – BT Pay - to encourage an active lifestyle, BT Pay includes in the “Offers” section the “Prizes in Motion”, where users can unlock special offers from partners and the bank. As a result of connecting a physical activity monitoring application, BT Pay will request permission to access data such as: number of steps, kilometers traveled, active minutes. These data are visible only to the user who connected them and are used exclusively for: verifying eligibility for offers, awarding prizes. The data is stored only for the duration necessary to fulfill these purposes. Some offers may also include other parameters, such as activity with the card or in the application, specify clearly in each offer.
Accessing the Rewards in Motion section is optional and does not affect the general use of BTPay. If you have granted access to data from the monitoring application, you can revoke it at any time from the settings of that application or the phone. Without access, you will not be eligible for offers in this category.
- BT Pay will also request access to device location, for displaying valid offers in the area where you are located (e.g. for automatic display of Star partners' offers (for holders of Star credit cards, for displaying on the map the partner locations related to the offers). You are not obliged to allow access to location, but you have the option to manually select the locality. If you refuse access, the other functionalities of BT Pay can be used without impediments
You can enable/disable notifications from the app's Settings menu. If notifications are not enabled ("on"), they will not be received as push notifications, but will be available in the Notifications section within the app.
b. assistance and support through the BT Pay chatbot
Through the BT Pay chatbot, you can chat in real time with a BT consultant. In this context, we process data such as: name, BT CIF, client type, card names, app version, phone operating system, and language selected in the chat, for identification and support.
📈 6. For the analysis and improvement of BT Pay's performance
To be able to draw up statistics that allow the measurement of BT Pay's performance, in order to improve its performance, we have a legitimate interest in collecting the following information about the devices on which it is installed - device identifier (Device ID), phone type, operating system, operating system version, device name, device settings, necessary accesses to have an internet connection.
Period of retention of personal data processed in BT Pay
Period of retention of personal data processed in BT Pay
Except for the situations expressly mentioned within this information note, your data, as a BT client, as well as the data regarding the transactions carried out through BT Pay, will be kept for a period of 5 years from the termination of your business relationship with the bank, according to the applicable legal provisions, except for the data that must be kept for a period of 10 years, according to the legal provisions in the financial, accounting, and fiscal field.
Recipients of personal data processed in BT Pay
Recipients of personal data processed in BT Pay
The data provided directly by the users of the application or of which the Bank may become aware in the context of installation, registration, enrollment/ use of the Application, may be disclosed by Banca Transilvania to certain categories of recipients, as follows:
- other BT Clients who have the right and the need to know them (all BT Pay users are BT Clients)
a. BT Pay users which you have authorized on your accounts including in the application
If you have fully authorized representatives on all BT accounts and have granted them access to these also in the application, they will have access in the application to personal data about you and the counterparties in the transactions mentioned in the section II. The functionalities “Accounts” and “Savings” from this information note, except for the cards attached to the accounts. The authorized persons can view this data, make transfers and currency exchanges, access statements and transaction history, share the IBAN, set up recurring payments, and manage savings and deposits.
b. BT Pay users which designated you with full operating rights on all their accounts opened at BT.
If other BT customers, natural persons, account holders, have granted you full operating rights on all their BT accounts, they will see in the application your first and last name, as well as the fact that you are their proxy. When you carry out transactions on these accounts, we will disclose to the account holders the data regarding the transactions made (information about you and about the counterparties involved in the transactions).
c. other BT clients who hold additional user cards attached to your accounts.
If you have requested the issuance of additional cards in your account in the name of additional card users, they can view your account balance in BT Pay.
d. other BT clients, on the account of which you hold an additional card issued in your name.
If you have an additional card issued on another BT client's account, the account holder will also be able to see details in BT Pay about transactions made with that card (amount, merchant, date, etc.).
e. other BT clients BT Pay users, which they find out from the icon displayed next to your phone number/your contact in their device's agenda that you are a BT Pay user (and implicitly find out that you are also a BT client).
f. BT clients to whom you make payments from BT Pay
When making transactions through BT Pay to accounts/phone numbers of other BT customers from accounts that belong to you, the data related to these transactions (usually, your full name, the amount, the account number, payment explanations) will be accessible to the beneficiaries to whom you made the payment.
- contractual partners of the bank
a. Service providers who assist us in providing the Application and in activities related to it (e.g., SMS transmission service providers, e-mail; trusted service providers for signing documentation in the application with an advanced electronic signature, etc.); identification service providers (for identification in BT Pay that involves photographing the identity document and/or the face - selfie/video selfie -, BT uses the services of the provider Onfido and those of some of its subcontractors, who process, only on behalf of and under the instructions of the bank, the data from the identity document, the image - including that from the video selfie taken in BT Pay - and respectively the biometric data of the face, used for identification in BT Pay. The data processing will be carried out in some cases also in third countries. The transfer of personal data to these states is based either on adequacy decisions issued by the European Commission (e.g. in the United Kingdom), or other appropriate safeguards, in accordance with the mechanisms provided by the GDPR consisting of Standard Contractual Clauses approved by the European Commission which you can find here: https://eur-lex.europa.eu/legal-content/RO/TXT/PDF/?uri=CELEX:32021D0914)
b. Apple (Apple Pay solution), in case you have chosen to enroll your card in this payment solution
c. other entities within the BT Financial Group whose services/products are accessible through BT Pay (e.g. distribution of fund units through BTAM, optional pension funds managed by BT Pensii or privately managed by BRD Pensii)
d. BT partnerswhose services/ products are accessible through BT Pay, including according to specific information notes (e.g. insurance companies, Timesafe SRL for eSIM etc)
Categories of recipients to whom personal data are disclosed in the context of registration or enrollment in/through BT Pay as well as the separate services RoPay BT, Bill Payments, Overdraft,Credit Card and credit line increase exclusively online, 100% online personal loan are mentioned in the specific information notes for the processing of personal data within these services.
List of recipients above is completed with the one provided in General information note concerning the processing and protection of personal data belonging to BT Clients, section VIII.
Links and third-party applications
The application contains links to the websites belonging to partner merchants .
At the same time, the application offers users the possibility to access:
- third-party applications - for monitoring physical activity- by logging in with the account data from the respective application through the BT Pay application, in order to unlock some preferential offers from the section Moving Awards a BT Pay.
- through section Offers, personalized links from partner merchants, on accessing which third parties will be able to know that the person accessed them from BT Pay, therefore implicitly the fact that they are a BT customer.
🔒Responsibility regarding the processing of personal data - the bank does not control, does not administer and is not responsible for the way the merchant partners process your personal data on their websites or applications, even if you access these platforms from BT Pay. BT cannot guarantee that this data is managed in accordance with the legislation on personal data protection (e.g. GDPR, Law 506/2004, Law 190/2018), cannot verify the accuracy or currency of the data that these platforms/websites hold about you. Each third-party website or application has its own rules regarding data processing. We recommend that you consult their privacy policies to ensure that they are in line with your interests.
Rights related to the processing of personal data in BT Pay
Rights related to the processing of personal data in BT Pay
Your processing of your personal data within BT Pay is subject, in addition to this notice, to the provisions General information notes regarding the processing and protection of personal data belonging to BT clients , integral part of BT Privacy Policies, which you can find on the website www.bancatransilvania.ro, in the Privacy Hub section or upon request at any bank branch.
Within the aforementioned General Information Note, you will also find the rights you can exercise regarding the processing of your personal data, the ways in which you can exercise them, as well as the contact details of the Data Protection Officer (DPO) and how you can contact them.
