Information notice on the processing of personal data of BT customers for customer due diligence purposes for the prevention of money laundering and terrorist financing
1. General provisions
Banca Transilvania, S.A., S.A. (hereinafter also referred to as "the bank", "BT", "we", "us"), hereby informs you of how it intends to process your data, as a BT Customer, for the main purpose of customer due diligence for the prevention of money laundering and terrorist financing.
This information note is supplemented by the provisions of General information notice on the processing and protection of personal data of BT customers (hereinafter also referred to as the "BT General Information Notice" or "Notice"), which you are advised to consult. Within the Note you will find including the definition of BT Customer, beneficial owner, politically exposed person and definitions of other specialist terms.
The primary legislation establishing the obligation for the BT to apply the know-your-customer measures is primarily represented by Law no. 129/2019 on preventing and combating money laundering and terrorist financing, as well as amending and supplementing certain regulatory acts.
Customer due diligence for the prevention of money laundering and terrorist financing, including risk-based verification, is carried out by BT through the application of customer due diligence measures that involve both identity verification and the processing of personal data required by law, both at the time a particular individual acquires the status of BT Customer (data collection), for the entire period during which this status is held (data updating), as well as after this time, for the period of time legally established after the termination of the status of BT Customer (data storage and processing for purposes permitted by law).
As long as you are a BT Customer, you are obliged to update the data collected/supplied in the bank's records in order to know your customers, whenever they change.
2. Personal data that we process for the purpose of customer knowledge
Thus, in order to open and conduct the contractual relationship with most categories of BT Customers, the bank is legally obliged to collect from/about BT Customers, for the performance of a task serving a public interest, as appropriate, at least the following categories of personal data: name, surname, date and place of birth, personal identification number (CNP) or similar unique identifier, domicile, residence, telephone number, fax number, e-mail address, occupation, name of employer or nature of own business, important public position held or politically exposed person (PEP) status, information about the purpose and nature of the business relationship and source of funds, and copy of ID.
The application of know-your-customer measures includes the use of the data collected to:
- making and sending reports to the institutions competent to receive them, in accordance with the legal provisions applicable to the bank (such as, but not limited to: reports for declaring transactions exceeding the amount established by law to the National Office for the Prevention and Combating of Money Laundering);
- assessing and monitoring the financial-commercial behaviour of BT's customers during the course of their business relationship with the bank, in order to detect unusual transactions and suspicious transactions, in accordance with the legal obligations of customer due diligence imposed on the bank for the prevention of money laundering and terrorist financing;
3. Retention period of personal data processed for the purposes of customer intelligence
The data collected and, where applicable, updated, together with the records of all financial transactions arising from the conduct of the business relationship with BT, will be stored in the bank's records for a period of at least 5 years from the date of termination of the business relationship, according to the legally prescribed retention period (in Law 129/2019).
If the business relationship is not opened, your data will be stored by BT for at least 5 years from the date of the bank's refusal to open the business relationship.
In case of refusal of BT Customers to provide/update/process these data, their contractual relationship with the bank may not be opened or, if applicable, may be terminated at the initiative of BT.
Data processed for customer intelligence purposes may be subject to automated decision-making processes, where appropriate, such as:
- in order to apply know-your-customer measures for the purpose of preventing and combating money laundering and terrorist financing, checks will be carried out on databases of persons suspected of financing terrorist acts or, where appropriate, persons at high risk of fraud and, if BT customers are included in these records, the bank reserves the right to refuse to enter into a business relationship with them or to terminate the contractual relationship;
- to protect BT Customers and BT walk in clients against fraud, as well as for the bank to properly fulfill its KYC obligations, it monitors the Customers transactions and, if it identifies suspicious transactions (such as unusual payments as frequency, value, reported to the source of funds declared or the purpose and nature of the business relationship, transactions initiated from different cities at short time intervals, which did not allow the travelling between those cities, transactions whose details generate suspicions of money laundering or terrorist financing, attempts to use BT cards on suspicious websites), may take measures to block the transactions, accounts’ cards, taking these decisions solely based on automatic processing;
4. Rights of the data subject
Data processed for the purpose of customer intelligence may be disclosed/transferred by BT, as appropriate, to the categories of recipients mentioned in BT's General Information Notice. In this General Notice you will also find details of your rights in relation to the processing of your data for the purposes indicated, how you can exercise them or how you can contact the BT Data Protection Officer (BT DPO). .
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