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    BT DIRECT S.A. POLICY REGARDING THE PROCESSING AND PROTECTION OF PERSONAL DATA ("BT Direct Privacy Policy")

    Applicable version starting from the date of 17.12.2025

    The current version of the policy DownloadThe previous version of the policy (May 25, 2018 – September 30, 2019)DownloadThe previous version of the policy (October 1, 2019 - March 31, 2024)Download

    About this Privacy Policy

    ToBT Direct IFN S.A. (referred to hereinafter “BT Direct” or "we") we constantly take care that the personal data of all individuals we interact with are processed in full compliance with the applicable legal provisions and with the highest standards of security and confidentiality.

    For guiding and supporting us in our activity in the field of processing and protecting personal data, we have appointed a data protection officer or DPO, which can be contacted by any person regarding any aspects related to how BT Direct processes this data, by sending a complaint to:

    • BT Direct headquarters: Mun. Cluj-Napoca, Bdul. 21 December 1989, nr. 77, The Office, Building C-D, ground floor, county Cluj 
    • email address:dpo@btdirect.ro

    In the following, we present our policy in this very important area, which we commit to reviewing at certain intervals, with a view to its continuous improvement.

    Through this Policy we understand to fulfill our obligation to inform all categories of natural persons whose personal data we process in the course of our activities (“data subjects”) in accordance with the provisions of Art. 13 -14 of EU Regulation no. 679/2016 or the General Data Protection Regulation (hereinafter referred to as “GDPR”).

    Whenever we have the objective possibility to directly inform certain categories of targeted persons about the processing of their data, we commit to proceed accordingly.

    In some cases, however, either we do not have the objective possibility, or it would involve a disproportionate effort for us to directly fulfill this obligation. For all these situations, we fulfill our obligation to inform through this Privacy Policy.

    If you are our customer - BT Direct Client - and you want to consult only the section regarding the processing of data of this category of data subjects, you can access:General information notice regarding the processing and protection of personal data belonging to BT Direct Customers, what is an integral part of this Policy.

    The present Policy does not address BT Direct employees, this category of data subjects being informed regarding the personal data processed by BT Direct as an employer through a separate document.

    We will present to you below what categories of personal data we process within our activity, who the data subjects are for this processing, for what purposes we use personal data, to whom we disclose or transfer them, how long we keep them, in what way we ensure their security, as well as what rights the data subjects can exercise in connection with this processing.

    In case you are not familiar with the meaning of different specialized terms used in GDPR or the legislation applicable in the banking field, we recommend that you first study the section regarding:

    • A. Specialized terms used in Politics

    When we use the terms below in this Policy, they will have the following meaning:

    a)“Personal data" means any information regarding an identified or identifiable natural person (“data subject”); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, identification number, location data, an online identifier, or to one or more specific elements, characteristic of their physical, physiological, genetic, mental, economic, cultural or social identity;

    b)  „Processing of personal data”  sau  "data processing", means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or making available in any other way, alignment or combination, restriction, erasure or destruction;

    c) „GDPR”means Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC;

    d)“BT Financial Group” - Banca Transilvania S.A. together with entities controlled by it such as (subsidiaries/affiliates BT) BT Microfinanțare IFN SA (“BT Mic”), BT Asset Management S.A.I. S.A., (“BTAM”), BT Leasing Transilvania IFN S.A. (“BTL”), BT Direct IFN S.A. (“BTD”), BT Capital Partners S.S.I.F. S.A.(“BTCP”), BT Pensii Societate de Administrare a Fondurilor de Pensii Facultative SA (BT Pensii), Salt Bank, Victoria Bank, BT Leasing Moldova, BT Code Crafters SRL (“BT Code Crafters”), Improvement Credit Collection SRL (“ICC”), Fundația Clubul Întreprinzătorului Român (“BT Club”), Fundația Clujul are Suflet and other entities that may join this group in the future;

    e) "Operator" means legal entity, which, alone or together with other persons, establishes the purposes and means of processing personal data;

    f) "The data subject" means the natural person whose personal data is processed;

    g) "Recipient" means the natural or legal person, public authority, agency or other body to whom the personal data are disclosed, regardless of whether or not it is a third party;

    h)“Third party”means a natural or legal person, public authority, agency or other body, other than the Data Subject, the Operator, the Authorized Person and which, under the direct authority of the Operator or the Authorized Person is authorized to process Personal Data;

    i) "Monitoring Authority" means an independent public authority established by a member state, responsible for monitoring the application of GDPR. In Romania, the supervisory authority is the National Authority for the Supervision of Personal Data Processing - "ANSPDCP";

    j) "Biometric data" means personal data resulting from specific processing techniques related to the physical, physiological or behavioral characteristics of a natural person that allow or confirm the unique identification of that person, such as facial images or fingerprint data;

    k) "Health Data" means personal data related to the physical or mental health of an individual, including the provision of healthcare services, revealing information about their health status;

    l) "Ultimate beneficiary" according to the provisions of art. 4 para. 1 of Law no. 129/2019 for the prevention and combating of money laundering and terrorist financing, as well as for the modification and completion of certain normative acts, is any natural person who ultimately owns or controls the client and/or the natural person on whose behalf a transaction, operation or activity is carried out and includes at least the categories of natural persons mentioned in art. 4 para. 2 of this normative act;

    m)“Publicly exposed person” according to the provisions of art. 3 para. 1 of Law no. 129/2019 for the prevention and combatting of money laundering and the financing of terrorism, as well as for the amendment and completion of certain normative acts, the persons are natural persons who exercise or have exercised important public functions and include at least the categories of natural persons mentioned in art. 3 para. 2 of this normative act.

    B. Who is BT Direct?

    BT Direct IFN S.A.este o instituție financiară nebancară, avand CUI RO16036850, nr. înmatriculare J2018001566126 and the following contact details: headquarters in Mun. Cluj-Napoca, Bdul. 21 December 1989, nr. 77, The Office, Building C-D, ground floor, county Cluj, phone number 0264302000, email address contact@btdirect.ro, website www.btdirect.ro (referred to hereinafter „the BT Direct website”). BT Direct is part (subsidiary) of the Transilvania Bank Financial Group.

    The provisions of this Policy refer to the processing of personal data that BT Direct IFN S.A. carries out as an operator.

    C. What personal data does BT Direct process, who owns them and for what purposes do we use them?

    In the context of the activity we carry out, we process different categories of personal data, depending on the capacity in which the data subjects interact with us. The purposes for which we process the data are directly dependent on the way in which the different categories of data subjects engage with BT Direct.

    In relation to the relationship you have with BT Direct in a certain context, we distinctly present below how we will process your personal data:

    1. If you are a BT Direct customer (e.g. debtors who have concluded a loan agreement with BT Direct or applicants who have completed applications to obtain this status, co-debtors, additional credit card users etc.)

    a. Who is Client BT Direct?

    „BT Direct Client” or ”Client” este persoana fizică care face parte din oricare dintre următoarele categorii de persoane vizate:

    • residents who contracted a credit agreement (card or non-card) from BT Direct, referred to as “debtors”;
    • residents who requested at BT Direct the opening of a contractual relationship (card or non-card), by completing a credit application, even if this application is rejected or if it is withdrawn;
    • debtor s of those indicated in letter a or b;
    • additional credit card users, requested by the persons mentioned in letter a, with the consent of the corresponding co-borrowers.

    We remind you that complete details, in printable format, about the processing by BT Direct of its regular customers' data - BT Direct Customers - can also be found inGeneral information note regarding the processing and protection of personal data belonging to BT Direct Clients.

    b. The purposes for which we process BT Direct Customers' data

    We process personal data in your capacity as BT Direct Customers, where applicable, for the following purposes:

    • identity verification, aiming to prevent money laundering and terrorist financing, as well as to confirm the status of BT Direct Client;

    The identity verification is carried out when establishing and during the course of a business relationship, when ordering any transaction or when requesting information or performing operations such as, but not limited to: information about loans contracted from BT Direct, submitting/transmitting any requests/notifications, handing over cards, as well as during telephone calls initiated by Clients or by us. Your identity is verified based on identity documents that are within the validity period, which must be presented in original, and in the online environment and during telephone calls initiated by the Client or by BT Direct, by requesting the provision and validation of information already in our records regarding you;

    • the knowledge of the clientele for the prevention of money laundering and terrorist financing, including risk-based verification, by applying customer due diligence measures that involve both identity verification and processing certain personal data required by law, both at the time a certain individual acquires the status of Client (data collection), throughout the period during which this status is held (data updating), as well as after this moment, for the legally established period after the cessation of the Client status (data storage and processing for the purposes permitted by law);
    • the assessment of solvency, the reduction of credit risk, the determination of the level of indebtedness of Clients interested in personalized offers related to BT Direct's credit products or the contracting of these types of products (credit risk analysis);
    • the conclusion and execution of credit contracts (card type or non-card);
    • the collection of receivables and the recovery of debts recorded by Clients;
    • the registration, management and resolution of payment refusals (in the case of card type loans);
    • the realization and transmission of reports to the competent institutions to receive them, in accordance with the applicable legal provisions BT Direct;
    • the realization of analyses and keeping records of economic, financial and/or administrative management;
    • the administration within the internal departments of the credit products offered;
    • the prevention of acquiring or reacquiring Client status by individuals with inappropriate behavior, which is likely to hinder the conduct of prudent lending activities, in accordance with the legal obligations that BT Direct has;
    • the defense in court of the rights and interests of BT Direct, the resolution of disputes, investigations or any other petitions/complaints/requests in which we are involved;
    • the carrying out of risk controls on BT Direct procedures and processes, as well as the implementation of audit or investigation activities;
    • the taking of measures/providing information or responses to requests/notifications/complaints of any nature addressed to BT Direct by any person and/or by authorities or institutions, through any channel, including through electronic communications services and the internet;
    • the proof of requests/agreements/options regarding certain aspects requested/discussed/agreed upon during discussions, including telephone ones, initiated by Clients or by BT Direct, by recording the aspects discussed and, where appropriate, the audio recording of telephone conversations;
    • the informing of Clients regarding the status of credit applications submitted and, where applicable, the loans contracted by them at BT Direct (such as, but not limited to account statements, communication of approval/rejection decisions of credit applications);
    • the transmission of advertising messages, only in accordance with the consent expressed by Clients on dedicated BT Direct forms;
    • collecting Customer feedback regarding the quality of BT Direct services/products/employees (service quality evaluation);
    • internal analyses (including statistical);
    • archiving - both in physical and electronic format - of documents, creating backup copies;
    • provision of registry and secretariat services regarding the correspondence addressed to BT Direct and/or sent by it, as well as for the conduct of courier activities;
    • the security of the information systems used by BT Direct;
    • fraud prevention.

    c. Categories of personal data processed for BT Direct Clients  

    • identification date: name, first name, nickname (if applicable), date and place of birth, personal identification number (CNP) or another similar unique identifier, identity document details (including series and number), as well as a copy of it, residential address and address where the Client resides;
    • contact details: postal address, phone number, email address
    • citizenship;
    • information about the purpose and nature of the business relationship;
    • financial dates;
    • information about bank accounts from which you make the payments of the installments related to the loans contracted from BT Direct;
    • fiscal date (country of tax residence);
    • profession, occupation, employer's name or nature of one's own activity (if applicable),
    • information about the important public function held- if applicable- and political opinions (exclusively in the context of obtaining information related to the status of exposed person PEP);
    • information about family situation (including marital status, number of children, children in care, etc.);
    • information about the economic and financial situation (including data on income, data regarding owned/properties held, as well as data relating to payment behavior);
    • the image (in the copy of the identity documents);
    • the voice, in the context of conversations and recordings of telephone conversations;
    • age, for the verification of eligibility to contract credit products;
    • opinions, expressed within the complaints/claims/conversations, including telephone ones, regarding products/services/employees of BT Direct;
    • signature (including within signature specimens);
    • identifiers, such as, but not limited to: credit card numbers, expiration dates of cards, credit contract numbers or credit application numbers;
    • data regarding health status, exclusively if the processing of such data is necessary for Clients to prove the difficult situation in which they and their family members find themselves, especially in view of granting facilities for contracted loans;
    • dates related to the contracted/requested loan product: product type, product status, grant date, granted amounts, due date, credit value, amount paid, monthly installment, outstanding amounts, number of days overdue, date of the first default, delay category and date of the last payment. Part of this data is processed including in the Credit Bureau, as you are informed through the specific information note:Information regarding the processing of personal data in the Credit Bureau System;
    • information regarding fraudulent/potentially fraudulent activity, consisting of data related to accusations and convictions related to crimes such as fraud, money laundering and financing of acts of terrorism;
    • information related to the commission of crimes or offenses in the financial-banking field, in direct relation to BT Direct, established by final or irrevocable court decisions, as the case may be, or by uncontested administrative acts;
    • any other personal data belonging to Clients, which is brought to our knowledge in various contexts by other Clients or by any other persons.
    2. If you are a natural person related to the applicant of a BT Direct loan - natural person from the debtor group (e.g. husband/wife/partner of a BT Direct loan applicant etc.)

    a. Who is a natural person connected with the applicant of a BT Direct loan?

    In the case where a person submits a credit application to BT Direct, in accordance with the legal obligations to which any non-banking financial institution is subject, it is necessary for us to provide data about some natural persons with whom the credit applicant is in connection. These persons are generally, but not limited to: spouse/partner, legal representatives/associates/shareholders of legal entities with which the credit applicant is in connection.

    b. The purposes for which we process data belonging to individuals connected with the applicant of a BT Direct loan?

    If you are such a person, we process your data, where applicable, for the following main purpose:

    • assessment of solvency, reduction of credit risk, determining the degree of indebtedness of Clients interested in personalized offers related to BT Direct's credit products or contracting these types of products (credit risk analysis);

    In the context of analyzing the credit application of a credit applicant, BT Direct processes including your personal data, if you fall into any of the categories of individuals mentioned above (individuals related to a credit applicant, namely the so-called persons who are part of the debtor group), since BT Direct is subject to legal obligations to establish and analyze its exposure to related customer groups, as part of the credit risk analysis.

    Also, as the declarant, BT Direct will report these exposures and the composition of debtor customer groups connected to BNR, the Central Credit Risk (only where applicable).

    Your data is required by BT Direct in order to proceed with the analysis of the credit request/application, and the applicant's refusal (or yours) to provide or have them processed may result in our inability to analyze and/or approve the loan.

    The personal data that belong to you are transmitted/disclosed, as applicable, to the Credit Risk Center within the BNR, as well as, respecting the principle of the need to know, to entities within the BT financial Group and/or to service providers used by BT Direct in the process of analyzing the credit application.

    The retention period of your data in BT Direct records is equal to that of the existence of a group/groups of clients with which you are connected.

    Other related purposes to the main purpose indicated above, for which we process your data are, as appropriate, the following:

    • identity verification, including, where applicable, for the confirmation/denial of your status as a BT Direct Client;
    • the preparation and transmission of reports to the competent institutions to receive them, in accordance with the applicable legal provisions of BT Direct (such as, but not limited to: the Central Credit Risk within BNR);
    • the realization of analyses and the keeping of records of economic, financial and/or administrative management of BT Direct;
    • the management within the internal departments of the services and products offered by BT Direct;
    • the appearance in court of the rights and interests of BT Direct, resolution of disputes, investigations or any other petitions/complaints/requests in which BT Direct is involved;
    • the carrying out of risk controls on BT Direct procedures and processes, as well as the implementation of audit or investigation activities;
    • the taking of measures / the provision of information or responses to requests / notifications / complaints of any kind addressed to BT Direct by any person and / or by authorities or institutions, through any channel, including through electronic communication services and the internet;
    • internal analyses (including statistical);
    • the archiving - both in physical and electronic format - of documents, making backup copies;
    • the provision of registry and secretariat services regarding the correspondence addressed to BT Direct and/or sent by it, as well as for the conduct of courier activities;
    • the assurance of the security of the information systems used by BT Direct and of the physical spaces in which we conduct our activities;
    • fraud prevention.

    c. Categories of personal data processed for individuals in the group of a BT Direct debtor 

    • identification date - name, surname, CNP;
    • the function, the quality, the holdings and, if applicable, the powers of representation held within some legal entities of the debtor group;
    • depending on the case, other data held by BT Direct or available publicly, which are necessary for fulfilling the main purpose related to credit risk analysis.
    3. If you are a signatory and/or a contact person on behalf of the contractual partners of BT Direct

    a. Who is the signatory/contact person on behalf of the contractual partners BT Direct?

    • Signatories are, generally, the legal representatives or other persons designated by the contractual partners to sign the contracts concluded with BT Direct (regardless of whether the contractual partners are BT Direct Clients legal entities account holders or service providers, collaborators, suppliers of goods contracted by BT Direct);
    • Contact persons there are persons designated by the contractual partner and communicated to BT Direct by it in order to keep in touch for the proper execution of the contract, regardless of whether their data are or are not mentioned in the content of the contract.

    b. The purposes for which we process the data of signatories/contact persons from BT Direct contractual partners

    If you are a signatory/contact person on behalf of any contractual partner of BT Direct, we process your data, where applicable, for:

    • The conclusion and proper execution of the contract concluded with the contractual partner (usually this is your employer), as well as for other purposes, closely related to the conclusion and execution of the contract, namely:
    • the realization and transmission of reports to the competent institutions to receive them, in accordance with the applicable legal provisions BT Direct;
    • the implementation of analyses and keeping records of economic, financial and/or administrative management of BT Direct;
    • the appearance in court of the rights and interests of BT Direct, resolution of disputes, investigations or any other petitions/complaints/requests in which BT Direct is involved;
    • the carrying out of risk controls on BT Direct procedures and processes, as well as the implementation of audit or investigation activities;
    • the taking of measures/providing information or responses to requests/notifications/complaints of any kind addressed to BT Direct by you or by authorities or institutions, through any channel, including via electronic communications services and the internet;
    • internal analyses (including statistical);
    • archiving - both in physical and electronic format - of documents, creating backup copies;
    • the provision of registry and secretariat services regarding the correspondence addressed to BT Direct and/or sent by it, as well as for carrying out courier activities;
    • the security of the information systems used by BT Direct and the physical spaces where BT Direct operates;
    • fraud prevention.

    c. Categories of personal data processed for the signatories/contact persons from the contractual partners

    We generally process the following categories of personal data that concern you, as appropriate:

    For the signatories:

    • identification number - name and surname;
    • function;
    • signature.

    For contact persons:

    • identification number - name and surname;
    • contact date- work phone number and/or work email address;
    • function.

    The information note dedicated to signatories and contact persons acting on behalf of BT Direct's contractual partners can be foundhere.  

    4. If you are a visitor of the BT Direct website

    a. Who is a visitor of the BT Direct website?

    Any natural person who accesses this qualitythe BT Direct website.

    b. The purposes for which we process the data of visitors to the BT Direct website

    Through cookies or other similar technologies, we process your data as a visitor of the BT Direct website for the purposes described in detail in the cookie policy related to the website and briefly in the banner and cookie settings center.

    For the website https://www.btdirect.ro/, The cookie policy can be found by also accessing the following link: https://www.btdirect.ro/politica-cookies/.

    If you enter your data on the BT Direct website in various complaint/request forms, applications for BT Direct products/services/campaigns, subscription to newsletters in various fields, we process the data entered in these forms, as applicable, for:

    • the taking of measures/providing information or responses to requests/notifications/complaints of any kind addressed to BT Direct by any person, as well as to those addressed by authorities or institutions, through any channel, including through electronic communications and internet;
    • proving the requests/agreements/options regarding certain aspects requested/discussed/agreed, including in the context of phone calls initiated by you or by BT Direct, by recording the discussed aspects and, if necessary, the audio recording of the phone conversations;
    • the collection of your opinion regarding the quality of BT Direct services/products/employees (service quality evaluation);
    • internal analyses (including statistical);
    • the carrying out of risk controls on BT Direct procedures and processes, as well as the implementation of audit or investigation activities;
    • archiving - both in physical and electronic format - of documents, creating backup copies;
    • the provision of registry and secretariat services regarding the correspondence addressed to BT Direct and/or sent by it, as well as for carrying out courier activities;
    • the security of the information systems used by BT Direct;
    • fraud prevention.

    Please note that subscribing or unsubscribing any email address entered by you in forms/fields named "newsletter", available on the BT Direct website to receive information from various areas of interest, is managed through these online forms (subscription) and respectively from unsubscribe links within the messages received as a result of the subscription (unsubscription).

    c. Categories of personal data processed for visitors of the BT Direct website

    If you visit the BT Direct website we will collect the following categories of personal data:

    • processed data through cookies;
    • IP address;
    • information about the equipment used to access the website.

    Also, within the forms available on the BT Direct website, we collect, as applicable:

    • identification date- name, surname;
    • contact details - email address and/or phone number.

    We draw your attention to the fact that the BT Direct website may contain links to websites whose privacy policy/data processing policy is different from that of BT Direct. Individuals who send personal data to any of these websites should be aware that they are subject to the privacy/data processing policy of those websites, which we recommend be read. The BT Direct policy regarding the processing and protection of personal data does not apply to the information provided on those websites, BT Direct has no control over the personal data processing that the providers of those websites perform for their own purposes and assumes no responsibility regarding these processes.


    5. If you are a potential BT Direct Client (“BT Direct prospect”)

    a. Who is a BT Direct prospect?

    You can have the quality of prospect BT DirectIf you have requested, through the website in its portfolio or through contractual partners of BT Direct information about BT Direct products/services, you have initiated the contracting of these without completing this action or you have subscribed to various campaigns organized by us.

    b. The purposes for which we process the data of BT Direct prospects

    If you are a BT Direct prospect, we process your data, if applicable, for the following purposes:

    • identity verification, in order to confirm/deny the status of BT Direct client;
    • the adoption of measures/providing information or responses to requests/notifications/complaints of any kind addressed to BT Direct by any person, as well as those addressed by authorities or institutions through any channel, including via electronic communication services and the internet;
    • the proof of requests/agreements/options regarding certain aspects requested/discussed/agreed, including in the context of phone calls initiated by you or by BT Direct, by recording the aspects discussed and, if applicable, audio recording of phone conversations or, if applicable, audiovisual;
    • the collection of your opinion regarding the quality of BT Direct services/products/employees (service quality evaluation);
    • internal analyses (including statistical);
    • the carrying out of risk controls on BT Direct procedures and processes, as well as the implementation of audit or investigation activities;
    • archiving- both in physical and electronic format- of documents, creating backups;
    • the provision of registry and secretariat services regarding the correspondence addressed to BT Direct and/or sent by it, as well as for carrying out courier activities;
    • the security of the information systems used by BT Direct;
    • fraud prevention;
    • the calculation of the commissions to which certain categories of employees are entitled.

    c. Categories of personal data processed for BT Direct prospects

    If you are a BT Direct prospect, we usually process you as follows:

    • identification date- name, surname;
    • contact details- email address and/or phone number.
    6. If you are a candidate for available positions at BT Direct or for the conduct of internships organized by it

    a. Who is a BT Direct candidate?  

    You are acandidatefor available positions at BT Direct or for internship organized by BT Direct if you have sent us or if we have received your CV to use it for recruitment purposes, directly from you or from/by the intermediary of other persons, or if you have made us aware in any other way that you are interested in occupying some positions at BT Direct/participating in internships at BT Direct.

    b. The purposes for which we process the data of BT Direct candidates

    We process your data, as applicable, for:

    • recruitment for the position/positions or, as the case may be, for the internship you wish to occupy/follow within BT Direct, as well as for purposes closely related to this activity, such as:
    • the taking of measures/providing information or responses to requests/notifications/complaints of any kind addressed to BT Direct by any person, as well as to those addressed by authorities or institutions, through any channel, including through electronic communications and internet;
    • the proof of requests/agreements/options regarding certain aspects requested/discussed/agreed upon, including during phone calls initiated by you or by BT Direct, by recording the aspects discussed and, if applicable,
    • the audio recording of phone conversations;
    • internal analyses (including statistical);
    • the performance of risk controls on BT Direct procedures and processes, as well as the execution of audit activities or investigations;
    • archiving - both in physical and electronic format - of documents, creating backup copies;
    • provision of registry and secretariat services regarding the correspondence addressed to BT Direct and/or sent by it, as well as for the conduct of courier activities;
    • the security of the information systems used by BT Direct;
    • fraud prevention.

    In case you apply only for a specific position/internship, your personal data will be processed by BT Direct only within the recruitment process for that specific position/internship, and this data will be deleted at the conclusion of the respective recruitment process.

    If, on the other hand, you choose to be contacted generally for vacant positions/internships conducted in BT Direct, we will keep your data and will use it for recruitment purposes for a period of 1 year, a term that can be extended with your consent.

    During the recruitment process, references from previous employers or from teaching staff may become relevant. If we need these, we will contact you to request your permission to obtain these references on your behalf. If you do not express your consent in this regard, you will need to obtain these references yourself if you wish to continue the recruitment process.

    c. Categories of personal data processed for BT Direct candidates

    Candidates of BT Direct we generally process the following categories of personal data, as they are indicated in the CV submitted to/transmitted to BT Direct:

    • identification number - name, surname;
    • age, for the verification of your eligibility to become an employee or, as the case may be, to participate in certain BT Direct internship programs;
    • contact date - email address and/or phone number;
    • date regarding studies and professional experience;
    • any other relevant data from the CV.
    7. If you are a person who addresses BT Direct requests/notifications/complaints through any channel (“BT Direct petitioner”)

    a. Who are you/when do we process your data as a BT Direct petitioner?

    You are such a person if you make any request to BT Direct, through any channel, whether you are a BT Direct client or if you belong to any other category of individuals.

    b. The purposes for which we process the data of BT Direct petitioners

    Depending on the situation and the concrete quality you have in relation to BT Direct, when you send us a request we process your personal data for the following purposes:

    • identity verification, including for the purpose of confirming/denying the client status of BT Direct;
    • the taking of measures/providing information or responses to requests/notifications/complaints of any kind addressed to BT Direct by any person, as well as to those addressed by authorities or institutions, through any channel, including through electronic communications and internet;
    • the proof of requests/agreements/options regarding certain aspects requested/discussed/agreed during the phone calls initiated by you or BT Direct, by recording the discussed aspects and, if applicable, the audio recording of the phone conversations;
    • the collection of your opinion regarding the quality of BT Direct services/products/employees (service quality evaluation);
    • the carrying out of risk controls on BT Direct procedures and processes, as well as the implementation of audit or investigation activities;
    • internal analyses (including statistical);
    • archiving - both in physical and electronic format - of documents, creating backup copies;
    • the provision of registry and secretariat services regarding the correspondence addressed to BT Direct and/or sent by it, as well as for carrying out courier activities;
    • the security of the information systems used by BT Direct;
    • fraud prevention;
    • the calculation of the commissions to which certain categories of employees are entitled.

    c. Categories of personal data processed for BT Direct petitioners

    In order to register, confirm receipt, analyze, formulate and send a response to any requests/notifications/complaints you address to us, we process the following categories of personal data:

    • identification date: name, surname and other data in this category that you provide us or personal data that BT Direct needs to process for the identification of the BT Direct petitioner to prevent the disclosure of confidential information (including personal data) to recipients who are not entitled to receive them;
    • contact information: correspondence address, email address, phone number;
    • the voice, in the context of conversations and recordings of telephone conversations (initiated by petitioners or by BT Direct);
    • according to the case, any other information that BT Direct is aware of and that is necessary for analyzing the requests.
    8. If you are a third natural person whose data we process outside of a direct relationship with BT Direct (“third party BT Direct”)

    Who is/when do we process your data as a third party BT Direct?

    You are included in this category of targeted persons if any personal data concerning you is disclosed/transferred to us by BT Direct clients, in the context of their relationship with us, or by any other person. Your data is processed in this context as a third party of BT Direct, even if you have other direct relationships with us (e.g. a BT Direct loan applicant provides us with the sale-purchase contract of the property where you are listed as the seller. In this case, we will process the data from this contract in your capacity as a third party, even if you are actually also a BT Direct client and we process your data for other purposes related to the contractual relationship you have established with us).

    Thus, as an example, we process your data in your capacity as BT Direct third parties, if you belong to any of the following categories of individuals:

    • members of a BT Direct client family or BT Direct employee- it is possible that, in certain situations, Clients may bring to our attention data related to family members, especially in the context of formulating and analyzing a loan application or carrying out a credit contract.

    At the same time, BT Direct employees may provide data belonging to family members, in various contexts related to their work relationship with us (e.g. minor children of employees, other family members of BT Direct employees);

    • individuals whose data are mentioned on various documents made available by BT Direct– in case a BT Direct client or any person we interact with submits to/transmits to BT Direct various documents, in different situations (e.g. certificates or documents of any type containing personal data of the signatories or, as the case may be, of other persons mentioned in the content of the documents) we will process this data having in mind the necessity to keep these documents, even if we may not need to process the data in any other form than their storage;
    • persons in connection with whom BT Direct receives requests/inquiries for informationfrom various institutions and/or public authorities, from notaries, lawyers, court bailiffs etc.;
    • participants in various events or actions of social responsibility organized by BT Direct, but whose data needs to be processed in order to ensure the logistics of the events;
    • any other categories of natural persons whose personal data is made available to us by any person with whom we interact or who comes into our possession in any other way.

    b. The purposes for which we process third-party data BT Direct

    We process your data as a third party BT Direct based on the purpose necessary in our relationship with the person who provided them to us, as well as for the following related purposes:

    • the management of labor relations with BT Direct employees, as appropriate;
    • the performance of risk controls on BT Direct procedures and processes, as well as the execution of audit activities or investigations;
    • internal analyses (including statistical);
    • archiving - both in physical and electronic format - of documents, creating backup copies;
    • the provision of registry and secretariat services regarding the correspondence addressed to Bt Direct and/or sent by it, as well as for the conduct of courier activities;
    • the security of the information systems used by BT Direct;
    • fraud prevention.

    c. Categories of personal data processed by BT Direct third parties

    The most common dates we process for third parties BT Direct are, for example:

    • identification date - name, surname, personal numeric code (CNP);
    • the relationship between you and a BT Direct client or employee, as appropriate;
    • position held within a legal entity;
    • signature;
    • any other data that is made available to us by any person we interact with in the course of our activities.
    9. If you are a person who has expressed your options regarding the processing of your personal data for advertising purposes on the BT Direct forms (as applicable, consent or refusal)

    a. Who can be the individuals who have expressed their options regarding the processing of their data for advertising purposes (as applicable, consent or refusal)

    Currently, they are considered to be individuals who have expressed themselves at BT Directthe agreement for their personal data to be processed for advertising purposesany of the following categories of targeted persons:

    • BT Direct clients or any BT Direct third parties who have expressed this consent on the dedicated BT Direct form.

    I am currently people who have expressedthe refusal to have their personal data processed for advertising purposes, BT Direct clients or any BT Direct third parties who expressed from the beginning on the dedicated form their refusal for their data to be processed for this purpose, as well as persons who, although they initially expressed an agreement for their data to be processed for advertising purposes, later withdrew this consent.

    b. The purposes for which we process the personal data of individuals who have expressed at BT Direct their options regarding the processing of their data for advertising purposes (as applicable, consent or refusal)

    If you have expressed your consent for your data to be processed for advertising purposes, we will process them as follows:

    • the transmission of advertising messages*, according to the expressed consent (advertising purpose);
    • the verification of individuals' identity, in order to confirm/deny their status as BT Direct Clients;
    • the proof of requests/agreements/options regarding advertising options, by recording the discussed aspects and, where appropriate, audio recording of phone conversations (initiated by BT Direct or by you);
    • internal analyses (including statistical);
    • archiving - both in physical and electronic format - of documents, creating backup copies;
    • the provision of registry and secretariat services regarding the correspondence addressed to BT Direct and/or sent by it, as well as for carrying out courier activities;
    • the security of the information systems used by BT Direct;
    • fraud prevention.

    If you have expressed your refusal regarding the processing of personal data for advertising purposes, we will process your data for all of the above purposes, except for the one regarding the transmission of advertising messages.

    *BT Direct wants to inform interested individuals about the products/services/events offered/organized by it or by BT Direct partners, in which sense it processes the personal data of these individuals, if they have expressed their consent to receive advertising messages.

    c. Categories of personal data processed for individuals who have expressed their consent at BT Direct regarding the processing of their data for advertising purposes, recipients of this data, and the duration of their processing

    The data processed by BT Direct for the purpose of sending advertising messages are usually:

    • identification date: name, surname;
    • contact details: phone number and/or email address or correspondence address provided by BT Direct by Clients interested in receiving advertising messages, recorded in our records and for the purpose of customer knowledge;
    • In the case of BT Direct Clients: other information we learn about clients, in the context of their use of BT Direct services/products (e.g. transaction data, age, location, income range, etc.), which we will study automatically (profiling) to form an opinion related to the products/services/events that would suit them (personalized advertising).

    The personal data will be processed by us for the purpose of sending advertising messages until the termination of the contractual relationship with BT Direct Clients or, as the case may be, until the moment of their withdrawal of consent to receive such messages (the latter variant including in the case of any other categories of individuals who are not BT Direct Clients).

    In some cases, for the transmission of advertising messages, BT Direct will contract service providers, who will process the personal data of the data subjects on behalf of and for BT Direct, only for the transmission of the advertising messages established in strict compliance with BT Direct's instructions and under our close supervision.

    The interested individuals can choose to receive advertising messages from several categories, including: products and services of BT Direct, events organized by BT Direct, products/services of partners that are related to products/services of BT Direct, and events organized by BT Direct partners.

    The list of current partners of BT Direct whose products/services and events are intended to be promoted in advertising messages sent to individuals who have opted for this is accessible at the link:https://www.btdirect.ro/storage/app/media/documente/Privacy-Hub/Parteneri-BT-Direct.pdf.

    In the event that you opted to receive advertising messages about products/services events offered/organized by BT Direct partners, these entities will process personal data for the purpose of transmitting these messages, under the careful supervision and coordination of BT Direct and, where applicable, together with it. For any potential processing of personal data carried out by BT Direct partners outside or adjacent to the transmission of advertising messages, such as, for example, for the purpose of concluding contracts related to their promoted products/services, these partners will act as operators of the processed personal data.

    The agreement to be contacted for advertising purposes can be withdrawn or modified at any time through multiple methods, distinctly indicated on the form dedicated to expressing options related to the processing of personal data for advertising purposes.

    The withdrawal of consent operates only for the future and does not affect the legality of the data processing carried out before the moment of this withdrawal.

    Please note that subscribing or unsubscribing to any email address you enter in the forms/fields labeled "newsletter", available on the BT Direct website to receive information from various areas of interest, is managed through the respective online forms (subscription) and respectively from unsubscribe links contained in the messages received after subscribing (unsubscription).

    We also inform you that subscribing/unsubscribing to/from the "newsletters" that you choose on the BT Direct website does not influence the options regarding the processing of your data for advertising purposes completed on the BT Direct form dedicated to expressing marketing options.

    D. What are the sources from which BT Direct collects personal data?

    Generally, the personal data belonging to the data subjects whose data we process are collected by us directly from them, on various occasions and in various ways, such as:

    • at the time of establishing and during the course of the business relationship with BT Direct;
    • on the occasion of the conclusion and execution of contracts for products/services offered by BT Direct;
    • by completing forms available on the BT Direct website, on other websites owned by other entities in the Group;
    • by registering/participating in various contests/campaigns organized by BT Direct in the units through which you can contract the credits offered by us or on the BT Direct website;
    • when we are requested information / we receive complaints / complaints at the phone numbers of BT Direct, at the address of our headquarters or at the email addresses;
    • when applying for available positions in BT Direct (online, by sending/dropping off CVs at our headquarters or to various email addresses, at career fairs or other events);
    • when visiting the BT Direct website.

    However, there are situations when data is collected from other sources, such as:

    • from co-debtors of the Clients;
    • from BT Direct partners who mediate our lending activity (e.g. Banca Transilvania S.A., partner stores);
    • from authorities or public institutions (e.g. courts, prosecutors, judicial executors, BNR, ANPC, ANSPDCP etc.), notaries, lawyers, in the context in which they send us notifications or requests regarding Clients;
    • from insurance companies;
    • from banks;
    • from international payment organizations;
    • from public sources, such as but not limited to: National Trade Register Office, ANAF, the court portal, the internet etc.;
    • from records such as the Credit Bureau, the Credit Risk Central, in case there is a legal basis and a specific and legitimate purpose for consulting them;
    • from private database providers - e.g. entities authorized to manage databases of individuals accused of financing acts of terrorism and those publicly exposed;
    • from entities within the BT Financial Group, for the purpose of using them for specific and legitimate purposes;
    • from contractual partners;
    • from debt collection companies (e.g. we can obtain the new contact details of Clients from companies that support us in debt recovery activities, data that the latter obtain based on their own interactions with them or with people close to them);
    • from any other natural or legal persons who send us complaints/requests containing Customer data (e.g. persons who inform us that you no longer have the same contact details as those declared in BT Direct records);
    • from entities with which BT Direct merged, such as ERB Retail Services IFN S.A.

     

    E. What are the grounds on which BT Direct processes personal data and the consequences of refusing to have data processed?

    The grounds on which BT Direct processes personal data are, as applicable:

    • the necessity to process data for the fulfillment of a task that serves a public interest;
    • the legal obligation of BT Direct; .
    • the conclusion/implementation of contracts concluded between BT Direct and the data subject;
    • the legitimate interest of BT Direct and/or of third parties;
    • the consent of the data subjects.

    Except in cases where personal data is processed based on the consent of the data subjects, and in some cases where the basis for processing is legitimate interest, the refusal of individuals to have their data processed by BT Direct will make it impossible to provide the requested services or to fulfill their requests.

    F. To whom does BT Direct disclose/transfer the personal data it processes?

    The personal data of BT Direct Clients and, where applicable, other categories of data subjects mentioned in this Policy, are disclosed by BT Direct or, where applicable, transferred, in accordance with the principles of the GDPR, based on the applicable legal grounds depending on the situation and only under conditions that ensure full confidentiality and data security, to categories of recipients, such as, but not limited to:

    • BT Direct partners who mediate our lending activity (e.g. Banca Transilvania S.A., partner stores);
    • alți Clienți care au dreptul și nevoia de a le cunoaște (ex. codebitori);
    • entities within the BT Financial Group;
    • cessionaires;
    • contractual partners (service providers) used by us in the course of our activities, such as but not limited to: IT services (maintenance, software development), archiving in physical and/or electronic format, courier services, auditing, services related to card issuance, etc;
    • international payment organizations (e.g. Mastercard);
    • payment processors;
    • financial-banking entities;
    • authorities and public institutions, such as, but not limited to the National Bank of Romania (BNR), the National Agency for Fiscal Administration (ANAF), the Ministry of Justice, the Ministry of Internal Affairs, the National Office for Preventing and Combating Money Laundering (ONPCSB) including, where applicable, their territorial units;
    • public notaries, lawyers, bailiffs;
    • Credit Risk Center*
    • The Credit Bureau and Participants in the Credit Bureau system**;
    • insurance companies;
    • debt collection companies/debts;
    • entities to which BT Direct has outsourced the provision of services.

    BT Direct has the legal obligation to report to the Central Credit Risks (CRC) the credit risk information for each debtor who meets the condition of being reported, namely to have recorded an individual risk regarding them, as well as information about detected card frauds.

    **BT Direct has the legitimate interest to report in the Credit Bureau System, which is also accessible to other Participants (mainly credit institutions and non-banking financial institutions) the personal data of debtors who record delays in loan payments of at least 30 days, after prior notification of the persons concerned in this regard at least 15 days before the reporting date. Reporting is carried out according to the provisions of the specific information noteInformation regarding the processing of personal data in the records of the Credit Bureau, which is made available to you at the time of making a BT Direct credit application.

    G. For how long does BT Direct process personal data?

    The personal data processed by BT Direct for the purpose of customer verification to prevent money laundering and financing of terrorism, including data regarding the transactions carried out, will be kept for at least 5 years from the date of termination of the business relationship with the customer (termination of the lending relationship). Additionally, in the event that the business relationship is not opened, the data contained in the application will be stored at the level of BT Direct for at least 5 years from the date of rejection of the loan application or, as the case may be, from the date of the customer's withdrawal from the approved loan.

    Regarding the data processed in the Credit Bureau system, they are stored at the level of this institution and disclosed to Participants for 4 years from the date of the last update, except for the data of credit applicants who have withdrawn their credit application or who have not been granted the credit, which are stored and disclosed to Participants for a period of 6 months.

    The personal data for which BT Direct has a legal obligation to report to the Credit Risk Central (CRC) will be kept in the CRC records for a period of 7 years from the date of their registration.

    For the data processed on the basis of the consent of the data subjects for the purpose of sending advertising messages, it will be processed until the termination of the business/contractual relationship with BT Direct or, as the case may be, until the withdrawal of the respective agreement.

    In order to prove that complaints/requests for information/measures have been received and that responses have been formulated and sent to them, the data related to these petitions will be kept in the records of BT Direct (together with the personal data contained in them) both in paper and electronic format, for the duration of the business/contractual relationship for BT Direct clients, respectively for a period necessary to fulfill the purpose for which they were processed (formulating the response/providing information), plus a period of 3 years - the legal statute of limitations in case the data does not belong to BT Direct clients.

    The personal data processed for BT Direct candidates will be kept until the end of the recruitment process for the available position or, in case the candidates have expressed interest in being contacted for more suitable positions, the data from CVs and other documents they made available to BT Direct for this purpose will be kept for a maximum period of 1 year, unless a request for their deletion from our records is made within this time frame. This period may be extended with the candidate's consent.

    Any other personal data processed by BT Direct for other stated purposes will be kept for the period necessary to fulfill the purposes for which they were collected, to which non-excessive terms may be added, established according to the applicable legal obligations in the field, including but not limited to the provisions regarding archiving.

    H. What are the rights of the data subjects that can be exercised in connection with the processing of their data by BT Direct?

    Any targeted person is guaranteed the exercise of the rights provided by the applicable legislation in the field of processing and protection of personal data, namely:

    a) the right of access: the data subjects can obtain from BT Direct confirmation that their personal data is being processed, as well as information regarding the specifics of the processing such as: the purpose, categories of personal data processed, recipients of the data, the period for which the data is kept, the existence of the right to rectification, deletion or restriction of processing. This right allows the data subjects to obtain free of charge a copy of the processed personal data, as well as any additional copies for a fee;

    b) the right to data rectification: the persons concerned can request BT Direct to correct the incorrect data related to them or, as the case may be, to complete the data that is incomplete;

    c) the right to erasurethe data subjects can request the deletion of their personal data when:

    • these are no longer necessary for the purposes for which we have collected and processed them;
    • the consent for the processing of personal data has been withdrawn and BT Direct can no longer process them on other grounds;
    • personal data is processed contrary to the law;
    • Personal data must be deleted in accordance with relevant legislation.

    d) the right to withdraw consentThe persons concerned may withdraw their consent regarding the processing of personal data processed on the basis of consent at any time. The withdrawal of consent does not affect the legality of the processing carried out before this moment.

    e) right of opposition: the persons concerned may oppose at any time the processing for marketing purposes, as well as the processing based on the legitimate interest of BT Direct, for reasons related to their specific situation;

    f) the right to restrict processingthe data subjects may request the restriction of the processing of their personal data if:

    • verify the accuracy of personal data, for a period that allows us to check the accuracy of the data in question;
    • the processing is illegal, and the data subject opposes the deletion of personal data, requesting instead the restriction of their use;
    • the data is no longer necessary for processing, but the data subject requests them for a legal action;
    • in case the data subject has opposed processing, for the period of time in which it is verified whether the legitimate rights of BT Direct as the operator prevail over the rights of the data subject.

    g) the right to data portability: individuals concerned may request, under the law, that BT Direct provide them with certain personal data in a structured, commonly used, and machine-readable format. If the individuals concerned request, BT Direct may transmit the respective data to another entity, if technically feasible;

    h) the right to object to an automated individual decision;  

    i) the right to file a complaint with the National Supervisory Authority for Personal Data Processing: the persons concerned have the right to lodge a complaint with the National Authority for the Supervision of Personal Data Processing in case they believe their rights have been violated: National Authority for the Supervision of Personal Data Processing, B-dul G-ral. Gheorghe Magheru 28-30 Sector 1, postal code 010336 Bucharest, Romania,anspdcp@dataprotection.ro.

    For the exercise of the rights mentioned in points a) – h) above, or for any questions about the processing of personal data carried out by BT Direct, the data subjects can use the contact details of the data protection officer designated by our company, by sending the request:

    • by postal way, to the address fromMun. Cluj-Napoca, Bdul. 21 December 1989, nr. 77, The Office, Building C-D, ground floor, county Cluj, with the mention "to the attention of the data protection officer"
    • at the email addressdpo@btdirect.ro.

     

    I. How does BT Direct protect the personal data it processes?

    BT Direct develops an internal framework of standards and policies to maintain the security of personal data. These are updated periodically to comply with applicable regulations and the highest standards in the field.

    Specifically and in accordance with the law, BT Direct adopts and implements appropriate technical and organizational measures (policies and procedures, cybersecurity, etc.) to ensure the confidentiality and integrity of personal data and how it is processed.

    BT Direct employees have the obligation to maintain confidentiality and cannot illegally disclose personal data that they process in the course of their activities.

    BT Direct ensures that its contractual partners who have access to personal data and who act as a representative of BT Direct are imposed contractual obligations in accordance with legal provisions and that it verifies their compliance with the obligations they have assumed.

    The contractual partners acting as the authorized representative of BT Direct will process personal data on behalf of and for us, only in accordance with the instructions received from BT Direct and only respecting the security and confidentiality requirements within the imposed limits.

    We guarantee that BT Direct will not sell the personal data it has collected from visited persons and that it will not disclose this data except to those entitled to know it, in compliance with the principles and legal obligations established.

    The present policy is reviewed regularly to guarantee the rights of the data subjects and to improve the ways of processing and protecting personal data.

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