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Privacy Policy

1. General Provisions

This personal data processing policy has been drafted in accordance with the requirements of the Law “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by BEST CARGO SRL (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator’s Policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://bestcargo.md.

2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://bestcargo.md.

2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data – actions as a result of which it becomes impossible to determine, without the use of additional information, the ownership of personal data to a specific User or other subject of personal data.

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator – a state body, municipal body, legal entity or individual, independently or jointly with other persons, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data – any information relating directly or indirectly to an identified or identifiable User of the website https://bestcargo.md.

2.9. Personal data authorized for dissemination by the subject of personal data – personal data, access to which is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data authorized for dissemination in the manner prescribed by the Personal Data Law (hereinafter – personal data authorized for dissemination).

2.10. User – any visitor to the website https://bestcargo.md.

2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.

2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data – any actions as a result of which personal data is destroyed irretrievably with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material media of personal data are destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right:

  • to receive from the subject of personal data reliable information and/or documents containing personal data;
  • in the event that the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
  • independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other laws.

3.2. The Operator is obliged to:

  • provide, upon request, the subject of personal data with information concerning the processing of his/her personal data;
  • organize the processing of personal data in accordance with the procedure established by the current legislation of the Republic of Moldova;
  • respond to appeals and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
  • report to the authorized body for the protection of the rights of subjects of personal data, upon request of this body, the necessary information within 30 days from the date of receipt of such a request;
  • publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
  • take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
  • stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
  • fulfill other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Subjects of personal data have the right:

  • to receive information concerning the processing of their personal data, except in cases provided for by laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
  • to demand from the Operator the clarification of their personal data, blocking or destruction of it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
  • to impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
  • to withdraw consent to the processing of personal data;
  • to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
  • to exercise other rights provided for by the legislation of the Republic of Moldova.

4.2. Subjects of personal data are obliged to:

  • provide the Operator with accurate data about themselves;
  • inform the Operator about the clarification (updating, modification) of their personal data.

4.3. Persons who have transmitted to the Operator inaccurate information about themselves, or information about another subject of personal data without the latter’s consent, shall be liable in accordance with the legislation of the Republic of Moldova.

5. The Operator May Process the Following Personal Data of the User

5.1. Last name, first name, patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. Year, month, date and place of birth.

5.5. The website also collects and processes anonymized data about visitors (including “cookie” files) using Internet statistics services (Yandex Metrica and Google Analytics, among others).

5.6. The above-listed data are hereafter collectively referred to as Personal Data in the Policy.

5.7. The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, or intimate life.

5.8. Processing of personal data authorized for dissemination from among the special categories of personal data specified in part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions provided for in Article 10.1 of the Personal Data Law are observed.

5.9. The User’s consent to the processing of personal data authorized for dissemination is drawn up separately from other consents to the processing of his/her personal data. The conditions provided for, in particular, in Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.9.1 The User provides consent to the processing of personal data authorized for dissemination directly to the Operator.

5.9.2 The Operator is obliged, no later than three working days from the moment of receiving the said User’s consent, to publish information on the processing conditions, on the existence of prohibitions and conditions for the processing of personal data authorized for dissemination by an unlimited circle of persons.

5.9.3 The transfer (dissemination, provision, access) of personal data authorized for dissemination by the subject of personal data must be terminated at any time at the request of the subject of personal data. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the subject of personal data, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator to whom it is sent.

5.9.4 Consent to the processing of personal data authorized for dissemination terminates upon the Operator’s receipt of the request specified in clause 5.9.3 of this Policy regarding the processing of personal data.

6. Principles of Personal Data Processing

6.1. The processing of personal data is carried out on a lawful and fair basis.

6.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.

6.3. Merging databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.

6.4. Only personal data that meet the purposes of their processing are subject to processing.

6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Processed personal data should not be excessive in relation to the stated purposes of their processing.

6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

6.7. Personal data is stored in a form that allows identifying the subject of personal data for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by law.

7. Purposes of Personal Data Processing

7.1. Purpose of processing the User’s personal data:

  • informing the User by sending emails.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending the Operator an email to info@bestcargo.md with the subject line “Opt-out of notifications about new products, services, and special offers”.

7.3. Anonymized User data collected using Internet statistics services serves to gather information about User actions on the site, improve the quality of the site, and its content.

8. Legal Grounds for Processing Personal Data

8.1. The legal grounds for processing personal data by the Operator are:

  • the Operator’s statutory (founding) documents;
  • contracts concluded between the Operator and the subject of personal data;
  • laws and other regulatory legal acts in the field of personal data protection;
  • Users’ consents to the processing of their personal data, to the processing of personal data authorized for dissemination.

8.2. The Operator processes the User’s personal data only if it is filled in and/or sent by the User independently through special forms located on the website https://bestcargo.md or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.

8.3. The Operator processes anonymized data about the User if this is allowed in the User’s browser settings (saving of “cookie” files and the use of JavaScript technology are enabled).

8.4. The subject of personal data independently decides to provide their personal data and gives consent freely, by their own will, and in their interest.

9. Conditions for Processing Personal Data

9.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.

9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty or law, to exercise the functions, powers, and duties assigned by the legislation of the Republic of Moldova to the operator.

9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Republic of Moldova on enforcement proceedings.

9.4. The processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.

9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.

9.6. Processing of personal data is carried out, access to which is provided to an unlimited number of persons by the subject of personal data or at their request (hereinafter – publicly available personal data).

9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with the law is carried out.

10. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

10.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator via email at info@bestcargo.md with the subject line “Update of personal data”.

10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by the contract or current legislation. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator’s email address info@bestcargo.md with the subject line “Withdrawal of consent to the processing of personal data”.

10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently review these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

10.6. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination, do not apply in cases of processing personal data in state, public, and other public interests determined by the legislation of the Republic of Moldova.

10.7. The Operator ensures the confidentiality of personal data during their processing.

10.8. The Operator stores personal data in a form that allows identifying the subject of personal data for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.

10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, or the withdrawal of consent by the subject of personal data, as well as the detection of unlawful processing of personal data.

11. List of Actions Performed by the Operator with the Obtained Personal Data

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

11.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

12. Cross-Border Transfer of Personal Data

12.1. Prior to commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the transfer of personal data is intended provides reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may only be carried out if there is written consent from the subject of personal data for the cross-border transfer of their personal data and/or the performance of a contract to which the subject of personal data is a party.

13. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by law.

14. Final Provisions

14.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at info@bestcargo.md.

14.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until replaced by a new version.

14.3. The current version of the Policy is freely available on the Internet at https://bestcargo.md/privacy-policy.