Privacy Policy

1. Scope of this Privacy Policy

This Privacy Policy applies when BTB processes personal data in connection with:

• website use;
• service requests;
• ferry booking requests;
• customs, transit, ENS / ICS2, CHED, veterinary, phytosanitary or other documentation support;
• port, terminal, ferry, rail or operational coordination;
• payment processing;
• invoices, payment requests or payment links;
• email, phone, SMS, website form, app, messenger or other communications;
• document exchange;
• customer support;
• accounting, legal, compliance and administrative activities.

This Privacy Policy applies to personal data of Clients, company representatives, drivers, carriers, contact persons, partners, suppliers, website visitors and other persons whose data may be provided to BTB in connection with a request or service.

2. Categories of personal data we may process

Depending on the service and interaction, BTB may process the following categories of personal data:

• name and surname;
• company name and role / position;
• email address;
• phone number;
• billing details;
• contact details;
• correspondence and communication history;
• service request details;
• booking request details;
• payment references and invoice information;
• bank transfer details, where applicable;
• vehicle and trailer plate numbers;
• vehicle registration information;
• driver name and contact details;
• driver passport or ID details, where required for the service;
• transport documents;
• CMR data;
• bill of lading data;
• invoice and packing list data;
• consignee and consignor contact data;
• customs, transit, ENS / ICS2, CHED or other declaration references;
• MRN or other operational references;
• cargo-related documents that may include personal data;
• document-sharing links or files sent to BTB;
• website technical data, such as IP address, browser type, device information and usage data;
• cookie-related data, as described in the Cookie Policy;
• messenger username, profile name or other messenger identifier, where available;
• selected communication channel, such as Telegram or Viber;
• lead-generation form or request-source information;
• messages, files and communication history submitted through lead-generation, CRM or messaging tools used by BTB;
• any other personal data voluntarily provided to BTB or required for the requested service.

BTB does not request unnecessary personal data. The Client should not provide personal data that is not required for the requested service.

3. Personal data provided by Clients about other persons

In many logistics, customs, ferry, port and transport operations, the Client may provide personal data about other persons, including drivers, company representatives, carriers, consignors, consignees or operational contacts.

The Client is responsible for ensuring that such personal data is provided lawfully and that the relevant persons are informed, where required, that their data may be shared with BTB and processed for the requested service.

The Client should provide only personal data that is necessary, accurate, complete and relevant for the service.

BTB may rely on personal data and documents provided by the Client for the purpose of performing the requested service.

4. Purposes of processing

BTB may process personal data for the following purposes:

• responding to service requests;
• identifying the Client and contact person;
• reviewing documents and information provided by the Client;
• preparing, processing or coordinating requested services;
• providing customs, transit, ENS / ICS2, CHED, veterinary, phytosanitary, port, terminal, ferry, rail or logistics support;
• coordinating ferry booking requests;
• communicating with Clients, drivers, carriers, operators, agents, authorities and third parties;
• issuing invoices, proforma invoices, payment requests or payment links;
• processing and confirming payments;
• providing service updates, instructions, confirmations or references;
• handling cancellations, refunds, complaints or disputes;
• maintaining accounting and tax records;
• complying with legal, regulatory, customs, tax, accounting or authority requirements;
• protecting BTB’s rights and legitimate interests;
• preventing fraud, misuse, unauthorized access or payment abuse;
• improving website functionality, security and user experience;
• maintaining records of communications and services.

5. Legal bases for processing

Depending on the situation, BTB may process personal data based on one or more of the following legal bases:

• performance of a contract or steps taken before entering into a contract;
• compliance with legal obligations;
• legitimate interests pursued by BTB or a third party;
• consent, where required by applicable law;
• establishment, exercise or defence of legal claims;
• protection of vital interests, only in exceptional situations where applicable.

BTB’s legitimate interests may include providing requested services, coordinating logistics operations, communicating with Clients and third parties, preventing fraud, maintaining records, protecting legal rights, managing disputes and ensuring website and payment security.

Where processing is based on consent, the person may withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

6. Payment data and NETOPIA Payments

BTB may process payment-related information such as invoice number, payment reference, payment amount, payment status, transaction reference, payer name, company details and payment confirmation.

Online card payments are processed through NETOPIA Payments.

BTB does not store full card details.

Card data, payment authorization, 3D Secure checks, fraud prevention checks, payment confirmation and refund processing may be handled by NETOPIA Payments, banks, card issuers, card schemes and other payment infrastructure providers according to their own legal obligations and privacy terms.

BTB may receive payment status, transaction references and other payment-related confirmations required to identify, reconcile and process the payment.

7. Website data and cookies

When a person visits the BTB website, BTB may process technical data such as IP address, browser type, device information, pages visited, date and time of access and other technical information needed for website security, functionality and analytics.

Cookies and similar technologies may be used for website operation, security, preferences, analytics or other purposes described in the Cookie Policy.

More information about cookies is provided in the separate Cookie Policy.

8. Communication channels

BTB may communicate and exchange information through digital and operational communication channels, including:

• email;
• website forms;
• BTB app or online request flows;
• online payment or booking flows;
• messaging applications;
• SMS;
• phone communication;
• document-sharing links;
• electronic files;
• other communication channels agreed or used with the Client.

Personal data may be processed through these channels when needed to handle requests, provide services, send confirmations, request missing documents, provide operational instructions, process payments or handle complaints.

The Client is responsible for providing correct contact details and monitoring the communication channels used for the service.

8.1. Leeloo.ai, Telegram and Viber

BTB may use Leeloo.ai and related lead-generation, CRM and messaging functionality to receive, route, organize and manage service requests submitted by Clients or website visitors.

When a person submits information through a BTB lead-generation form or chooses to continue communication through Telegram or Viber, BTB may process the information submitted through the form, the selected communication channel, messenger-related identifiers where available, communication history, service request details and files or documents voluntarily provided by the person.

BASARABIA TRANSIT BRIDGE S.R.L. remains the data controller for personal data processed for BTB service requests. Where Leeloo.ai processes personal data on behalf of BTB for the provision of lead-generation, CRM, messaging or related technical functionality, it acts as a service provider / data processor in relation to such processing.

Telegram and Viber are independent third-party communication platforms. Where a person chooses to communicate with BTB through Telegram or Viber, personal data may also be processed by the relevant platform according to its own terms, privacy policy and technical operation.

Information received through these channels may be used to identify and respond to the request, communicate with the Client, determine the requested service, request missing information or documents, maintain communication history and, where appropriate, create or manage a BTB service request.

Service-request information collected through these channels is not used by BTB for unrelated direct marketing unless BTB has another applicable lawful basis or obtains separate consent where required by law.

9. Recipients of personal data

Depending on the service, BTB may share personal data with:

• customs authorities;
• competent authorities;
• veterinary, phytosanitary or inspection bodies;
• port operators;
• terminal operators;
• ferry operators;
• rail operators;
• shipping lines;
• carriers and transport companies;
• freight forwarders and logistics partners;
• agents and subcontractors;
• banks and payment processors;
• NETOPIA Payments;
• accounting providers;
• legal advisors;
• IT, hosting, website, email, app, security and communication service providers;
• Leeloo.ai and other lead-generation, CRM or messaging infrastructure providers used by BTB;
• Telegram and Viber, where the Client chooses the relevant platform as a communication channel;
• courier or document delivery providers, where applicable;
• public authorities, courts, enforcement authorities or regulators where required by law.

BTB shares personal data only where reasonably necessary for the requested service, payment processing, legal compliance, accounting, dispute resolution, fraud prevention or protection of BTB’s rights.

10. International transfers

Some BTB services may involve routes, partners, operators, authorities, ports, terminals, carriers or agents located outside the European Economic Area.

This may include, depending on the route and service, countries such as Moldova, Ukraine, Turkey, Georgia, Serbia, North Macedonia or other countries involved in the transport, ferry, customs, transit or logistics operation.

Where personal data must be transferred outside the European Economic Area, BTB will do so only where necessary for the requested service or where another lawful transfer mechanism is available under applicable data protection rules.

The Client understands that international transport and logistics services may require sharing certain personal data with non-EEA authorities, operators, agents, carriers or partners in order to perform the requested service.

Some digital communication, CRM, lead-generation or messaging service providers used by BTB may process or store personal data in countries outside the European Economic Area. Where applicable, BTB will use or rely on an appropriate lawful transfer mechanism or other safeguard required under applicable data protection law.

11. Data retention

BTB keeps personal data only for as long as necessary for the purposes for which it was collected.

Retention periods may depend on:

• service status;
• contract or request status;
• accounting and tax obligations;
• customs, transport or authority requirements;
• payment and refund processing;
• complaint or dispute handling;
• legal limitation periods;
• fraud prevention and security needs;
• legal, regulatory or operational obligations.

When personal data is no longer required, BTB may delete, anonymize or archive it according to applicable rules and internal procedures.

12. Data security

BTB applies reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration or disclosure.

Such measures may include access controls, secure communication practices, limited internal access, document handling procedures, IT security measures and service provider controls.

However, no electronic communication, website, email, messaging application, payment system or digital transmission can be guaranteed to be completely secure.

Clients should avoid sending unnecessary personal data and should use secure communication channels where possible.

13. Data subject rights

Subject to applicable law and conditions, individuals may have the following rights regarding their personal data:

• right of access;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to object to processing;
• right to data portability;
• right to withdraw consent, where processing is based on consent;
• right to lodge a complaint with the competent data protection authority.

Requests regarding personal data may be sent to: info@bt-bridge.com

BTB may request additional information to verify the identity of the person making the request and to locate the relevant data.

BTB will respond to data protection requests within the time required by applicable law.

14. Complaints to the data protection authority

If a person believes that BTB processes personal data in breach of applicable data protection rules, that person may contact BTB first at: info@bt-bridge.com

The person may also have the right to lodge a complaint with the competent supervisory authority.

In Romania, the competent supervisory authority is the National Supervisory Authority for Personal Data Processing — Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP).

15. Accuracy of personal data

The Client must ensure that personal data and documents provided to BTB are accurate, complete and up to date.

If any personal data changes or is incorrect, the Client should inform BTB as soon as possible.

BTB is not responsible for service delays, incorrect filings, booking issues, payment issues, failed communication or operational consequences caused by incorrect, incomplete or outdated personal data provided by the Client.

16. Children’s data

BTB services are intended for business, logistics, customs, transport, ferry and related operational purposes.

BTB does not knowingly request or intentionally process personal data of children through its services.

If BTB becomes aware that children’s personal data has been provided without a valid reason or lawful basis, BTB may delete or restrict such data where appropriate.

17. Automated decision-making

BTB does not use personal data for automated decision-making that produces legal effects concerning individuals or similarly significantly affects them.

Some payment, fraud prevention, security, banking or card authorization checks may be performed by payment processors, banks, card issuers or other payment infrastructure providers according to their own rules and privacy terms.

18. Changes to this Privacy Policy

BTB may update this Privacy Policy from time to time.

The updated version will be published on the BTB website and will indicate the effective date.

Clients and website visitors are encouraged to review this Privacy Policy periodically.

Continued use of the website or BTB services after publication of an updated Privacy Policy may be considered acceptance of the updated version, where permitted by applicable law.