PRIVACY POLICY
PRIVACY AND PERSONAL DATA PROTECTION POLICY
Last updated: 23 August 2026
1. GENERAL PROVISIONS
E-BROKER SYSTEM SRL attaches particular importance to protecting the privacy and security of the personal data of its clients, their representatives, website users, and other persons with whom the Company interacts in connection with the provision of customs and related services.
This Privacy Policy describes how E-BROKER SYSTEM SRL collects, uses, discloses, stores and protects personal data, as well as the rights of data subjects.
Personal data is processed in accordance with:
Law No. 195/2024 of the Republic of Moldova on the Protection of Personal Data;
Customs Code of the Republic of Moldova No. 95/2021;
applicable tax, accounting and customs legislation;
other legislation applicable to the activities of E-BROKER SYSTEM SRL.
This Policy applies, in particular, to personal data collected through the www.e-broker.md website, electronic forms, the Personal Account, electronic correspondence, and in connection with the provision of customs representation and assistance services.
2. PERSONAL DATA CONTROLLER
The controller of personal data is:
E-BROKER SYSTEM SRL
IDNO: 1016600013859
Republic of Moldova, Chișinău Municipality
Business/contact address: MD-2037, 69 Industrială Street, Office 205
E-mail: office@e-broker.md
Website: www.e-broker.md
For any questions concerning the processing of personal data or for the exercise of rights provided by law, data subjects may contact:
3. CATEGORIES OF DATA SUBJECTS
E-BROKER SYSTEM SRL may process personal data relating to:
individual clients;
administrators, employees and representatives of corporate clients;
exporters, importers and consignees of goods;
carriers and drivers of means of transport;
persons authorised to represent clients;
suppliers and contractual partners;
persons whose personal data appears in commercial, transport or customs documents;
users of the www.e-broker.md website;
users of the Personal Account;
persons requesting information, consultations or services through electronic forms, e-mail, telephone or other communication channels.
4. PERSONAL DATA WE PROCESS
Depending on the service requested and the applicable legal requirements, E-BROKER SYSTEM SRL may process the following categories of personal data.
4.1. Identification data
Including:
first name and surname;
IDNP (Personal Identification Number);
series and number of the identity document, where such information is necessary for customs formalities;
signature;
information concerning authorisation and representation;
other identification data required for customs formalities.
4.2. Contact data
Including:
telephone number;
e-mail address;
postal address, residential address or delivery address, where necessary for the requested operation.
4.3. Data relating to legal entities and their representatives
Including:
company name;
IDNO/tax identification number;
position of the contact person;
details of administrators or representatives;
details of authorised persons;
professional contact details.
4.4. Data relating to customs and commercial operations
Information contained in the following documents may be processed:
customs declarations;
commercial invoices;
packing lists;
AWBs;
CMR consignment notes;
contracts;
orders and order confirmations;
payment documents;
banking documents required to substantiate the transaction value;
certificates of origin;
permits and other authorisation documents;
licences and certificates;
transport documents;
powers of attorney and other authorisations;
correspondence relating to the customs operation;
screenshots or other evidence relating to the purchase of goods;
documents and information requested by the Customs Service of the Republic of Moldova or other competent authorities.
4.5. Data relating to means of transport
Depending on the operation, this may include:
registration number of the tractor unit and/or trailer;
information contained in CMR documents;
information about the carrier;
information required for customs declaration or transit procedures.
4.6. Technical data
When using the website or Personal Account, certain technical information may be processed automatically, including:
IP address;
date and time of access;
information about the browser and device used;
technical and security logs;
authentication-related information;
information necessary to prevent unauthorised access and identify security incidents.
5. DATA CONTAINED IN UPLOADED DOCUMENTS
Users may submit documents required for the provision of customs services through the forms available on www.e-broker.md.
Such documents may contain personal data relating both to the applicant and to other persons.
The person submitting the documents should provide only information that is relevant and necessary for the requested service and should avoid providing excessive personal data that is not required for the relevant procedure.
Where submitted documents contain special categories of personal data, such data will only be processed to the extent necessary and where an appropriate legal basis for such processing exists.
6. PURPOSES OF PERSONAL DATA PROCESSING
E-BROKER SYSTEM SRL primarily processes personal data for the following purposes.
6.1. Provision of customs services
Including:
preparation of import and export customs declarations;
preparation of H1 and H6 declarations;
customs transit operations;
representation of clients before the Customs Service of the Republic of Moldova;
tariff classification of goods;
determination of customs value;
analysis of commercial and customs documents;
customs consultancy;
assistance with permits and authorisation documents;
preparation of documents required for customs procedures;
communication with competent authorities.
6.2. Entering into and performing contractual relationships
Personal data may be processed for:
identification of the client;
preparation and performance of contracts;
management of requests;
invoicing for services;
keeping records of operations;
communication with the client.
6.3. Compliance with legal obligations
E-BROKER SYSTEM SRL, acting as a customs representative, is required to retain and provide certain documents and information to competent authorities in the cases and for the periods prescribed by law.
6.4. Management of the Personal Account
Personal data may be used for:
creation of the client's account;
authentication;
verification of the user's identity;
access to the archive of documents and declarations;
secure exchange of documents;
management of access rights;
account security.
6.5. Communication
Personal data may be used to respond to:
requests submitted through website forms;
requests for consultation;
e-mail messages;
telephone enquiries;
enquiries submitted through other available communication channels.
6.6. Information systems security
Technical data may be processed for:
protecting the website and Personal Account;
preventing unauthorised access;
detecting attempted fraud;
identifying technical incidents;
protecting IT infrastructure and client documents.
6.7. Protection of the Company's rights and legitimate interests
Including:
establishing, exercising or defending legal claims;
handling complaints and disputes;
preventing fraud;
maintaining records of operations performed.
7. LEGAL BASIS FOR PROCESSING
Depending on the circumstances, personal data is processed on one or more of the following legal grounds.
Performance of a contract or steps taken prior to entering into a contract
Where processing is necessary to provide a service requested by the client.
Compliance with a legal obligation
Where E-BROKER SYSTEM SRL is required to process or retain certain information in accordance with customs, tax, accounting or other applicable legislation.
Legitimate interests of E-BROKER SYSTEM SRL
For example:
ensuring information systems security;
preventing fraud;
managing client relationships;
protecting the Company's rights;
maintaining records necessary for the Company's activities.
Legitimate interests will only be relied upon where such interests are not overridden by the fundamental rights and freedoms of the data subject.
Consent
Consent is used as a legal basis only where required by law or where the relevant processing cannot be based on another lawful ground.
The data subject may withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal.
8. MANDATORY NATURE OF CERTAIN DATA
Certain information is mandatory under applicable legislation or necessary for the performance of the requested customs service.
Without such information, E-BROKER SYSTEM SRL may be unable to:
identify the represented person;
verify commercial documents;
prepare a customs declaration;
submit documents to customs authorities;
provide the requested service.
Therefore, failure to provide mandatory information may result in the inability to provide the relevant service.
9. RECIPIENTS OF PERSONAL DATA
E-BROKER SYSTEM SRL does not sell or trade personal data.
Where necessary and permitted by law, personal data may be disclosed to:
the Customs Service of the Republic of Moldova;
other competent public authorities and institutions;
institutions involved in issuing permits or certificates;
postal operators and carriers, where necessary for the relevant operation;
IT, hosting, maintenance and cybersecurity service providers;
e-mail and communications service providers;
accounting or legal service providers;
courts, law enforcement bodies or other public authorities in cases provided by law;
other processors providing services necessary for the activities of E-BROKER SYSTEM SRL.
Persons processing personal data on behalf of E-BROKER SYSTEM SRL are required to comply with the confidentiality and security requirements established by applicable legislation and contractual arrangements.
10. GOOGLE reCAPTCHA
To protect electronic forms against automated messages, spam and abusive use, the www.e-broker.md website uses Google reCAPTCHA.
When this service is used, Google may process certain technical data, including the user's IP address, device information and information about the user's interaction with the website.
The use of reCAPTCHA is subject to Google's applicable Privacy Policy and Terms of Service.
11. TRANSFERS OF PERSONAL DATA OUTSIDE THE REPUBLIC OF MOLDOVA
In connection with the use of certain technological services provided by international service providers, some technical data may be processed using infrastructure located outside the Republic of Moldova.
In such circumstances, E-BROKER SYSTEM SRL takes appropriate measures to ensure that personal data is transferred in accordance with applicable data protection legislation and subject to appropriate safeguards.
12. PERSONAL ACCOUNT AND ACCESS SECURITY
The Personal Account is an electronic environment intended for clients of E-BROKER SYSTEM SRL and may contain documents and information relating to customs operations.
Additional authentication and security mechanisms may be used to reduce the risk of unauthorised access.
Users are responsible for:
keeping their login credentials confidential;
not disclosing passwords or other authentication methods to third parties;
informing E-BROKER SYSTEM SRL if they suspect unauthorised access to their account.
13. PERSONAL DATA RETENTION PERIOD
E-BROKER SYSTEM SRL retains personal data only for as long as necessary for the purposes for which it was collected and to comply with applicable legal obligations.
Documents relating to customs operations
Such documents are retained for the period prescribed by applicable customs legislation, generally for at least 5 years, or for a longer period where required by law or where an inspection, dispute or other relevant proceeding is ongoing.
Contractual, accounting and tax documents
These are retained for the periods prescribed by applicable accounting, tax and archiving legislation.
Requests that do not result in the provision of a service
Relevant data may be retained for a reasonable period, generally up to 12 months, for the purposes of handling the request and protecting the Company's legitimate interests, after which it will be deleted or anonymised unless another legal basis requires its continued retention.
Information systems security data
Technical logs may be retained for the period necessary to identify and investigate security incidents in accordance with internal security policies.
Following expiry of the applicable retention periods, personal data will be deleted, destroyed, anonymised or archived in accordance with applicable law.
14. SECURITY MEASURES
E-BROKER SYSTEM SRL applies technical and organisational measures appropriate to the risks associated with the processing of personal data.
Such measures may include:
access controls;
individual user accounts;
additional authentication for access to certain systems;
restriction of employee access according to job responsibilities;
data backups;
protection of IT infrastructure;
monitoring of security events;
confidentiality obligations for employees and contractors;
internal procedures for handling security incidents;
updating and maintaining information systems.
Access to personal data is granted only to persons who require such access for the performance of their professional duties.
15. RIGHTS OF DATA SUBJECTS
Subject to the conditions established by Law No. 195/2024, a data subject may have the following rights.
Right to information
The right to receive clear information about how personal data is processed.
Right of access
The right to obtain confirmation as to whether E-BROKER SYSTEM SRL processes the person's personal data and to obtain access to such data.
Right to rectification
The right to request correction of inaccurate personal data and completion of incomplete data.
Right to erasure
A data subject may request the deletion of personal data in the circumstances provided by law.
This right is not absolute.
Personal data cannot be deleted where its continued retention is necessary to comply with a legal obligation, establish, exercise or defend legal claims, or in other circumstances provided by law.
Right to restriction of processing
In the circumstances provided by law, the data subject may request temporary restriction of the processing of their personal data.
Right to data portability
Where provided by law, the data subject may request to receive their personal data in a structured, commonly used and machine-readable format.
Right to object
The data subject may object to certain processing based on the controller's legitimate interests, subject to the conditions provided by law.
Right to withdraw consent
Where processing is based on consent, the data subject may withdraw that consent at any time.
Right not to be subject to solely automated decision-making
The data subject is entitled to the protection provided by law in relation to decisions based solely on automated processing that produce legal effects concerning them or similarly significantly affect them.
16. AUTOMATED DECISION-MAKING
In the ordinary course of providing customs services through www.e-broker.md, E-BROKER SYSTEM SRL does not use decision-making based solely on automated processing that produces legal effects concerning the client or similarly significantly affects the client.
IT tools used for document management, security or to assist employees do not replace the professional assessment of the persons responsible for providing the relevant service.
17. EXERCISE OF DATA SUBJECT RIGHTS
To exercise their rights, a data subject may submit a request to:
The request must enable identification of the applicant and indicate the right the applicant wishes to exercise.
E-BROKER SYSTEM SRL may request additional information where necessary to verify the applicant's identity and prevent disclosure of personal data to an unauthorised person.
Requests will be handled within the time limits and in accordance with the procedures established by applicable legislation.
18. RIGHT TO LODGE A COMPLAINT
If a person considers that their personal data is being processed in breach of applicable legislation, they have the right to lodge a complaint with:
The National Centre for Personal Data Protection of the Republic of Moldova
and may also apply to a competent court in accordance with applicable law.
The exercise of the right to lodge a complaint does not prevent the person from first contacting E-BROKER SYSTEM SRL in an attempt to resolve the matter.
19. PERSONAL DATA OF OTHER PERSONS PROVIDED BY THE CLIENT
Where a client provides E-BROKER SYSTEM SRL with personal data relating to another person — for example, an administrator, employee, driver, representative, consignee, consignor or authorised person — the client must ensure that there is a lawful basis for providing such information.
E-BROKER SYSTEM SRL will use such data only to the extent necessary to provide the requested service and comply with applicable legal obligations.
20. PERSONAL DATA RELATING TO MINORS
The services of E-BROKER SYSTEM SRL are not specifically intended for minors.
Where processing of a minor's personal data is necessary for a particular customs operation, such processing will only take place on an appropriate legal basis and, where required, through the minor's legal representative.
21. COOKIES AND SIMILAR TECHNOLOGIES
The www.e-broker.md website may use cookies and similar technologies necessary for:
technical operation of the website;
security of electronic forms;
authentication;
maintaining user sessions;
preventing automated or fraudulent access.
Where analytics, marketing or other cookies or technologies requiring consent under applicable legislation are used, they will only be activated in accordance with the applicable legal requirements.
Additional information about the specific categories of cookies used may be provided in a separate Cookie Policy available on the website.
22. LINKS TO EXTERNAL WEBSITES
The www.e-broker.md website may contain links to websites operated by public authorities, partners or other third parties.
E-BROKER SYSTEM SRL does not control how such external websites process personal data.
Users are advised to review the privacy policy of the relevant external operator before providing personal data.
23. CHANGES TO THIS PRIVACY POLICY
E-BROKER SYSTEM SRL may update this Privacy Policy from time to time, including where:
applicable legislation changes;
the services provided change;
new systems or technologies are introduced;
personal data processing practices change.
The current version of this Policy will be published on www.e-broker.md, indicating the date of the latest update.
In the event of significant changes, E-BROKER SYSTEM SRL may also use other reasonable means to inform data subjects.
24. CONTACT INFORMATION
For any questions regarding this Policy or the processing of personal data, please contact:
E-BROKER SYSTEM SRL
IDNO: 1016600013859
MD-2037, 69 Industrială Street, Office 205
Chișinău Municipality, Republic of Moldova
E-mail: office@e-broker.md
Website: www.e-broker.md
By using the services of E-BROKER SYSTEM SRL and submitting personal data through www.e-broker.md, the data subject confirms that they have been given the opportunity to review this Privacy Policy.
Last updated: 23 August 2026