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Personal data processing policy

FAN TRANSPORTATION SRL (”FAN Moldova”) understands the importance of your data and is committed to protecting its confidentiality and security. That is why it is important for us to provide you, in an integrated and practical manner, with information relating to the processing of your personal data as data subjects (customers, potential customers, consumers, potential consumers, employees, former employees, candidates for filling positions, users of the website www.fancourier.md) under this Personal Data Processing Policy, applicable for the purposes listed below.

In accordance with the legislation of the Republic of Moldova on the protection of personal data, including the applicable provisions of Law No. 195 of 25.07.2024 on the protection of personal data, FAN TRANSPORTATION SRL administers, under conditions of safety and only for the specified purposes, the personal data that you provide to us about yourself, in the context of purchasing and using the services of FAN TRANSPORTATION SRL under the brand FAN Courier.

1. The purposes for which we collect and process your personal data

FAN TRANSPORTATION SRL collects and processes your personal data for the following processing purposes:

  • the main purpose is the provision of postal services, namely courier services;
  • the administration, improvement and provision of the services offered by the website www.fancourier.md;
  • commercial service-sales activities, comprising the realisation, administration and development of service sales on the website www.fancourier.md, the administration of customer accounts, market research/studies and statistics;
  • advertising, marketing and publicity, activities to promote the services of FAN TRANSPORTATION SRL, carrying out promotional campaigns, sending newsletters (information bulletins), as well as monitoring service sales and consumer behaviour;
  • post-sale activities, comprising customer relations services, informing users/customers regarding the evaluation of the services offered, including the evaluation of services on the website www.fancourier.md, improving the quality of services, resolving requests, notifications and complaints;
  • support and customer relations activities through the Call Center service;
  • carrying out internal/external audit;
  • for evidentiary purposes in connection with the above activities and for archiving;
  • the creation and management of notifications regarding the delivery and status of shipments, including by SMS, e-mail or other means of communication used by FAN Moldova;
  • ensuring the traceability of postal operations and shipments;
  • the prevention, identification and documentation of situations of fraud, unauthorised use of services or of the identity of FAN Moldova;
  • fulfilling the legal obligations incumbent on FAN TRANSPORTATION SRL as a provider of postal services and a controller of personal data.

2. The categories of personal data that we process

In order to achieve the above purposes, we process the following categories of personal data:

For the provision of the courier service: name, surname, address, telephone number, e-mail, data necessary for identifying and delivering the shipment, as well as other data recorded on the transport documents/AWB.

For commercial service-sales activities, comprising the realisation, administration and development of sales, including online sales on the website www.fancourier.md, the administration of customer accounts, market research/studies and statistics: name, surname, address, telephone, e-mail, delivery addresses, data concerning the customer account and information concerning the services requested or used.

For the administration, improvement and provision of the services offered by the website www.fancourier.md: name, surname, address, e-mail, technical information regarding the visitor’s device, the IP address, the type of hardware equipment, information regarding the time interval and the date on which the website was used, as well as other information resulting from the use of Cookies applications.

For more information relating to cookies, please consult the Cookies Policy displayed on the website.

For advertising, marketing and publicity, activities to promote the services of FAN TRANSPORTATION SRL, carrying out promotional campaigns, sending newsletters, tracking and monitoring sales and consumer behaviour: name and surname, telephone, e-mail, address, as well as information regarding preferences and interaction with the services and communications of FAN Moldova.

In the case of promotional campaigns, additional data strictly necessary for identifying the winners and fulfilling the applicable legal obligations may be processed.

For post-sale activities, comprising customer relations services, informing users/customers regarding the evaluation of the services offered by FAN TRANSPORTATION SRL and the activities carried out through the Call Center: name and surname, telephone, e-mail, address, voice, information regarding the request submitted and other data provided in the course of interaction with FAN Moldova.

For evidentiary purposes in connection with the above activities and for archiving: the storage of the personal data mentioned in the purposes above with a view to maintaining records related to the activities carried out, to protect rights in court and to exercise other rights in accordance with the law and the contracts concluded, as well as to fulfil any archiving requirements.

Within the notification and communication functionalities regarding deliveries, the telephone number, the e-mail address, the shipment identifiers, as well as access codes or other authentication elements may be collected and processed, when these are used for secure access to information regarding shipments.

Personal data that benefit from a special protection regime are collected and processed only to the extent that this is necessary and permitted by the applicable legislation.

The provision of certain personal data is necessary in order for FAN TRANSPORTATION SRL to be able to perform the requested services, to deliver the shipments and to fulfil the applicable legal obligations.

3. To whom we disclose your personal data

In order to achieve one or more of the purposes mentioned above, FAN TRANSPORTATION SRL may disclose your personal data to the following categories of recipients:

  • the contractual partners of FAN TRANSPORTATION SRL, including partners involved in the provision of postal and courier services, only to the extent necessary for the provision of the services and in compliance with the obligations of confidentiality and data protection;
  • service providers, including providers of IT services, telecommunications, SMS, e-mail, software platforms, payment/banking services, archiving services, marketing or other services necessary for carrying out the activity;
  • processors that process data on behalf of and in accordance with the instructions of FAN TRANSPORTATION SRL;
  • other entities within the FAN group, when this is necessary for achieving the processing purposes;
  • public authorities and other competent bodies of the state, when the provision of the data is necessary or required by the applicable legislation;
  • the data subjects, in the context of the exercise of their rights.

Access to personal data is limited to authorised persons and to recipients who need this data for the fulfilment of their duties or the provision of the respective services.

4. The exercise of the rights of data subjects

Data subjects benefit from the rights provided by the legislation of the Republic of Moldova on the protection of personal data, including:

  • the right to be informed regarding the processing of personal data;
  • the right of access to personal data and to information regarding the manner in which it is processed;
  • the right of intervention over personal data, including the right to request the rectification, updating, completion or, under the conditions of the law, the erasure or transformation into anonymous data of data whose processing does not comply with the legislation;
  • the right to request the restriction of the processing of data, under the conditions of the law;
  • the right to data portability, to the extent applicable;
  • the right to object to the processing of personal data, for well-founded and legitimate reasons related to the particular situation of the person;
  • the right to object at any time, free of charge and without justification, to the processing of personal data for direct marketing purposes;
  • the right not to be subject to an individual decision based exclusively on the automated processing of data, under the conditions of the law;
  • the right to lodge a complaint with the supervisory authority competent in the field of the protection of personal data;
  • the right to address the competent courts of law.

The exercise of these rights may be carried out by e-mail to the Data Protection Officer (DPO):  dataprotection@fancourier.md  .

In order to be able to respond to requests concerning personal data, FAN TRANSPORTATION SRL may request the verification of the identity of the person who submits the request, to the extent that this is necessary for protecting the data and preventing unauthorised disclosure.

In the event that the request is submitted by a representative of the data subject, FAN TRANSPORTATION SRL may request the documents necessary for verifying the right of representation.

In the absence of confirmation of identity or of proof of the capacity of legal representative (special notarial power of attorney or final court decision), FAN TRANSPORTATION SRL cannot act upon the request and will not be able to communicate personal data.

5. Provisions relating to minors

FAN TRANSPORTATION SRL does not aim, in its data processing activities, to process the personal data of minors.

Particular attention is paid to ensuring that any processing of the personal data of minors is carried out in accordance with the requirements of the applicable legislation.

FAN TRANSPORTATION SRL does not carry out promotional direct marketing activities towards minors.

In the event that, in the course of using the services or communicating with FAN Courier, personal data of a minor are provided, they will be processed only to the extent permitted by the applicable legislation and for the purposes for which they were provided.

Any person who provides us with personal data through the website or other applications or devices covered by this Policy guarantees, to the extent permitted by law, that the information provided is correct and that they have the right to provide this data.

6. The duration of data processing

Personal data will be kept for the period necessary to achieve the purposes for which they were collected, as well as for the periods during which FAN TRANSPORTATION SRL has a legal obligation to keep them or has a justified legitimate interest in keeping them.

For the data declared within the Call Center service, the duration of data processing is, as a rule, 3 years, or until the exercise of the right to object, to the extent that the applicable legislation permits this.

FAN TRANSPORTATION SRL may keep personal data for a longer period when this is necessary for evidentiary purposes, for the defence or exercise of rights in court, for archiving, for fulfilling legal obligations or for carrying out internal statistics and analyses, to the extent permitted by law.

Upon expiry of the retention period, the data will be erased, destroyed or anonymised, as the case may be, in compliance with the applicable legal obligations.

7. Other information

Please check, on each use of our website www.fancourier.md, this Personal Data Processing Policy in order to be permanently informed regarding the manner in which your data is processed.

In the event of a transfer or reorganisation of the activity, FAN TRANSPORTATION SRL will take the measures necessary to ensure the protection of personal data.

For the erroneous recording of personal data caused by the provision of incorrect information by the sender, customer or other persons who enter the data into the systems used for generating the transport documents, FAN TRANSPORTATION SRL does not assume responsibility for the accuracy of data that was not entered by it, to the extent permitted by law.

8. The processing of personal data in the recruitment and selection process

8.1 Categories of personal data processed

Within the recruitment process, the following categories of personal data may be processed, but not limited to:

a) Identification and contact data: name, surname, date of birth, citizenship, place of residence, telephone number, e-mail address;

b) Data concerning the professional and educational path: CV, cover letter, information regarding studies and professional training, diplomas, certificates, attestations, previous professional experience and recommendations;

c) Financial data: data necessary for the reimbursement of expenses related to participation in interviews or other recruitment activities, where applicable;

d) Audio-video recordings: only if the selection process involves video interviews or recordings and only to the extent permitted by the applicable legislation;

e) Special categories of data: only if they are strictly necessary and there is a legal basis for processing them.

8.2 The purposes of processing personal data

The data are processed for the purpose of managing the recruitment and selection process, namely for identifying and evaluating candidates with a view to filling the positions available within FAN TRANSPORTATION SRL.

Thus, personal data are processed exclusively for purposes related to carrying out the recruitment and selection process, as follows:

  • the analysis and evaluation of the application in relation to the requirements of the position;
  • the organisation of interviews and/or selection tests/trials;
  • communication with the candidate throughout the recruitment and selection process;
  • transmitting information regarding the status of the application;
  • compliance with legal obligations regarding equal opportunities and non-discrimination;
  • carrying out internal analyses and statistics for human resources purposes;
  • the possibility of taking the application into consideration for other vacant positions, when there is the candidate’s consent or another applicable legal basis.

8.3 The grounds for processing

Personal data are processed on the basis of the grounds provided by the applicable legislation, as the case may be, including for:

  • carrying out the steps necessary at the candidate’s request prior to concluding a contract;
  • fulfilling the legal obligations of FAN TRANSPORTATION SRL;
  • achieving the legitimate interests of the controller, in compliance with the rights and freedoms of the data subject;
  • the candidate’s consent, when this is necessary;
  • the processing of special categories of data, only under the conditions and for the purposes permitted by the applicable legislation.

8.4 The source of the personal data

Personal data are collected:

  • directly from the candidate, through online applications, e-mail, registration form or other means of communication;
  • through recommendations made by persons who know the candidate, to the extent permitted by law;
  • through participation in recruitment events;
  • through online recruitment platforms;
  • from other sources permitted by the applicable legislation.

8.5 The recipients of the personal data

The data may be accessed, depending on necessity:

a) within FAN TRANSPORTATION SRL by the human resources/recruitment department and the managers involved in the selection process;

b) by external service providers, including providers of IT platforms and solutions or recruitment platforms;

c) by other entities, when this is necessary and permitted by the applicable legislation.

8.6 The storage period of the personal data

Personal data are kept for the duration of the recruitment and selection process for the position concerned.

If the recruitment and selection process ends without the candidate being hired, the data will be kept for a reasonable period, necessary for fulfilling the purposes for which they were collected and/or for the period for which the candidate has expressed their consent, when the processing is based on consent.

After the expiry of the applicable period, the data will be erased or anonymised, except in situations where the law requires their retention for a longer period.

9. The processing of personal data in the context of complaints, notifications, compensation claims, sending/collection of shipments

FAN TRANSPORTATION SRL processes the personal data of natural persons who submit complaints, notifications or compensation claims, for the purpose of registering, verifying, analysing and resolving them, as well as for ensuring the traceability and evidencing of the manner of handling customer requests.

Furthermore, the data may be processed in the context of the sending, receiving, delivery and collection of shipments.

Purposes and grounds of processing

The processing of this data is carried out for fulfilling the legal obligations applicable to FAN TRANSPORTATION SRL as a provider of postal services, for the execution of the contract or the carrying out of the steps requested by the data subject, as well as, as the case may be, for protecting the legitimate interests of the controller.

The processing may have as its purpose:

  • resolving complaints and notifications;
  • resolving compensation claims;
  • ensuring the traceability of postal operations;
  • the prevention and documentation of frauds;
  • the defence of the rights and legitimate interests of the controller;
  • fulfilling legal obligations;
  • verifying the identity of the person who requests information or submits a request.

FAN TRANSPORTATION SRL has published a mechanism for resolving complaints, including for situations concerning the loss, theft, destruction or damage of shipments and non-compliance with the quality conditions of the services.

The categories of data processed

In order to achieve the purposes mentioned above, FAN TRANSPORTATION SRL may collect and process the following categories of personal data:

  • name and surname;
  • postal address;
  • telephone number;
  • e-mail address;
  • data concerning the shipment and the AWB number;
  • identification data, when these are necessary for verifying the identity;
  • signature, when it is necessary;
  • data concerning the payment or the compensation, when these are necessary for resolving the request.

In certain strictly determined situations, FAN TRANSPORTATION SRL may request the presentation of an identity document for verifying the identity of the person, to the extent that this is necessary and permitted by the applicable legislation.

Identification of persons and presentation of the identity document

For requests submitted in person or for situations in which verification of identity is necessary, the applicant may be invited to present an identity document.

The processing of the data from the identity document is carried out only to the extent that it is necessary for the purpose pursued and permitted by the applicable legislation.

10. Unauthorised use of the identity of FAN TRANSPORTATION SRL and fraudulent communications – delimitation of the controller’s responsibility

10.1. General information

FAN TRANSPORTATION SRL brings to the attention of data subjects that there may be situations in which unauthorised third parties fraudulently use the name, visual identity or references to the services of FAN Moldova by sending messages via SMS, e-mail, instant messaging applications or through other similar channels.

Such communications:

  • are not generated, transmitted, controlled or authorised by FAN TRANSPORTATION SRL;
  • are not the result of a processing of data carried out by the controller;
  • represent unauthorised uses of the company’s identity by third parties, over which the controller exercises no control.

10.2. The connection between personal data and the AWB

FAN TRANSPORTATION SRL processes personal data in connection with shipments for which there is a valid AWB, registered in the company’s internal systems.

Any request, notification or communication concerning:

  • non-existent parcels;
  • differences in weight;
  • fees or payments associated with shipments that cannot be correlated with a real and verifiable AWB

is not, in the absence of such a correlation, a communication generated by FAN TRANSPORTATION SRL and does not involve a processing of data carried out by the controller.

10.3. Delimitation of responsibility

FAN TRANSPORTATION SRL is not responsible for the processing of personal data carried out by third parties who fraudulently use the company’s identity, outside a contractual or legal relationship with the controller.

In such situations, FAN TRANSPORTATION SRL is the entity whose identity may be abusively used, without exercising control over the processing carried out by third parties.

11. The processing of personal data originating from external e-commerce platforms and marketplaces

11.1. Within the courier activity, FAN TRANSPORTATION SRL processes personal data recorded on the transport documents/AWB generated as a result of orders placed on external e-commerce platforms or marketplaces.

In these situations, the respective platforms or the senders may bear responsibility for the initial collection and entry of the recipients’ data, and FAN TRANSPORTATION SRL processes the data necessary for executing the transport service and informing the recipient regarding the status of the shipment.

11.2. Lack of control over the veracity of the data entered by the sender

FAN TRANSPORTATION SRL:

  • does not establish the initial source of the personal data entered on the external platforms;
  • does not modify the data provided by the sender at the moment of generating the AWB;
  • does not always have the technical or legal possibility of verifying the accuracy, currency or belonging of the contact data to the actual recipient.

Situations may arise in which:

  • the contact data are entered erroneously;
  • the contact data of another person are used;
  • the data are intentionally entered incorrectly by the sender.

In these cases, the processing carried out by FAN TRANSPORTATION SRL is based on the data recorded on a valid AWB provided by the sender or by the platform through which the shipment was generated, without the transport operator being able to be held responsible for the inaccuracy of the data provided by third parties, except in the situations provided by law.

11.3. The absence of a data security breach

The transmission of automatic notifications generated on the basis of a valid AWB, which contains data entered erroneously by the sender, does not constitute, from the perspective of FAN TRANSPORTATION SRL, in itself:

  • a breach of the security of personal data;
  • an unauthorised disclosure of data;
  • a processing outside the declared purpose,

to the extent that the notification is generated within the normal process of providing the postal service and is transmitted on the basis of the data provided for the respective shipment.

The notifications are transmitted for the purpose of informing regarding the status of a shipment and the provision of the transport service.

These clarifications refer strictly to the processing and systems of FAN TRANSPORTATION SRL itself.

11.4. In situations where the personal data have been collected and entered into external e-commerce platforms or marketplaces, FAN TRANSPORTATION SRL processes the data necessary for executing the transport service, on the basis of the information recorded on the AWB.

For clarifications concerning:

  • the manner of collecting and entering the data;
  • the veracity of the data;
  • the correlation of the data with a particular order;
  • information regarding possible unauthorised uses or entry errors,

data subjects are directed to address themselves directly to the initial controller of the data, namely the e-commerce platform, the marketplace or the sender, as the case may be.

11.5. The limitation of responses and investigations of an evidentiary nature

FAN TRANSPORTATION SRL cannot initiate investigations of an evidentiary nature concerning:

  • the initial origin of the data;
  • the identity of the person who entered the data into an external platform;
  • the person who initiated or paid for the order,

when this information is not located in the systems of FAN TRANSPORTATION SRL itself.

These aspects fall, as the case may be, within the competence of the initial controller of the data or of the competent authorities.

11.6. Operational details

In accordance with the applicable legislation, FAN TRANSPORTATION SRL may provide, upon request and after verifying the identity of the requesting person, information and an operational report limited to the data existing in its own systems, such as AWB numbers and operational statuses, without disclosing personal data of other persons or information of an investigative nature.

12. Modification of the notice of the personal data processing policy

We reserve the right to update this notice whenever necessary, including as a result of changes in the applicable legislation, the services offered or the ways in which personal data are processed.

We recommend that you periodically check the updated version available on our website www.fancourier.md, as changes may occur.

Last updated: August 2026