Disclaimer & privacy

Last updated: 12 September 2026

1. Who is responsible for your personal data?

Transfluvia NV, with registered office at Transportcentrum LAR K20, 8930 Menen, Belgium, company number 0405.517.606, attaches importance to the protection of personal data and processes such data in accordance with applicable data protection legislation, including Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), and Belgian data protection legislation.

For processing activities for which Transfluvia itself determines the purposes and essential means, Transfluvia acts as data controller.

You may contact Transfluvia with any questions about this privacy notice or the processing of your personal data at:

Transfluvia NV
Transportcentrum LAR K20
8930 Menen
Belgium
E-mail: customs@transfluvia.be

2. When does this privacy notice apply?

This privacy notice applies to personal data processed by Transfluvia as controller in connection with, among other things:

  • relationships with customers, prospects, suppliers and other business partners;
  • customs, excise, tax, freight forwarding, logistics and related services;
  • advisory and support services in connection with its activities;
  • customer, supplier and file administration;
  • invoicing, payments and debt collection;
  • communications by e-mail, telephone, Microsoft Teams or other channels;
  • use of its website, software and digital applications;
  • the security and proper functioning of its IT systems and services;
  • job applications and recruitment;
  • complaints, audits, disputes and administrative or judicial proceedings.

For certain processing activities, Transfluvia may also act as a data processor, in particular where it processes personal data exclusively on behalf of and in accordance with the instructions of a customer, for example in connection with certain software applications or other services.

Where Transfluvia acts as processor, the relevant customer in principle determines the purpose of the processing and acts as controller. Processing is then governed by the applicable agreement and the provisions included therein in accordance with Article 28 GDPR.

Whether Transfluvia acts as controller or processor is determined by the parties' actual role in the relevant processing activity.

3. What personal data does Transfluvia process?

Depending on the nature of the relationship, assignment or service, Transfluvia may process, among other things:

  • first name, surname and other identification data;
  • address, e-mail address, telephone number and other contact details;
  • professional information such as job title, employer, department and business contact details;
  • information relating to companies with which a person is associated;
  • powers of representation, mandates, powers of attorney and functions;
  • information from or contained in identity documents insofar as necessary and legally permitted;
  • financial information, including bank account, payment and invoicing details;
  • information relating to commercial and financial transactions;
  • customs, excise, tax, transport and logistics data;
  • information contained in invoices, packing lists, transport documents, customs declarations, certificates, authorisations and other file documents;
  • information concerning vehicles, consignments or goods where related to a natural person;
  • communications and correspondence, including e-mails, letters, telephone contacts and Microsoft Teams communications;
  • information concerning assignments, files, declarations, audits, requests, objections, appeals and disputes;
  • user, access, log and technical data relating to IT systems, software and digital applications;
  • IP addresses and other technical data processed when our website or systems are used;
  • information submitted in connection with a job application, such as a curriculum vitae, education, professional experience and other information supplied by the applicant.

Transfluvia requests or retains a copy of an identity document only where necessary for the relevant purpose and legally permitted.

Transfluvia does not seek systematically to collect special categories of personal data within the meaning of Article 9 GDPR. Where such data nevertheless necessarily appear in a file, they are processed only where a valid legal basis exists.

4. From whom does Transfluvia obtain personal data?

Transfluvia may obtain personal data directly or indirectly, including:

  • from the data subject;
  • from Transfluvia's customer or principal;
  • from the data subject's employer or principal;
  • from directors, employees or representatives of customers and suppliers;
  • from suppliers, manufacturers, sellers and buyers;
  • from carriers, freight forwarders, agents, terminal operators, warehousing companies and other parties in a commercial or logistics chain;
  • from professional advisers;
  • from customs, tax and other public authorities;
  • through electronic customs and government platforms;
  • from public registers, official databases and other lawfully accessible sources;
  • through Transfluvia's website, software and information systems.

Where personal data have not been obtained directly from the data subject, Transfluvia provides the information referred to in Article 14 GDPR where and insofar as required and no statutory exception applies.

5. Why does Transfluvia process personal data and on what legal basis?

Transfluvia processes personal data only where a valid legal basis exists.

5.1 Performance of contracts and pre-contractual measures

Where a natural person is personally party to an agreement, personal data may be processed to respond to enquiries, prepare and handle quotations, accept and perform assignments, communicate about services, provide services or software, invoice and process payments and provide support.

The legal basis is the performance of the agreement or taking steps at the request of the data subject before entering into an agreement.

5.2 Legal and regulatory obligations

Transfluvia processes personal data where necessary to comply with legal or regulatory obligations, including obligations relating to customs, excise duties, VAT and taxation, accounting, administrative audits, authorisations and approvals, sanctions, prohibitions and restrictions, trade and product regulations, security, fraud prevention and statutory documentation and retention obligations.

5.3 Legitimate interests

Transfluvia may process personal data on the basis of its legitimate interests or those of a third party, provided that the data subject's interests or fundamental rights and freedoms do not override those interests.

These interests may include efficient customer and business administration, communication with business partners, management and improvement of services, IT, network and information security, access management and logging, preventing and investigating errors, misuse and fraud, debt collection, internal controls and quality monitoring, documenting and demonstrating proper performance of assignments, handling complaints, establishing, exercising or defending legal claims and defending Transfluvia, its directors, employees and auxiliaries against claims or allegations of liability.

5.4 Consent

Where processing is based on consent, for example for certain non-essential cookies or electronic marketing communications where consent is legally required, that consent may be withdrawn at any time for the future.

Withdrawal does not affect the lawfulness of processing carried out beforehand.

6. Is providing personal data mandatory?

In certain cases, providing personal data is necessary to enter into or perform an agreement, handle an assignment, comply with legal or regulatory requirements, complete customs, tax or other administrative formalities or verify a person's identity or authority to represent another person or entity.

If the necessary data are not provided, Transfluvia may be unable to accept or perform an assignment or complete a particular formality.

7. Customs, excise and related services

In connection with customs, excise, tax and related services, Transfluvia may process personal data and disclose them to competent public authorities where necessary to perform an assignment or comply with legal obligations.

This may include data required for customs declarations, excise formalities, import, export and transit formalities, authorisations, inspections and audits, origin formalities, sanitary or phytosanitary formalities, trade measures, prohibitions and restrictions, refunds, objections or administrative appeals.

The personal data required depend on the goods, transaction, customs procedure and applicable legislation.

8. To whom does Transfluvia disclose personal data?

Transfluvia discloses personal data only where necessary and lawful for the relevant purpose.

Depending on the processing concerned, data may be disclosed to Belgian, foreign and European customs authorities, tax and excise authorities, sanitary and phytosanitary authorities, supervisory and enforcement authorities, carriers, freight forwarders, terminal operators, warehousing companies, agents, banks, payment service providers, insurers, accountants, lawyers, bailiffs, experts, IT, hosting, cloud, communications, security and software providers, subcontractors, auxiliaries, courts, arbitral tribunals and competent authorities.

Microsoft

Transfluvia uses Microsoft 365, Exchange Online, Outlook and Microsoft Teams for, among other things, e-mail, calendar and communications functionality, collaboration, online meetings and other business processes.

Personal data may be processed by Microsoft as part of the services it provides to Transfluvia and in accordance with Microsoft's applicable contractual and data protection terms.

Transfluvia also uses IT, hosting, cloud, security, software and website service providers which may process personal data as part of their services to Transfluvia.

Transfluvia ensures that service providers processing personal data for it are engaged in accordance with applicable data protection legislation and that, where required, appropriate contractual safeguards are put in place.

9. Transfers outside the European Economic Area

Transfluvia uses IT, cloud, communications and other service providers whose services may, in certain circumstances, result in personal data being processed or transferred outside the European Economic Area (“EEA”) or accessed from outside the EEA.

Microsoft 365

For European customers of various Microsoft 365 services, Microsoft provides an EU Data Boundary, under which customer data and certain other personal data are, to a significant extent, stored and processed within the European Union and EFTA.

This does not mean that all processing takes place exclusively within the EEA without exception. Data may still leave the EU Data Boundary or be accessed from outside it for certain global technical and operational processes, cross-border Teams communications, user-initiated communications with persons outside the EU Data Boundary, certain support, security or service activities and certain directory, network, diagnostic or pseudonymised data.

Where personal data are transferred to a country outside the EEA, Transfluvia ensures that a valid transfer mechanism exists in accordance with Chapter V GDPR, such as an adequacy decision by the European Commission or appropriate safeguards, including Standard Contractual Clauses approved by the European Commission.

Microsoft regulates data protection and international transfers, among other things, in its current Microsoft Products and Services Data Protection Addendum.

Further information about applicable safeguards and, where applicable, a copy thereof may be requested from customs@transfluvia.be.

10. How long does Transfluvia retain personal data?

Transfluvia does not retain personal data for longer than necessary for the purposes for which they are processed.

The specific period is determined taking into account the duration of the customer or business relationship, the nature of the assignment or file, statutory and regulatory retention obligations, tax, accounting, customs and administrative periods, applicable limitation and expiry periods, the need to demonstrate performance of assignments or compliance with legal obligations and security and fraud-prevention purposes.

Where an audit, investigation, objection, appeal, liability claim or judicial or administrative proceeding is pending or can reasonably be anticipated, relevant data may be retained for as long as necessary to establish, exercise or defend legal rights and claims, including the defence of Transfluvia, its directors, employees or auxiliaries.

Data are subsequently deleted or anonymised when further identification is no longer necessary or justified.

11. Security of personal data

Transfluvia takes appropriate technical and organisational measures to protect personal data against unauthorised access, unlawful processing, accidental loss, destruction, damage, unauthorised alteration and unauthorised disclosure.

The measures are tailored to the nature, scope, context and purposes of the processing and the associated risks.

12. Website and cookies

When the website is used, technical data may be processed, including IP addresses, session data, log data and information obtained through cookies or similar technologies.

Strictly necessary cookies may be used for the proper and secure functioning of the website.

Non-essential cookies and similar technologies are used only after the required prior consent has been obtained.

For a detailed overview of the cookies and technologies used, their providers, purposes, retention periods and categories and how consent can be given, refused or withdrawn, please refer to Transfluvia's separate cookie notice.

13. Automated decision-making

Transfluvia does not make decisions based solely on automated processing, including profiling, which produce legal effects concerning a data subject or similarly significantly affect that person.

14. What rights do you have?

Depending on the processing concerned and the applicable legal conditions, you have rights including the right to information, access, rectification, completion, erasure, restriction of processing and data portability, as well as the right to object to processing based on a legitimate interest and to object at any time to direct marketing.

Where processing is based on consent, you may withdraw that consent.

These rights are not absolute. Transfluvia may be required or entitled to retain data where a statutory retention obligation applies, data are necessary for an ongoing assignment, an audit or proceeding is pending or retention is necessary for the establishment, exercise or defence of legal claims.

You may exercise your rights by contacting customs@transfluvia.be.

Transfluvia may request additional information where reasonably necessary to verify the requester's identity.

15. Direct marketing

Where Transfluvia uses personal data for direct marketing purposes, this is done on a valid legal basis and in accordance with the applicable rules on electronic communications.

You may object at any time and free of charge.

16. Complaints

If you have questions or complaints about how Transfluvia processes your personal data, you may first contact customs@transfluvia.be.

You also have the right to lodge a complaint with:

Data Protection Authority
Rue de la Presse 35
1000 Brussels
Belgium
contact@apd-gba.be

Lodging a complaint does not affect any other administrative or judicial remedies.

17. Changes to this privacy notice

Transfluvia may amend this notice where its activities or services, processing activities, IT systems or service providers or applicable laws or regulations change.

The most recent version is published on the website together with the date of the latest update.

Where a change has material consequences for an existing processing activity, Transfluvia will provide additional information where and insofar as required by the GDPR.

Liability

The information on this website is provided for general information purposes only. Although Transfluvia takes reasonable care to ensure that it is accurate and up to date, it cannot be guaranteed that all information is complete, accurate or current at all times.

The information on this website does not constitute individual customs, tax, legal or other professional advice and must not be regarded as such. Assessment of a specific situation requires a separate assignment and assessment.

To the extent permitted by applicable law, Transfluvia is not liable for damage arising solely from the use of or reliance on general information provided on this website.

The website may contain references or links to third-party websites or services. Transfluvia has no control over their content or operation and is not responsible for them.