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Privacy Policy

Information on the processing of personal data by CloseMRN Paweł Dubel in connection with closemrn.pl, closemrn.com and the handling of requests. Version dated 17 September 2026.

1. Controller

The controller of your personal data is CloseMRN Paweł Dubel, ul. Piłsudskiego 36 lok. 87, 10-577 Olsztyn, Poland, VAT ID PL5214052379. For any matter concerning personal data write to contact@closemrn.com.

2. Data we process

We process the data you supply in forms and correspondence and technical data related to the use of the website:

  • client and contact details: first name, last name, company, VAT number, e-mail address and optionally a phone number;
  • shipment data: booking number, container numbers, MRNs and other references, port, route, description of goods, dangerous goods information and remarks;
  • export clearance data: exporter and consignee details, EORI number, invoices and packing lists, means of transport and the persons named in the customs representation authorisation;
  • attachments (PDF, JPG, PNG, XLSX): booking confirmations, export documents, dangerous goods and transit documents; they may contain data of third parties, for example forwarders’ or counterparties’ staff;
  • the content of contact form messages and subsequent e-mail correspondence;
  • technical data: IP address, timestamps, server and reverse proxy logs and the draft identifier stored in a cookie.

3. Purposes and legal bases

We process data under Article 6(1) of Regulation (EU) 2016/679 (GDPR):

  • point (b): steps taken at your request before entering into a contract (reviewing the request, preparing terms) and performance of the contract for handling the request;
  • point (c): compliance with legal obligations, in particular customs law (export declarations lodged as customs representative and their documentation), tax and accounting duties;
  • point (f): the controller’s legitimate interests: handling business correspondence, securing the website and forms, preventing abuse and establishing, exercising or defending legal claims.

4. How the website forms work

The request and contact forms do not require an account. After submission the request and its attachments are stored on the controller’s server and passed to the CloseMRN team by e-mail from the company account in Google Workspace (Gmail). The request reference and an encrypted identifier in a cookie let you return to an unfinished draft in the same browser. Drafts that are never submitted are deleted 30 days after the last change.

Providing a booking number may trigger a technical check with the carrier whether the booking exists; the check concerns the booking number only and involves no personal data.

5. Recipients and processors

Data may be disclosed to the following recipients, only to the extent necessary for the purposes described above:

  • Google Ireland Ltd.: e-mail and calendar in Google Workspace (processor);
  • the hosting provider of the server running the website and storing requests (OVH): servers within the European Union (processor);
  • port system operators (DAKOSY, dbh, Portbase, Port of Antwerp-Bruges/NxtPort), terminals and carriers: as regards shipment data entered in connection with the order (independent controllers);
  • the party lodging the transit declaration when arranging T1: as regards data and documents required for the declaration (independent controller);
  • the customs authorities of Germany, the Netherlands and Belgium (offices of export and exit): as regards export declarations lodged under the export clearance service (independent controllers);
  • accounting, invoicing and banking providers: as regards settlements;
  • public authorities: where required by law.

6. Transfers outside the European Economic Area

E-mail is handled in Google Workspace; Google may also process data in the United States. Transfers rely on Commission Decision (EU) 2023/1795 on the EU-U.S. Data Privacy Framework and on the standard contractual clauses adopted by Decision (EU) 2021/914. Information about the safeguards is available on request.

7. Retention

We keep data for as long as necessary for the purpose and thereafter for the periods required by law:

  • requests, attachments, correspondence and order documents, including export declaration records and authorisations: for the duration of the service and 5 years from the end of the tax year in which the service was performed (tax and customs documentation);
  • enquiries that did not lead to an order: up to 12 months from the last contact;
  • unsubmitted form drafts: 30 days from the last change;
  • technical server logs: up to 90 days;
  • data needed to establish, exercise or defend claims: until the limitation periods expire.

8. Your rights

Under the GDPR you have the right to:

  • access your data and obtain a copy (Article 15);
  • rectification (Article 16);
  • erasure (Article 17), subject to documentation retention duties;
  • restriction of processing (Article 18);
  • portability of data processed under a contract (Article 20);
  • object to processing based on legitimate interests (Article 21).
  • Requests may be sent to contact@closemrn.com. You may also lodge a complaint with the Polish Data Protection Authority (Prezes Urzędu Ochrony Danych Osobowych, uodo.gov.pl) or with the supervisory authority of your place of residence or work.

9. Cookies and browser storage

The website uses only mechanisms strictly necessary for the forms to work. We do not use advertising cookies or analytics tools.

  • closemrn_intake: an HttpOnly cookie (30 days) with the draft identifier that lets you return to a form in the same browser;
  • sessionStorage: temporary storage of the cooperation enquiry in the current browser tab, cleared after submission;
  • client portal session: an authentication cookie for logged-in clients, until logout.

10. Automated decisions

We do not make decisions based solely on automated processing, including profiling, within the meaning of Article 22 GDPR. The carrier booking check and the validation of container or MRN number formats are purely technical.

11. Security

We apply technical and organisational measures appropriate to the risk: TLS-encrypted connections, private request directories with restricted access, request origin checks, file type and integrity verification, backups and mailbox access limited to staff handling requests.

12. Changes

We update this policy when the scope of processing or the law changes. The version published on the website applies. Version dated 17 September 2026.

Last updated: 17 September 2026