Privacy Policy

Last Updated: 12 March 2026

 

1. Who We Are

 

Bringing Momentum Closer (“BMC”, “we”, “us”) provides offshoring logistics support by integrating South African talent into European logistics operations (freight-forwarding support, customer service, data processing, supply-chain coordination). 

 

2. Scope

 

This policy describes how we process personal information when:

• You browse our website or contact us

• You are (or work for) a client or prospect

• You are a candidate for placement

• or we perform services that involve processing personal data on behalf of our clients.

 

When we act on client instructions, the client is the controller, and BMC is the processor (GDPR) / operator (POPIA).

 

3. What Data We Collect

 

Depending on context, we may process:

• Identity & contact data: name, job title, business email/phone, company

• Operations data (B2B): shipment references, manifests, invoices, routing instructions, communications metadata, issue logs

• Support & ticketing: requests, timestamps, system identifiers

• Recruitment data (candidates): CV, experience, references

• Website data: device, browser, pages viewed, IP (per our cookie notice)

 

4. Purposes & Legal Bases (GDPR) / Justification (POPIA)

 

We process personal data to:

• deliver and administer services

• manage relationships

• provide support

• improve quality

• comply with the law

• performance of a contract

• legitimate interests in operating and improving services, legal obligations, and consent where required (e.g. certain marketing) 

 

5. When We Act As Processor (on behalf of clients)

 

For service delivery, BMC processes operational and customer data strictly on the controller’s documented instructions under a Data Processing Agreement (DPA). We ensure confidentiality, security, sub-processor controls, assistance with data-subject requests, return/erasure at the end of an engagement, and audit cooperation.

 

6. International Transfers

​

• EU to South Africa / other third countries: If personal data is transferred from the EEA/UK to BMC or sub‑processors outside the EEA, we implement Standard Contractual Clauses (SCCs) and supplementary measures where appropriate. 

• South Africa to outside SA: Transfers comply with POPIA Section 72 (adequate protection, consent, contractual necessity, or other permitted grounds). Note: POPIA protects juristic persons as well as natural persons, so SA‑origin data may require SA‑specific contractual protections beyond EU SCCs.

 

7. Data Retention

 

We retain personal data only as long as necessary for the purposes above (and as required by law, tax, and audit). Clients may instruct shorter retention for processor data.

 

8. Security

 

We deploy organisational and technical measures suitable to risk (access controls, least‑privilege, encrypted transport, logging/monitoring). Controllers remain responsible for their own systems. 

 

9. Your Rights

 

• If GDPR applies: access; rectification; erasure; restriction; portability; objection; and rights in relation to automated decision‑making.

• If POPIA applies: rights to access, correction, objection to processing, and to lodge complaints with the Information Regulator. 

 

To exercise rights, contact us at info@bringingmomentumcloser.com (or via your employer/controller if BMC is processing on their behalf).

 

10. Supervisory Authorities

​

• Belgium/EU: Data Protection Authority (APD/GBA): https://www.dataprotectionauthority.be 

• South Africa: Information Regulator: https://inforegulator.org.za/

 

11. Children & Special Categories

 

We do not target services to children. Any handling of special categories (e.g. in HR/recruitment) follows applicable law and client instructions.

 

12. Updates

We may update this policy; new versions will be posted here with a new “Last updated” date.

​

13. Contact

If you have any questions about this Privacy Policy, please contact us: info@bringingmomentumcloser.com​​​​

​