Privacy Policy

Last updated : 17 May 2024

Xpo-Online Ltd ("we", "our", “us” or "Delivery Pal") is committed to protecting the privacy of drivers who apply to driver with us (“driver applicants”), our drivers, including all users of our driver mobile device application ("Driver App"), our website  deliverypal.net (“Website”)  and related services. We’ll be the “controller” of the information we hold about you. This privacy policy applies to driver applicants, drivers (“you” or “your”). Please read this privacy policy which explains how and why we collect, use and protect your information.

1CONTACT DETAILS

If you have any queries, please get in touch by contacting our Support Team by emailing us at support@deliverypal.app. For requests concerning this privacy policy or how we handle your information more generally, see the Your rights section below.

2HOW WE COLLECT YOUR INFORMATION

We collect your information when you interact with us, such as when you apply to become a driver, use the Delivery Pal Driver App, Website or related services. We also look at how you use the Driver App and Website, to help us improve our services and optimise driver experience. In particular, we collect your information when you:

  • 1Apply to ride with us or change your account settings;
  • 2Use the Driver App or the Website;
  • 3Contact us directly via email, phone, post, message; and
  • 4Browse and use our Website (before and after you apply to drive with us).
    • We also collect information from third party sites, such as advertising and social media platforms.
3.INFORMATION THAT WE COLLECT ABOUT YOU

As part of our commitment to your privacy, we want to be clear about the types of information we collect.

Our driver application and account set up
  • 1When you apply to drive with Delivery Pal, we ask you to provide information about yourself including your name, contact details, vehicle type, date of birth, relevant address, your right to work, and whether you have any unspent criminal convictions.
  • 2During the application process, or at subsequent times where further checks are considered as necessary, we (or a third party) will ask you to provide further information and documents, such as a copy of your passport and proof of address for criminal background checks and right to work checks. If you are required by applicable law to have a licence or insurance for your vehicle type, we might also ask you to provide evidence that you’re compliant with this law, as well as your vehicle registration details. We will track the progress of your application and record the results of your criminal background check (pass/fail only).
  • 3During the application process you will be asked to submit a photo (“selfie”) or video of yourself and a photo of your identity document to check your identity. Your selfie will be compared with the photo in the identity document. This comparison is made automatically using an identity verification platform with facial recognition, operated by a third party service provider.
  • 4For your account set-up, we will ask you to provide financial (including bank details), tax and business registration information, and further information related to your services for Delivery Pal such as contact details of your next of kin (whose details you have permission to share with us for emergency purposes), where you want to work, your kit and a photo. We'll keep a copy of your signed Delivery Pal Driver agreement with us (“Supplier Agreement”).
    • Payment and deliveries
    • 1We record your deliveries, your calculated fees and associated fee statement.
    Your location
    • 1When you request to use a location-based function in the Driver App, we access your location from your device in order to provide this functionality. This includes when you opt to use these functions whilst your status is set to ”offline” i.e. not available for orders. If you do not want us to view your location when you are “offline”, please do not request these functions.
    • 2When your status is set to “online” (i.e. available for orders) in the Driver App, we collect your location data on a continuous basis for the purposes of engaging your services under your Supplier Agreement including to provide delivery estimates to our customers based on your speed and the type of vehicle you've told us you are using. If you do not want us to view your location, please change your rider status to "offline", but please note that you will need to be online in the Driver App to be offered and/or complete orders.
    • 3Unless you request to use a location-based function or set your status to “online” in the Rider App, we do not access or otherwise collect your location data.
    Your use of the Driver App, Website and Support
    • 1When you use the Driver App and Website we collect information about your use of them, including about your driver online status (when using the Driver App) and (when online) your order progress swipes.
    • 2When you interact with our Support team via email, phone, post, chat or on the Driver App or Website (“Support”), including when you report any incident, our team may collect and use information about you. If you interact with Support by phone, your calls may be recorded for legitimate business purposes, including for Support and Customer Services training and improvement purposes.
    • 3When you use the Driver App you may be asked to submit a selfie or video of yourself to check your identity. Your selfie will be compared with the photo in the identity document you provided at onboarding when we check your identity documents. This comparison may be made automatically using an identity verification platform with facial recognition, operated by a third party service provider.
    Technical data
    • 1We collect technical information about your device and your use of your device, including through the use of cookies and other similar technologies, for example, technical information about your device, including characteristics of and performance data about your device, the Driver App and operating system, your device type, unique device identifier, network connection type, app version, phone language, screen size and platform. To track delivery orders, we use near-field communication technology to understand when you "check-in" at a Partner location to collect an order. We also ask for permission to access the camera on your device to enable you to take and upload to the Driver App a photo of where you have left an order at a customer's delivery address.
    • 2When it comes to cookies and similar technologies, you can change your cookie preferences at any time, including withdrawing any consent you provided at any time. You can also manage and delete cookies through most internet browsers by changing your cookie settings but if you do so, the Website may not work properly.
    • 3For further information on our use of cookies and how to manage them please see our Cookies Policy at   https://www.deliverypal.net/cookies-policy. 
    Information about your services
    • 1 We may receive information about your services or any incident you may have been involved with from the partners who work with us such as restaurants and takeaway partners (our "Partners" ), other riders or members of the public.
    • 2We may collect information about you from the feedback you send us or provide to us through focus groups or surveys.
    • 3When you use websites or applications of third parties in connection with your services for Delivery Pal, including during the application and onboarding process, those sites or applications may collect and process your information independently of Delivery Pal. We recommend that you check their privacy policies to understand how they process your personal information.
    • 4By accessing the Driver App using other digital routes such as (but not limited to) a tablet or other devices/technology, then Delivery Pal's personal information collection and usage as set out in this privacy policy will apply in that context too.
    If you do not provide your information

    If you do not provide some or all of the requested information, Delivery Pal may be unable to accept your application or to complete set-up or manage your driver account.

4USE OF YOUR INFORMATION AND WHY

We will only process your information if there is a reason for doing so, and if that reason is permitted under data protection law.

  • 1Where we need to process your information for the performance of a contract with you, or at your request before we enter into a contract, we use your information to:
    • aprovide and manage your Driver application, driver account, and onboarding process, including to execute your Supplier Agreement;
    • bperform identity verification, right to work, road licence and insurance checks (where permitted by law) to ensure that you are legally compliant when providing the services and to comply with our internal policies;
    • cprovide you with access to and use of the Driver App as a means of Delivery Pal engaging your services, including to enable you to accept orders;
    • dmanage delivery operations and make the most efficient decisions using automated means when offering you orders, based on your location and your vehicle type;
    • ereview your past orders, including location data whilst on delivery, to understand whether you are fulfilling your obligations under your Supplier Agreement, and take any appropriate action (including termination of your Supplier Agreement);
    • fcommunicate with you about operational information relating to your services to Delivery Pal, such as closed zones, any important changes or developments to the Driver App;
    • genable Support and Customer Services to communicate with you to support your services;
    • hoffer you order-specific delivery fees and calculate and administer payments for your driver services;
  • 2We may use your information for compliance with our legal or regulatory requirements to:
    • akeep a record of payments made to you;
    • bcalculate and administer taxes (including, if applicable, withholding taxes) and to report necessary tax information to relevant authorities;
    • ccomply with other legal or regulatory requirements.
  • 3We also process your information where we have a legitimate interest to do so, as set out below:
    • aTo communicate, by email, post, phone, message, push notifications or in-app messages, with you to
      • i.contact you for your feedback on your rider experience;
      • ii.inform you about opportunities to make more money in connection with the services you provide, such as by delivering at certain times or by referring your contacts to consider joining Delivery Pal as a driver;
      • iii.send you news and information in connection with your driver services, the driver community or to help you to understand more about Delivery Pal, such as by sending you news, information and general updates, tech updates, for example to help you to find appropriate road safety equipment.
    • bFor our onboarding and delivery operations to
      • iaudit and store evidence of identity verification, right to work, road licence and insurance checks (where permitted by law) to ensure that you are legally compliant when providing the services and to comply with our internal policies, protect our reputation and mitigate our legal risks;
      • iicheck whether or not you have unspent criminal convictions. We use a “basic” DBS check because it is in our legitimate interests (and the legitimate interests of our customers, other drivers and Partners) to try to prevent our platform from being used for any unlawful purpose and to protect the safety of our customers, other drivers and Partner staff, with whom you will work closely when providing the services;
      • iiienable you to use or benefit from an insurance policy;
      • ivenable our Support, tech and engagement teams to help you with any issues, enquiries or complaints efficiently and effectively, including to fix any bugs or other technical issues in the Driver App using technical information relating to your device;
      • vprovide Delivery Pal services and a positive experience to our customers and Partners, such as by providing live order progress updates using your order progress swipes on the Driver App.
    • cTo develop our business, systems and services to
      • iensure and improve the efficiency of our services, for example to understand from past data (and never live) (such as your past order progress swipes and other Rider App usage, feedback you gave about orders and your past location data), what causes a negative customer, Partner or rider experience, inefficient deliveries or damage to Delivery Pal, and use this past data to responsibly design, develop and test new tools and processes and to improve our business, systems and services;
      • iianalyse data about your past rides to make certain assumptions about the types of promotional offers that may be particularly beneficial to you when providing services to Delivery Pal. For example, this might result in us sending you offers relevant to the area where you most often work;
      • iiitrain our algorithms to make the most effective and accurate decisions, such as training our order despatch algorithm;
      • ivto interact with you (such as via communications or Driver App functionality) to encourage Delivery Pal’s network efficiency based on our analysis of your services.
    • dTo protect Delivery Pal to
      • iexercise or defend legal claims and to exercise and protect the rights of Delivery Pal, drivers, Partners, customers or others, including determining our liability;
      • iienforce the terms of your Supplier Agreement and keep records of such enforcement, including using your information to analyse whether you have breached your Supplier Agreement (such as by misusing the Driver App or acting fraudulently), which may result in us disabling your driver account or terminating your Supplier Agreement if we have the right to do so;
      • iiiinvestigate any complaints or incident reports relating to a rider and to prevent fraud or other misuse of our systems and services;
      • ivenable auto-login for you into the Driver App and for API authentication;
      • vensure the integrity and security of Delivery Pal’s Driver App, Website and related services, and Delivery Pal systems and network.
5COMMUNICATIONS

Where we have a lawful basis for doing so we will use your information to let you know by email, post, phone, message, push notifications or in-app messages about Delivery Pal’s products and services useful to your driver services, about future opportunities with Delivery Pal and/or any promotions from third party partners which are designed to support your provision of services to Delivery Pal, such as by reducing the cost to you of providing services and by helping you to provide the services more safely through special deals we find for drviers. You always have the option to unsubscribe from promotional electronic communications.

6AUTOMATED DECISIONS

Delivery Pal uses automated decision-making to assign orders based on your location and your vehicle type, ensuring that orders are allocated in the most efficient way. A completed delivery under your Supplier Agreement is the collection of order item(s) from one or more Partners and delivery to one or more customer(s). We analyse your information and automatically confirm which deliveries you are due fees for.

You can choose to unassign from a delivery at any time, through the Driver App where possible or by contacting Support. In addition, you can simply reject offers of
orders freely.

We sometimes use automated systems to provide a more accurate, fair and efficient way of identifying suspected fraud and instances of potential breaches of your Supplier Agreement and based on the information collected as described in the Information That We Collect About You section above. These automated systems may result in us temporarily disabling your driver account and conducting a manual review of any incident which could lead to termination of your Supplier Agreement. Please note that we never use solely automated processes to make a decision about whether to terminate a Supplier Agreement (see the Terminating Your Supplier Agreement section below).

7TERMINATING YOUR SUPPLIER AGREEMENT

As described above, we use automated processes to help identify certain events that may indicate a breach of your Supplier Agreement. These automated processes may result in us temporarily disabling your driver account if we suspect fraud or a similar misuse of our systems.

Where we identify a potential breach of a Supplier Agreement, we complete a manual review of the information collected and we may also look for further evidence, such as similar events in the past. This person completing the manual review then makes a decision about the severity of the event and the action required. The action taken could include termination of your Supplier Agreement. We would let you know of any such decision by email and give you the opportunity to respond.

Any decision taken to terminate a Supplier Agreement may also, where appropriate, be checked by another member of our reviews team to confirm the decision taken by the person who examined the case.

8SHARING YOUR INFORMATION

The information we collect about you is transferred to and stored on our servers located within the EU.

  • 1Sharing your information internally: We share your information with other Delivery Pal Apps for carrying out certain processing activities only where necessary for the purposes set out in the Use of Your Information and Why section above.
  • 2Sharing your information with third parties: We do not share your information with any third-party service provider.
  • 3In certain circumstances, we may also share your information:
    • aIf our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.
    • bIf we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal or regulatory requirement. This includes where we’re under a legal obligation or need to provide information to relevant tax authorities, respond to police requests for personal information or to exchange information with other companies and organisations for the purposes of fraud protection and prevention.
    • cWhere we reasonably believe that you or another person has been harmed or is at risk of harm in connection with your driver services for Delivery Pal.
    • dIn order to enforce our contractual terms with you.
    • eIn the event of a dispute relating to your services to Delivery Pal, or to protect the rights of Delivery Pal, Partners, customers, or others, including to prevent fraud.
    • fWith such third parties as we reasonably consider necessary in order to detect or prevent crime, e.g. the police.
9RETENTION OF YOUR INFORMATION

We will only retain your information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain information for a longer period in the event of a complaint.

To determine the appropriate retention period for personal information, we will take into account factors including:

  • 1the amount, nature and sensitivity of the information;
  • 2the potential risk of harm from unauthorised use or disclosure of your information;
  • 3the purposes for which we process your information and whether we can achieve those purposes through other means;
  • 4our contractual obligations and rights in relation to the information involved;
  • 5legal obligation(s) under applicable law to retain information for a certain period of time;
  • 6applicable regulatory, tax, accounting or other requirements;
  • 7statute of limitations under applicable law(s);
  • 8our legitimate interests for retaining the information (see ‘Use of Your information and Why’ above);
  • 9whether there is an actual or potential dispute; and
  • 10

    guidelines issued by relevant data protection authorities.

    In some circumstances you can ask us to delete your information (see Your Rights section below).

    At the end of a retention period, we will delete or anonymise your information (so that it can no longer be associated with you) and is therefore no longer considered personal information. We may use this information indefinitely without further notice to you, for example for research or statistical purposes.

10SECURITY

We adopt robust technologies and policies to protect your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have implemented procedures to deal with any personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we take steps to protect your information, we cannot guarantee the security of your information transmitted to the Website or the Driver App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Where you have chosen a password which allows you to access certain parts of the Driver App or Website, you are responsible for keeping this password confidential. You must keep any password you create, or other secure login method, secret, and prevent unauthorised access to your account. We advise you not to share your password
with anyone.

11YOUR RIGHTS

Under certain circumstances, you have rights under data protection law in relation to the information we hold about you. These include:

  • 1 The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this privacy policy. If your Supplier Agreement has been terminated and you have questions about this, contact the Support team via email at support@deliverypal.app.
  • 2The right of access. This is also known as a “data subject access request”. You have the right to receive a copy of the information we hold about you and to check that we are processing it lawfully.
  • 3The right to rectification. You are entitled to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
  • 4The right to erasure. This is also known as “the right to be forgotten”. You have the right to request the deletion or removal of certain information that we hold about you where there is no good reason for us continuing to process it. This right is not absolute and only applies in certain circumstances.
  • 5The right to restrict processing. You have the right to block or suppress further use of your information in certain circumstances. When processing is restricted, we may still have a lawful reason to hold your information, but we will not use it further.
  • 6The right to data portability. You have the right to receive your information in a structured, commonly used and machine-readable format. This right is not absolute and only applies in certain circumstances.
  • 7The right to withdraw consent. Where we rely on consent to use your information, you have the right to withdraw that consent at any time. Withdrawing consent will not, however, make unlawful our use of your information before you withdraw your consent. If you withdraw your consent we may not be able to provide certain services to you.
  • 8The right to object to processing. You have the right to object to certain types of processing of your information, including processing for direct marketing purposes and profiling.
  • 9You also have the right not to be subject to a decision based solely on automated processing of your information.

    • To exercise any of these rights, please contact our Data Protection Officer in writing via email at support@deliverypal.app. If you are unhappy with how we handled your information you can contact your local data protection authority. In the UK this is the ICO and their contact details can be found by visiting https://ico.org.uk. We would, however, really appreciate the chance to deal with your concerns before you approach your local data protection authority and so we ask that you please contact us first.

12CHANGES TO OUR PRIVACY POLICY

We update this privacy policy from time to time, so remember to check back in every so often, in case anything has changed and, where appropriate, we may notify you of the changes, for example by email or other method.

This privacy policy was published on: 25th April 2024
Xpo-Online Limited, Unit D, Herons Way, Balby Carr Bank, Doncaster, DN4 8WA.