Privacy Policy

Last updated : 17 May 2024

Where this privacy policy refers to “Delivery Pal”, “we”, “us", “our”, this means Xpo-Online Ltd (company number 8870473). Xpo-Online Ltd’s registered address is Unit D, Herons Way, Balby Carr Bank, Doncaster, DN4 8WA.

Delivery Pal is committed to protecting the privacy of individuals who represent a partner which has a corporate relationship with Delivery Pal or is a prospective business partner of Delivery Pal (Partner(s)).

Please read this privacy policy which explains how and why we collect, use and protect your information.

1.Contact details
If you have any queries or requests about this privacy policy or how we handle your information more generally, you can get in touch by contacting our Support team by email at support@deliverypal.app.
2.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. We collect your information in a variety of ways, such as when we onboard a restaurant as a new partner and when you use the Delivery Pal Apps. More details about how your information is collected are listed below.

a.Lead generation

When looking for opportunities with new partners, we may obtain your business contact details from a third-party source, such as LinkedIn, Google, a publicly available source, business data provider, or a business contact that has provided us with your details.

b.Negotiation of a contract with Delivery Pal Partners

When a contract is being negotiated with a Delivery Pal Partner, we ask you as a Partner Representative to provide information about yourself including your name, business contact details and business address. We may record calls and meetings for quality and training purposes. We will inform you of such recording and give you the opportunity not to be recorded.

c.Onboarding a new Delivery Pal Partner

To complete the onboarding process, Delivery Pal will conduct due diligence on new Partners, which includes identity and tax verification checks. As part of our checks on Partners we require Partner Representatives to complete an identity verification using our third-party identity verification provider. If you are tax registered, we will also conduct a tax verification using the Partner’s tax identification number. During the onboarding process, we create a business profile for the Partner, and we will ask the Partner Representative to provide information in order to create and maintain this partner profile, which will include business payment data. 

d.Management 

When there is a change of ownership, we process your personal information as a Partner Representative for the purposes of managing the Partner’s relationship with Delivery Pal, which includes conducting an identity verification as described above. Where a Partner chooses to register via the Delivery Pal Partner App (App) , we will collect your personal information as a Partner Representative, for the purposes of registering on the App and to enable the Partner to access the App.

e.Payment

When we make payments to or receive payments from Partners, we produce payment files (which are transferred to third party providers for the purposes of processing payments), which include Partner payment data and may include your name if you’re a sole trader or an unincorporated business.

f.Your location

When you have provided permission at a device level, we process location data obtained from your use of the App and via our security providers. This is collected for the reasons explained in “Use of your information and why” below.

g.Support

When a Partner requires support from us we collect certain information, such as information about your query, notes regarding the issue, your use of the App (if relevant) and your contact details, as a Partner Representative. When you interact with our Support team (“Support”) via email, phone, post, chat or on the App, including when you report any incident, our team collects and uses information about you. If you contact Support by phone, your calls may be recorded and analysed for performance, training, and improvement purposes.

h.Technical data

We collect technical information about your device and your use of your device, including through the use of cookies and similar technologies to: 

  • enable auto-login for you into the App; and
  • obtain technical information about your device, including characteristics of and performance data about your device, the App and operating system, your device type, network connection type, IP address from which you are accessing the App, app version, device language, screen size and platform.
  • When it comes to cookies and similar technologies, you can change your cookie preferences at any time, and withdraw 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, our websites may not work properly.
i. Information about the services

We collect information about you from the feedback you send us or provide to us. When you use websites or applications of third parties in connection with the services being provided by Delivery Pal, including during the 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.

3.Use 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 by law. We process your information where we have a justifiable reason for doing so. We have listed these reasons below.

To facilitate the contract between Delivery Pal and the Delivery Pal Partner to:
  • provide and manage the Partner application, account, and onboarding process, as well as to execute a contract between the Partner and the relevant Delivery Pal entity;
  • provide you with access to and use of the App as a means of Delivery Pal providing the Partner with services, including to enable the Partner to
    make orders;
  • communicate with you about operational information relating to any services being provided to you by Delivery Pal, such as any important changes or developments to a Delivery Pal App and about your upcoming booked orders;
  • Support to communicate with you to support the provision of services to the Delivery Pal Partner; and
  • enable us to process payments to or from the Delivery Pal Partner.
To communicate with you to:
  • help you complete the Delivery Pal Partner application;
  • get your feedback through surveys for our marketing or advertising materials, in which case we will not identify you unless you have consented to Delivery Pal using your information in this way. We also use your survey comments and feedback for our internal business purposes, such as to generate aggregated insights to help us assess and improve our services. Your name will not be used when generating or sharing these aggregated insights;
  • provide you with news and information in connection with Delivery Pal and to help you to understand more about Delivery Pal, by email or phone;
  • inform you of Delivery Pal product updates; and
  • provide support to you for live operations.
For onboarding and managing our relationship with Delivery Pal Partners to:
  • create and maintain Partner account information;
  • enable our Support, tech and engagement teams to help you with any issues, enquiries or complaints efficiently and effectively, and to fix any bugs or other technical issues in our Apps using technical information relating to your device;
  • use location data for the purposes of confirming the position of your restaurant (if relevant) to avoid drivers arriving at the incorrect location; 
  • arrange to take pictures of restaurant premises for the Delivery Pal app or website; and
  • maintain a list of restaurants that Delivery Pal has onboarded.
To develop our business, systems and services to:
  • understand from your data what attributes to a positive or negative customer, restaurant or driver experience with Delivery Pal and what might cause inefficient deliveries or damage to Delivery Pal, and use this data to responsibly design, develop, test and implement new tools, processes, and relationships to improve our business, systems and services;
  • analyse data to make certain assumptions about your position within the Delivery Pal Partner entity so that we send you the types of promotional offers that may be particularly relevant to your area of business;
  • use basic location data on an aggregate basis to develop and improve our business;
  • promote and improve our services, by making it easier for drivers to find your business location and contact details;
  • interact with you (such as via communications or App functionality) to encourage Delivery Pal’s network efficiency based on our analysis of your services; and
  • analyse your activity on the App so that we can administer, support, improve and develop our business and for statistical and analytical purposes and to help us to prevent fraud.
To protect Delivery Pal:
  • for the exercise or defence of legal claims and to exercise and protect the rights of Delivery Pal, restaurant partners, customers, drivers, or others, including determining our liability;
  • to enforce the terms of any contract and keep records of such enforcement, including using your data to analyse whether you have breached a contract (such as by misusing the App or acting fraudulently), which may result in us disabling or terminating a contract if we have the right to do so; and
  • to investigate complaints or incident reports relating to Delivery Pal’s relationship with Partners and prevent fraud or other misuse of our systems and services, including by using systems to assess whether or not a Partner’s dispute is valid or whether a partner is operating in compliance with our partner agreement.
We also process your information where we are under a legal or regulatory obligation to do so. We use your information to:
  • carry out our due diligence, including by performing identity verification checks using our third-party ID verification service provider and
    tax verification checks;
  • keep a record of payments made to or from the Delivery Pal Partner to the extent they include your information;
  • comply with any other legal obligation or regulatory requirement to which we are subject.

Where we rely on our legitimate interest as a basis for processing your information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interest for processing.

4.Communications

Where we have a lawful basis for doing so (and are permitted to do so by law) we will use your information to let you know by email, post, phone, SMS, push notifications or in-app messages about Delivery Pal’s products and services and/or any promotions from third parties relevant to your business (such as about broadband and telecommunications services, payment processing, and customer review platforms). Where local law requires us to, we will ask for your consent before sending the relevant communication and offer an option to unsubscribe from these communications.

5.Sharing your information

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

Sharing your information internally: We share your information with other Delivery Pal Companies carrying out certain processing activities only where necessary for the purposes set out in the “Use of Your Information and Why” section above.

We share your information with third party service providers that provide services on our behalf, including:

  • IT service providers: including cloud, software, analytics, communications and data storage providers and SDKs.
  • Operational service providers: including feedback and survey providers, onboarding providers, our support service providers, payment providers, user research partners, marketing agencies, professional advisors, financial and administrative services providers and other suppliers, business partners, contractors and subcontractors.
  • Drivers: where a Delivery Pal Partner is registered on the App, we will share your contact details with the drivers in order to facilitate transactions on the App.

In certain circumstances, we will also share your information:

  • if 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;
  • if 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 obligation or regulatory requirement. This includes where we’re under a legal obligation to or need to provide information to relevant tax authorities, respond to police data requests or to exchange information with other companies and organisations for the purposes of fraud protection and prevention;
  • in order to enforce our contractual terms with the Delivery Pal Partner;
  • in the event of a dispute relating to the Partner’s services to Delivery Pal or the services provided to the Delivery Pal Partner, or to protect the rights of Delivery Pal, Delivery Pal Partners, customers, or others, including to prevent fraud; and
  • with such third parties as we reasonably consider necessary in order to detect or prevent crime, eg. the police.
6.Data transfers

In some cases the personal information we collect from you as a Delivery Pal Partner Representative may be processed outside of the country in which you reside. These countries may not have the same protections for your information as in your country of residence. However, we are obliged to ensure that your information processed by us and our suppliers outside of your country is protected in the same way as it would be if it was processed within your country.

Whenever we transfer your information outside of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • we will only transfer your information to countries that have been deemed to provide an adequate level of protection for personal information; or
  • where we use certain service providers, we may use specific contracts approved for use in the UK or the EEA, as applicable, which give personal information adequate protection.
7.Retention 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 periods for information, we will take into account factors including:

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

8.Security

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 websites or the Apps; 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 Apps or websites, 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. If you choose to share your password with your substitute, please make sure they are also aware that they must keep it confidential and secure and not share it with anyone else.

9.Your rights

In certain circumstances, under local data protection law, you may have rights in relation to the information we hold about you. We will handle a request to exercise these rights in line with the applicable law.

If you are in the UK or the EU, you have the following rights:

  • 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 policy.
  • The right of access. This is also known as a “data subject access request”. You have the right to receive a copy of your information if we hold any information about you and to check that we are processing it lawfully.
  • The 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.
  • The 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. The right is not absolute and only applies in certain circumstances.
  • The right to restrict processing. You have rights 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.
  • The 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.
  • The 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.
  • The 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.

If you wish to exercise your privacy rights, please contact Support in writing at support@deliverypal.app.

10.Changes 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 will notify you of the changes, for example by email or another method. Any changes to our privacy policy will be posted on the Delivery Pal website and to the App and, as appropriate, through notification in the App or by email.

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