Privacy Policy

1. Data We Collect

We collect and process the following personal data to operate the 121Deliveries platform:

Account Data: Name, email address, phone number, and account role (client or courier).

Courier Compliance Data: Identity documents, right-to-work verification, courier insurance, and vehicle details.

Real-Time Location Data: Accurate and approximate GPS location data of couriers. This is collected when the courier is online, available for jobs, and during active deliveries (including when the app runs in the background). Location data is strictly used for courier discovery, dispatch matching, tracking active deliveries, and platform safety.

Order & Delivery Data: Pickup and delivery addresses, store/business references, order status, delivery verification metadata, chat logs, and timestamps.

Payment & Billing Data: Transaction metadata related to platform fees, courier billing periods, outstanding balances, and invoices. We do not store financial account or card details. Payments from couriers to the platform are processed securely by our third-party provider, GoCardless (Open Banking). Delivery payments between clients and couriers are settled directly in cash/personally.

2. Lawful Basis for Processing

We process personal data under the UK GDPR on the following lawful bases:

• Contract: To provide and maintain our platform services, match jobs, and facilitate delivery agreements.
• Legitimate Interests: To maintain platform security, prevent fraud, manage courier billing periods/automated suspensions, and improve our services.
• Legal Obligation: To comply with UK accounting, tax, and regulatory requirements.

3. How We Use Your Data

We use the collected data to:

• Operate, maintain, and optimize the 121Deliveries marketplace.
• Match clients with available local couriers in real time.
• Display live delivery tracking to clients during an active job.
• Facilitate direct operational communication (in-app chat/calls) between clients and couriers regarding active orders.
• Calculate platform commissions, manage automated billing periods (via cron updates), and process payments via GoCardless.
• Detect, prevent, and address technical issues, fraud, or safety incidents.

4. Data Sharing

Client and Courier Sharing: Courier names, vehicle details, contact numbers, and real-time GPS locations are shared with clients strictly during active delivery assignments to facilitate successful completion.

Third-Party Service Providers: We share necessary billing metadata with GoCardless to process platform fees. We also use secure hosting and database infrastructure to run the system.

Legal Requirements: We may disclose data if required by UK law, law enforcement, or regulatory authorities.

We do not sell your personal data to any third parties.

5. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy:

• Account Data: Retained for the duration of your active account and as required by law post-closure.
• Order & Billing Records: Retained for up to 6 years to comply with UK tax and accounting laws.
• GPS Location Data: Generally retained for 30 days, unless a longer retention period is required for dispute resolution, fraud investigation, or legal claims.
• In-App Chat Logs: Retained for 12 months from the date of the message.

6. Security

We implement appropriate technical and organisational security measures designed to protect your personal data against unauthorised access, loss, alteration, misuse, or disclosure. Server interactions, authentication tokens, and payment processing are fully encrypted.

7. Your Rights Under UK GDPR

You have the following rights regarding your personal information:

• The right to access your personal data.
• The right to rectify inaccurate or incomplete data.
• The right to request the deletion of your data (subject to legal retention requirements).
• The right to restrict or object to certain data processing activities.
• The right to data portability.

To exercise any of these rights, please contact us at: privacy@121.app

If you believe your data has been handled incorrectly, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) (www.ico.org.uk).

8. Data Controller

Maciej Woldanski trading as 121Deliveries
United Kingdom
ICO Registration Number: [Wpisz swój numer po rejestracji w ICO]

9. Platform Role & Disclaimers

121Deliveries is a technology platform that acts solely as an independent marketplace connecting clients with independent self-employed couriers. 121Deliveries is not a transport provider, carrier, or employer, and is not a party to the delivery agreement or cash settlement made directly between the client and the courier.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect operational, technical, or legal changes (such as updates to billing frequencies or integrated payment webhooks). Any changes will be published directly within the platform with an updated effective date.