Privacy Policy
The section structure covering what the platform collects, why, and for how long. The wording underneath it is supplied by legal counsel before launch.
This is a draft awaiting review by qualified legal counsel. It is not legal advice and does not yet govern use of Scorto. Bracketed values are facts the operator must supply before publication.
Contents.
Who we are
operating entity name — to be supplied before publication, registered at registered address — to be supplied before publication under company number company registration number — to be supplied before publication, operates the Scorto platform. This policy explains what personal data we handle, why, and what rights you have.
Our role differs by whose data it is. For retailer, courier, and franchise-operator account data we are the controller — we decide why and how it is processed. For end-customer data we are generally a processor: the retailer collects the customer's name, address, and phone number and passes it to us so a delivery can be completed, and the retailer remains the controller of it. If you are an end customer, the business you ordered from is your first point of contact.
Where a franchise operator handles your onboarding or a dispute in your territory, they process your data under our instruction and under a written agreement.
What we collect
From retailers: business name and trading details, business registration or tax identifier, the business owner's identity documents, contact details, Stripe account identifiers, wallet and transaction history, orders dispatched, and disputes raised.
From couriers: name and contact details, a government-issued identity document, the outcome of an identity verification check, vehicle registration and insurance details where a vehicle is used, delivery history, ratings, earnings and deduction records, location data while a delivery is active, and proof-of-delivery photographs.
About end customers, received from the retailer: delivery address, contact telephone number, and order details necessary to complete the delivery. We do not collect customer data directly and customers do not hold accounts.
Technical data: authentication tokens and session records, device and log data, and records of access to the platform. Administrator sessions additionally record multi-factor authentication events.
We do not collect special category data. We do not use the platform to profile individuals for advertising, and we do not sell personal data.
Why we collect it
To operate the service: creating accounts, matching deliveries to couriers, routing and tracking those deliveries, generating estimated arrival times, recording proof of delivery, and settling payments and payouts.
To verify identity and prevent fraud: confirming that a business exists and that a courier is who they say they are, detecting duplicate accounts, and identifying patterns such as repeated cancellation after acceptance or repeated deviation from an assigned route.
To resolve disputes fairly: a refund claim is assessed against delivery logs, location history, and the proof-of-delivery photograph, so that an outcome rests on record rather than on assertion.
To meet legal and accounting obligations, and to communicate operational information such as order status, payout notifications, and material changes to the service.
Legal bases
Where we are the controller, we rely on the following bases under UK GDPR and EU GDPR as applicable.
Performance of a contract: creating and maintaining your account, dispatching and tracking deliveries, and processing payments and payouts. Without this data the service cannot be provided.
Legitimate interests: fraud prevention, identity verification, platform security, route and performance monitoring, and dispute resolution. We have considered the impact on you and have limited monitoring to what an operating delivery platform requires — location is tracked during an active delivery, not throughout a courier's day.
Legal obligation: retaining transaction and tax records, and responding to lawful requests from authorities.
Consent: optional communications only. Where we rely on consent you may withdraw it at any time without affecting the lawfulness of earlier processing.
Location data
A courier's location is processed while a delivery is active, so that the retailer can see progress, an estimated arrival time can be calculated, and significant deviation from the assigned route can be flagged. Tracking is tied to an accepted delivery. It begins when a delivery is accepted and ends when it is completed or cancelled.
We do not track a courier's location when no delivery is active, and we do not use location data to monitor a courier outside working deliveries. Location history is retained against the delivery record so that it is available if that delivery is later disputed.
Location is transmitted over an encrypted connection and stored encrypted. Access is restricted by role: a retailer sees the location of couriers carrying their own deliveries, a franchise operator sees activity in their territory, and central operations sees active deliveries platform-wide.
Routing and estimated arrival times are calculated using Google Maps. Location data shared with that service is subject to Google's own terms and privacy policy.
Proof-of-delivery images
A courier photographs the order at the point of delivery. The photograph is the evidence a dispute is judged on, so it is retained against the consignment record rather than discarded on completion.
Couriers are instructed to photograph the goods at the delivery point and to avoid capturing people, vehicle registration plates, or the interior of a property. A photograph may nonetheless incidentally capture personal data such as a door number or a doorstep.
Access is limited to the retailer who dispatched the delivery, the courier who made it, the franchise operator for that territory, and central operations reviewing a dispute. Photographs are not published, are not used for marketing, and are not used to train any automated system.
If you believe a photograph of your property contains personal data that should not have been captured, contact privacy contact email — to be supplied before publication and we will review and, where appropriate, delete or redact it.
Retention
We keep personal data only as long as it is needed for the purpose it was collected for, or as long as the law requires.
Indicative periods: account and verification records for the life of the account and [RETENTION — ACCOUNT CLOSURE] afterwards; delivery records, including location history and proof-of-delivery photographs, for [RETENTION — DELIVERY RECORDS] from completion, so that they remain available for a dispute; financial and transaction records for [RETENTION — FINANCIAL RECORDS] to meet accounting and tax obligations; customer contact details for the duration of the delivery and no longer.
Where data is retained for a legal obligation, it is retained for that purpose alone and access is restricted accordingly. When a retention period ends, data is deleted or irreversibly anonymised.
Your rights
Subject to the conditions in applicable data protection law, you have the right to access the personal data we hold about you, to have inaccurate data corrected, to have data erased in certain circumstances, to restrict or object to processing, and to receive data you provided in a portable format.
Where processing is based on legitimate interests you may object, and we will stop unless we have compelling grounds that override your interests. Where processing is based on consent you may withdraw it at any time.
To exercise a right, contact privacy contact email — to be supplied before publication. We will respond within one month, extendable by two further months for complex requests, and we will tell you if an extension applies. We may need to verify your identity first. There is no charge unless a request is manifestly unfounded or excessive.
If you are an end customer, ask the retailer you ordered from in the first instance, as they are the controller of your order data. If you approach us directly we will pass the request to them and help them respond.
You may complain to a supervisory authority. In our case that is supervisory authority — to be supplied before publication. You may also complain to the authority where you live or work.
International transfers
We aim to process and store personal data within the United Kingdom and the European Economic Area. Some of our service providers process data outside those areas.
Where data is transferred outside the UK or EEA, we rely on an adequacy decision covering the destination country, or on Standard Contractual Clauses together with the UK International Data Transfer Addendum where required, supported by an assessment of the safeguards in place.
Details of the transfer mechanism relied on for a particular provider are available on request from privacy contact email — to be supplied before publication.
Contact
Questions about this policy, or a request to exercise a right, should be sent to privacy contact email — to be supplied before publication, or by post to operating entity name — to be supplied before publication, registered address — to be supplied before publication.
For general enquiries that do not concern personal data, contact contact email — to be supplied before publication.
We review this policy periodically and when the platform changes materially. Where a change affects how we use your data we will give notice through the platform or by email.