Privacy Notice - Courier

What data do we collect and how will it be used?

When you choose to use Stuart to provide your delivery services, we need access to some of your personal data.

If you are a substitute appointed by a courier, this section also applies to you regarding the verification of your identity and your right to work. However, we do not collect financial data from substitutes.

Integration

We use this data to process your application, create your account, contact you, verify your identity and confirm your eligibility to work.

We keep this data even if the integration process is not completed, in order to improve our services and to prevent any further abusive or fraudulent applications.

Biometric data

As part of your application and in order to verify your identity and prevent fraud, we ask you to provide a copy of your identity papers. We also record a short video of your face. We use a specialised service provider to process your biometric data in the form of facial scans, which are then compared with your identity documents.

Deliveries

Once your application has been approved, you will be able to create an account on Stuart’s Driver Mobile App (DMA).

The DMA will be used to collect location data only when you set your status as available for deliveries. This collection of data will be used by us to assign deliveries, organize supply and demand and solve potential problems related to delivery routes. Clients and customers will also be able to follow the delivery. Lastly, we also keep a record of your deliveries, routes taken and contact with customers as part of the delivery tracking, fraud prevention and litigation management.

Your data may also be used to manage complaints from our customers or recipients of goods for our internal quality improvement process.

Throughout this processing, we collect login data in order to operate and improve our application and website. We use this data to develop statistics to improve our services.

You can find more information on how we use your data in the table below.

Financial Compliance

As part of our commitment to ensuring compliance with applicable legal and regulatory requirements, we partner with a payment solutions provider. This provider will perform its necessary "Know Your Customer" (KYC) checks on independent couriers who use our services. These checks are required to verify identity, prevent fraud, and ensure adherence to their legal obligations. Please note that we do not process financial data or perform financial KYC checks on substitutes, as payments are managed directly by the main courier.

Disabilities

Where applicable, Stuart uses information about your disabilities as required to ensure compliance with the law and make sure the appropriate adjustments are made. This helps us give you the right help and make our service better for you.

This data includes special category data including information about your health.

We only use the details you provide and make sure that this is only shared with the people who have a need to know. We don't share this data unless we are required to do so by law.

Direct Marketing

Where you have given your consent or where we are permitted to do so by law, we will contact you to let you know about Stuart’s products and services including those of our partners.

In most cases, Stuart will contact you via email or in-app notifications. You will have the option to opt-out of such communications.

Please note that Stuart may also contact you with service messages, such as to inform you of updates to our terms and conditions or to notify you of incidents. These are not considered direct marketing and we are not able to offer an opt-out for such communications.

You can find more information on how we use your data in the tables below.

Lawful basis

The table below summarises the lawful bases Stuart relies upon to process your personal data.

Purposes	Lawful Bases
Provision of Services	Contractual Necessity
Right to Work check	Legal obligation
Processing your application to become a courier	Legitimate Interests
Identity Verification (biometric verification)	Explicit Consent
Service and professional vehicle monitoring (including location services in the DMA)	Legitimate Interest
Direct Marketing	Consent (or legitimate interests where we have a pre-existing relationship with you)
Retention of data	Legitimate Interests
Dispute Resolution	Legitimate Interests

Categories of data collected

Category	Purposes	Source	Recipients	Retention period
Personal identifiers (e.g. your name)	● Account creation and management ● Enabling a commercial relationship with customers ● Verification of identity including know your customer (KYC) checks ● Right to Work check ● Fraud prevention ● Handling complaints from customers or recipients of goods ● Direct marketing	● You ● Stuart	● Our service providers ● Subsidiaries ● Customers	Up to 6 months for candidates after the last contact Up to 5 years after termination of the account*.
Contact details (such as your email address)	● To contact you ● Enabling a commercial relationship with customers ● Handling complaints from customers or recipients of goods ● Direct marketing	● You ● Stuart ● Our service providers	● Our service providers ● Subsidiaries ● Customers	Up to 5 years after termination of the account*.
Identity documents (such as your passport or driving licence)	● Verification of identity ● Right to Work ● To meet legal obligations ● Fraud prevention	● You	● Our service providers ● Subsidiaries	Up to 6 months for candidates after the last contact Up to 5 years after termination of the account*.
Financial information (such as bank details)	● Billing	● You ● Stuart	● Our service providers	Up to 5 years after termination of the account*.
Financial information (such as bank details)	● Billing	● You ● Stuart	● Our service providers	Invoices are kept for 10 years from the end of the tax year*.
Vehicle related data (type, usage indicators)	● Organisation of deliveries ● Follow-up of deliveries ● Improvements to our services)	● You ● Our partners	● Subsidiaries ● Our service providers ● Our partners	Up to 5 years after termination of the account*.
Connection data (such as IP address)	● Follow-up of deliveries ● Improving our services ● Security of our systems	● You ● Our service providers	● Subsidiaries ● Our service providers	Up to 5 years after termination of the account*.
Delivery history	● Billing ● Follow-up of deliveries ● Improving our services ● Handling complaints from customers or recipients of goods ● Fraud prevention	● You ● Stuart ● Our service providers	● Our service providers ● Subsidiaries ● Customers	Up to 5 years after termination of the account*.
Location data (such as GPS coordinates in the DMA)	● Dispatching and follow-up of deliveries ● Management of potential problems related to delivery routes ● Visibility for Clients and end-customers ● Fraud prevention and litigation/complaint management	● You ● Our service providers	● Our service providers ● Subsidiaries ● Customers	Up to 3 months after the completion of the delivery*.
Biometric data (facial scans)	● Identity verification and authentication ● Fraud prevention	● Our service providers	● Our service providers	Deleted after verification

*Termination as defined in Article 14 of our General Terms and Conditions.

We may need to process this data for a longer period of time when required by law, to settle a dispute or to ensure the security of our systems.

Stuart does not sell your personal data to third parties.

What are your rights?

You can :

Accessing your data ;
Correct inaccurate personal data about you;
Limiting our processing of your data;
Request the erasure of your data** ;
Object to the use of your data, where we base our processing on the legal basis of legitimate interest***.

You can find more information about your rights and how to exercise them here, as well as the measures taken to protect your privacy.

**The right to be forgotten applies unless the data must be retained due to legal or regulatory requirements, for safety, security and fraud prevention purposes, or due to an account issue such as an unresolved claim or dispute.

***You will need to provide Stuart with the reasons relating to your particular circumstances for objecting. Stuart may continue to process the data, and therefore reject your request, if there are compelling legitimate grounds for the processing which override the interests and rights of the data subject, or if the data is necessary for the establishment, exercise or defence of legal claims