This Policy applies to our API solution, website (Stuart.com), and to our mobile application software ("App"). However, you should also refer to the General Conditions of Use (“GCU”). If you are one of our Independent Couriers, you should in addition refer to the Special Conditions (“SC”).
Capitalised terms used in this Policy have the meaning given to them in the GCU.
Primarily this Policy is relevant to our Members, who are either Users of our Services, or Independent Couriers, who help us provide our Services. However, it is also relevant to customers who receive Stuart deliveries, and to general visitors to our website.
No matter who you are, your privacy is important to us. We keep your information secure and manage it in accordance with our legal responsibilities.
The controller of your personal information is Stuart Delivery Limited.
By providing us with your personal information, you agree to it being used and disclosed in the manner set out in this Policy.
You do not have to provide your personal information to us, but without it there may be limits on the Services you can receive.
1. What personal information do we collect?
When you browse Stuart.com, we collect certain limited information (such as your browser type and IP address) automatically. We do this whether or not you are a Member. See below for more about why we collect this information, and about the cookies and analytics services which support our website and App.
The personal information we collect is set out in the table below. We have broken the information down into groups which tell you when the information is collected, and how long, in general, we keep it for. "Non-members" may be Senders or Recipients of deliveries whose details are entered on their behalf by a User.
Group 1: When you create an Account with us or when you opt to receive a delivery
- Country of residence (or establishment of the company)
- Postal address
- Email address
- Telephone number
- Name of the company
- Estimated number of deliveries
How long do we keep it?
- Members: for 42 months from the date you last log-in to the App
- Non-members: for 42 months
Group 2: When you use the App or when a delivery is in progress
- IP address
- Navigation data
- The specific location of your mobile device (if you allow us to access your device's location services)
- Your delivery history potentially including the place where you were at a given hour
- The history of the trips taken to make your deliveries
- The specific location of the Independent Courier's device (which may also reveal a Member's or User's location at the time goods are collected, or delivered)
- The delivery route taken by an Independent Courier
- Incidents or complaints relating to a delivery
- Calls and text messages between Members
- Your signature
- A description of the goods
How long do we keep it?
- For IP address, credentials and navigation data
- Members: for 12 months from the date you last log-in to the App
- Non-members (where relevant): for 12 months
- For the other information
- Members: for 42 months from the date you last log-in to the App
- Non-members (where relevant): for 42 months
Group 3: When you are invoiced for, or pay for, Services
- Payment details
- Transaction history
How long do we keep it?
2. Why do we collect personal information?
The overall purposes for collecting personal information are:
- To manage your Account with us;
- To make our Services available to you; and
- To improve our Services, our App and our website.
Some of the more detailed and specific purposes are set out below. We have also given an indication of which groups of information from Section 1 are most relevant to each purpose, as well as the lawful basis we rely upon to use your personal information for that purpose. Our lawful basis impacts, amongst other things, the rights which are available to you.
- Setting up an Account (1) ('contractual necessity');
- Managing your Account and resolving Account queries (1) ('legitimate interests' and 'contractual necessity');
- Allowing you to access our Services (1 and 2) ('contractual necessity');
- Putting you in touch with Independent Couriers (1 and 2) ('contractual necessity');
- Handling the commercial relationship with our Members and between our Members (1, 2 and 3) ('legitimate interests');
- Undertaking tracking and fulfilment of deliveries (1 and 2) ('legitimate interests' and 'contractual necessity');
- Providing assistance to a Member when delivering goods (1 and 2) ('legitimate interests' );
- Facilitating intermediation between a User and a Stuart (1 and 2) ('legitimate interests' and 'contractual necessity');
- Handling payments and resolving billing queries (3) ('contractual necessity'); and
- Technical and practical improvement of the Services (2 plus cookies and analytics) ('legitimate interests').
Where some of the above services are optional in nature, we may also make these consent based. It will be apparent to you where we attempt to obtain your consent, and, in these circumstances, you will have a right to withdraw your consent at any time.
We might also use your contact details to get in touch with you from time to time to tell you about improvements to our Services. We may also send you messages about similar products and services which we offer, and which we think you might find interesting. If at any time you do not want to receive these messages, you can contact us using the details set out below, or you can use the unsubscribe link at the bottom of our emails. If we obtain prior opt-in consent, then our lawful basis for marketing to you will be consent. However, we may also market to existing Members on a 'legitimate interests' basis, subject to your right to prevent marketing at any time.
For Independent Couriers Only
As set out above and in the SC, we will track the location of your device when it is switched on and set to "Available". We do this to monitor the deliveries which you accept, and to ensure the quality of our Services. In line with the SC, we may review the route taken to complete a delivery following a complaint from a User, and might take actions in accordance with Annex II of the SC based on that information.
We might use your contact details to get in touch and ask you if you would like to refer a friend who you think might be interested in working as an Independent Courier. If you provide us with the contact details of a third party, you are verifying that you believe they would be happy to be contacted by us about such an opportunity.
3. Who is your information shared with?
As a basic principle, your personal information is only provided to the members of our team who need to access it to deliver the Services to you.
Your personal information will also be available to the Stuart who delivers your goods.
Third Party Providers
We may provide your personal information to third party service providers who process information on our behalf to help deliver the Services. We take steps to ensure that third parties who have access to your personal information treat it with the same consideration that we do.
Your information may be shared with other Stuart entities and third party organisations located in other countries around the world (e.g. where a service provider is located overseas). As privacy laws in other countries may not be equivalent to those in your home country, we only make arrangements to transfer data overseas where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws.
Where required under applicable laws we will take measures to ensure that personal information handled in other countries will receive at least the same level of protection as it is given in your home country. We do so by implementing safeguards such as standard contract clauses, or reliance on certification schemes, such as the EU - U.S. Privacy Shield Framework. You have a right to contact us for more information about the safeguards we have put in place.
From time to time we may be required to disclose information about you to law enforcement bodies, agencies or third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests.
You understand that we may disclose or share personal information with third parties as outlined above to deliver our Services, and, where applicable, in accordance with your expressed wishes. If you are concerned about these arrangements, you should not use our Services.
4. Cookies and analytics
We use analytics tools and cookies on our website and the App to help deliver our Services, identify any service issues, improve our Services, provide content tailored to Members' personal preferences, remember Account details and monitor site traffic and usage.
These tools may be provided by third-party service providers (Facebook, Google, LinkedIn, …) and may include the collection and tracking of certain data and information regarding the characteristics and activities of visitors to our website or App. We may disclose data, including personal information, to certain such third-party services providers in order to obtain such services.
One of these providers is Google Analytics and more information about the ways in which they collect and process your personal data can be found here: (https://www.google.com/policies/privacy/partners).
More about cookies
A cookie is a small file deposited by us on the device you use to access our website or App.
Cookies collect information about the pages of the App or website you have viewed. They allow us to make improvements to our Services over time.
We collect both "session" and "persistent" cookies. The former are not usually stored after your browsing session has ended. The latter are stored for longer. However, no cookies will be stored on your device for more than 13 months.
The cookies which we use are described in more detail below:
You can find further help on the dedicated pages of your browser. Some of the most common are here:
You can also configure your browser to send you a code, indicating the websites you do not want to be tracked (“Do Not Track” option):
5. Protecting you and your rights
Keeping information secure
We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. User and Recipient phone numbers are encrypted, and will not be made available to an Independent Contractor unless the User and/or Recipient notifies the Independent Contractor directly.
However, you should bear in mind that no internet-based platform can be 100% secure and so we cannot be held responsible for unauthorised or unintended access that is beyond our control.
The Company shall take all reasonable precautions to ensure the secure storage of your password.
However, the security of your password also depends on its design.
It is preferable to have a sufficiently long password, composed of at least 3 different character types (letter, number, special character). It should also not have any obvious connection with you (e.g. your address or your partner's name).
Mnemonics make it possible to create complex passwords, such as:
- only use the first letters of the words of a phrase; for example the phrase "It's easier to deliver with Stuart" corresponds to the password I'e2dwS;
- using a capital letter if the word is a noun (e.g. Stuart);
- keeping punctuation signs (e.g. ’); and
- using the figures 0 to 9 (e.g. 'to' becomes '2').
Exercising your rights
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have the following rights:
- to request a copy of your personal information which is within our custody and control, together with details about how we use that information;
- to request that we correct inaccurate or misleading personal information;
- to erase personal information (if we are no longer entitled to process it),
- to restrict the processing of your personal information,
- to transfer your personal information where it is based on 'contractual necessity' or 'consent',
- to object to the processing of personal information which is based on 'legitimate interests',
- to object to how we use your personal information for direct marketing purposes,
- to obtain a copy of personal information safeguards used for transfers outside of the European Economic Area,
- to lodge a complaint with your local supervisory authority. In the UK, this is the Information Commissioner's Office.
In relation to all of these rights, please email or write to us at the address below. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
If you have a complaint about how we have handled your personal information you can contact us using the details below and we will investigate your complaint.
We keep this Policy under regular review and update it from time to time. Please review this Policy periodically for changes.
If you do not accept the amended Policy, please stop using our Services.
If you have any questions about this Policy, or would like to exercise your rights with respect to your personal information, please contact us via email@example.com or write to:
Stuart Delivery Limited, 71 Central Street, London, United Kingdom, ECV1 8AB