Privacy Policy

Privacy and Data Protection Policy for
Kindra Cargo

Last Updated: 30/07/2024

Table of Contents
1. Introduction
2. Identity and Contact Details of the Data Controller
3. Contact Details for Data Protection Inquiries
4. Categories of Personal Data Collected and Purposes of Data Processing
5. Legal Basis for Processing
6. Recipients or Categories of Recipients of the Personal Data
7. Details of Data Transfers Outside the UK
8. Data Retention Periods
9. Data Subject Rights
10. Right to Withdraw Consent
11. Right to Lodge a Complaint with the ICO
12. Source of Personal Data
13. Automated Decision-Making and Profiling
14. Cookies and Tracking Technologies
15. Changes to This Policy
16. Age Verification and Children’s Privacy
17. Data Security Measures
18. Data Breach Notification
19. Updating Your Personal Data
20. Special Category Data
21. Third-Party Services or Links
22. Glossary of Terms

Introduction

Welcome to Kindra Cargo (“we”, “our”, “us”). We are committed to protecting and respecting
your privacy. This Privacy and Data Protection Policy outlines how we collect, use, and
protect your personal data when you use our courier app for drivers to accept bulk loads
from customers.

1. Identity and Contact Details of the Data
Controller
Kindra Cargo LTD
181 Balfour Street, OL41NS
Email: admin@kindracargo.co.uk
Phone: +44 7441395840

2. Contact Details for Data Protection Inquiries
We do not currently have a designated Data Protection Officer. For any questions about this
policy or our data protection practices, please contact us using the details provided in
Section 1.

3. Categories of Personal Data Collected and
Purposes of Data Processing
We collect and process the following types of personal data for the specified purposes:
a) Identification data (e.g., name, address, email, phone number):- To create and manage your account- To communicate with you about our services- To verify your identity for security purposes

b) Location data (e.g., GPS data):- To match drivers with nearby customers- To track deliveries and provide estimated arrival times

c) Vehicle information (e.g., make, model, registration number):- To verify driver eligibility- To ensure appropriate vehicles are matched with specific loads

d) Transaction data (e.g., payment information, order details):- To process payments- To maintain records of services provided

e) Device data (e.g., IP address, browser type):- To improve our app’s functionality- To detect and prevent fraud
Example: When you sign up as a driver, we collect your name, email, and phone number to
create your account and communicate with you about available loads.

4. Legal Basis for Processing
We process your personal data based on the following legal grounds:
a) Contractual Necessity:- Processing identification data, location data, and transaction data to provide our courier
services

b) Legal Obligation:- Retaining transaction data for tax and accounting purposes

c) Legitimate Interests:- Using device data to improve our services and prevent fraud- Processing vehicle information to ensure appropriate matching of drivers and loads
Example: We have a legitimate interest in using your location data to efficiently match you
with nearby delivery opportunities, which benefits both drivers and customers.

d) Consent:- Sending marketing communications (which you can opt out of at any time)
We have carefully considered and balanced our legitimate interests against your individual
rights and interests.

5. Recipients or Categories of Recipients of the
Personal Data
We may share your personal data with:- Payment processors to handle transactions- Cloud storage providers to securely store your data- Analytics providers to help us improve our services- Regulatory and law enforcement authorities if required by law
We ensure that all third-party service providers are contractually bound to protect your
personal data in compliance with UK GDPR.

6. Details of Data Transfers Outside the UK
Currently, we do not transfer your personal data outside the UK. If this changes in the future,
we will update this policy and ensure that any such transfers are protected by appropriate
safeguards, such as:- Transferring to countries deemed adequate by the UK government- Implementing standard contractual clauses approved by the ICO- Obtaining your explicit consent for the proposed transfer

7. Data Retention Periods
We retain personal data for as long as necessary to fulfil the purposes outlined in this policy
unless a longer retention period is required or permitted by law. Specific retention periods
include:- Account data: Retained for the duration of your account, and for 6 months after account
closure to handle any post-closure queries or disputes- Transaction data: Retained for 5 years for tax and legal compliance- Location data: Retained for 30 days to handle any delivery disputes- Device data: Retained for 12 months to support fraud detection and prevention

8. Data Subject Rights
Under UK GDPR, you have the following rights regarding your personal data:

– Right to access: Request access to your personal data within 30 days of your request

– Right to rectification: Request correction of inaccurate or incomplete data within 30 days

– Right to erasure: Request deletion of your personal data under certain conditions, within 30 days

– Right to restrict processing: Request restriction of processing under certain conditions

– Right to data portability: Request transfer of your data to another service in a
machine-readable format

– Right to object: Object to processing based on legitimate interests or for direct marketing
To exercise these rights, please contact us using the details provided in Section 1. We will
respond to your request within 30 days.
Example: If you want to access all the personal data we hold about you, you can email us at
admin@kindracargo.co.uk with your request, and we’ll provide the information within 30
days.

9. Right to Withdraw Consent
Where we process data based on consent, you have the right to withdraw this consent at
any time by contacting us using the details in Section 1. This will not affect the lawfulness of
processing based on consent before its withdrawal. Please note that withdrawing consent for
essential communications may affect our ability to provide you with our services.

10. Right to Lodge a Complaint with the ICO
If you believe your data protection rights have been violated, you have the right to lodge a
complaint with the Information Commissioner’s Office (ICO):
Website: www.ico.org.uk
Phone: 0303 123 1113

11. Source of Personal Data
We primarily collect data directly from you when you use our app. In some cases, we may
receive data from third parties such as:

– Credit reference agencies for identity verification- Insurance providers for driver eligibility checks
We will inform you if we collect personal data about you from sources other than direct
interaction.

12. Automated Decision-Making and Profiling
We use automated processes to match drivers with customer loads based on location,
vehicle type, and availability. This automated decision-making is necessary for the
performance of our contract with you. While this process doesn’t produce legal effects, it
does determine the delivery opportunities presented to you. You can request human
intervention, express your point of view, or contest any automated decisions by contacting us
using the details in Section 1.
Example: Our system might automatically match you with a nearby bulk load delivery based
on your location and vehicle type. If you believe you’ve been unfairly excluded from a
delivery opportunity, you can contact us to review the decision.

13. Cookies and Tracking Technologies
Our app uses the following types of cookies and similar technologies:

– Strictly necessary cookies: To enable core app functionality- Performance cookies: To analyse app usage and improve our services

– Functionality cookies: To remember your preferences
You can manage your cookie preferences through your device settings or by contacting us.

14. Changes to This Policy
We may update this policy from time to time. We will notify you of any significant changes via
email and in-app notification at least 30 days before the changes take effect. We encourage
you to review this policy periodically.

15. Age Verification and Children’s Privacy
Our app is not intended for use by individuals under the age of 18. We implement age
verification checks during the account creation process. If we become aware that we have
collected personal data from a minor without parental consent, we will take steps to delete
such information promptly.

16. Data Security Measures
We implement robust security measures to protect your data, including:- Encryption of data in transit using TLS 1.3 protocol- Encryption of data at rest using AES-256 encryption- Regular security audits and penetration testing by third-party specialists- Multi-factor authentication for user accounts- Strict access controls and authentication procedures for our staff

17. Data Breach Notification
In the event of a data breach that is likely to result in a high risk to your rights and freedoms,
we will notify you and the ICO without undue delay, within 72 hours of becoming aware of
the breach. This notification will include the nature of the breach, likely consequences, and
measures taken to address the breach.

18. Updating Your Personal Data
You can update your personal information at any time by logging into your account or by
contacting us using the details in Section 1. We encourage you to promptly update your
information if it changes.

19. Special Category Data
We do not intentionally collect or process special category data (such as health information,
biometric data, or information about racial or ethnic origin). If we need to process such data
in the future, we will only do so with your explicit consent or where permitted by law, and we
will update this policy accordingly.

20. Third-Party Services or Links
Our app may contain links to third-party websites or services. We are not responsible for the
privacy practices of these third parties. We encourage you to review their privacy policies
before providing any personal information.

Glossary of Terms

– **Personal Data**: Any information relating to an identified or identifiable natural person

– **Data Controller**: The entity that determines the purposes and means of processing
personal data.

– **Data Processing**: Any operation performed on personal data, such as collection,
recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation,
use, disclosure by transmission, dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction.

– **UK GDPR**: The United Kingdom General Data Protection Regulation, the data
protection law that applies in the UK.

– **ICO**: Information Commissioner’s Office, the UK’s independent authority set up to
uphold information rights in the public interest.

– **Cookies**: Small text files that are placed on your device to help the website provide a
better user experience.

– **Special Category Data**: Personal data revealing racial or ethnic origin, political opinions,
religious or philosophical beliefs, trade union membership, genetic data, biometric data, data
concerning health or data concerning a natural person’s sex life or sexual orientation.

—
This Privacy and Data Protection Policy ensures that your personal data is handled in
compliance with the UK GDPR, providing transparency and protection for our users. For any
questions or concerns, please contact us using the details provided in Section 1