Dynamite Technologies OU ("we", "our", “us” or " Tcourier network ") is committed to protecting the privacy of riders who apply to ride with us (“Courier applicants”), our riders and their substitutes, including all users of the rider mobile device application (the " Tcourier network App") and related services. We’ll be the “data controller” of the information we collect about you.

This privacy policy applies to Tcourier network Applicants, riders and substitutes (to the extent that we are able to identify you, except for paragraphs 2.1 to 2.3 and any other references to the application and on boarding process, which do not apply to substitutes) (“you” or “your”). If you are a rider, you must ensure that your substitute has read this privacy policy before riding with us. When a rider engages a substitute, the rider and substitute will have access to each others’ information shown in the Tcourier network App, such as recent deliveries and tips.

If you have any queries or requests concerning this privacy policy or how we handle your data more generally, please get in touch with us using the following details.

• By contacting our Data Protection Officer: [email protected]

We collect your information in a variety of ways, such as when you apply for TCouriers Membership and when you use the Tcourier network App. More details about how your information is collected are listed below.

• When you apply to ride with Tcourier network , we ask you to provide information about yourself including your name, contact details, vehicle type, date of birth, postcode, your right to work, and whether you have any unspent criminal convictions.
• During the application process, we (or a third party) will ask you to provide further information and documents, such as a copy of your passport and proof of address for criminal background checks and right to work checks. If you are required by applicable law to have a licence or insurance for your vehicle type, we’ll also ask you to provide evidence that you’re compliant with this law, as well as your vehicle registration details. We will track the progress of your application and record the results of your criminal background check.
• During the application process, we (or a third party) will ask you to provide further information and documents, such as a copy of your passport and proof of address for criminal background checks and right to work checks. If you are required by applicable law to have a licence or insurance for your vehicle type, we’ll also ask you to provide evidence that you’re compliant with this law, as well as your vehicle registration details. We will track the progress of your application and record the results of your criminal background check.

• We record your deliveries, your tips if obtained via the Tcourier network App, your calculated fees and associated fee statement. We also record your self-serve bookings requested, made and confirmed through the Tcourier network App and any priority access you have.
• We collect your most recent rider activity relating to your attendance of booked sessions (where you make bookings), super peak participation and whether you’ve avoided late cancellations. This information is shown as “Statistics” in the Tcourier network App.

• When you request to use a location-based function in the Tcourier network App, for example when you want to find a zone centre or use the zone selector control, we access your location from your device in order to provide this functionality. This includes when you opt to use these functions whilst your status is set to “”offline” i.e. not available for orders. If you do not want us to view your location when you are “offline”, please do not request these functions.
• When your status is set to “online” (i.e. available for orders) on the Tcourier network App, we intermittently collect your location data. If you do not want us to view your location, please change your rider status to offline, but please note that you will need to be online for the Tcourier network App to allow you to be offered and/or complete orders.

• We use cookies or other similar technologies to enable auto-login for you into the Tcourier network App, for API authentication and to obtain technical information about your device that may affect the technical functionality of the Tcourier network App, for example, certain characteristics of and performance data about your device, Tcourier network App and operating system, including your device type, network connection type, app version, phone language, screen size and platform.
• You have the right to use your device settings to reject or remove these functional technologies, however please be aware that if you do this, the Tcourier network App will not function correctly and you will not be able to carry out your services as a rider with Tcourier network.

• We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information if: we need to process your information for the performance of a contract with you, or at your request before we enter into a contract; we have your consent; we have a justifiable reason for processing your data; it is in the public interest for us to process your data; or we are under a legal obligation to do so.
• Where we need to process your information for the performance of a contract with you, or at your request before we enter into a contract, we use your information:
• To provide and manage your Tcourier network Application, account, and onboarding process, including to execute your Supplier Agreement;
• To provide you with access to and use of the Tcourier network App as a means of Tcourier network engaging your services, including to enable you to accept orders and to provide you with the self-service booking tool;
• To communicate with you about operational information relating to your services to Tcourier network, such as closed zones, any important changes or developments to the Tcourier network App and about your upcoming booked sessions;

• To help you to complete your Tcourier network Application;
• To contact you for your feedback on your rider experience;
• To inform you about opportunities to make more money in connection with the services you provide, such as by riding at certain times or by referring your contacts as riders;
• To send you news and information in connection with your rider services and the rider community and to help you to understand more about Tcourier network.

• To perform right to work, road licence and insurance checks, and to audit and store evidence of these, to ensure that you are legally compliant when providing the services and to comply with our internal policies, protect our reputation and mitigate our legal risks;
• We check whether or not you have unspent criminal convictions using a “basic” DBS check because it is in our legitimate interests (and the legitimate interests of our customers, riders and Business Partners) to try to prevent our platform from being used for any unlawful purpose and to protect the safety of our customers, other riders and Business Partner staff, with whom you will work closely when providing the services.
• To make the most efficient decisions when offering you orders based on factors like your location, and to determine your level of priority access to booking using your “Statistics” data. Data protection law describes this as profiling;
• To enable you to use or benefit from an insurance policy
• To enable our Rider Support, tech and engagement teams to help you with any issues, enquiries or complaints efficiently and effectively, including to fix any bugs or other technical issues in the Tcourier network App using technical information relating to your device;
• To provide Tcourier network services and a positive experience to our customers and Business Partners, such as by providing live order progress updates using your order progress swipes on the Tcourier network App;

• To understand from your data (such as your order progress swipes and other Tcourier network App usage, feedback you give about orders and your location data) as well as the data of other riders, what attributes to a positive or negative customer, business or rider experience with Tcourier network and what might cause inefficient deliveries or damage to Tcourier network, and use this data to responsibly design, develop, test and implement new tools, processes, and relationships to improve our business, systems and services;
• To analyse data about your rides to make certain assumptions about the types of promotional offers that may be particularly beneficial for you when providing services to Tcourier network. For example, this might result in us sending you deals relevant to the area where you most often work. Data protection law describes this as profiling;
• To train our algorithms to make the most effective and accurate decisions, such as training our order dispatch algorithm
• To interact with you (such as via communications or Tcourier network App functionality) to encourage Tcourier network's network efficiency based on our analysis of your services;

• Tor the exercise or defence of legal claims and to exercise and protect the rights of Tcourier network, Business Partners, customers, or others, including determining our liability;
• To enforce the terms of your Supplier Agreement and keep records of such enforcement, including using your data to analyse whether you have breached your Supplier Agreement (such as by misusing the Tcourier network App or acting fraudulently), which may result in us disabling or terminating your Supplier Agreement if we have the right to do so;
• To investigate any complaints or incident reports relating to a rider and to prevent fraud or other misuse of our systems and services;

• To enable your referrer to understand whether they are eligible to receive a referral fee, if you use a referral code in your application;
• To administrate and develop rider events and other rider initiatives; and
• In rider onboarding campaigns where you agree we may do so. We sometimes also use anonymous or aggregated forms of your information in the media or in rider onboarding campaigns (from which you are not identifiable).
• Where we are under a legal obligation to do so we may use your information:
• To keep a record of payments made to you; and
• To comply with any other legal obligation or regulatory requirement to which we are subject.
• Data protection law describes some processing activities in this section as profiling (see above). You have certain rights in relation to this type of processing. Please see 'Your Rights' section below for more information.
• Where we rely on our justifiable reasons for processing as a basis for processing your personal information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our justifiable reasons for processings. You can find out more information about these balancing tests by contacting us using the details above.

Where you have given your consent or where we have a justifiable reason for doing so (and are permitted to do so by law) we will use your information to let you know by email about Tcourier network's products and services and/or any promotions from third parties which are designed to support your provision of services to Tcourier network, such as by reducing the cost to you of providing services and by helping you to provide the services more safely through special deals we find for riders. You always have the option to unsubscribe from these emails.

A completed delivery under your Supplier Agreement is the collection of order items from one or more partner business(s) and delivery to one or more customer(s). Delivery fees are paid for completed deliveries only. We analyse your data and automatically confirm which deliveries you are due fees for.

You can choose to unassign from a delivery at any time, through the Tcourier network App where possible or by contacting Rider Support. In addition, you can simply reject offers of orders freely.

Choosing to not complete a delivery, without informing Tcourier network and while still claiming the delivery fee, is fraudulent activity and a serious breach of your Supplier Agreement.

Given the volume of deliveries we deal with, we use automated systems to make the automated decisions described above as they provide a more accurate, fair and efficient way of identifying suspected fraud, preventing repeated breaches of your Supplier Agreement and limiting the negative impact on our service. Human checks would simply not be possible in the time frames and given the volumes of deliveries that we deal with.

You have the right to contest the automated decisions referred to in this section by using the contact details set out in this privacy policy, in which case a person will review the decision.

• The information we collect about you will be transferred to and stored on our servers located within the EU. We are very careful and transparent about who else your information is shared with globally.
• Sharing your information internally: We share your information with other Tcourier network group companies only where necessary for the purposes set out in section 3.
• Sharing your information with third parties: We share your information with third party service providers who will store your information on their servers. The types of third party service providers whom we share your information with includes:
• IT service providers: including cloud, software, analytics, communications and data storage providers.
• Operational service providers: including feedback and survey providers, background and right to work verification and onboarding providers, our support service providers, payment providers, user research partners, professional advisors, financial services providers and other suppliers, business partners, contractors and subcontractors.
• Partner Businesses and customers: we provide limited information to Partner Businesses and customers whose orders you accept, for the purposes of our operations.
• Anyone who refers you as a rider: Your referrer will be given updates about progress towards their referral fee in relation to you, such as if you've reached the required orders for them to receive their fee or if their referral has been unsuccessful.
• Media: where we have the legal right to do so, such as if you share (including by publishing or causing to be published) any details about your rider services for Tcourier network which are misleading or inconsistent with our records of your rider services for Tcourier network, including regarding details about your earnings, we may share your information (such as in the form of a correction) with the media.
• In applicable circumstances, we may also share your information:
• If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors;
• if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation or regulatory requirement. This includes where we’re under a legal obligation to respond to police data requests or to exchange information with other companies and organisations for the purposes of fraud protection and prevention;
• where we reasonably believe that you or another person has been harmed or is at risk of harm in connection with your rider services for Tcourier network;
• in order to enforce our contractual terms with you;
• in the event of a dispute relating to your services to Tcourier network, or to protect the rights of Tcourier network, Businesses partners, customers, or others, including to prevent fraud;
• With such third parties as we reasonably consider necessary in order to detect or prevent crime, e.g. the police; and
• when a rider engages a substitute, the rider and substitute will have access to each others’ information shown in the Tcourier network App, such as recent deliveries and tips. If a rider makes a request to us for access to their personal data then in our response we may provide to the rider some personal data about the substitute, for example data relating to deliveries the substitute has worked on.

• We will not retain your information for any longer than we think is necessary.
• Information that we collect will be retained for as long as needed to fulfil the purposes outlined in the ‘Use of my information’ section above, in line with our justifiable reasons for processing or for a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes.
• When determining the relevant retention periods, we will take into account factors including:
• our contractual obligations and rights in relation to the information involved;
• legal obligation(s) under applicable law to retain data for a certain period of time;
• statute of limitations under applicable law(s);
• our justifiable reasons for processing where we have carried out balancing tests (see section on ‘Use of your information and why’ above);
• (potential) disputes; and
• guidelines issued by relevant data protection authorities.
• Otherwise, we securely erase your information where we no longer require your information for the purposes collected.

• We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.
• Where you have chosen a password which allows you to access certain parts of the Tcourier network App, you are responsible for keeping this password confidential. We advise you not to share your password with anyone, other than any substitute you are working with. If you do choose to share your password with your substitute, please make sure they are also aware that they must keep it confidential and secure and not share it with anyone else.
• Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Under data protection law, you may have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact us using the contact details set out below. For additional information on your rights, please contact your data protection authority.

The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.
• The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.
• The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold by contacting us (see Contact Details).
• The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of the information that we hold about you by contacting us (see Contact Details). The right is not absolute and only applies in certain circumstances.
• The right to restrict processing. You have rights to ‘block’ or ‘supress’ further use of your information. When processing is restricted, we can still store your information, but will not use it further.
• The right to data portability. You have the right to obtain your personal information in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions. To learn more please get in touch (see Contact Details).
• The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. if we rely on consent as a legal basis for processing certain information), you have the right to withdraw that consent at any time. You can do this by contacting us (see Contact Details). Withdrawing consent will not however make unlawful our use of your information while consent had been apparent.
• The right to object to processing. You have the right to raise an objection to certain types of processing, including processing for direct marketing and profiling. You can object by contacting us on the details above.

Any changes to our Privacy Policy will be posted to the Tcourier network App and, as appropriate, through notification in the Tcourier network App or by email.