Courier Privacy Policy

BY ACCEPTING THIS PRIVACY NOTICE, YOU PROVIDE YOUR CONSENT FOR RELAY TO USE YOUR BIOMETRIC DATA TO VERIFY YOUR IDENTITY AND CHECK YOU DO NOT ALREADY HAVE AN ACCOUNT – SEE SECTION 6 BELOW. IF YOU DO NOT CONSENT, PLEASE EMAIL gdpr@relaytech.co AND SUCH CHECKS WILL BE MADE MANUALLY.

Changes in November 2025. We have updated this Courier Privacy Policy to include additional detail on the processing activities that Relay undertakes. See Section 3 (Performance), Section 6 (Sensitive personal information), Section 7 (Information about Criminal Convictions) and Section 8 (Relay’s use of automated systems). Please note that Relay only processes your personal data in connection with our agreement with you and to improve the services.

Relay Technologies Ltd (“we”, “our”, “us” or “Relay”) is committed to protecting the privacy of couriers who apply to deliver with us (“courier applicants”) and our couriers, including all users of our courier mobile device application (“Courier App”), and related services.

We’ll be the “controller” of the information we hold about you. We are registered with the Information Commissioner’s Office under registration number ZB489499. As the controller, we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This privacy policy applies to courier applicants and couriers (“you” or “your”). We may update this privacy policy at any time in accordance with Section 16 below (Changes to this Privacy Policy).

Please read this privacy policy which explains how and why we collect, use and protect your information.

When we refer to “our agreement with you”, we are talking about the agreement that is formed between us for the provision of delivery services when you sign the Courier Terms.

1. Data Protection Principles

We will comply with data protection law, which says that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

2. How We Collect Your Information

We collect your information when you apply to become a courier, use the Courier App, contact us and when you provide the delivery services.

3. Information That We Collect About You

Your courier application and account set up

• When you apply to deliver with Relay, we ask you to provide information about yourself including your name, contact details, tax status information, vehicle type, date of birth, relevant address, your right to work, and whether you have any unspent criminal convictions.
• During the application process, or at later stages where further checks are considered necessary, 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 basic DBS checks and right to work checks. If you are required by applicable law to have a licence or insurance for your vehicle type, we may also ask you to provide evidence of compliance, as well as your vehicle registration details. We will track the progress of your application and record the results of your criminal background check (pass/fail only).
• We will also require you to complete training which includes an assessment element with a pass mark of 70%. We will process your passmark to determine whether you are suitable for the role.
• During the application process, you will be asked to submit a photo (“selfie”) or video of yourself and a photo of your identity document to verify your identity. Your selfie will be compared with the photo in your identity document. This comparison is made automatically using an identity verification platform with facial recognition, operated by our service provider.
• For your account set-up, we will ask you to provide financial information (including bank details), tax and business registration information, and further details related to your services for Relay, such as where you want to work, and a photo. We’ll keep a copy of your signed Courier Terms.

Payment

• We record your deliveries, your calculated fees and details of payment.
• Payment is via our partner which is integrated into the Courier App. It allows you to see how much money you’ve got to withdraw and records withdrawals, routes done and how much you’ve earned.
• We also process your tax status information.

Performance

• We will record all information related to the services which may include without limitation, your delivery efficiency, number of late cancellations, unattempted delivery rate, unsuccessful deliveries, customer reported missing items, number of undelivered items not returned to the pitstop and compliance with Relay Technologies’ delivery rules. The factors and weighting may change from time to time. We will use this information to categorise your performance which will have a bearing on the routes you are offered, when you are offered the routes and the remuneration available for those routes. This categorisation is automated (see Section 8 (Relay’s use of automated systems) below).

Your location

• When you are completing a route in the Courier App, we collect your location data on a continuous basis for the purpose of engaging your services under your Courier Terms and measuring performance. This includes providing delivery estimates to customers based on your speed and confirming your presence at the designated Pitstop to collect and return parcels.
• We do not access your location when you are not completing a route and the Courier App is closed.
• When you view the planner, we collect a single location data point to determine if there is a relevant route invite nearby to offer you.

Your use of the Courier App and Courier Support

• When you use the Courier App, we collect information about how you use it, including your preferences, which routes you view, and your route invites swipes and your calls to customers.
• When you interact with our Courier Support team via email, phone, post, chat, or through the Courier App or Courier Site (“Courier Support”) or Customer Services, including when you report an incident, our team may collect and use information about you. If you contact Courier Support by phone, your calls may be recorded for legitimate business purposes, including for training and service improvement purposes for Courier Support and Customer Services.
• When using the Courier App, you may periodically be asked to submit a selfie or video of yourself to verify your identity. Your selfie will be compared with the photo from the identity document you provided during onboarding. This comparison may be carried out automatically using an identity verification platform with facial recognition, operated by our service provider (see Section 6 (Sensitive Personal Information) below).
• We look at how you use the Courier App to help us improve our services and optimise the courier experience. For example, we collect information about your engagement with the Courier App and your response to push notifications to determine the appropriate communications to be sent to you from Relay Technologies.

Technical data

• We collect technical information about your device and how you use it. For example, we collect technical details such as characteristics and performance data about your device, the Courier App and operating system, your device type, unique device identifier, and app version.
• We ask for permission to access your device’s camera so that you can verify your identity as part of the onboarding process and once onboarded, take and upload a photo in the Courier App showing where you’ve left an order at a customer’s delivery address.

Information about your services

• We may receive information about your services or any incident you may have been involved with from the Pitstops who work with us.
• We may collect information about you from the feedback you send us or provide to us through focus groups or surveys.
• If you access the Courier App using other digital methods—such as (but not limited to) a tablet or other devices/technologies—Relay’s collection and use of personal information, as outlined in this privacy policy, will also apply in that context.

If you do not provide your information

If you do not provide some or all of the requested information, Relay may be unable to accept your application, to complete set-up or manage your courier account or perform its obligations under the Courier Terms.

However, if you do not consent to Relay using your biometric data as described in Section 6 (Sensitive Information) then Relay will verify your identity manually.

4. Use of Your Information and Why

We will only process your information if there is a reason for doing so, and if that reason is permitted under data protection law.

Performance of a contract with you

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 courier application, courier account, and onboarding process, including to execute the Courier Terms;
• Provide you with access to and use of the Courier App as a means of Relay engaging your services, including enabling you to book routes;
• Process your area preferences and offer you available routes in that area;
• Manage delivery operations and make the most efficient decisions using automated means when offering you routes (see Section 8 (Relay’s use of automated systems) below);
• Measure your performance (see Performance) to determine whether you are meeting your obligations under your Courier Terms and take appropriate action (including terminating our agreement with you if necessary);
• Communicate with you about operational updates related to your services for Relay, such as closed Pitstops or important Courier App changes;
• Enable Courier Support and Customer Services to assist you with any service-related issues;
• Offer you bespoke delivery fees and calculate and administer payments for your courier services and any adjustments or bonuses, for example, determining if a cancellation fee for an unmatched prebook route.

Legal or regulatory obligations

We may also use your information to meet our legal or regulatory obligations, including to:

• Perform identity verification, right to work, road licence, and insurance checks (where permitted by law) to ensure that you are legally compliant when providing services, and to comply with our internal policies;
• Keep a record of payments made to you;
• Calculate and administer taxes (including, if applicable, withholding taxes) and report necessary tax information to relevant authorities;
• Comply with other applicable legal or regulatory requirements.

Legitimate interest

We also process your information where we have a legitimate interest in doing so, including to:

Communicate with you via email, post, phone, message, push notification, or in-app message to:

• Request feedback on your courier experience;
• Inform you about opportunities to earn more (e.g., delivering at peak times or referring others to join Relay);
• Share news, updates, or community info related to your courier services, such as tech improvements or safety equipment suggestions.

Onboarding and delivery operations to:

• Audit and store evidence of identity verification, right to work, road licence and insurance checks (where permitted by law) to ensure legal compliance, uphold internal policies, protect our reputation, and reduce legal risk;
• Check whether you have unspent criminal convictions (see Section 7 (Information about Criminal Convictions) below);
• Enable you to access or benefit from an insurance policy;
• Check you are being paid correctly and monitor withdrawals made to assist in management of cashflow;
• Support you efficiently through Courier Support, tech, and engagement teams—such as resolving issues or technical problems in the Courier App using relevant device data;
• Provide a smooth experience to customers and Partners, including live delivery updates via your progress swipes in the Courier App.

Develop our business, systems and services to:

• Improve efficiency based on past data (such as order swipes, app usage, feedback, and location data) to understand what causes poor experiences or inefficiencies and improve Relay’s systems and services;
• Analyse past activity and delivery data to inform rates and tailor promotional offers that may be relevant to you—for example, based on areas where you frequently work;
• Train our algorithms to make effective and accurate dispatch decisions;
• Interact with you (e.g., through app features or messages) to improve network efficiency based on your service patterns.

Protect Relay and others, including to:

• Exercise or defend legal claims and protect the rights of Relay, couriers, customers, Pitstops, or others;
• Enforce the Courier Terms and keep a record of enforcement actions, such as disabling your account or terminating your agreement if necessary (e.g., for app misuse or fraud).

Safety, fraud protection and security, including to:

• Investigate complaints or incidents involving a courier;
• Prevent fraud or misuse of our systems and services;
• Enable auto-login to the Courier App and API authentication;
• Ensure the security and integrity of the Courier App and Relay’s systems and network;
• Help protect the safety of couriers, customers, Pitstop staff, and the public.

Referrals and courier initiatives, including to:

• Allow your referrer to confirm their eligibility for a referral fee if you used a referral code in your application.

Consent

There are also circumstances where we require your explicit consent which is optional, namely when we use your biometric data (facial image) to verify your identity (see Section 6 (Sensitive Personal Information)).

5. Communications

As referred to in Section 4 above, we will contact you by email, text message or push notifications to provide service related information to you. You can unsubscribe from emails by clicking the unsubscribe link at the bottom of an email, you can unsubscribe from text messages by following the unsubscribe instructions contained in the message and you can change the settings in the Courier App to unsubscribe from push notifications.

6. Sensitive personal information

Situations in which we will use your sensitive personal information

In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with the engagement. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your particularly sensitive personal information are listed below together with the condition we rely upon for processing this information.

We will use your biometric data namely the photograph on your identification and a video of your facial image to verify that you are who you say you are and to ensure that you do not already have a courier account. We rely on explicit consent for this processing, which you are providing by accepting this privacy notice. Your consent can be withdrawn at any time. If you do not wish to provide consent, then please inform gdpr@relaytech.co and the checks will be made manually instead.

• We will use information about your physical or mental health, or disability status, to comply with our legal obligations. We need to process this information to exercise rights and perform obligations in connection with the engagement.

If we reasonably believe that you or another person are at risk of harm and the processing is necessary to protect you or them from physical, mental or emotional harm or to protect physical, mental or emotional well-being. We rely on the substantial public interest of vital interests.

We may use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation to ensure meaningful equal opportunity monitoring and reporting. We rely on the substantial public interest condition of equality of opportunity or treatment.

7. Information about criminal convictions

We collect information about criminal convictions to determine your suitability for the role and where appropriate, to check you are eligible to benefit from Relay’s top-up hire and reward insurance.

It is in both parties’ legitimate interests to ensure a safe working environment and to minimise risks to the parcel recipients, other road users and the general public. We rely on the substantial public interest condition of preventing and detecting unlawful acts and in some circumstances it is necessary to perform or exercise obligations or rights in connection with the engagement. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

8. Relay’s use of automated systems

Relay uses automated systems to manage operations and key elements of the Agreement and to help identify potential breaches. Except where specifically stated, Relay does not use solely automated systems to make any decision that could have a serious impact on a courier—such as a legal or similarly significant effect.

Use of automated systems to manage operations, send communications and measure performance

Relay uses automated systems to support delivery operations, to send communications to couriers based on their engagement with the App and to measure and categorise performance which in turn is used to manage routes and calculate route invite delivery fees.

The measurement and categorisation of your performance is necessary for the performance of the contract between you and Relay. If you feel you have been allocated to a performance tier incorrectly or do not understand why you have been allocated to a certain tier, you have the right to email Relay explaining why and seeking a review by the courier team. The courier team will conduct a review of the allocation, taking into account your explanation and any supporting data, and will override or adjust the automated decision if appropriate. Relay will confirm receipt of the request and provide an outcome within 3 business days of the review. Upon request, Relay will provide an explanation of the main factors and data points used in determining the tier.

Use of automated systems to identify and investigate potential breaches or fraud

We process personal information (as outlined in the Information That We Collect About You section) with the support of automated systems to help detect suspected fraud, misuse of the App, or potential breaches of the Courier Terms in a more accurate, fair, and efficient way.

Our systems may help flag such activity which could result in your courier account being suspended while the issue is reviewed. The process involves a manual review before any action is taken.

9. Terminating our agreement with you

As described above, we use automated systems to help identify certain events that may indicate a breach of the Courier Terms. These systems may result in the temporary disabling of your courier account if we suspect fraud or similar misuse of the Relay platform.

If a potential breach of the Courier Terms or suspected fraud is identified, we carry out a manual review of the information collected. We may also look for supporting evidence, such as similar past events. A member of our courier reviews team will assess the case, determine the severity of the issue, and decide on the appropriate action. This could include termination of your agreement with us. If this occurs, we will notify you by email and provide an opportunity for you to respond.

10. Sharing Your Information

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the UK. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

The following activities are carried out by third-party service providers: KYC checks, DBS checks, DVLA check, verification of right to work code, payment provider, telematics and various analytics.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC and disclosures to shareholders such as directors’ remuneration reporting requirements.

We may also share your personal data with law enforcement or other government agencies where we consider it necessary to do so.

11. Transferring information outside the UK

We may transfer the personal information we collect about you to countries outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (in the case of transfers out of the EEA) or the United Kingdom Government (in the case of transfers out of the United Kingdom); and/or
• where we use certain service providers, we may use specific contracts approved by the European Commission (in the case of transfers out of the EEA) and/or the United Kingdom Government (in the case of transfers out of the United Kingdom), in both cases which give personal data the same protection it has within the EEA and/or United Kingdom as applicable.

12. Security

We adopt robust technologies and policies to protect your information from being accidentally lost, accessed or used without authorisation, altered, or disclosed.

We limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have procedures in place to manage any personal data breach and will notify you—and any relevant regulator—where we are legally required to do so.

13. How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider:

• The amount, nature and sensitivity of the personal data.
• The potential risk of harm from unauthorised use or disclosure of your personal data.
• The purposes for which we process your personal data and whether we can achieve those purposes through other means.
• The applicable legal requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use that information without further notice to you.

14. Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

15. Your Rights

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the DPO. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

To exercise any of these rights, please contact our courier support team in writing at gdpr@relaytech.co.

If you are unhappy with how we have handled your information, you can contact your local data protection authority. In the UK, this is the Information Commissioner’s Office (ICO). However, we would really appreciate the opportunity to address your concerns directly before you contact a data protection authority, so we kindly ask that you reach out to us first.

16. Changes To Our Privacy Policy

We update this privacy policy from time to time, so remember to check back in every so often, in case anything has changed and, where appropriate, we may notify you of the changes, via the Courier App or by another method.