1. Who processes your data
The controller is your employer, [business name, address, contact email]. To run the delivery app we use the PRODEL service of Three Button Trading Ltd, which acts as processor on our instructions under a contract pursuant to article 28 GDPR.
2. What data and why
- Account details: name, email, phone (optional), role — so you can sign in to the app.
- Position of your device: sent to the office dashboard only while you have a route in progress and not during a break, and only when the app is open in the foreground. It is used to coordinate deliveries, calculate arrival times and re-optimise the stop order. Only the latest position is stored — no movement history, no speeds — and it is deleted when the route is finished. The app always shows an indicator when it is sending position.
- Actions in the app: route start and finish times, time of each delivery or failure, breaks, undos, stops you added, cash-on-delivery amounts you declared as collected, proof photos you took — to carry out and document deliveries and for the business’s history.
Estimated arrival time for the recipient. The recipient may be sent, by the office or by you, a link showing an estimated arrival window (e.g. 10:25 – 11:00) and how many stops come before theirs. The estimate is calculated on the server from the stop order, travel times and, while a route is in progress, the last position sent by your device. On that page the recipient never sees your position, a map or your name. If you send the link yourself, the message goes out from your own messaging app, so the recipient sees the number it was sent from.
3. Legal basis
Performance of your employment or engagement contract and the business’s legitimate interest in coordinating deliveries (article 6(1)(b) and (f) GDPR). Location data is not used for other purposes [e.g. performance appraisal or disciplinary control] without separate notice and a legal basis.
4. Who sees it and for how long
- The business’s dispatchers, inside the app.
- Three Button Trading and its sub-processors (hosting in Germany, email delivery, maps), as described in PRODEL’s Privacy Policy.
- When you choose navigation, the stop’s coordinates open in your device’s navigation app (Waze, Google Maps or Apple Maps — whichever you have chosen), under that app’s terms.
- Account details and actions are kept while your account exists and up to 30 days after the business’s PRODEL subscription ends, [or: … according to the business’s retention policy].
5. Your rights
You have the right of access, rectification, erasure, restriction and objection, and the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection (www.dataprotection.gov.cy). To exercise them, contact [the business’s contact person, email].
6. Practical
- Do not operate the app while driving; it is designed for use with the vehicle stopped.
- If the phone is shared, sign out at the end of your shift.
- Proof photos should show the parcel or the delivery point, not people.