Rider Privacy Policy - Australia
Roofoods Ltd and Deliveroo Australia ("we", "our", "us" or "Deliveroo") is committed to protecting the privacy of riders who apply to ride with us ("rider applicants"), our riders and their substitutes, including all users of the rider mobile device application (the "Rider App") and related services. We’ll be the "controller" of the information we collect about you.
This privacy policy applies to rider 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 onboarding 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 Rider App, such as recent deliveries and tips.
Please read the following privacy policy which explains how and why we collect, use and protect your information.
1. CONTACT DETAILS
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.
2. INFORMATION THAT WE COLLECT ABOUT YOU
We collect your information in a variety of ways, such as when you apply to be a Deliveroo rider and when you use the Rider App. More details about how your information is collected are listed below.
Your rider application and account set up
- When you apply to ride with Deliveroo, 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.
- For your account set-up, we will ask you to provide financial (including bank details), tax and business registration information, and further information related to your services for Deliveroo such as contact details of your next of kin (whose details you have permission to share with us for emergency purposes), where you want to work, your kit and a photo ID document. We record your Deliveroo rider payment arrangement and a copy of your signed supplier agreement with us ("Supplier Agreement").
- During onboarding you will be asked to submit a photo ("selfie") or video of yourself and a photo of your identity document. Your selfie will be compared with the photo within the identity document. This comparison will be done using an identity verification platform, operated by our service provider called Onfido.
Payment and kit ordering
- We record your deliveries, your tips if obtained via the Rider App, your calculated fees and associated fee statement.
- When you order kit through our Deliveroo kit store, you are asked to provide information about yourself including your name, contact details, delivery address, order details and payment information (if required).
Your location
- When you request to use a location-based function in the Rider 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 Rider 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 Rider App to allow you to be offered and/or complete orders.
Your use of the Rider App and Rider Support
- When you use the Rider App we collect information about your usage of the Rider App, including about your rider status and (when online) your order progress swipes.
- When you interact with our rider support function via email, phone, post, chat or on the Rider App (“Rider Support”) or Customer Services, including when you report any incident, our team may collect and use information about you. Your communications with us will be stored. If you contact Rider Support by phone, your calls may be recorded for internal Rider Support training and improvement purposes.
Cookies
- We use cookies or other similar technologies to enable auto-login for you into the Rider App, for API authentication and to obtain technical information about your device that may affect the technical functionality of the Rider App, for example, certain characteristics of and performance data about your device, Rider 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 Rider App will not function correctly and you will not be able to carry out your services as a rider with Deliveroo.
Information about your services
- We may receive information about your services or any incident you may have been involved with from the restaurants who work with us (our "Partner Restaurants"), our customers, other riders or members of the public.
- If you take advantage of the perks offered by a third party partner, the partner will share information with us about your interest in those perks.
- We may collect information about you from the feedback you send us or provide to us through focus groups or surveys.
- When you use websites or applications of third parties in connection with your services for Deliveroo, including during the application and onboarding process, those sites or applications may collect and process your information independently of Deliveroo. We recommend that you check their privacy policies to understand how they process your personal information.
- We may request your personal information to verify your right to work, such as copies of your identification documents and/or a photograph of you.
Providing your information in other ways
- By accessing the Rider App using other digital routes such as (but not limited to) a tablet or other devices/technology, then Deliveroo's personal information collection and usage as set out in this privacy policy will apply in that context too.
- When you use websites or applications of third parties in connection with your services for Deliveroo, including during the application and on-boarding process, those sites or applications may collect and process your information independently of Deliveroo. We recommend that you check their privacy policies to understand how they process your personal information.
If you do not provide your information
- If you do not provide some or all of the requested information, Deliveroo may be unable to accept your application or to complete set-up or manage your account.
3. USE OF YOUR INFORMATION AND WHY
- We will only process the personal information 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 information; it is in the public interest for us to process your information; 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:
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- to provide and manage your rider application, account, and onboarding process, including to execute your Supplier Agreement;
- to provide you with access to and use of the Rider App as a means of Deliveroo 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 Deliveroo, such as closed zones, any important changes or developments to the Rider App and about your upcoming booked sessions;
- to enable Rider Support and Customer Services to communicate with you to support your services;
- to offer you order-specific delivery fees (where available in your market) and calculate and administer payments for your rider services and any referrals. Sometimes it may be necessary to use your location data to confirm what payments are due to you, for example whether a surge fee was applicable to you at a certain time and location; and
- to enable you to access and use the Deliveroo rider kit store website and services to order, pay for and receive delivery of Deliveroo rider kit.
- We also process your information where we have a justifiable reason for doing so. We have listed these reasons below:
To communicate with you
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- to help you to complete your rider 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 Deliveroo, such as by sending you the “Roosletter”, tech updates and helping you to find appropriate road safety equipment;
For our onboarding and delivery operations
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- 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 because it is in our legitimate interests (and the legitimate interests of our customers, riders and Restaurant 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 Restaurant 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;
- 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 Rider App using technical information relating to your device;
- to provide Deliveroo services and a positive experience to our customers and Restaurant Partners, such as by providing live order progress updates using your order progress swipes on the Rider App;
To develop our business, systems and services
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- to understand from your information (such as your order progress swipes and other Rider App usage, feedback you give about orders and your location data) as well as the information of other riders, what attributes to a positive or negative customer, restaurant or rider experience with Deliveroo and what might cause inefficient deliveries or damage to Deliveroo, and use this information 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 Deliveroo. For example, this might result in us sending you offers relevant to the area where you work most often;
- to train our algorithms to make the most effective and accurate decisions, such as training our order dispatch algorithm, Frank;
- to interact with you (such as via communications or Rider App functionality) to encourage Deliveroo’s network efficiency based on our analysis of your services;
To protect Deliveroo
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- for the exercise or defence of legal claims and to exercise and protect the rights of Deliveroo, Restaurant 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 information to analyse whether you have breached your Supplier Agreement (such as by misusing the Rider 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;
For referrals and rider initiatives
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- 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:
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- 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.
- 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.
4. DIRECT MARKETING
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 Deliveroo’s products and services (such as kit) and/or any promotions from third parties which are designed to support your provision of services to Deliveroo, such as by reducing the cost to you of providing services and by helping you to provide the services more safely through special offers we find for riders. You always have the option to unsubscribe from these emails.
5. AUTOMATED DECISION-MAKING
Deliveroo uses automated decision making to assign orders and ensure they are completed. A completed delivery under your Supplier Agreement is the collection of order item(s) from one or more restaurant(s) or other partner(s) and delivery to one or more customer(s). Rider fees are paid for completed deliveries only. We analyse your information and automatically confirm which deliveries you are due fees for.
You can choose to unassign from a delivery at any time, through the Rider App where possible or by contacting Rider Support. In addition, you can simply reject offers of orders freely.
We sometimes use automated systems to provide a more accurate, fair and efficient way of identifying suspected fraud and instances of potential breaches of your Supplier Agreement. In such cases we may send you a notification about this behaviour. However, we never use automated processes to make a decision about whether to terminate a Supplier Agreement (see Section 6 below).
6. TERMINATING YOUR SUPPLIER AGREEMENT
As described in Section 5 of this privacy policy, we use automated processes to help identify certain events that may indicate a breach of your Supplier Agreement. This may include, for example, when you choose to not complete a delivery without informing Deliveroo and while still claiming the delivery fee. Such a case would be fraudulent activity and a serious breach of the Supplier Agreement.
Where automated processes identify a potential breach of a Supplier Agreement, we complete a manual review of the information collected and we may also look for further evidence, such as similar events in the past. This person completing the manual review then makes a decision about the severity of the event and the action required. The action taken could include termination of your Supplier Agreement.
Any decision taken to terminate a Supplier Agreement may also, where appropriate, be checked by a senior member of our operations team to confirm the decision taken by the person who examined the case.
7. SHARING YOUR INFORMATION
- The information we collect about you will be transferred to and stored on our servers located within the European Economic Area (“EEA”) and the UK. 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 Deliveroo 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:
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- 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 Restaurants and customers: we provide limited information to Partner Restaurants and customers whose orders you accept, for the purposes of our operations.
- Insurance companies: if you decide to purchase third party products or services (such as insurance), or where you are enrolled into a Deliveroo insurance policy, you or the provider may request that we provide your information to the provider to enable them to provide the products, services or policy to you, so we will share this information for this purpose. We may also need to share your information with our insurers to establish whether we are liable for any incident you have been involved in whilst providing services to us.
- Rider perk partners: where we believe their services will be of interest to you.
- 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 Deliveroo which are misleading or inconsistent with our records of your rider services for Deliveroo, 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:
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- 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 Deliveroo;
- in order to enforce our contractual terms with you;
- in the event of a dispute relating to your services to Deliveroo, or to protect the rights of Deliveroo, Restaurants partners, customers, or others, including to prevent fraud;
- with such third parties as we reasonably consider necessary in order to enforce our rights under the Supplier Agreement and/or 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 Rider App, such as recent deliveries and tips. If a rider requests access to their personal information we may provide in our response to the rider certain personal information about the substitute, for example information relating to deliveries the substitute has worked on.
- International data transfers: In some cases the personal information we collect from you might be processed outside the EEA/UK, such as in the United States, the Philippines and the countries in which Deliveroo operates (which are set out on www.deliveroo.co.uk). These countries may not have the same data protection as the EEA/UK has. However, we are obliged to ensure that personal information processed by us and/or by our suppliers outside of the EEA/UK is protected in the same way as it would be if it was processed within the EEA/UK. There are certain safeguards in place when your information is processed outside of the EEA/UK.
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- We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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- your information is transferred to countries that have been deemed to provide an adequate level of data protection by the European Commission or other relevant body;
- we use a derogation which is provided for in applicable data protection law; or
- we use the EU-approved standard contractual clauses.
- Please contact us if you would like further details on our international transfer of your personal information.
8. RETENTION OF YOUR INFORMATION
- 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:
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- our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain information 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.
9. SECURITY
- We adopt robust technologies and policies to ensure the personal information we hold about you is suitably protected.
- 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 Rider 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 information 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 unauthorised access.
10. ACCESSING AND UPDATING
- You have the right to access the information we hold about you unless an exception under applicable law applies. If you wish to do this, please contact our Australian Rider Support team on the contact details provided above. In the event that you make an access request, we reserve the right to charge a fee of five Australian Dollars ($5.00) to meet our costs in providing you with details of the information we hold about you.
- If your contact details or other information that we hold about you changes, please let us know as soon as you can. You can do this by contacting our Australian Rider Support team on the contact details provided above. Rider Support will assist you on behalf of both Deliveroo Australia Pty Ltd (whose office is at 161 Collins Street, Melbourne, VIC, 3000) and Roofoods Limited (whose registered office is at 1 Cousin Lane, London, EC4R 3TE, United Kingdom).
11. CHANGES TO OUR PRIVACY POLICY
Any changes to our privacy policy will be posted to the Rider App and, as appropriate, through notification in the Rider App or by email.
This privacy policy was last updated: 21 May 2021
12. COMPLAINTS
If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you may also contact the body responsible for administering the privacy laws in your country. In Australia, you can contact the Office of the Australian Information Commissioner.