Sorted legal

Platform Legals

Sorted Track – Product privacy notice

Section A – Introduction

A1. Who are we

•Sorted is a game-changing technology company which is harnessing the power of tech to transform the world of deliveries. We aim to improve the delivery experience for everyone involved in it: the customer, the carrier, the channel partner and the retailer.
•References to we, our or us in this privacy notice are to Sorted Holdings Limited (company number 8609014) and each of its direct and indirect subsidiaries, including Sorted Group Limited (company number 9060564). The registered office of both Sorted Holdings Limited and Sorted Group Limited is at Level Six, 111 Piccadilly, Manchester, M1 2HY .

A2. About Track

• Track is our intelligent technology platform which enables retailers to pull all of their delivery tracking data into one place to help them manage customer expectation, resolve issues quickly and track their delivery experience performance.
• As with most technology products, the usage and operation of Track involves the collection and handling of various forms of personal information.

A3. Who should read this privacy notice

•You should read this privacy notice if you are:

• an employee or contractor of one of our retailer customers who has been asked to use Track on behalf of your employer (please read sections A, B and D)
• a customer of one of our retailer customers who has placed an order with that retailer which involves that retailer delivering products to you (please read sections A, C and D)

A4. Track and your personal information

•In most cases where we are collecting and handling personal information, we do this on behalf of our retailer customer. For example:

• we may hold personal information about a retailer’s employees so that we can enable those employees to log into the Track dashboard and use it on behalf of the retailer
• we will collect personal information about deliveries which are being made to the retailer’s customers to enable the retailer to track deliveries being made to those customers

•Where we are carrying out activities that involve us collecting and handling personal information on behalf of a retailer customer:

• the retailer is legally responsible for deciding how your personal information is treated and for what purposes it is used
• we are committed, both by data protection legislation and our agreement with that retailer, to carry out those activities in accordance with the retailer’s instructions
• the retailer will publish a privacy notice informing you what personal information it collects about you, how it is used and what your rights are in respect of it
• if you have any questions about how your personal information is being handled, or want to make any requests in respect of it, you should contact the retailer

•We are constantly looking to improve Track to ensure that we can provide the best service to our retailer customers, improve the user experience for the retailers’ users and help the retailers to offer the best delivery experience to their customers. To help us to do this, we:

• track and analyse the way in which users interact with Track
• analyse delivery data to gain delivery insights and improve the service

• Where we use your personal information for the purposes of improving the service in general, as opposed to on behalf of a particular retailer customer, we are responsible for ensuring that those activities are carried out in a lawful and fair way, for providing you with information about those activities and for dealing with any enquiries or requests about those activities.

A5. Our commitment to you

• We are committed to protecting your privacy and will only use your personal information in accordance with applicable data protection legislation, including the UK General Data Protection Regulation and the Data Protection Act 2018. We have prepared this privacy notice to provide you with more information about these activities and your rights in respect of them.

Section B – User tracking

B1. Usage data we collect

•If you are accessing and using Track on behalf of your employer, we may collect and analyse the following types of data about your usage:

• your name and work email address
• your Track username
• the IP address of the device you use to access Track and information about the device that you are using to access Track, such as device type, browser and operating system
• the date and time that you access Track, the functionality that you utilise and details of mouse movements, mouse clicks and keystrokes

•Information about your usage of Track may be collected through cookies and/or log files. For more information about the cookies we use, see paragraph B5.

B2. How we use usage data

•We use the usage data that we collect to enable us to better understand how users interact with Track, so that we can work to improve Track and provide a positive user experience, increasing effectiveness and improving functionality.
•We do this because we, our retailer customers, our users and our retailers’ customers have a legitimate interest in us doing so, as providing a better product will result in a better user and delivery experience for everyone involved.
•We also reserve the right to use usage data to detect and investigate any potential misuse of Track, to protect the legitimate interests of ourselves, our retailer customers and other users.

B3. Share of usage data

•We use third party tools to help us collect and analyse usage data, and the usage of these tools may result in our service providers having access to personal information about you.
•We may also disclose usage data to your employer in connection with any investigation into misuse or abuse of Track.
•We partner with Microsoft Clarity to capture how you use and interact with our website through behavioural metrics, heatmaps, and session replay to improve our products/services. Website usage data is captured using first and third-party cookies to determine the popularity of products/services. Additionally, we use this information for site optimization and fraud/security purposes.

B4. Retention usage data

•We retain usage data for a period of seven days.
•Any reports that we generate as a result of analysing usage data may be retained for a longer period. However, reports will relate to usage of Track in general and not to the specific usage patterns of individually identifiable users.

B5. Cookies

•When you are using Track, we use “cookies” to keep track of your usage and give you a better user experience. This includes the following cookies:

• functional cookies, to ensure that Track functions correctly and that it can be presented to you in the most effective manner
• Google Analytics, Hotjar and Microsoft Clarity to track how you make use of Track (to opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout)
• Except for cookies which are strictly necessary, we will only set cookies with your consent. You can allow, deny or customise cookies by using the prompt which is displayed when you first access Track. A full list of the cookies we use and the details of these cookies can be viewed by choosing the customise option.

Section C – Analysis of delivery data

C1. Delivery data we analyse

• To provide the Track service to our retailer customers, we collect various types of delivery data from carriers, including:

• name and address of recipient
• expected delivery date
• status of delivery

• Whilst we report on deliveries on an individual basis to our retailer customers, we do not carry out analysis on deliveries at an individual level. Instead, we aggregate delivery data and use the aggregated data to gain delivery insights customer and improve the service

C2. How we analyse delivery data

• We analyse the data to help us to identify and understand where and when issues arise to help us to spot similar potential issues in future, enabling us to highlight them to our retailer customers so that they can resolve them proactively and minimise the impact on their customers.
• We do this because we, our retailer customers and their customers have a legitimate interest in us doing so, as providing better delivery insights and a better product will result in a better delivery experience for everyone involved.

C3. Sharing of delivery data

• We do not share your personal information with anyone in connection with this analysis, but the resulting delivery insights (which will not identify you personally) will be used to provide a better service to our retailer customers.

C4. Retention of delivery data

• The period for which we retain delivery data will depend on our agreement with our retailer customer.
• The aggregated data is used to gain delivery insights which we then use to improve Track. These insights will be used in Track for so long as they are relevant, but are used on an aggregated basis, rather than to identify individual customers.

Section D – General

D1. Other circumstances in which we may share your personal information

• Our group consists of various companies. Personal information collected by one company within our group may be shared with other companies within our group. This is in our legitimate interests to enable us to operate our group effectively and to enable us to provide our retailer customers with an efficient service. All members of our group are bound by this privacy notice.
• We may also share your personal information with:

• providers of outsourced services, such as hosting and IT support or maintenance services (to the extent necessary for the provider to provide those outsourced services to us)
• professional advisors, such as solicitors, auditors and insurers
• the prospective seller or buyer of any business or assets in the event that we sell or buy any business or assets
• law enforcement authorities in connection with any suspected misuse of Track or other suspected illegal activity

• In certain cases, the sharing of your personal information to a third party as described above may involve your personal information being transferred outside of the United Kingdom. This may be to:

• a country in the European Economic Area or that is otherwise considered to have data protection rules that are equivalent to those in the United Kingdom
• a country which is not considered to have the same standards of protection for personal data as those in the United Kingdom, in which case we will take all steps required by law to ensure sufficient protections are in place to safeguard your personal information, including where appropriate putting in place contractual terms approved by the relevant regulatory authorities.

D2. Updating and removal of your personal information

• If you believe that any of the personal information that we hold about you is inaccurate or out-of-date, please contact us using the details in paragraph D5 and we will be happy to correct it.
• In certain circumstances you may be entitled to request that we stop using your personal information in a particular manner or that we erase personal information that we hold about you. To make a request of this nature, please contact us, providing full details of the activities that you object to and/or personal information you want to be erased and the reason(s) for your request. We will consider all requests upon receipt and confirm to you whether we are able to agree to your request.

D3. Enquires, issues and complaints

• You are entitled by law to ask for a copy of your personal information at any time. Please contact us using the details in paragraph D5.
• In the unlikely event that you have any concerns about how we use your personal information, please contact us as described in paragraph D5. This includes situations where you want to request the rectification or erasure of your personal information, restrictions to be placed around how we use your personal information, or to object to a particular use.
• If you make a complaint about our handling of your personal information, it will be dealt with in accordance with our complaints handling procedure. In the first instance it will be reviewed by an appropriate member of our team who will respond to you within one month. If you are dissatisfied with this response you may request that your complaint be escalated, in which case it will be passed to a senior person in our business who will review your complaint and the initial response and provide a further response within one month of your request to escalate the matter.
• If we are unable to resolve your complaint, you may make a complaint to the Information Commissioner’s Office. Please see https://ico.org.uk/make-a-complaint/ for more information.

D4. Changes to this privacy notice

• We reserve the right to alter this privacy notice at any time. Such alterations will be posted on our website. You can also obtain an up-to-date copy of our privacy notice by contacting us as described in paragraph D5. Should you object to any alteration, please contact us.

D5. Contacting us

• If you need to contact us about this notice or any matters relating to the personal information we hold on you, you can contact us as follows:

• By post: Sorted Group Limited, Level Six, 111 Piccadilly, Manchester, M1 2HY
• By email: legal@sorted.com.

D6. Further information

• We hope that the contents of this privacy notice address any queries that you may have about the personal information we may hold about you and what we may do with it. However, if you do have any further queries, comments or requests, please contact us as described in paragraph D5 above.
• Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/your-data-matters/.

June 2023
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