Client & Customer Privacy Policy
Changes to privacy notice

In September 2025, we updated this privacy notice to simplify and consolidate it to make it easier for customers to understand and to provide further information on various types of processing.

1. Important information and who we are

Relay Technologies Limited (“Relay”) is a final mile delivery company which delivers goods to customers on behalf of retailers.When we refer to ‘customers’ or ‘you’ in this privacy notice, we are referring to the consumers who ordered the goods.  When we refer to ‘retailers’, we are referring to the online shops from which the goods were purchased (our clients). Where we refer to a ‘PUDO’, we are referring to a convenience store or other locations where you can collect or drop-off your parcel.Relay respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. This privacy notice provides specific information on how Relay collects and processes your personal data. It is important that you read this privacy notice so that you are fully aware of how and why we are using your data. Relay is the data controller and is responsible for your personal data. Relay is registered with the Information Commissioner’s Office and its registration number is ZB489499.(In some limited cases, Relay processes your personal data in the capacity of a data processor. Where this is the case, you should review the retailer’s privacy notice for information on how your personal data is processed in connection with delivery of your parcel. For information on how to exercise your legal rights, see section 13 ‘How can you exercise your legal rights?’).

2. Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review.

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

3. How do we collect your personal information?

Relay collects personal information from retailers and customers in the following ways:

• following requests or instructions to complete deliveries;
• use of our services and website;
• contact made with us for any reason including any enquiries or complaints;
• completed Relay forms and receipts (including proof of delivery receipts);
• completed customer satisfaction surveys and feedback on our website;
• reviews left on third-party websites;
• information entered or submitted via the Relay website;
• for entrance to Relay’s sites.

4. What types of information do we collect?

Relay may collect, use, store and transfer different types of personal data about you. This includes information provided from retailers, information you provide to us and information we create when providing services to you or other customers. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) unless you provide it to us as part of a request or complaint. Nor do we collect any information about criminal convictions and offences.Our website is not intended for children and we do not knowingly collect data relating to children.For more details of the personal data we process, and how this data is collected or obtained, see the table below in section 5.

5. How do we use your personal data?

Relay uses the information that we collect for a number of different purposes in order to:

a) provide and continuously improve our services;

b) enhance or improve customers' experience of our services via customer satisfaction surveys or reviews on third party websites;

c) enhance or improve our services by analysing the data collected such as delivery preferences, factors affecting delivery and how you interact with or use our websites and applications;

d) record and monitor communications with customers to ensure consistent service levels, prevent or detect fraud, resolve queries and complaints and for performance management and training purposes;

e) prevent and detect fraud and money laundering, and taking action against fraudsters or people who commit an offence;

f) use digital imagery to help maintain the safety and security of our drivers, property, deliveries and the public; and

g) undertake research for analytical and statistical purposes.

We may use artificial intelligence (AI) to provide a better user experience and to improve our services. Our AI systems are designed to process your data securely and in accordance with applicable data protection laws. We do not make decisions based solely on automated processing or profiling that produce legal effects concerning you (or have similarly significant effects).

Relay will only process your personal data if there is a legal basis under data protection laws and the table below identifies these (more than one lawful basis may apply in some situations). In summary, these are:

i) Legitimate Interests: the processing is necessary for legitimate interests pursued by Relay or another party;

ii) Legal Obligation: the processing is necessary to comply with the law; or

iii) Consent: you give consent for us to process your data for a specific purpose.

The purposes for which Relay processes personal data and the legal bases for doing so in each case are:

Types of data
Source
Purpose &
How do we use your personal data
Lawful basis
Order details, contact information and signature
This includes name, address, alternative delivery addresses, email address and telephone number(s). A signature may be required for us to deliver or for you to collect or drop-off a parcel at a PUDO.
This information is collected from the retailer and from the customer or third party (such as a neighbour) that is accepting the delivery/receiving the parcel.We may also obtain personal details from third parties to verify delivery addresses.
Purpose: Providing delivery/collection services to you as a result of an order you placed with a retailer.

Uses:
1) To deliver or collect/drop-off a parcel at a PUDO and record that this has taken place

2) Invite you to confirm delivery preferences

3) Provide dispatch and delivery notifications which may be by email, text message or WhatsApp message

4) To identify you to provide tracking information

5) Contact you in the event assistance is required to deliver or a parcel

6) Respond to any communications from you

7) Send you requests to complete customer satisfaction surveys

8) Investigate parcels that have not been received
Legitimate Interest: it is in your, our and the retailer’s legitimate interest for the personal data to be processed in this way so that the delivery/collection can be completed and we can fulfil our contracts with the retailers you purchased the goods from.

Consent: where a third party accepts delivery of your parcel, they do so voluntarily by consent.
Delivery preferences and location

Recording your delivery preferences and location of the parcel
This information will be created when you provide contact information and preferences in the course of an interaction with Relay.
Purpose: Delivering the parcel to you and recording where it was delivered.

Uses:
1) Recording preferred delivery address/location

2) Recording the GPS location and a photograph of where the parcel was delivered to/left in a safe place. (The photograph may contain location or other information that links the image to a customer or otherwise identifies an individual.)
Legitimate interest: It is in your, our and the retailer’s legitimate interest for your personal data to be processed in this way so that the parcel can be delivered to your preferred place, we have a record of where the parcel was delivered and we can fulfil our contracts with the retailers you purchased the goods from.
Contact history, including enquiries and complaints

These are details of any enquiry, complaint or claim you have made to us and may include emails, letters, chatbot, social media messages, call recordings and any other records of communication used to contact us in relation to a parcel or our services.
You will provide this information to us when you contact us to make an enquiry or complaint. This will include any information you provide including any special category and/or confidential information provided.
Purpose: Handling and resolving enquiries and complaints.

Uses: To investigate and respond to any requests and complaints including claims that parcels were not received.
Legitimate interest:  It is in your, our and the retailer’s legitimate interest for your personal data to be processed in this way so that we can seek to resolve the matter.

Explicit consent (special category data): we process any special category data provided by you with your explicit consent.
Recordings of you

Images recorded on CCTV and other equipment used to protect our customers, employees and property.
We will record images of you if you visit a location where CCTV is in operation, such as our warehouses. Our vehicles may be fitted with reversing cameras as well as forward-facing / cab cameras. We also record communications with our customer service team.
Purpose and uses: Prevention and detection of crime, assist with insurance claims and training and monitoring purposes.
Legitimate interest: it is in both our and society’s legitimate interests for Relay to take steps to protect our clients, customers, employees, the public and property.

It is in both our legitimate interests and our clients’ and customers’ for us to monitor and improve our customer services.

Legal obligation: We have a legal obligation to take steps to keep people safe and to co-operate with police and insurance companies.
Feedback on the services

Completed customer surveys used to review and improve our services, feedback provided via our website or reviews on third party websites.
You provide this information if you agree to complete a survey or questionnaire about the service you received or provide feedback on our website or via a third party website.
Purpose and uses:

To evaluate and improve our services and develop new service offerings. For example, we use customer satisfaction surveys, feedback on our website and reviews left with third parties like TrustPilot to evaluate and understand how our services are working, how they can be improved and for the purposes of developing new delivery services or new enhanced services. If you include personal identifiers or order details in your review, Relay will use this to identify your order to evaluate and improve our services.
Legitimate interest: It is in our, your and our client’s legitimate interest for us to improve our services to benefit customers.

Sharing data with retailers

Data collected as part of providing the services (eg order status, tracking information, location and proof of delivery) and complaints about the service

We collect this information as part of providing the services to you.
Purposes: To enable the retailer to monitor the services being provided and help the retailers fulfil their contracts with customers.

Uses: For example, we provide updates for the delivery of goods ordered from the retailer, the reasons why deliveries fail and information relating to the delivery of the parcel.
Legitimate Interest: Our retailers have contractual obligations with you that they need to fulfil and we have contractual obligations with the retailer that we need to fulfil. We both have a legitimate interest towork together and share information to fulfil those contractual obligations. It is in your legitimate interests that we do so in order that the services are provided and complaints are resolved.
Data analytics

Data collected as part of the provision of the services (eg delivery preferences, location data, reaction to Relay communications)
We collect this information as part of providing the services to you.
Purpose: To improve the services and develop new service offerings.

Uses: For example, analysis of customers’ reaction to our communications, customers’ delivery preferences, location data and proximity to collection points, data updated and added by customers, delivery success and customer experiences.
Legitimate interest: It is in our and your legitimate interest for us to analyse this data in order to improve the services and develop new service offerings to benefit customers.
Use of our website

IP address, order number, postcode
You automatically provide your IP address and if you use the tracking service you also provide your order number and postcode.
Purpose and uses: Enhancing our client and customers' experience of our services and websites. For example, we use information on your visits to our websites to evaluate and understand how different people navigate our websites and how long they spend on particular pages.
Legitimate Interest: it is in our, your and the retailers’ legitimate interests for us to understand how you use our services so we can enhance and improve them for your benefit.
Financial Details

Records of payments and payment information such as payments for property damage.
You provide this information yourself if we need to make a payment to you.
Purpose and use: To make a payment to you.
Legitimate interest: it is in our and your legitimate interests for us to process this information to make the payment to you.
6. Who do we share your personal data with?

Relay employees and workers, contractors or agents may access information:Relay employees, contractors or agents may access information:

● to provide delivery of items to you, or management of a service;

● to process, deal or respond to any enquiry, complaint or other contact you have made with us;

● to contact you regarding customer satisfaction surveys and reviews left on third party websites;

● to evaluate customer satisfaction surveys and reviews and improve service delivery; and

● for troubleshooting and maintenance purposes.

Retailers:

We share personal data with retailers for the purposes of providing services to them, for example the provision of proof of delivery and status of delivery information for items delivered to you on their behalf. See ‘Sharing data with retailers’ in the table above for further information.

Other third Parties:

We use data processors who are third parties providing elements of the services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

We use the following data processors:

● Technology service providers – our partners who provide IT, applications and website services;

● Verification service providers – our partners who provide address verification and address location data to improve the speed and accuracy of our delivery service;

● Customer service providers – our partners who work with us to administer your delivery and provide you with any help you may need;

● Third party delivery companies – our self-employed couriers and parcel firms who may deliver your goods on our behalf;

● Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We may share your data with other third parties (including the police, law enforcement agencies, credit reference and fraud prevention agencies and other bodies) to protect our or another person’s rights, property, or safety, in connection with the prevention and detection of crime.In some circumstances we are legally obliged to share information. For example, under a court order or where we cooperate with a regulator undertaking an investigation into complaints or criminal conduct. We might also share information with other regulatory bodies in order to further their, or our, objectives. In any scenario, we’ll satisfy ourselves that we have a lawful basis on which to share the information and document our decision making and satisfy ourselves we have a legal basis on which to share the information.

7. Transfer of Information Outside of the UK and EEA

In operating our services, it may become necessary to transfer the data that we collect from you to third parties and business partners who are located outside of the UK. Any such transfer of information will only be in connection with the services that Relay provides and for a purpose that is stated in this privacy notice. Relay will ensure that the information is protected to a level which meets the requirements of English law such as by ensuring that the location has approved protections in place and/or by having standard contractual clauses in place with the third party to ensure your rights are protected.

8. Will you be contacted for marketing purposes?

We send commercial e-mails to individuals at our retailers or other companies with whom we want to develop or maintain a business relationship in accordance with applicable laws. Individuals at our retailers can opt out of receiving marketing emails at any time by using the contact details at the end of this notice.We send commercial e-mails to individuals at our business clients or other companies with whom we want to develop or maintain a business relationship in accordance with applicable laws. Individuals at our business clients can opt out of receiving marketing emails at any time by using the contact details at the end of this notice.

Relay does not conduct any form of direct marketing targeted at our customers though we may ask you for feedback on the performance of our services via customer satisfaction surveys.

We will not share your information with any third parties for the purposes of direct marketing.

9. How do we keep your data safe?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. How long do we keep your information for?

We will hold your personal information within a secure dedicated database for as long as is necessary to provide our delivery and other services to you. Once services are completed, we will determine how long to retain the different types of information about you based on our Data Management Policy and the following requirements:

• How long the information is needed for the specific purpose or purposes it is used for;

• Legal and regulatory requirements – for example, if Relay is required to retain client and/or customer records for an additional period of time in order to comply with a legal (including regulatory) requirement; and

• To maintain records in the event of any potential or actual claims.

‍In some circumstances you can ask us to delete your data: see section 12. What are your legal rights below? for further information.We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

11. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

12. What are your legal rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

o If you want us to establish the data's accuracy;

o Where our use of the data is unlawful but you do not want us to erase it;

o Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and/or

o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us on the contact details above.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. How can you exercise your legal rights?

If you wish to exercise any of your legal rights, please contact Relay on the details below. In the limited cases where Relay is a data processor, we will inform you of this and re-direct your request to the retailer.

14. How can you ask questions or raise concerns?

If you have any questions about this privacy notice or our privacy practices, please contact us on the details above.
‍Email address: gdpr@relaytech.co

Postal address: 63-66 5th Floor Suite 23, Hatton Garden, London, EC1N 8LE.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so we ask that you contact us in the first instance on the details above.

15. Changes to this privacy notice

This privacy notice may be updated from time to time so you may wish to check it each time you submit personal information to Relay. The date of the most recent version will appear on this page (see section 16. Version control below). We encourage you to check our privacy notice from time to time to ensure you understand how your data will be used and to see any minor updates. If material changes are made to the privacy notice we will provide a more prominent notice at the start.

16. Version control

This privacy notice was last updated in: September 2025.