Thanks for visiting our website www.dxdelivery.com (the Site). This Privacy Notice set outs the basis on which we process any personal data which is provided to us here at DX, whether that data is provided to us by you directly or from a third party.
Please read this Notice carefully and ensure that you understand our rights and responsibilities under it.
DX (Group) Plc, a company registered in the United Kingdom under number 08696699, with its registered offices at Ditton Park, Riding Court Road, Datchet, Slough, England SL3 9GL
Full details are set out in the relevant sections of this Privacy Notice below, but in summary:
- We generally receive personal data relating to you:
- from you directly, where you contact us through our website (dxdelivery.com) (“Site”) or otherwise, or where we do business with you or your organisation; or
- from third parties with whom each of you and we have a separate relationship. For example, if you have received a package delivered by us then we will have been provided with your contact details by the third party who sent you that package;
- Strictly depending on the type of service we are providing, we use your data to provide our services, or in the course of our business activities with your organisation, or to correspond with you, or to meet our legal obligations and improve our Site and services. We may also use your data in the performance of contracts with third parties (for example, if we have been appointed by a third party to deliver parcels or mail on their behalf to individuals including you);
- We only provide your personal data to third parties for our limited business purposes or as permitted by law. We don’t share your data with third party advertisers without your consent;
- We store data for specified periods for our limited business purposes;
- You have certain rights, prescribed by law, in relation to the processing of your data, such as rights to request access, rectification or deletion of your personal data;
- We may use apps, widgets, tools, plug-ins or social media facilities where we do not control what happens to your data but that is strictly for the service provider that provides that service;
- This Privacy Notice does not apply to our employees, contractor or workers, or candidates for employment or engagement (for whom we have separate, internal privacy notice); and
- You can contact us to enquire about any of the contents of this Privacy Notice.
1.1 In this Privacy Notice we describe the types of personal information we collect about customers and consumers, how we may use the information and with whom we may share it. The Privacy Notice also describes the measures we take to safeguard the personal information. In addition, we tell you how you can ask us to (i) access or change the personal information we maintain about you, (ii) withdraw consent you previously provided to us, (iii) refrain from sending you certain communications, and (iv) answer questions you may have about our privacy practices.
2. What personal data we obtain
2.1 We may obtain consumer personal information (such as name, contact details and payment information) in connection with various activities such as (i) use of the DX websites and applications, (ii) activities, including delivery and pickup of shipments, (iii) requests to track shipments or answer questions, (iv) events in which we participate, and (v) promotions and other offers.
2.2 The types of personal information we may obtain include:
2.2.1 Individual and business contact information (such as name, company name, physical address, email address, and telephone or fax number);
2.2.2 Shipping information (such as (i) shipping-related contact details like the shipper's, and consignee's and/or neighbour's (DX’s "leave with neighbour" feature) name, physical address, email address and telephone number, (ii) signature for proof of delivery, (iii) DX account number, and (iv) information given to us that helps us access locations to which we provide service) and information provided to us regarding the content of certain shipments, but only to the extent an identifiable person can be linked to such content;
2.2.3 Names, email addresses and telephone numbers of others to whom we are asked to send information;
2.2.4 Information provided in response to surveys;
2.2.5 Username, password and other credentials used to access DX products and services
2.2.6 Social media handles, content and other data posted on our official social media pages or elsewhere on the Internet (such as other public locations), and information (such as email address and other information you allow to be shared) we obtain through DX-related social media apps, tools, widgets and plug-ins (including third-party login services such);
2.2.7 The geographic location of your mobile device if you use certain features of our apps;
2.2.8 Payment information (including payment card details or online payment services number and billing address) and financial information (such as bank account number);
2.2.9 Tax/VAT identification number in circumstances in which you request products or services for which this information is required, or in connection with certain promotions or sweepstakes; and
2.2.10 Other personal information that may be provided to us to obtain a DX product or service.
2.3 When we pick up or deliver a shipment or provide other services, we may obtain physical location data. This includes, for example, data identifying the actual location of a physical address using information such as GPS data, pictures of delivery location including, and images of the various locations.
2.4 In addition, when you visit our websites, use our apps, or interact with DX-related tools or plug-ins, we may collect certain information by automated means, such as cookies and web beacons. The information we collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken, and dates and times of activity. A "cookie" is a text file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. A "web beacon" also known as an Internet tag, pixel tag or clear GIF, links web pages or apps to web servers and may be used to transmit information back to a web server. Through these automated collection methods, we examine and identify usage patterns. We may link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. We also may use third-party analytics tools that collect information about visitor traffic on our websites or apps. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our websites or apps. Both we and others (such as our internal marketing division) may collect personal information about our visitors' online activities, over time and across third-party websites, when using our websites and apps.
2.5 We may process data about your use of the Site ("usage data"). This may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use. This data is obtained through our analytics tracking system. Often usage data will be aggregated in such a way that it contains no information pertaining to an individual at all: as such is it not actually personal data but we address it in this Privacy Notice for completeness’ sake. We process usage data for the purpose of improving our Site. The legal basis for this processing is our legitimate interests, namely the improvement of our Site.
2.6 We may process personal data contained in or relating to any communication that you send to us, whether through the Site, by email, through social media, by using live-chat functions, or as feedback on our services which you provide based on our customer satisfaction surveys, including through third parties like TrustPilot who we engage to solicit feedback on our behalf. All of this together is correspondence data. This may include the communication content and metadata associated with the communication, as well as any contact details you provide to us such as your name, email address, phone number, job title, address or social media username. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of the Site, our business and our communications.
2.7 We may process personal data contained in any enquiry you submit to us indicating your interest in our services or business (enquiry data), such as the contents of your enquiry and any contact details you provide to us such as your name, email address, phone number, job title or address. This may be processed for the purposes of marketing relevant services to you. The legal basis for this processing is our legitimate interests, namely ensuring that enquiries are followed up appropriately and marketing our services.
2.8 We may process personal data which we have obtained from you in connection with deliveries of mail, parcels or consignments which are either addressed to you or for which you have provided a signature. That data could include your name and signature. We may also process personal data which is generated by our drivers when delivering mail or parcels to you for the purposes of confirming delivery. That could include geo-location data (showing that our driver was in your locality) or photographs of the delivery location. All of this information together is delivery data. This may be processed by us for the purposes of recording and evidencing delivery of mail and parcels carried by us. The legal basis for this processing depends on whether the delivery data relates to the addressee for the mail, parcel or consignment or whether it relates to another individual who is not the addressee but who signed for the delivery. In relation to the addressee, the legal basis for our processing is the performance of a contract benefiting the addressee. In relation to other individuals, the basis for our processing is our legitimate interests, namely ensuring that we are able to demonstrate that we have performed our delivery obligations.
2.9 We may record calls made to us. These recordings may be processed by us for the purposes of record-keeping and administering the activity to which the call relates (for example, complaint handling or enquiry handling) and for training purposes. The legal basis for this processing is our legitimate interest, namely ensuring that we are able to properly track, manage and respond to telephone communications.
Personal data we obtain from others
2.10 We may process personal data relating to personnel at organisations to whom we provide services, or from whom we purchase services service data). For example, we may process information relating to key account contacts at our suppliers and customers, with whom we deal regularly in the course of our business. Service data may be processed by us in connection with the supply, receipt and administration of the relevant services. The legal basis for this processing is our legitimate interests, namely ensuring that we are able to supply, receive and administer relevant services in the course of our business.
2.11 We may process personal data relating to individuals to whom mail, parcels or consignments carried by us are to be delivered (addressee data), such as the name, address and contact details of those individuals. Addressee data is provided to us by our business customers: for example, if we provide carriage services to a retailer of furniture, then that retailer will necessarily have to provide us with personal data relating to the addressee in order for us to deliver the furniture ordered. Addressee data may be processed by us in connection with the carriage and delivery of the relevant mail, parcels or consignments, and in connection with associated administration and correspondence, both with the relevant business customer and with the addressee. The legal basis for this processing is the performance of a contract benefiting the addressee: for example, if you have ordered a package from a retailer then you have a contract with that retailer, and our delivery services help that retailer perform its obligations to you. We may also use addressee data to contact addressees shortly after delivery to solicit feedback on the provision of our services. The legal basis for that processing is our legitimate interests, namely ensuring the quality of our services.
2.12 We have installed CCTV systems in some of our premises, and on some of our vehicles. We may process stills or footage which contains images of individuals (CCTV data). CCTV data may be processed by us for the purposes of monitoring building and vehicle security and crime prevention and detection. The legal basis for this processing is our legitimate interests, namely ensuring the safety and security of our staff, premises and property.
2.12 The providers of third-party apps, tools, widgets and plug-ins on our websites and apps. Also may use automated means to collect information regarding your interactions with these features. This information is subject to the privacy policies or notices of these providers.
3. How we use your personal data that we obtain
3.1 We may use the information we obtain to:
3.1.1 Pick up, deliver and track shipments;
3.1.2 Provide products and services you request (such as logistics, supply chain management, customs clearance and brokerage services, and financial services);
3.1.3 Process and collect payments;
3.1.4 Provide customer support and respond to and communicate with you about your requests, questions and comments;
3.1.5 Establish and manage your DX account;
3.1.6 Offer you products and services we believe may interest you;
3.1.7 Communicate about, and administer your participation in, special events, programs, surveys, contests, and other offers or promotions;
3.1.8 Enable you to post on our blogs and interact with DX through social media;
3.1.9 Send information to your contacts if you ask us to do so;
3.1.10 Process claims we receive in connection with our services;
3.1.11 Operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analysing and enhancing our products, services, websites, and apps; and performing accounting, auditing, billing, reconciliation and collection activities);
3.1.12 Perform data analyses (including market and consumer search, trend analysis, financial analysis, and anonymisation of personal information);
3.1.13 Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
3.1.14 Comply with applicable legal requirements and our policies.
3.2 In addition, we use information collected online through cookies, web beacons and other automated means for purposes such as (i) customizing our users' visits to our websites and apps, (ii) delivering content (including advertising) tailored to our users' interests and the manner in which our users browse our websites and apps, and (iii) managing our business. We may supplement data we collect through automated means with information about your location (such as your postal code) to provide you with content that may be of interest to you. We also use this information to help diagnose technical and service problems, administer our websites and apps, identify users of our websites and apps, and gather demographic information about our users. We use data to determine usage patterns and how we may tailor our websites and apps to better meet the needs of our users. Our websites and apps are not designed to respond to "do not track" requests from browsers.
3.3 We also may use the information we obtain about you in other ways for which we provide specific privacy notice at the time of collection.
4. How we share Information
4.1 We do not sell or otherwise share personal information about you, except as described in this Privacy Notice. To perform our pick-up and delivery services, we may share shipping information with third parties such as shippers, consignees, third party payers and recipients. We may also share personal information with third parties who perform services on our behalf based on our instructions. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
4.2 We also may share the personal information we obtain with our affiliates. We may share physical location data with other third parties to, for example, enhance location-based services and develop accurate and up-to-date maps. In addition, except as described below, unless you object, we may share other personal information with third parties for those parties' own purposes, such as to offer products or services that may interest you.
4.3 Information collected through third-party apps, tools, widgets and plug-ins is collected directly by the providers of these features. This information is subject to the privacy policies of the providers of the features, and DX is not responsible for those providers' information practices.
4.4 Many of our customers outsource all or a part of their supply chains to us. Through our forwarding and logistics business units, we manage these supply chains, focusing on supply chain optimization, freight forwarding, and international trade and brokerage services for our customers. We also provide information technology systems and distribution facilities adapted to the unique supply chains of specific industries such as health care, technology and consumer/retail businesses. In the course of providing forwarding and logistics services, we may obtain, use and disclose personal information about our customers' customers. In these circumstances, we process the information based on the agreement with our customer.
4.5 We also may disclose information about you (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
5. How we protect personal data
5.1 We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Although we take steps to limit access to our facilities and vehicles to authorized individuals, information that is located on the outside of a package or letter may be visible to others.
5.2 We have put in place appropriate security measures to prevent your personal data from being lost, used, accessed, altered or disclosed by accident or without authorisation. In addition, we limit access to your personal data to those officers, employees and contractors 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.
5.3 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.
6. Other processing by us
6.1 We may process any of the personal data identified in this Privacy Notice where necessary in connection with legal claims. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
6.2 We may also process any of the personal data where necessary for compliance with a legal obligation to which we are subject, or in order to protect your or another individual’s vital interests.
6.3 We may process any of the personal data in connection with backups of any element of our IT systems or databases containing that personal data. The legal basis for this processing is our legitimate interests, namely ensuring the resilience of our IT systems and the integrity and recoverability of our data.
7. Third party personal data
7.1 Please do not supply any other person's personal data to us, unless we prompt you to do so and/or we have agreed in writing prior to receiving the data from you. Any information that we receive that is not identified shall be notified to you and destroyed immediately.
8. Providing your personal data to others
8.1 We may disclose your personal data to other entities within our group of companies.
8.2 We may disclose your personal data to our insurers and/or professional advisers as necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
8.3 We may disclose personal data to our suppliers or subcontractors, or to third parties with whom you have a contractual relationship (such as retailers from whom you have ordered packages for delivery) in connection with the uses described above. For example, we may disclose:
8.3.1 addressee data to our sub-contractor drivers;
8.3.2 delivery data to the sender of the relevant mail, package or consignment;
8.3.3 any personal data in our possession or control to organisations which host the servers on which our data is stored; and
8.3.4 enquiry and correspondence data to our email service providers, on whose servers our correspondence may be stored temporarily or backed up longer-term.
8.4 We may also disclose personal data which relates to our business to any third party which purchases (or proposes to purchase) our business, or the part of our business to which that personal data relates.
8.5 We may also disclose personal data where necessary for compliance with a legal obligation to which we are subject, or in order to protect your or another individual’s vital interests, or in order to enforce our rights.
9. International transfers of your personal data
9.1 In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
9.2 The hosting facilities for our Site and all of our major systems are located within the EEA, generally in the United Kingdom, although some are in Ireland and we may transfer any personal data to our hosting service providers in that country.
9.3 We may transfer the personal information we collect about you to countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Notice and in accordance with applicable law. We use contractual protections for the transfer of personal information among various jurisdictions (including, for example, Information Commissioners Office Guidance on General Data Protection Regulations 2016 and standard contractual clauses). You may contact us if you would like further information about these safeguards.
10. Retaining and deleting personal data
10.1 This section sets out information about our data retention policies, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
10.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
10.3 We will retain and delete your personal data as follows:
10.3.1 usage data will be retained for ninety (90) days from collection, and then deleted. However, this may differ depending on the contractual obligation and/or the legitimate interest of DX. As an exception, aggregated usage data from which no individual can be identified may be retained by us indefinitely;
10.3.2 enquiry and correspondence data will be retained for the duration of the enquiry or chain of correspondence, and then for twelve (12) to eighteen (18) months afterwards depending on the content. For example, enquiry correspondence is normally retained for one year but complaints or responses to our satisfaction surveys will be retained for eighteen (18) months;
10.3.3 delivery data and addressee data will be retained until delivery of the relevant items is complete (or until the sender has confirmed that the item is no longer to be delivered) and will then be deleted after three (3) months;
10.3.4 telephone recordings will be retained for six (6) months;
10.3.5 service data will be retained for as long as we provide or receive the relevant services, and will then be deleted after two to six years depending on the content. For example, documents recording goods received by us will be retained for two years, while invoices (whether issued to or by us) will be retained for six years;
10.3.6 CCTV data will be deleted after ninety (90) days.
10.4 We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person, or in connection with any legal claim.
10.5 Subject to applicable law, (i) you may obtain a copy of certain personal information we maintain about you or update or correct inaccuracies in that information by filing a Subject Access Request (ii) you may have the right to obtain access to personal information we maintain about you by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated below.
10.6 We offer you certain choices about how we communicate with you and what information we collect from you. You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in our marketing emails, or by contacting us in "Our Details" section below. You also may ask us not to send you other marketing communications by contacting us as specified in the "Our Details" section below, and we will honour your request. Consistent with the choices available in the "How We Share Information" section, you may withdraw your consent. In addition, as required by law, you may object at any time on legitimate grounds and free of charge to the processing of your personal information, and we will apply your preferences going forward.
11. Your rights
11.1 In this section we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. You can read guidance from the Information Commissioner’s Office at www.ico.org.uk for a fuller explanation of your rights.
11.2 Your principal rights under data protection law are:
11.2.1 the right to access: you have the right to confirmation as to whether or not we process your personal data and, where we do, to access to the personal data, together with additional information including details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee;
11.2.2 the right to rectification: you have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed;
11.2.3 the right to erasure: in some circumstances you have the right to the erasure of your personal data. These might include if the personal data are no longer needed for the purposes for which they were processed or if the processing is for direct marketing purposes. However, there are some exclusions of the right to erasure, such as where processing is necessary for compliance with a legal obligation or in connection with legal claims;
11.2.4 the right to restrict processing: in some circumstances you have the right to restrict the processing of your personal data. Where processing has been restricted, we may continue to store your personal data and will observe the restrictions on processing except in the case of processing permitted by applicable law (for example, in connection with legal claims or for reasons of public interest);
11.2.5 the right to object to processing: you have the right to object to our processing of your personal data on the basis of the legitimate interests pursued by us or by a third party. If you make such an objection, we will stop processing the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or unless the processing is for legal claims. You also have the right to object to our processing of your personal data for direct marketing purposes and if you do so we will stop processing your personal data for that purpose;
11.2.6 the right to data portability: if the legal basis for our processing of your personal data is consent, or the performance of a contract with you, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others; and
11.2.7 the right to complain to a supervisory authority: if you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
11.3 You may exercise any of your rights in relation to your personal data by written-notice to us by sending an email to email@example.com
12. About cookies
12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
12.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
13. Cookies that we use
14. Advertising and service providers
14.2 On our websites and apps, we may collect information about your online activities for use in providing you with advertising about products and services tailored to your individual interests. This section of our Privacy Notice provides details and explains how to exercise your choices.
15. Managing cookies
15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
15.1.1 https://support.google.com/chrome/answer/95647?hl=en (Chrome);
15.1.3 http://www.opera.com/help/tutorials/security/cookies/ (Opera);
15.1.4 https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
15.1.5 https://support.apple.com/kb/PH21411 (Safari); and
15.2 Blocking all cookies will have a negative impact upon the usability of many websites.
15.3 If you block cookies, you may not be able to use all the features on our Site.
16. Third Parties and Security
16.1 The Site contains links to third party websites and refers to third party service providers and other entities. If you follow a link to any third party website or deal with any third party entity referred to on the Site, then you should note that these third parties may have their own privacy and cookie policies, and that we are not responsible for their use of any personal data which you may provide to them. You should ensure that you have read and understood any relevant policies.
16.2 Although we do our best to ensure the security of personal data provided to us (and to use only reputable service providers), any transmission of data via the Internet is by its nature insecure and we cannot guarantee the security of any personal data you provide to us.
17.1 This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our websites to notify you of any significant changes to our Privacy Notice and indicate at the bottom of the Privacy Notice when it was most recently updated.
18. Our details
18.1 You can contact us:
- 18.1.1 by post, using the postal address: DX (Group) Plc, Ditton Park, Riding Court Road, Datchet, Slough, SL3 9GL;
- 18.1.2 using the contact form on our website; or
- 18.1.3 by email on: firstname.lastname@example.org
Last updated: 10th May 2019