Last updated
March 5, 2024
Driver Privacy Notice
1. Introduction
1.1 Instabee Group AB and all affiliates within the Instabee Group (“Instabee”, “we” or “us”) ("Instabee", "we", or "us") are committed to respecting and protecting your privacy. Our goal is to be clear about what personal data we collect and how we use and protect it in accordance with applicable laws and regulations. Instabee Group AB and its subsidiaries and affiliates within the InstabeeGroup ("Instabee", "we", or "us") respect your privacy. It is important to us that we process your personal data responsibly and securely, in accordance with applicable laws and regulations.
1.2 In this privacy notice (the "Driver Privacy Notice"), we explain howInstabee processes personal data about you as a driver, employed by us or hired by one of our, direct or indirect, subcontractors that performs transportation services for Instabee ("Drivers"). This Driver Privacy Notice also contains information on how we safeguard your personal data and what rights you have in relation to our processing.
1.3 When this Driver Privacy Notice refers to “Instabee”, “we” or “us”, only one individual Instabee company is and can be the data controller of the actual processing of personal data described in this Driver Privacy Notice. For information on which company within Instabeethat is the applicable data controller, please refer to Section 8 below. For the avoidance of doubt, this Driver Privacy Notice does not include information on how your employer processes your personal data. You are referred to consult your employer to receive such information.
1.4 We offer various transportation services of goods to our direct and indirect customers, partners and/or our partners' direct and indirect customers as well as any other recipients of goods (jointly referred to as "customers"). Our commitment to our partners and customers is to provide efficient, optimized, secure, reliable, green, smooth and precise transportation services by using the latest technology and by providing great customer service and customer experience. We have also committed to (i) reward our subcontractors (and in turn we recommend them to reward Drivers) that performs excellent services on our behalf; and (ii) provide Drivers with tools and functionality that enable Drivers to perform the services efficiently and to easily communicate with customers and other concerned parties, and in general simplify the Drivers' tasks by minimizing manual work and instead use digital solutions. We are also committed to create engagement among Drivers and follow Driver’s progress by analysing and compiling metrics. We process your personal data for the purposes set out in this Driver Privacy Policy e.g. in order to ensure that we can fulfil our commitments to our customers, partners, subcontractors and Drivers and in order to fulfil our obligations pursuant to applicable laws and regulations.
1.5 As a responsible business partner, we have requirements on our subcontractors, e.g. to provide high quality services on fair working conditions. You are employed or hired by one such subcontractor of ours. Accordingly, we may process your personal data in order to ensure that our subcontractors and partners fulfil their obligations towards us and under applicable laws.
1.6 As a Driver for Instabee you need to install and use the "Driver App" on your smartphone, when performing services for us, if not otherwise instructed by Instabee. The Driver App will collect certain personal data about you when performing services for us and such personal data will be processed by us, as further described in this Driver Privacy Notice. You must not use the Driver App during leisure time or when you are not working for Instabee, in order to avoid that we collect personal data about you when not relevant.
1.7 Note that the information in this Diver Privacy Notice may be updated from time to time. The latest version of this Driver Privacy Notice will always be available in the Driver App. When this Driver Privacy Notice is updated, you will receive a notification in the Driver App.
2. For What Purposes Do We Process Your Personal Data?
2.1 The personal data we process about you depends to some extent on what type of transportation services you perform for us (e.g. pick-up, linehaul, home deliveries and/or box deliveries of parcels).
2.2 When you have not given us your personal data yourself, we could have received the personal data in the following ways:
From your employer/principal (i.e. our direct or indirect subcontractor).
From your use of the Driver App, our website or any other digital tools or services used by you when performing the transportation service for us.
From customers, our partners, or any other party rating or submitting feedback or reports to us.
Through camera surveillance or phone recordings.
We may also internally generate personal data about you, e.g. a driver ID-number and driver level.
2.3 We safeguard your personal data with a high level of security and to this end, we have implemented appropriate technical and organisational security measures to protect your personal data from unauthorised access, change, dissemination or destruction. Examples of security measures we take are data encryption and access control.
Personal data is all information that may be associated with you as an individual. We process the following personal data about you as a Driver:
Basic personal data:
Your name, photo, “driver ID” and contact details (i.e. email address and phone number).
Name of your employer and, if relevant, information relating to a change of employer.
Log-in data to Driver App.
Driver level (a level/ranking/rating on how efficient a Driver is based on historical data), set by us, and supporting comments.
Your location (i.e. historical and live GPS-data) when performing transportation services and any other task related to such services, including during execution of the assigned route for parcel delivery/return.
The type and registration number of the truck you are driving when performing transportation services and when delivering/returning parcels.
Your signature.
Driver's license competence.
Feedback, incidents and other information reported by you or someone else (if any).
Test results from aptitude tests in conjunction with onboarding process (i.e. before Driver is permitted to perform transportation services for Instabee).
Your language skills, as required for performing the transportation services.
Personal data relating to transportation services performed by Drivers:
Delivery route, total number of routes and other route information (e.g. routed distance, routed hours, numbers and estimations regarding the route(s), etc).
Time to deliver parcels/complete the assigned route, including route length, time to first stop, number of stops per hour, departure from last stop and service time etc., and time loading/unloading the truck and scanning/register items/parcels.
Early and late arrivals and departures (e.g. for loading, to first stop and to/from last stop).
Driving speed, time and distance.
The number of delivery stops made (including multiple parcel stops).
The number of parcels delivered/not delivered and/or number of pallets collected/loaded.
Number of and reasons for cancellations of routes/deliveries and missed stops/deliveries (e.g. due to delays, damaged parcels or premature end of route).
Type of parcel delivered (e.g. weight).
Customers' Driver ratings (e.g. the number of one- to five-stars ratings), reviews and reports.
Sensor data such as pedometer data (e.g. steps count, information on whether you are running, walking etc.), gyrometer data and GPS-data.
On which routes you perform better and on which routes where there is room to improve the performance.
General performance data.
Phone calls (and recordings thereof) through the Driver App, made e.g. to customers (including other recipients of deliveries) and Instabee's traffic control centre.
Compensation data (e.g. recommended compensation/salary for Drivers).
Other personal data (in exceptional cases) if included in:
Information reported through our whistleblowing channel or through any similar channels and any information thereafter reported or obtained when investigating such matter.
Information collected or reviewed due to an audit or survey of our subcontractor and/or your employer/principal.
Reports on suspected thefts, illegal actions or unprofessional behaviour and potentially warnings or suspensions.
Random alcohol test result (if any).
2.4 If you visit any of our premises or terminals, we may have camera surveillance on such locations. In some trucks, we may also have installed cameras that monitor the surroundings of the truck. Areas/trucks with camera surveillance is marked with signs. In such cases video may be recorded. Note that also our subcontractors, partners and customers may have camera surveillance of their premises, terminals and trucks and in such case Instabee is not responsible for the camera surveillance.
3. For What at Purposes Do We Process Your Personal Data?
3.1 Before you start as a Driver you will have to conduct a test and you and/or our subcontractor will have to provide certain information on your skills, competence and past experience. Such personal data will be processed for the purpose of determining if you will be able to become a Driver for Instabee.
3.2 When you perform the transportation services as a Driver, we process the personal data listed above for the following purposes:
To provide our services.
To provide you with access to relevant systems (including the Driver App) necessary to fulfil your tasks when performing the transportation services.
To assign an appropriate Driver for certain routes/areas based on base location, driver level, past performance (generally as well as in the specific area), ratings, etc.
To monitor and follow the transports and parcels in order to e.g. (i) ensure quality, security and efficiency, and to estimate delivery/pick-up time, (ii) ensure that the subcontractor fulfils its obligations, including but not limited to ensuring and evidencing that the goods are delivered as specified at the correct time and location, (iii) assess, reprioritize, optimize, and inform concerned parties if the route planned for the Driver will be completed in time or not, and (iv) evaluate Driver performance.
To communicate with Drivers, Instabee’s employees/representatives, partners and customers with regard to transport, deliveries and returns, including informing and providing notices and live updates to customers on where the Driver is located and when a delivery or pick-up of a return can be expected, e.g. for transparency, predictability and enhanced customer experience (sharing name, photo and geographical position).
To improve/optimize/schedule current and future routes, our models for routing and estimations of delivery/pick-up time for transportation services, for you as a Driver, customers and routes in general, e.g. for the purposes of creating more efficient and by that more environmental friendly routes.
To create and compile data and statistics, analyse and share data, statistics and insights with you and the subcontractors you are employed/hired by (e.g. Driver's performance/development compared to past performance by the Driver as well as Drivers in general, common mistakes, improvement areas, etc.).
To create and compile data and statistics, analyse and to some extent share data, statistics and insights with customers and partners (e.g. number of home deliveries made in a certain area, where Instabee’s services are commonly used and other aggregated data/insights).
To measure, monitor and evaluate Driver performance and to prepare, calculate and compile compensation to the subcontractor and indirectly Drivers, e.g. for the purpose of recommending the subcontractor Instabee’s view on a reasonable compensation to the Driver based on the level of performance, the number of stops and other relevant factors during a parcel delivery route.
To measure and evaluate the Driver movement pattern, efficiency and quality when performing the services, and to better estimate service time, delivery time and delivery/pick-up times, that appropriate time is allocated for routes/stops, and for current and future route planning, e.g. for the purposes of creating a more efficient and by that a more environmentally friendly transportation service.
To perform audits, surveys etc. of subcontractors to verify quality and compliance with our code of conduct, other obligations imposed on the subcontractor (e.g. the requirement to employ Drivers on fair working conditions), and applicable laws and regulations.
Managing and investigating reports/information regarding irregularities, non-compliance, fraud, theft, illegal activities, complaints, incidents, and conduct, submitted through our whistleblowing channel or otherwise obtained.
To provide, execute and evaluate our Driver gamification project (if you choose to participate in it), which serves as a tool for e.g. measuring efficiency and performance, to develop and improve Drivers' own performance, to collect, compile and analyse information and to create engagement, incentives and instant gratification and to provide feedback to Drivers and subcontractors. In addition to our Driver gamification project we may also publish a list of “Top Drivers” (in different categories) on our public website. If you are listed as one of our Top Drivers on the website, your name, picture and a brief comment (on what makes you a Top Driver) will be available for the public on our website.
To provide, uphold, maintain, improve and develop our software, the Driver App, our transportation services, route planning (including the efficiency and the environmental impact), customer service and other services to customers and partners, and our offering and operations in general, and to provide automated assistance and personal content to Drivers, partners and customers.
To administrate Instabee’s contractual relationships with subcontractors, customers, and partners.
To manage the Driver's professional development by implementing and conducting generic and/or individual development programs, arrangement of trainings and development activities, including on-boarding trainings, ad-hoc trainings or certifications according to Instabee’s performance and development processes
4. What Are The Legal Basis Associated With Each of the Above Processing?
4.1 We perform most of the processing, for the purposes described in this Driver Privacy Notice, based on a so-called balancing of interest. Thus, we have assessed that the processing described in this Driver Privacy Notice is necessary for the purposes of the legitimate interests pursued by us or a third party (e.g. your employer), i.e. to manage the logistic regarding deliveries of parcels, to ensure that parcel deliveries are made securely and in time to the right destination, to provide great customer services, to improve route planning and the quality of our services in general, to ensure the quality of the services performed by our subcontractors, to recommend your employer to pay a fair compensation to you etc. We cannot reasonably achieve the same result by processing less personal data about you. We ensure that your personal data is processed securely and with due respect to your privacy. We also inform you of how we process your personal data and what individual rights you have. We have assessed that the processing conducted by us is reasonable to expect for anyone working in modern transportation services with a digital interface towards customers and partners. We are also rewarding your great performance based on the personal data processed by us and we minimize the amount of manual work you have to perform. In this context, we have assessed that our legitimate interests are not overridden by your privacy interests and your other fundamental rights and freedoms.
4.2 Some processing of your personal data may also be required due to legal obligations imposed on us (e.g. pursuant to accounting legislation).
5. How Long Do We Keep Your Personal Data?
5.1 The data we process as stated in this Driver Privacy Notice is retained as long as you remain a Driver (i.e. for as long as you are engaged to perform transportation services for us) and up to six months thereafter. Your data are then erased or anonymised so that it can no longer be linked to you.
5.2 Data may also be processed (i) if we have a purpose for retaining the data (e.g. the processing of aggregated data in order to generally improve our services), (ii) if retention is required by applicable legislation (e.g. accounting information may need to be retained for 7 years in addition to the current year) or (iii) if processing is required for the establishment, exercise or defence of legal claims (e.g. information relating to audit of our subcontractors or whistleblowing function). In such case, the applicable data will be retained for the required time period. In the event we are data controller for the camera surveillance, we may retain such data for up to twenty one (21) days, unless we have identified that certain camera recordings must be kept for a longer period pursuant to law, regulation or administrative decisions, or in the event we have a legitimate interest to investigate a suspected crime or other irregularities affecting us or any of our customers or partners. Certain sensitive data will be erased regularly, e.g. phone recordings will not be stored for more than 90 days since the call was recorded.
6. Recipients of Your Personal Data
6.1 Your personal data may be shared with our service providers (e.g. companies providing IT services, or other services to Instabee) and companies within the Instabee Group.
6.2 Your personal data will also be shared with:
Your employer (i.e. our direct or indirect subcontractor) e.g. in order to plan the routes, manage invoicing, report on your performance when carrying out the transportation services and recommend a fair remuneration for your performance to your employer.
Customers, and other parties involved in the applicable transportation services (including merchants, terminals/distribution centres, recipients of goods, or anyone acting on behalf of a customer), as relevant. Note that your first name, a picture of you, and your location will be displayed for customers that have ordered home delivery, either in the Instabee App or through Instabee’s website in conjunction with the home delivery.
Our merchants and similar partners (mainly in aggregated form) for the purpose of sharing insights.
6.3 We may also disclose your data to authorities or another third party, if required by law, regulation or administrative decisions, or in the event we have a legitimate interest to investigate, or have authorities to investigate, a suspected crime or other serious irregularities affecting us or any of our customers or partners.
6.4 If we share your personal data with a recipient who is an independent data controller for their processing of your personal data, e.g. your employer or a public authority, the recipient is responsible for the lawfulness of the processing in question. We limit the personal data that we share to what is relevant for the specific purpose.
6.5 Our IT suppliers and other service providers who processes personal data on our behalf, so-called data processors, must always sign an agreement with us so that we can ensure a high level of protection of your personal data with them as well. Specific safeguards are implemented with regard to service providers outside the EU/EEA, such as agreements that include the standard model clauses for data transfer adopted by the EU Commission and which are available on the EU Commission's website.
7. Your Rights in Connection With Our Processing
7.1 Pursuant to applicable data protection legislation, you have certain rights in relation to us. These are set out in general below:
Right of access (register transcript) – a right to information about our processing of your personal data and access to it.
Right to rectification – a right to have erroneous data rectified and partial data completed.
Right to object – a right to object to our personal data processing about you if it takes place based on a legitimate interest.
Right to erasure – a right to have your personal data erased under certain circumstances unless the data is necessary for a particular purpose or there is another legal ground for the processing.
Right to restriction of processing – a right to request that personal data processing is restricted, e.g. if you contest the accuracy of the data. Our access to the data is restricted while the accuracy of the data is investigated.
Right to data portability – a right to request that personal data are transferred from one data controller to another. This right is restricted to data that you have supplied to us yourself.
7.2 Some of the rights above are only applicable in certain situations. If you want to exercise any of these rights, or get more information, please contact us via the contact details below in section 8.1 (under the heading "Contact details to the data controller and the data protection officer"). You also always have the right to file a complaint about how we process your personal data to the relevant supervisory authority. Depending on where you are a resident, there are different supervisory authorities you may contact, see the table below:
Sweden
Supervisory Authority:
Integritetsskyddsmyndigheten (IMY)
www.imy.se
Denmark
Supervisory Authority:
Datatilsynet www.datatilsynet.dk
Finland
Supervisory Authority:
Tietosuojavaltuutetun toimisto // Dataombudsmannens byrå
www.tietosuoja.fi/en
Norway
Supervisory Authority:
Datatilsynet
https://www.datatilsynet.no/en/
Netherlands
Supervisory Authority:
Autoriteit Persoonsgegevens
www.autoriteitpersoonsgegevens.nl
Belgium
Supervisory Authority:
Autorité de protection des données // Gegevens-beschermings-autoriteit
www.dataprotectionauthority.be
Germany
Supervisory Authority:
Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit
www.bfdi.bund.de
8. Contact Details for the Data Controller and the Data Protection Officer
1. If not specifically indicated or communicated otherwise, Instabee Group AB (in Sweden) is the data controller in respect of the processing of personal data described in this privacy notice.
In the tables below you will find the contact details of Instabee Group AB and the other local companies within the Instabee Group, as well as to our Group Data Protection Officer (DPO). If you are unsure which company that is the data controller, you can always contact Instabee Group AB for further assistance.
Instabee Group AB, Org. No: 559396-6236, Hälsingegatan 40, 113 43 Stockholm, Sweden
Contact details for DPO: dpo@Instabee.com - dpo@budbee.com - dpo@instabox.com
Sweden
Budbee Group AB, Org. No: 559322-4255, Hälsingegatan 40, 113 43 Stockholm, Sweden
Instabox Group AB, Org. No: 559247-1568
Budbee Sweden AB, Org. No: 559322-4255
Instabox Sweden AB,Org. No: 556831-5393
Finland
Budbee Oy, Org. No: 2923782-9, Perhonkatu 6,00100 Helsinki, Finland
Netherlands
Budbee Netherlands B.V., Org. No: 74690280, Johan Huizingalaan 763A1066 VH Amsterdam, Netherlands
Germany
Budbee Germany GmbH, Org. No: HRB 233721, Postdamer Platz 10, 10785 Berlin
Instabox Germany GmbH, Org. No: HRB 231413 B
Denmark
Budbee Denmark ApS, Org. No: 39 77 23 61, Ehlersvej 11, 2900 Hellerup, Denmark
Instabox Denmark ApS, Org. No: 40 85 07 32
Norway
Instabox Norway AS, Org. No: 923 459 758
Belgium
Budbee Belgium B.V., Org. No: 768.864.263, Lange Lozanastraat 142, Antwerp 2018, Belgium
Instabox Belgium B.V., Org. No: 0774717620
9. Update and Questions
9.1 We will keep this privacy notice under regular review, continuously updating it when deemed necessary. If significant changes are made, and if such a change requires a notice or consent under applicable law, you will be notified of this or given the opportunity to issue your consent (if necessary).
9.2 Any questions regarding this Privacy Notice, please contact the DPO (dpo@instabee.com).