EMPIRE DELIVERY – PRIVACY POLICY

Last updated: Thursday 23rd 2026

Empire Delivery ("Empire", "we", "our", "us") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and protect the personal information of:

• Website visitors

• Customers receiving deliveries

• Retail partners

• Delivery personnel and contractors

• Anyone whose data is provided to us by partners or entered into our systems

This policy complies with:

• The UK GDPR

• The Data Protection Act 2018

• The Privacy and Electronic Communications Regulations (PECR)

• The Data Use & Access Act 2025 (DUAA)

1. Who We Are (Data Controller Details)

Empire Delivery Ltd
Registered in England & Wales
Company Number: 13238574
Registered Address: 33 Cambridge Road, Stansted, England, CM24 8BX
Email for general enquiries: hello@empiredelivery.uk
Dedicated Data Protection Contact: louis@empiredelivery.uk

Depending on the type of data, Empire may act as:

Data Controller

When we decide how and why data is used, including for:

• Website forms and enquiries

• Photos taken during delivery

• Delivery logs, tracking, and internal records

• Driver data

• Communications with customers

• Claims, disputes, or complaints

• Call recordings on our main telephone line

Data Processor

When retailers ("Partners") send us customer information solely to fulfil deliveries. We only process that information according to their instructions.

We have not appointed a statutory Data Protection Officer, but our Data Protection Lead can be contacted at: louis@empiredelivery.uk.

2. What Personal Data We Collect

A. Data you provide directly

• Name

• Address

• Email address

• Phone number

• Delivery instructions

• Website form submissions

• Signatures or confirmation-of-delivery notes

B. Data provided by Partners

Retailers provide us with:

• Customer name

• Delivery address

• Customer contact details

• Order information

• Delivery notes or special instructions

Partners are responsible for obtaining all necessary consents and ensuring data accuracy.

C. Data collected during delivery operations

• GPS location of drivers

• Route, timestamps, and delivery logs

• Proof-of-delivery photos

• Photos of item condition (before dispatch, upon arrival, and when placed inside the home)

• Photos inside homes (only where permitted—see Sections 3 & 4)

• Notes of issues, damage, or incidents

• Vehicle/driver safety and performance data

D. Data automatically collected on our website

• IP address

• Browser type

• Device information

• Cookies (including Google Analytics, only after consent)

E. Call recordings

ALL telephone calls made to and from our main customer service line (0330 120 1785) are recorded.

When you call our main line, you will hear an automated message informing you that your call is being recorded before you are connected.

Purpose of call recording:

• Quality assurance and staff training

• Monitoring service standards and customer service performance

• Resolving disputes, complaints, or claims

• Protecting both customers and staff from false allegations or misunderstandings

• Compliance with legal and regulatory obligations

• Verifying delivery instructions, order details, and agreements made over the phone

• Investigating incidents, complaints, or operational issues

Access to call recordings: Call recordings are stored securely and are only accessed and reviewed:

• For ongoing training and quality monitoring (on a sample basis)

• When a specific claim, dispute, complaint, or query is raised that requires verification of what was said

• When investigating a delivery issue, failed delivery, or operational concern

• When required by law, regulation, or legal proceedings

• By authorised Empire staff with a legitimate business need

We do not routinely listen to all calls. Recordings are only reviewed when there is a specific reason to do so, such as investigating a customer complaint, verifying delivery instructions given over the phone, training staff, or defending against a claim.

You have the right to object to being recorded. If you do not wish your call to be recorded, please inform the operator at the beginning of the call. However, please note that we may be unable to proceed with certain requests or provide the same level of support without a recording, particularly if a dispute or claim arises later.

We do not intentionally collect special category data.
If such data is accidentally captured (e.g., visible items in a home or in a photograph, or mentioned during a phone call), we delete or redact it unless needed for safety, insurance, or legal purposes.

3. Entering Customer Homes – Additional Privacy Explanation

When we enter your home to deliver or set up items:

• Our team may incidentally observe personal information within the property.

• We do not record or use such observations unless required for safety, delivery verification, or documenting damage.

Photos inside the home

We take photos inside homes only with clear verbal or written consent, except where photos are necessary to:

• Document damage

• Record safety issues

• Protect staff from false claims

We take only the minimum necessary photographs.
We avoid capturing faces, screens, children, or sensitive areas wherever possible.
All staff are trained in confidentiality and professional conduct when entering homes.

4. Photography & Inspection Policy

We may take photographs in the following situations:

1. At our warehouse

To record item condition before dispatch.

2. At the delivery location

To verify delivery, item condition, and proof of delivery.

3. Inside customer homes

Only with consent, unless needed to document damage or safety concerns.

Purpose of photography

• Proof of delivery

• Quality control

• Insurance and liability management

• Responding to queries from customers or partners

• Protecting staff from false claims

• Training and service improvement

• Defending legal claims

Access to photographs

• Authorised Empire staff

• Relevant retail partners (where required)

• Insurers, legal advisors, or regulatory authorities

Photos are never used for marketing without explicit written consent.

5. Lawful Bases for Processing (Required by UK GDPR)

Contract

To:

• Deliver your order

• Contact you about your delivery

• Manage fulfilment with partners

• Handle returns, issues, or warranty cases

Legitimate Interests

For:

• Proof of delivery & delivery verification

• Photography for safety, quality, and insurance

• Route planning and fleet optimisation

• Fraud prevention and property protection

• Protecting staff and customers

• Training and internal improvements

• Managing disputes and claims

• Safe entry into homes

• Recording all telephone calls to our main customer service line for training, quality monitoring, dispute resolution, verifying instructions, and protecting staff and customers

We have conducted a Legitimate Interests Assessment (LIA), confirming that our interests do not override your rights. A summary is available on request.

Legal Obligation

To:

• Maintain tax and accounting records

• Supply information to law enforcement

• Comply with health & safety obligations

• Respond to legal claims

Consent

For:

• Photos taken inside your home (unless required for safety or damage documentation)

• Website forms with optional fields

• Marketing communications

• Non-essential cookies (including analytics)

You may withdraw consent at any time.

6. How We Use Your Personal Data

We use your data to:

• Deliver and fulfil orders

• Contact you about your delivery

• Respond to enquiries

• Verify item condition

• Handle complaints or insurance claims

• Monitor driver safety and performance

• Improve our services

• Provide reporting to partners

• Prevent fraud, loss, or damage

• Train staff and monitor service quality through call recordings

• Resolve disputes, complaints, or claims using call recordings where relevant

• Verify delivery instructions, cancellations, or changes requested over the phone

• Investigate operational issues or failed deliveries

7. Data Retention

Data TypeRetention PeriodDelivery data6 months unless needed for disputesProof-of-delivery photos6–24 months, or longer if a claim existsWarehouse item-condition photosUp to 12 monthsWebsite form dataUp to 12 monthsRetailer/partner records6 years (legal requirement)GPS driver tracking7–90 daysIncident/damage reports6 yearsCCTV (if used)Typically 30 daysCall recordingsRetained indefinitely for operational purposes, training, and claim protection, up to a maximum of 5 years from the date of the call. Recordings may be deleted sooner if our telephony service provider removes older data from their systems. Recordings related to active claims, disputes, or legal matters will be retained for as long as necessary to resolve those matters, up to the 5-year maximum.

Where legal claims, disputes, or regulatory investigations exist, we may store data longer as required by law.

8. Sharing Your Data

We never sell your data.

We may share information with:

• Retail partners

• Delivery subcontractors

• Insurance providers

• Legal representatives

• Regulators (e.g., Information Commissioner, Police)

• IT and cloud service providers (e.g., routing, hosting, analytics, telephony and call recording platforms)

All third parties must follow strict confidentiality and data protection obligations.

A full list of our subprocessors is available on request.

9. International Data Transfers

Some data may be processed outside the UK (e.g., by Google, cloud hosting providers, or telephony service providers).
Where this occurs, we use approved safeguards:

• International Data Transfer Agreements (IDTAs)

• Standard Contractual Clauses (SCCs)

• UK Addendum models

• Countries with UK adequacy regulations

10. Cookies, Analytics & PECR Compliance

Our website uses cookies to improve performance.
Non-essential cookies (including Google Analytics) load only after you consent via our cookie banner.

Google Analytics collects:

• IP address

• Browser and device information

• Interaction and usage data

You can opt out by:

• Rejecting analytics cookies

• Changing your browser settings

• Using Google's opt-out tools

A detailed list of cookies (name, purpose, expiry) is available in our Cookie Policy.

11. Automated Processing & Human Oversight

We use technology for:

• Route optimisation

• Delivery scheduling

• GPS tracking

• Automated delivery confirmations

These systems do not produce decisions with legal or significant effects on you.
Human oversight is present at all relevant stages.

12. DUAA 2025 Compliance

In accordance with the Data Use & Access Act 2025:

• We maintain detailed audit logs of data access.

• We restrict data use strictly to the purpose for which it was collected.

• We do not use personal data for unrelated profiling or secondary purposes.

• Access to personal data is governed by role-based permissions.

13. Children's Data

We do not knowingly collect data relating to individuals under 16.
If such data is provided (e.g., by a partner to fulfil a delivery), we process it only as necessary to complete the delivery.

14. Your Rights Under UK GDPR

You have the right to:

• Access your data

• Correct inaccurate information

• Delete your data (where applicable)

• Restrict processing

• Object to legitimate-interest processing

• Data portability (for contractual data)

• Withdraw consent at any time

To exercise your rights, email: louis@empiredelivery.uk

Specific rights relating to call recordings:

• You can request access to any call recording in which you are a participant

• You can request deletion of your call recordings, subject to our legitimate need to retain them for ongoing claims, disputes, training purposes, or legal obligations

• You can object to call recording by informing the operator at the start of the call (though this may limit our ability to assist with future disputes, verify instructions, or provide full support)

• Where your objection to recording prevents us from providing a service or verifying an agreement, we may be unable to proceed with your request

15. Complaints

You can contact us at: louis@empiredelivery.uk

You may also complain to the UK regulator:

Information Commissioner's Office (ICO)
Website: www.ico.org.uk

16. Changes to This Policy

We may update this policy from time to time.
If changes affect how we process your personal data, we will notify:

• Partners

• Customers whose data we hold

• Anyone subscribed to updates

The latest version of this policy will always be available at empiredelivery.uk/privacy-policy.

Data Protection Lead: louis@empiredelivery.uk
Empire Delivery Ltd, 33 Cambridge Road, Stansted, CM24 8BX