Privacy policy

Privacy Policy – 5TWA SERVICES

Who is the data controller?

The data controller, i.e. the body that defines the purposes and means of the processing specified in this privacy policy is 5TWA SERVICE (Green Apple for General Contracting LLC) with registered address at JAALI Building, Office Number 45, AL-MAHALAH AL-KUBRA, GHARBIYA, EGYPT hereinafter referred to as “5TWA SERVICE” “we”, “our”, “controller”). We also use the terms “5TWA SERVICE” for your salutation.

Why and which personal data do we process?

Below you can see which of your data we need for which purposes and under which circumstances we share your data with others.

Personal data is information from which we can directly or indirectly relate to your person, such as first and last name, address, phone number, date of birth, location data or email address.

Which personal data do we process?

In order to provide our delivery service to our customers, we use various tools and systems that are absolutely necessary for the delivery of orders. We also use external and internal tools and systems to process your personal data for personnel management and business operations.

We collect, process and store the following categories of personal data within the scope of using the tools and systems:

Data categories

Explanation

Identification data

Name, Surname, Address, Facial recognition data and any other such data that shall be required for identification purposes from time to time.

Contact data

Email Address, Phone number,

Account data

Date of birth, Place of birth, nationality, gender, bank account details, social security number

Performance data

Usage time of applications, order details

Geolocation data

GPS data

Technical data

Device data

Contract details

Contract type, work permit

For what purposes do we process personal data?

We only collect your personal data if this is necessary and the purpose is legal and the processing is proportionate. Below we would like to give you more information for the purposes and legal basis:

Purpose

Why do we process data for this purpose?

Recruiting

As part of the application process, we collect, process and store your personal data on the basis of the data you have made available to us. The purpose of the processing is to make a decision regarding the hiring or refusal of an applicant.

Categories of personal data:

Identification data
Contact data
Account data

Our hiring process is based to a large extent on finding potential 5TWA SERVICE Representatives through direct hiring contracts.

Categories of personal data:

Contact data

Candidate reactivation

If a candidate does not continue the application process through direct interview or any missing data detected, SMS, emails or Whatsapp will be sent to remind the candidate of the steps that need to be taken to complete the application process.

Categories of personal data:

Identification data
Contact data

Contract

Conclusion of an employment contract

Categories of personal data:

Identification data
Account data

Onboarding

Preparation of the first working day, training of new employees

Categories of personal data:

Identification data
Account data

Presence monitoring

Assessment of the reliability of drivers with regard to the fulfilment of their contractual obligations.

Categories of personal data:

Contact details

Accounts

Creation of required accounts for the applications used

Categories of personal data:

Identification data
Account data

Working time recording

Recording of work performed by the employee

Categories of personal data:

Identification data
Start and end date of shift, breaks, legitimate absence

Presence monitoring

Assessment of the reliability of drivers in fulfilling their contractual obligations. Use of location data in case of irregularities during the shift. Monitoring of compliance with rest times.

Categories of personal data:

Identification data
Account data
Working hours
Rest times

Customer communication

Communication with customers about the status of the order or delivery

Categories of personal data:

Identification data
Contact details
Location data
Content of communication
Picture (if available)

Photos and videos

Taking and publishing photos and videos of employees

Categories of personal data:

Identification data
Picture/Video

Work permit

Review of existing employee contracts with regard to the validity of work permits

Categories of personal data:

Identification data
Contact details
Contract details

Personnel administration

We collect, process and store your personal data for the processing and creation of legally required documents and proofs as well as for the remuneration of our employees.

Categories of personal data:

Identification data
Contact data
Account data

Sick leave

Processing of incoming sick notes; communication with health insurance companies.

Categories of personal data:

Identification data
Contact details
Sick leave note

Internal communication

Different tools are used for communication between the employer us and the employees (in this case 5TWA SERVICE). The purpose of the processing is the communication of necessary information.

Categories of personal data:

Identification data
Contact data

Vacation file

Processing, granting and rejection of vacation requests submitted by employees; documentation

Categories of personal data:

Identification data
Contract details

Delivery

To ensure a prompt delivery of the products ordered by our customers, the coordination data of our 5TWA SERVICE Representatives is collected and the order is assigned to those 5TWA SERVICE Representatives who are in an optimal region.

Categories of personal data:

Identification data
Contact data
Geolocation data
Technical data

Delivery Estimation

In order to be able to inform customers of the expected delivery time, average speed data is processed in anonymous form.

Categories of personal data:

Geolocation data (anonymized)

Work disciplinary measures

Issuing a warning notice with breach of contract

Categories of personal data:

Identification data
Personnel file

Wage and salary payments

Preparation of wage and salary statements; payment of gross amounts; payment of social security contributions (if applicable)

Categories of personal data:

Identification data
Contact data
Bank account information

5TWA SERVICE equipment

Our employees receive 5TWA SERVICE equipment from us. This serves the uniform appearance of our 5TWA SERVICE Representatives as well as the protection of our employees. We manage and monitor the equipment provided to ensure that the necessary equipment is always available.

Categories of personal data:

Identification data
Contact data

Shift planning and time recording

We collect, process and store personal data of our 5TWA SERVICE Representatives for the planning of deployments and the actual exercise of deliveries. The purpose of the processing is to collect and monitor the hours worked and to create the necessary work records.

Categories of personal data:

Identification data
Contact data
Account data
Performance data
Geolocation data

Performance evaluation

Evaluation of driver performance based on the quality (restaurant and customer complaints), quantity of orders delivered. It also includes reliability before, during and after the shift. This also includes, but is not limited to, the punctual start of the shift, proper login and acceptance of orders during the shift until the end of the shift. Also the proper execution of the order.

Categories of personal data:

Identification data
Contact data
Performance data
Geolocation data
Technical data

Termination

Ordinary and extraordinary terminations of contracts with employees

Categories of personal data:

Identification data
Contact data

Off-boarding

Deactivation of existing accounts; return of received clothing and equipment.

Categories of personal data:

Identification data
Contact data

Archiving

Archiving of documents subject to retention for tax purposes.

Categories of personal data:

Identification data
Contact data
Date of birth
Tax information
Working times

How long do we store personal data?We generally delete your data after the purpose has been fulfilled. The exact deletion rules are defined in our regional deletion concepts. Different deletion rules apply depending on the purpose of the processing. Within our deletion concepts we have defined various data classes and assigned rule deletion periods to them. When the retention period is met, the stored data will be deleted accordingly.

Under certain circumstances, any requests for deletion may be opposed by legal retention periods, which prevent us from deleting the stored data for a fixed minimum period of time. In order to comply with these legal requirements, we block the relevant data after the purpose has been fulfilled and thereby guarantee data completeness and data integrity.

With which data processors and why do we share personal data?

We never give your data to unauthorized third parties. However, as part of our work we obtain the services of selected service providers and give them limited and strictly monitored access to some of our data. However, before we forward personal data to these data processors for processing on our behalf, each individual company undergoes an audit. All data recipients must meet the legal data protection requirements and prove their data protection level with appropriate proofs.

In the following we would like to inform you in a transparent and understandable way about all our data recipients with the respective reasons:

Data recipient

Reason

External service provider

They support our business activities by providing us with IT solutions and infrastructure or by ensuring the security of our business operations, for example by identifying and rectifying faults. Furthermore, personal data may also be disclosed to external tax consultants, lawyers or auditors if they provide services for which they have been commissioned.

Members of the 5TWA Group

Within a group it is sometimes necessary to use resources effectively. In this context, we support each other within our Group in optimizing our processes. In addition, we provide joint content and services. This includes, for example, the technical support of systems.

This is a joint controllership within the meaning of Art. 26 GDPR. The employer is fully responsible for fulfilling the data protection requirements together with 5TWA. Within the framework of joint regulations, both the employer and 5TWA have agreed that both will guarantee their rights equally. You can therefore address any requests both to the local entity that has engaged you as a 5TWA SERVICE, and to 5TWA, Business Bay Street 70, 10117 Dubai, UAE.

You can reach the data protection officer at dpo@deliveryhero.com.

Regulatory Authorities

In accordance with the applicable labor and social security laws, we may have to report your personal data related to the job, responsibilities, wages, employment contract information and entitlements to the Ministry of Labor Egypt and the SSC Egypt for the purpose of updating any related progress, changes, terminations or any other relevant information to wages. We may also need to provide information to the tax authority for monitoring purposes.

Prosecuting authorities and legal proceedings

Unfortunately, it can happen that a few of our 5TWA SERVICE Representatives and service providers do not behave fairly and want to harm us. In these cases we are not only obliged to hand over personal data due to legal obligations, it is of course also in our interest to prevent damage and to enforce our claims and to reject unjustified claims.

Cookies: In order to make the visit of our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your device and allow us or our affiliate to recognize your browser on your next visit (persistent cookies). You can set your browser so that you are informed about the setting of cookies and individually decide on their acceptance or exclude the acceptance of cookies for specific cases or in general. Failure to accept cookies may limit the functionality of our website/app.

You can install additional add-ons in your browser that block unnecessary cookies. By doing so, you will not see any interest-based advertisements.

Categories of personal data:

Limited device information such as IP address, device ID, MAC address, operating system, device type, Apple Advertiser ID (IDFA) or Android Ad ID (AAID)

Legal basis:

If processing takes place with your consent. Otherwise, the processing is based on our legitimate interest . Our legitimate interest lies in the aforementioned purpose.

You can find our cookie policy with all the cookies we use in our Cookies and Web-Tracking Policy.

What are your rights as data subjects and how can they be asserted?

You have the right to receive explicit information from us about the personal data we have stored about you, free of charge.

In addition, you have the following rights:

Right to access	You have the right to be informed which data we store about you and how we process this data.
Right to rectification	If you notice that stored data is incorrect, you can always ask us to correct it.
Right to erasure	You can ask us at any time to delete the data we have stored about you.
Right to restriction of processing	If you do not wish to delete your data, but do not want us to process it further, you can ask us to restrict the processing of your personal data. In this case, we will archive your data and only reintegrate it into our operative systems if you so wish. However, during this time you will not be able to use our services, otherwise we will process your data again.
Right to data portability	You can ask us to transmit the data stored about you in a machine-readable format to you or to another responsible person. In this context, we will make the data available to you in JSON format.
Right to object to the processing of your data	You can revoke your consent at any time or object to the further processing of your data. This also includes objecting to our processing, which we process without your consent but based on our legitimate interest. This applies, for example, to direct marketing. You can object to receiving further newsletters at any time. If you do not agree with one of our processing purposes based on our legitimate interest or wish to object to it, you may object to the processing at any time on grounds relating to his or her particular situation. Please raise a ticket via the 5TWA SERVICE Support feature available on the app. In this case we will review the processing activity again and either stop processing your data for this purpose or explain to you our reasons worth protecting and why we will continue with the processing.
Automated decision making	We also process your personal data in the context of algorithms in order to simplify our processes. Of course, you have the right not to be subject to decisions based solely on automated processing. If you believe that we have denied your access in an unjustified way, you can always contact us via the 5TWA SERVICE Support feature available on the app. In this case, we will examine the case separately and decide on a case-by-case basis.
Right of complaint	If you believe that we have done something wrong with your personal data or your rights, you can complain to the appropriate supervisory authority at any time.

To exercise your rights, you can contact us using the 5TWA SERVICE Support feature available on the app at any time.