Privacy Policy

CARRY: On-Board Courier Platform
Operated by: Handshake Tech Ltd (trading as CARRY)
Last updated: 11^th November 2026

Handshake Tech Ltd (“the Company”, “we”, “us”, or “our”) is committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, store and share Personal Data when you use the CARRY platform (“Platform”), which connects Brokers and Couriers for time-critical shipments worldwide. Brokers search for Couriers (for example by location, documents held and vehicle), agree jobs and rates with them, and follow Assignments on a map.

This policy is designed to comply with the UK GDPR and the Data Protection Act 2018.

This Privacy Policy should be read together with our Terms and Conditions of Use (“Terms”). Capitalised terms not defined in this Privacy Policy, including “Assignment”, “Broker”, “Courier”, “Platform” and “User”, have the meanings given in the Terms. “Personal Data” means any information relating to an identified or identifiable living individual.

This Privacy Policy is for your information. By using the Platform you acknowledge that you have been given it; this is not consent to processing. We process Personal Data on the legal bases explained in section 4.

References to an “Assignment” include what is referred to on the Platform as a “Mission”.

A Courier is also known in our industry as an On-Board Courier or “OBC”.

The Platform includes the CARRY mobile app (Android and iOS), used mainly by Couriers, and the CARRY web platform, used by Brokers.

1. Data controller

Handshake Tech Ltd, a company registered in England and Wales (company number 15081644) and trading as CARRY, with its registered office at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ, is the Data Controller responsible for your Personal Data.

If you have questions about this Privacy Policy or how your Personal Data is handled, you can contact us at: admin@carry-app.com

2. Scope of this policy

This Privacy Policy applies to Personal Data processed in connection with:

• Account creation and profile management

• Courier discovery and broker matching

• Agreeing jobs and rates between Brokers and Couriers

• Assignment coordination between Brokers and Couriers

• Location tracking during Assignments

• Communications through the Platform

• Document uploads related to shipments

• The in-app archive of completed Assignments

• Fraud prevention and platform security

• Broker search, monitoring and analytics on the web platform

• Legal and regulatory compliance

3. Data we collect

To facilitate Assignments between Brokers and Couriers, we may collect the following categories of Personal Data.

1. Account data

1. Name

2. Email address

3. Phone number

4. Password and login credentials

5. Business name and associated registration details (for Brokers)

6. Country and currency (used to show rates in your local currency or the currency required for a job)

2. Verification data

To protect the integrity and security of the Platform, we may require Users to complete verification, as described in the Terms.

For Couriers, this may include:

• Government-issued identification and a verification result

• Evidence that you are permitted to provide services in the jurisdictions in which you operate

• Visas and other travel documents

• Vaccination certificates, where a job requires them

• Driving licence and details of the vehicle you use (for Couriers who drive)

• Proof of insurance (if required by Brokers)

• Screening against sanctions or regulatory watchlists

For Brokers, this may include business identification details, evidence of authority over the shipments offered, and sanctions screening of the business and its representatives.

You upload your documents (such as visas, vaccination certificates and your driving licence) to the app. We check them and keep them while they are valid. Before a job is agreed, Brokers searching for Couriers see only a status indicator, for example that you hold the visa or vaccination a job requires. When you and a Broker agree a job, you allow that Broker to see the documents needed for that job. We remind you before a document expires so you can replace it, and we delete expired documents 90 days after expiry or when you replace them.

Verification may be carried out using third-party verification providers (see section 5). Verification status shows only that a User completed the checks we applied at the time. It is not a guarantee of a User’s identity, honesty or suitability.

3. Profile and Professional data

This may include:

1. Courier ratings and reviews (if introduced)

2. Availability status

3. Operational profile information

4. Professional credentials relevant to courier operations

5. Whether you drive, and the type of vehicle you use (for example van, large car or small vehicle)

6. Status indicators showing which documents you hold (for example a visa or vaccination)

7. Whether a Broker has marked you as a “preferred courier”. This marking is visible only to that Broker and is not shown to you. If we introduce ratings, Brokers and Couriers will be able to rate each other after a job, and ratings will be visible to both. We will update this Privacy Policy and tell you before we do.

4. Assignment data

During the use of the Platform, we may process:

1. Pickup and delivery locations

2. Assignment timing and status

3. Shipment references

4. Job offers, agreed rates, currency, and changes negotiated before or during the job

5. Communications between Users, including messages exchanged about an Assignment

6. Uploaded documents such as air waybills or customs paperwork

7. Photographs and proof-of-delivery records of goods, packaging and accompanying documents, taken at inspection, acceptance and delivery to record their condition and to prove delivery

8. An archive of completed Assignments, including the job chat (text, check-in photographs, documents and proof-of-delivery records), which the Broker and the Courier can both view in the app for up to 6 years after completion

5. Location data

Location tracking is used to facilitate courier discovery and Assignment coordination.

Brokers can search for Couriers by distance from a location (for example, within 25 miles of an airport or another location) using the Courier’s approximate location while they are Available.

1. Approximate Location: When a Courier sets their status to “Available”, the Platform may display approximate location to prospective Brokers.

2. Precise Location: During an active Assignment, the Platform collects precise real-time GPS location from the Courier so that the Broker can track shipment progress. Collection stops on completion or cancellation.

Couriers may disable “Available” status at any time through the app settings.

6. Financial data

The Platform does not currently process payments between Users, and we do not currently collect bank account details or transaction data for that purpose. Users agree payment terms between themselves and settle payments directly.

If we introduce payment services in future, we may process bank account details, transaction history and commission records, and payments may be handled by regulated third-party payment providers. We will update this Privacy Policy before doing so.

7. Technical and Usage data

We may collect:

1. IP address

2. Device type

3. Operating system

4. App version

5. Interaction logs

6. Security logs

7. Crash reports

8. Device identifiers and push notification tokens

9. How Brokers use search, filters and the map on the web platform

This information helps maintain platform reliability and security.

8. Compliance and Risk data

This may include records relating to suspicious activity, misuse, fraud prevention, sanctions screening, customs or aviation compliance, safety concerns, and legal or regulatory issues where relevant.

9. Special Category and Criminal Offence data

• Biometric data: Some verification providers compare a live image of your face with your identity document. This is special category data. We process it only with your explicit consent, and we offer an alternative manual verification route if you do not consent.

If you do not want us to use biometric verification, you can choose manual verification instead, either in the app at the verification step or by emailing admin@carry-app.com. Manual verification means a human review of your ID document, which may include a short video call, or an in-person check. Choosing manual verification will not affect your access to the Platform, but it may take longer.

• Criminal record (DBS Checks) or background checks: Where permitted by law and relevant to the role, we may ask Couriers to complete a basic criminal record check (which shows unspent convictions only), such as a basic DBS check in England and Wales or an equivalent in another country, and we process the result. We process criminal offence data only where UK law allows, relying on the conditions in paragraphs 10 and 14 of Schedule 1 to the Data Protection Act 2018 (preventing or detecting unlawful acts, and preventing fraud). We keep an appropriate policy document for this processing and review it regularly.

• Health data. If you choose to upload a vaccination certificate, we process it to show Brokers a status indicator in search results and, once you agree a job with a Broker, to let that Broker see the certificate. This is special category data. Uploading it is optional, and we process it only with your explicit consent, which you give when you upload it and when you agree a job. You can withdraw consent at any time by deleting the certificate in the app. If you do not upload one, it is not shown to Brokers, and you may not appear in searches that require it.

10. Information about other people

Shipment documents and Assignment communications may contain Personal Data about people who are not Users, such as recipients, consignees, senders and other contacts named in the documents. This can include names, addresses, phone numbers, email addresses, signatures and delivery confirmations.

We receive most of this information from Brokers and Couriers, who upload or enter it, for example in air waybills, product invoices, customs paperwork and proof-of-delivery records.

At proof of delivery, the Courier also takes a photograph of the identity document of the person who takes the shipment. This shows their name, photograph, document number and date of birth. We use it to show that the shipment was handed to the right person and to deal with disputes, fraud and legal claims. We keep this image in the Assignment archive for up to 6 years, as set out in section 7. Couriers must tell the recipient why the photograph is taken.

We use this information only to operate the Platform and support the relevant Assignment, to keep records, to deal with disputes, insurance and legal claims, to prevent fraud and misuse, and to meet our legal obligations. We share it with the Users involved in the Assignment and with the service providers and authorities described in section 5.

Users must have the right to provide this information and must use it only as set out in the Terms. If you are one of these individuals and want to ask what we hold about you, or to have it corrected or deleted, contact us at admin@carry-app.com.

Where we get your data

We collect Personal Data:

• from you, when you create an account, complete your profile, verify your identity and use the Platform;

• from other Users, for example when a Broker uploads shipment documents or enters recipient details, or when a Courier uploads photographs or proof of delivery;

• from identity verification and screening providers, who give us the results of the checks you complete (and, where used, sanctions and watchlist screening);

• from recipients, when a Courier records proof of delivery;

• from payment providers, if payment services are introduced; and

• automatically, from your device, when you use the Platform (see “Technical and Usage data” and “Location data”).

Do you have to provide it?

You do not have to give us Personal Data, but we need your account data and, where required, your verification data to give you access to the Platform and to keep it safe for all Users. If you do not provide it, or the verification checks cannot be completed, we may not be able to let you use the Platform, or may need to suspend or restrict your account, as set out in the Terms. Location data is needed for the features that depend on it, such as showing availability to Brokers and tracking an Assignment. You can switch off “Available” status at any time, but without location data you may not be able to take certain Assignments.

4. How we use your data

We process Personal Data for the following purposes and legal bases.

Where we rely on legitimate interests, these include operating the marketplace, preventing fraud, ensuring shipment security, and maintaining the safety of the Platform.

Automated decisions

We do not make decisions about you based solely on automated processing that have a legal or similarly significant effect on you. We may use automated tools to flag suspicious activity, such as possible fraud or misuse, but a member of our team reviews any flag before an account is suspended, restricted or closed.

If we introduce decisions of this kind, we will update this Privacy Policy and tell you, and you will be able to ask for human review and to challenge the decision.

5. Sharing your data

Because CARRY operates as a marketplace platform, sharing certain data between Users is necessary.

1. Broker to Courier

The Courier may receive:

1. Pickup and delivery details

2. Shipment documentation

3. Contact information for Assignment coordination

2. Courier to Broker

Prospective Brokers. While a Courier’s status is “Available”, prospective Brokers may see the Courier’s profile information, approximate location, vehicle type, and status indicators showing whether the Courier holds documents a job may require (such as a visa or vaccination). This does not include the documents themselves, or the Courier’s precise location or contact details.

A Broker engaging a Courier. Once a Broker engages a Courier for an Assignment, that Broker may receive:

• The Courier’s name and contact details

• The Courier’s professional profile

• Documents, photographs and proof-of-delivery records uploaded for the Assignment

• The documents required for the job (for example a visa or vaccination certificate), which you allow the Broker to see when you agree the job

• Messages exchanged between the Broker and the Courier about the Assignment

• The Courier’s precise real-time location, only while the Assignment is active

Brokers may use these documents only for that Assignment, as set out in the Terms.

Both the Broker and the Courier can view the archive of a completed Assignment in the app for up to 6 years after completion, for example to check payments and records or to deal with a dispute. The Broker can see archive records, and statistics based on them (for example completion and on-time rates), only for Assignments it was involved in. If a Courier or Broker closes their account, their details may remain visible to the other party in the archive until that period ends.

Precise location sharing stops when the Assignment is completed or cancelled.

3. Service Providers

We share Personal Data with trusted third parties who help us operate the Platform, such as:

• Payment processors (if payment services are introduced)

• Identity verification and screening providers

• Hosting and cloud providers

• Mapping services (for example, Google Maps)

• Email and messaging providers

• Customer support, security and analytics providers

Most of these providers process Personal Data only on our instructions. Some, such as identity verification providers, may act as independent controllers for part of their processing and have their own privacy notices, which we encourage you to read.

4. Authorities, insurers and advisers

We may disclose Personal Data to law enforcement authorities, regulators, courts, customs, aviation and airport security authorities, insurers and professional advisers (such as lawyers and accountants) where it is:

• Required by law or court order

• Necessary to comply with a legal obligation

• Necessary to establish, exercise or defend legal claims, or to deal with an insurance matter

• Necessary to prevent or detect crime or fraud

• Necessary to protect Users, goods or aviation safety

5. Business changes

If we sell, merge or reorganise our business, or transfer our rights and obligations as permitted by the Terms, Personal Data may be transferred to the new owner or successor, who must handle it in line with this Privacy Policy.

Users who receive Personal Data through the Platform must use it only for the Assignment and the Platform, protect it, tell us about any breach within 24 hours, and delete it when it is no longer needed, as set out in the Terms.

We do not sell Personal Data.

6. Controllers and data responsibilities

Handshake Tech Ltd acts as Data Controller for:

• Account management

• Platform operation

• Identity and security checks

• Security monitoring

• Location tracking

• Messaging

• Logging

• Fraud prevention

• Compliance with legal obligations

• Customer support

When Brokers or Couriers receive Personal Data through the Platform and determine their own purposes for processing it, they may act as independent data controllers and must comply with applicable data protection laws.

Only where we tell you in writing, or where this Privacy Policy says so, will we and a User jointly decide the purposes and means of specific processing. In that case we will put in place an arrangement under Article 26 UK GDPR, make its essence available to affected individuals, and act as your primary contact point.

7. Data retention

We keep Personal Data only for as long as necessary for the purposes in this Privacy Policy, and for operational, legal and compliance reasons. A period of six years reflects the period within which contract claims can generally be brought in England and Wales, and common tax record-keeping requirements. Typical retention periods are:

You can close your account at any time as set out in the Terms. After closure we keep data only for the periods in this section.

Retention periods may be extended where required by law, regulatory obligations, or legal claims.

When a retention period ends, we delete the data or anonymise it so that it can no longer identify you.

8. International data transfers

Some of the service providers used by the Platform are located outside the United Kingdom. In addition, Brokers and Couriers use the Platform internationally, so Personal Data shared between Users may be sent to, or accessed from, other countries, including countries that may not offer the same level of data protection as the UK.

Where we transfer Personal Data outside the UK, we make sure a lawful transfer mechanism is in place, such as:

• Transfers to countries covered by UK adequacy regulations (including, for certified US organisations, the UK–US data bridge);

• The UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses; or

• Where applicable, the limited exceptions in Article 49 UK GDPR, for example where a transfer is necessary to perform an Assignment.

Users who receive Personal Data through the Platform must handle it in line with data protection law, as set out in the Terms. You can contact us at admin@carry-app.com for more information about the safeguards we use.

9. Data security

We use appropriate technical and organisational measures to protect Personal Data, including:

1. Encrypted data transmission

2. Role-based access controls

3. Authentication and access management

4. Security monitoring

5. Incident response procedures

While we implement strong security measures, no system can guarantee absolute security.

If a personal data breach occurs, we will report it to the Information Commissioner’s Office where required, and tell affected individuals where the breach is likely to result in a high risk to them.

10. Your rights (UK GDPR)

Under UK data protection law, you have the right to:

1. Access the Personal Data we hold about you

2. Rectify inaccurate or incomplete data

3. Request erasure of your Personal Data (subject to legal obligations)

4. Restrict processing in certain circumstances

5. Object to processing based on legitimate interests

6. Data portability to transfer your data to another service

7. Ask for human review of a significant decision made solely by automated means, and challenge it, if we ever make one

8. Withdraw consent at any time where we rely on consent, without affecting earlier processing. To withdraw consent for biometric verification, contact us at admin@carry-app.com. To withdraw consent for vaccination data, delete your certificate in the app

To exercise any of these rights, contact us at admin@carry-app.com. We normally respond within one month of receiving your request. This can be extended by up to two further months for complex or numerous requests.

If you have a concern about how we handle your Personal Data, please contact us first at admin@carry-app.com. We will acknowledge your complaint within 5 business days and respond without undue delay. You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk or on 0303 123 1113, whether or not you have complained to us first.

11. Device permissions and just-in-time notices

The app may ask for permission to use features on your device:

• Location: to show your availability and track Assignments

• Camera: to photograph goods, packaging, documents and proof of delivery

• Photos and files: to upload documents and images

• Notifications: to send Assignment updates and security alerts

When access is requested, the app will explain why it is needed. For example, for location: “CARRY uses your location to allow Brokers to see your availability and track shipment progress during an Assignment.”

Precise location is requested only for active Assignments. The app uses your camera, photos and files only when you choose to take or upload something.

You can change or withdraw any permission at any time in your device settings. If you do, some features may not work. For example, you may not be able to appear as “Available”, take Assignments that require tracking, or upload proof of delivery.

12. User eligibility

The Platform is intended for professional logistics users aged 18 or over, as set out in the Terms. We do not knowingly collect Personal Data from anyone under 18. If we learn that we have, we will delete it.

13. Cookies and tracking technologies

CARRY is available as a mobile app (Android and iOS), used mainly by Couriers, and as a web-based platform, used by Brokers to search for Couriers, view a ‘live’ location map, monitor Assignments and review associated Assignment analytics.

On the web platform we use cookies, and in the app we use similar technologies, including software development kits (SDKs). SDKs are small pieces of third-party code built into the app that help it work and measure how it is used. We use these technologies to:

• Log you in and keep you signed in

• Manage your session and remember your settings

• Keep the Platform secure and detect misuse

• Provide mapping features, such as Google Maps, which may collect your IP address and usage data

• Analyse how the Platform is used and improve it

Technologies that are strictly necessary for the Platform to work, such as logging in and security, do not need your consent. For other technologies, such as most analytics, we will ask for your consent through a cookie banner on the web platform or a setting in the app, where required. You can change or withdraw your choices at any time, and this will not affect anything done before you withdrew consent.

You can also control cookies through your browser settings, and restrict tracking identifiers in your device settings. If you block strictly necessary technologies, parts of the Platform may not work.

14. Changes to this privacy policy

We may update this Privacy Policy from time to time. We will tell you about material changes by in-app notification and/or email, normally at least 30 days before they take effect, unless a shorter period is needed to comply with law or address a security risk. The “Last updated” date at the top shows the current version.

If a change affects how we use your data in a way that needs your consent, we will ask for it. Changes to this Privacy Policy do not affect your rights under data protection law.

15. Contact

For questions regarding this Privacy Policy or data protection matters:

Handshake Tech Ltd (trading as CARRY)
Registered office: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Email: admin@carry-app.com

ICO registration number: ZC283756

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