Powered by Zavengo

Privacy Policy

Operated by Zavengo Ltd for POP INs

Last updated: May 25, 2026

1. Who we are

The POP INs ordering and delivery service is provided and operated on POP INs's behalf by Zavengo Ltd("the Platform", "we", "us", "our"), a company registered in England and Wales (company number 17138225, registered office 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom).

Zavengo Ltd is the data controller for personal data processed to operate the POP INs service (popins.uk, the POP INsapps, and related services — together, "the Service") (ICO registration in progress). POP INs is the retail store you order from; where POP INs uses your personal data for its own purposes as a merchant it acts as a separate controller — POP INs's registered company details, ICO registration, and data-protection contact: [TO BE COMPLETED BY POP INs].

For data protection enquiries about the Service: privacy@popins.uk. You also have the right to lodge a complaint with the ICO at ico.org.uk/make-a-complaint.

2. What data we collect

Account data

Name, email address, phone number, delivery addresses, password (hashed).

Driver data

Name, email, phone, postcode, vehicle type, availability, location during active deliveries, profile photo, earnings history.

Waitlist data (pre-launch)

Name, email, phone, postcode, vehicle type — collected via our driver waitlist and customer sign-up forms.

Order data

Items ordered, delivery addresses, order history, payment information (processed by Stripe — we do not store card numbers), receipt images.

Conversations

AI shopping assistant chats ("Request Anything") and support chats with our team. Stored alongside your account so we can troubleshoot, train and improve the assistant, and resolve disputes.

Technical data

IP address, browser type, device information, push notification tokens, cookies for authentication.

3. How we use your data

To provide the delivery service and process your orders

To match you with available drivers in your area

To process payments via Stripe

To send order updates, OTP codes, and service notifications

To notify you when the service launches in your area (waitlist)

To improve our AI shopping assistant and price estimates

To prevent fraud and ensure safety (age verification, dispute resolution)

To comply with legal obligations

4. Lawful basis

Contract: processing necessary to fulfil your order, provide the Service, and respond to your support requests (including storing the support chat thread so we can investigate and follow up)

Consent: waitlist sign-ups, marketing communications, AI conversation recording (opt-out by using the standard catalogue instead of "Request Anything")

Legitimate interest: fraud prevention, service improvement, analytics

Legal obligation: age verification for restricted products, tax records

5. Who we share your data with

Drivers

Your name, delivery address, and phone number are shared with the driver assigned to your order, solely for delivery purposes.

Service providers (data processors)

ProviderPurposeLocation
StripePayments + Stripe Issuing (driver virtual cards)US
Pusher ChannelsRealtime messaging (order updates + support chat)GB
CloudflareCDN + WAF + Zero Trust Access (investors.zavengo.com)US
VercelWeb hosting + edge runtimeUS
NeonPostgres database hostingUS
AWS S3Object storage (receipt photos, customer avatars)EU
OpenFoodFactsPublic barcode + product lookup (no PII sent)FR
postcodes.ioUK postcode geocoding (postcode only)GB
SentryError monitoring + Crashlytics-equivalentUS
Firebase Cloud MessagingPush notifications (Android + iOS)US
ResendTransactional email (verify, receipts)US

Where data is transferred outside the UK, we rely on Standard Contractual Clauses (SCCs) or UK adequacy decisions to ensure appropriate safeguards.

We do not sell your personal data to third parties.

6. Data security

We take reasonable measures to protect your data, including:

AES-256-GCM encryption of sensitive personal data (names, emails, phone numbers, addresses) at rest

Passwords hashed with scrypt (never stored in plaintext)

HTTPS encryption for all data in transit

Role-based access control for staff

UK geo-restriction to limit service area

7. Data retention

Account data: retained while your account is active, deleted within 30 days of account deletion request

Waitlist data: retained until the service launches in your area, or until you request deletion

Order data: retained for 6 years for tax and legal compliance (HMRC requirement)

AI conversations: retained for 12 months for service improvement, then anonymised

Support chats: retained for 24 months so the team can investigate later complaints, refunds, and disputes; deleted on request once any related order is settled

Push notification tokens: automatically cleaned up after 30 days of inactivity

8. Your rights

Under UK GDPR, you have the right to:

Access your personal data (Subject Access Request)

Rectify inaccurate or incomplete data

Erase your data ("right to be forgotten")

Restrict processing in certain circumstances

Data portability — receive your data in a structured, machine-readable format

Object to processing based on legitimate interest

Withdraw consent at any time where processing is based on consent

To exercise any of these rights, contact privacy@popins.uk. We will respond within 30 days.

9. Cookies

We use only essential cookies required for the Service to function:

Session cookie (next-auth.session-token) — keeps you logged in

Site auth cookie — for development site access

We do not use advertising, analytics, or tracking cookies. No cookie consent banner is required as we only use strictly necessary cookies.

10. Automated decision-making and AI

Our "Request Anything" AI shopping assistant uses a Large Language Model (Anthropic Claude) to interpret free-text shopping requests, suggest items, and estimate prices. The assistant is decision-support only — a human Driver always reviews the basket and physically purchases the items.

No solely-automated decision producing a legal or similarly significant effect is made about you. Pricing estimates from the AI never become the final charge — that is set by the actual till receipt your Driver uploads.

If you object to AI processing of your request, use the standard catalogue instead of the "Request Anything" flow. No personal information beyond the request text + your account ID is passed to Anthropic.

11. Driver location data

While an active order is assigned to a Driver, the Driver app shares their live location with our servers so customers and admin can see ETA. Location sharing stops automatically when the order reaches DELIVERED or CANCELLED status.

Drivers can review and disable background location at any time in their iOS/Android settings; doing so prevents them from receiving new jobs.

12. Children

The Service is not intended for children under 18. We do not knowingly collect data from anyone under 18. Age-restricted products (alcohol, tobacco, vapes) require Challenge 25 ID verification upon delivery.

13. Changes to this policy

We may update this privacy policy from time to time. Material changes will be communicated via email or in-app notification. The "last updated" date at the top reflects the most recent revision.

14. Complaints

If you are unhappy with how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Phone: 0303 123 1113

Website: ico.org.uk

15. Changelog

  • 25 May 2026: moved legal-entity details, ICO reference, lawful-basis notes, retention policy, and processor list to the admin-editable DataController record so the lawyer can revise without a code deploy. No new categories of personal data are collected.
  • 18 May 2026: added explicit AI / automated-decision-making disclosure (section 10); clarified driver location data scope (section 11); published ICO registration reference ZC121599 (section 1). No new categories of personal data are collected, no new processors added.
  • 28 April 2026: initial publication.