1. Who we are

Zuno Group Ltd is the data controller for the personal data described in this policy.

• Registered in England and Wales, company number 16502562
• Registered office: 3rd Floor, 45 Albemarle Street, Mayfair, London W1S 4JL
• Registered with the Information Commissioner's Office, reference ZC228347
• Contact: [email protected]

Zuno runs a platform that connects customers with self-employed Service Operatives who carry out vehicle valeting. This policy explains what we hold about you, why, who else sees it, how long we keep it, and what you can ask us to do about it.

2. Who this policy is about

It covers everyone whose data we hold, not only people with an account:

• Customers, with or without an account
• Service Operatives, and people who started an application and did not finish
• Substitutes, who may carry out a booking in an Operative's place
• Business contacts, where we hold details of a business we have approached
• Waitlist sign-ups, where we are not yet operating in your area
• People who report a problem without signing in
• Visitors to our website
• Zuno administrators

3. What we collect, and where it comes from

3.1 If you are a customer

From you: your name, email address, phone number, service address including its precise location, your vehicle registration, and whether a dog travels in the vehicle.

From your bookings: dates, prices, the service chosen, ratings and any review text, dispute messages and any photographs you upload as evidence, and the record of the terms you accepted at checkout.

From other sources: your vehicle's make, model, year, colour, MOT and tax status, which we obtain from the DVLA and the DVSA using your registration, and address data from postcode lookup providers.

We also keep a record of when each vehicle was last cleaned, which affects the price we quote.

3.2 If you are a Service Operative or an applicant

Your name, date of birth, email address, phone number, home and business address, National Insurance number, Unique Taxpayer Reference, company registration number where you have one, business structure and tax address.

Your vehicle registration and its details, your equipment and utility capabilities, your service area, your photograph, and your bank details, which you enter directly with our payment provider and which we never see. Your name, your photograph and your vehicle registration are shown to the customer whose booking you accept.

Your public liability insurance: the provider, the policy number, the cover and its expiry date, and a copy of your certificate.

For identity and right to work: the outcome of an identity check, including the name and issuing country read from your document, its expiry date, and whether the name matched. For operatives who joined before the current check was introduced, we also hold a copy of the government photo identification they supplied, which we keep so that we can confirm who attended a booking and provide their details to an insurer or legal representative if we are asked for them. Where you use a Home Office share code instead, we keep the code, your date of birth and a copy of the Home Office result page. Section 5 explains this in full.

Your acceptance of our Operative Agreement, including the date, your IP address and your browser.

If you begin an application and do not complete it, we keep what you have given us so far. Section 9 explains for how long.

3.3 If you are a substitute

Your name, contact details, date of birth, right to work record, insurance provider, policy number, cover and expiry with a copy of your certificate, your vehicle registration, and a photograph of you. Your name, photograph and vehicle registration are shown to the customer whose booking you attend.

3.4 If you are a business contact

Where we have approached a business, we hold the business name, a contact name, email address, phone number, website, the areas covered, publicly available rating information, our own notes about the business, and a log of our correspondence.

We obtain this from public sources, including business listings and social media, rather than from you. You can ask us to stop contacting you and to delete what we hold at any time, by emailing [email protected].

3.5 If you join a waitlist or report a problem

Waitlist: your email address and postcode. Problem reports: what you tell us and any screenshot you attach.

3.6 If you visit our website

Your IP address, browser and device information, the pages you visit, and where you arrived from. Some of this is recorded for security whether or not you accept cookies, because it is how we detect attacks on accounts. Our Cookie Policy explains what is recorded only with your consent.

3.7 If you use the Zuno Operative app

When you turn on notifications in the app, your device gives us a push token: a long identifier that names that one app on that one device. We store it against your account, along with which platform it is (iPhone or Android) and which version of the app issued it, so that we can send you a job offer. It is not your phone number and it does not tell us where you are.

Your device obtains the token from Apple or from Google directly, not through us. You choose whether to allow notifications when your device asks, and you can change that at any time in your device settings.

A notification shows the service, the date and time, what you will earn, and the first part of the customer's postcode. It never shows the customer's name or their full address.

Signing out of the app deletes the token straight away. If you turn notifications off or remove the app, the token stops working; we stop using it as soon as a message to it fails, and delete it within the period in section 9.

Like any browser, the app sends us a browser identifier, known as a user agent. It names the app and its version and, depending on your device, can include your device model and your operating system version. We store it with a record of each time you open your dashboard, with your acceptance of the Operative Agreement, and with any problem report you send. We do not collect an advertising identifier, or anything about the other apps on your device.

The app also records how it is used and how well it is working, against your account: each time you open your dashboard, when you open the agreement screen and when you accept it, any fault the app meets on that screen or when you complete a job, and how long pages take to load. Our administrators use the dashboard record to see which operatives are actively using the app. We use the rest to find faults and to keep the app working. None of it is used for advertising. Section 9 sets out how long each is kept.

4. Why we use it, and our lawful basis

Where we rely on legitimate interests, we have considered whether our interest is outweighed by your rights. You can object at any time by emailing [email protected].

5. Identity checks, and facial verification

This section describes special category data. Please read it before you begin a check.

If you apply to work through Zuno as an Operative or a substitute, we verify who you are. The check is carried out by Stripe Identity on our instruction. You photograph your passport and take a short live selfie, and those images go directly from your device to Stripe. They do not pass through Zuno's systems.

We instruct Stripe to compare your selfie against the photograph in your document. That comparison uses biometric data, which is a special category of personal data under UK data protection law.

Stripe holds the document image and the selfie. Zuno receives and keeps the result: the first and last name read from the document, the issuing country, the document expiry date, whether the name matched, and, if the check failed, the reason. A Zuno administrator can view the images through a short-lived link when reviewing a check.

Where you prove your right to work with a Home Office share code instead, we keep the code, your date of birth and a copy of the Home Office result page. Where a substitute uses this route we also keep a photograph of you, so that we can confirm the person who attended a booking is the person who was checked.

If you ask us to delete your account, we ask Stripe to redact the verification session, which removes the images they hold.

6. Decisions made automatically

Parts of the platform decide things without a person reviewing them at the time:

• Pricing and vehicle classification. We use your vehicle's make, model and year to decide its size band and price, and in rare cases to decide that we cannot service it. Where we are not confident, we quote a standard size and flag the booking for review.
• Availability. We decide whether we cover your postcode, whether an Operative with the right clearance is available, and whether a slot can be met.
• Matching and dispatch. We decide which Operatives are offered a job, and whether an Operative may accept one, from their approval status, insurance, right to work expiry and other compliance checks.
• Right to work. Where an identity check returns a British or Irish passport, eligibility is granted automatically. Every other case is reviewed by a person.
• Payments to Operatives. Payouts are released automatically once the relevant conditions are met.
• Cancellations and refunds. A booking that no Operative accepts in time is cancelled and refunded automatically. Where a car is reported out of scope and no administrator has resolved it within 48 hours, the default outcome applies and the customer is refunded for that car.
• Deletion. We delete or anonymise some data automatically when its retention period ends. Where this would close an inactive account we email you first and give you thirty days to keep it open, by signing in or by booking.

You can ask a person to review any of these. Email [email protected] and we will look at it and tell you the outcome.

7. Who we share it with

We do not sell your personal data.

People who carry out your booking. Your Service Operative, and any substitute attending in their place, receive the details of the booking, including the service address and its location, your first name, your vehicle details, any access notes and the price of the job. They do not receive your phone number or email address. They are responsible for that data in their own right and are required to delete it after the job, other than the condition photographs they must keep. Where you make a damage claim, we give both you and the Operative the evidence we hold for that booking, including completion photographs.

The customer, if you are a Service Operative. The customer whose booking you carry out is shown your name, your photograph and your vehicle registration for that booking. Your photograph is shown only once they have signed in to their account, or on the page where they rate the service. Your name also appears on their receipt. The app and our emails do not show them your phone number, your email address or your home address.

Providers who process data on our behalf.

Public authorities and services. The DVLA and the DVSA, when we look up a vehicle registration. The Home Office, when an administrator checks a right to work share code. HMRC, where reporting rules require it.

If you sign in with Google or Apple, they confirm your identity to us and we receive your email address and name. They are responsible for their own handling of that.

Others, where the law requires it, or where we need to establish, exercise or defend a legal claim.

8. Where your data is processed

Our database is hosted in the United Kingdom and our file storage in the European Economic Area.

Some of the providers in section 7 are based outside the UK, or process data outside it. Where that happens we rely on the safeguards permitted by UK data protection law. You can ask us which safeguard applies to a particular provider.

9. How long we keep it

These are the maximum periods. Where a period runs from the end of a financial year, our financial year ends on 30 June.

Some records cannot be deleted on request because we are required to keep them, principally financial records and the evidence of a right to work check. Where that applies we will tell you which records we kept and why.

We are extending automatic deletion across the platform and it does not yet cover every category above. You can ask us to delete your data at any time and we will act on it, using the routes in section 10.

10. Your rights

You can ask us to:

• Give you a copy of your data, or tell you what we hold
• Correct it if it is wrong
• Delete it, subject to the records we must keep
• Restrict or object to what we do with it, including our use of legitimate interests
• Withdraw consent where we relied on it
• Receive it in a portable form, where that right applies

To delete your account, use the option in your account settings, or on your home page if you are a substitute, or the page at zuno.uk.com/delete-my-data if you cannot sign in. Before you confirm, we show you exactly what will be deleted, what will be kept, and why.

For anything else, email [email protected]. We will respond within thirty days.

11. Cookies and similar technologies

Our Cookie Policy sets out the cookies and browser storage we use, what each is for, and which ones need your consent. You can change or withdraw your consent at any time from the link in the footer.

12. Security

We serve every page over an encrypted connection, restrict access to personal data to the administrators who need it, and log administrative access to it.

13. Changes to this policy

The version and date at the top of this page always reflect the current version.

14. Contact and complaints

Email [email protected], or write to Zuno Group Ltd, 3rd Floor, 45 Albemarle Street, Mayfair, London W1S 4JL.

If you are unhappy with how we have handled your data you can complain to the Information Commissioner's Office at ico.org.uk, or by calling 0303 123 1113. We would rather you came to us first so we can put it right.