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Privacy Notice

How Maltero collects, uses, retains, and protects personal data across the website and mobile application.

Note

This notice covers both the Maltero website and the Maltero mobile application for iOS and Android. Last updated: April 2026.

1. Controller

Maltero is the controller for personal data processed through the Maltero website and mobile application.

For privacy-related enquiries, use the contact page. We will respond in accordance with Article 12 GDPR.

2. Scope

This Privacy Notice applies to personal data processed through: (a) the Maltero website, including its subdomains; and (b) the Maltero mobile application available on iOS and Android. It covers customers, drivers, and administrators.

Last updated: April 2026. We will update this notice if material changes occur to our data practices.

3. Legal bases for processing

We process personal data under the following lawful bases set out in the GDPR:

  • Article 6(1)(a) - Consent: location access, optional profile features, and Google OAuth sign-in.
  • Article 6(1)(b) - Contract performance: account registration, order processing, service delivery, and the rewards programme.
  • Article 6(1)(c) - Legal obligation: fiscal and commercial retention requirements.
  • Article 6(1)(f) - Legitimate interests: application security, error monitoring, fraud prevention, and performance optimisation.

4. Data we collect and why

We collect only the data that is necessary for the purposes described below.

  • Account data (name, email address, encrypted password, unique user ID, account type, creation and update timestamps, account balance): contract performance - to authenticate you and manage your account and order history.
  • Order and service data (pickup and delivery addresses with GPS coordinates, oil volumes, preferred dates and times, special instructions, order status, payment status, driver assignment, update timestamps): contract performance - to process and fulfil used-oil collection and delivery requests.
  • Location data (GPS coordinates, reverse-geocoded address information, distance calculations, route planning data): consent - to support address search, map display, and route planning. You can withdraw consent in your device settings at any time; this may limit app functionality.
  • Rewards programme data (credit balance, transaction history, oil volumes, reward calculations, redemption records): contract performance - to administer eligible exchange and reward behaviour according to current business rules.
  • Authentication and session data (JWT tokens, session data, OTP verification codes valid for 10 minutes, verification attempt logs retained 30 days): legitimate interests - to secure accounts and prevent unauthorised access.
  • Google OAuth data (Google user ID, email, name, profile photo if shared, OAuth tokens): consent - to enable single-click sign-in via Google.
  • Technical and log data (IP address, request timestamp, GMT offset, requested resource, HTTP status code, data volume, app version, OS, device type and model, unique request-tracking identifiers): legitimate interests - to deliver the service, maintain security, and diagnose errors. Retained for 7 days then deleted.
  • Error monitoring data (error messages, stack traces, anonymised usage data, device type, OS version, app version, crash reports, performance metrics): legitimate interests - personal data is automatically removed from error reports; IP addresses are anonymised; no user-identifiable information is included in crash reports. Retained 90 days.
  • Saved addresses and booking preferences: consent - to simplify repeat booking. Deleted when you remove them or close your account.

5. Third-party service providers

We use the following third-party processors. Data is shared only to the extent necessary for each service.

  • Clerk Inc. (USA) - authentication and session management. Transfer basis: EU Standard Contractual Clauses.
  • Google LLC (USA) - Google Maps / Places API for map display, address search, route planning, and geocoding. Transfer basis: EU adequacy decision.
  • Geoapify GmbH (EU) - reverse geocoding and address resolution.
  • Sentry / Functional Software Inc. (USA) - error monitoring and crash reporting. Transfer basis: EU Standard Contractual Clauses.
  • Stripe Inc. (USA) - payment processing infrastructure (payment flows are not yet active; this notice will be updated before activation). Transfer basis: EU-US Data Privacy Framework.
  • Vercel Inc. (USA) - website and API hosting. Transfer basis: EU Standard Contractual Clauses.

6. International transfers

Some of our service providers are located in the United States or other third countries outside the EEA. All transfers are made on the basis of EU Standard Contractual Clauses, an EU adequacy decision, or a recognised certification framework as identified in Section 5.

7. Retention periods

We retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal obligations.

  • Account data: for the lifetime of your account plus 3 years, unless a different lawful retention period applies.
  • Order and commercial data: retained according to applicable commercial, accounting, and tax obligations.
  • Technical server logs: 7 days.
  • OTP verification codes: 10 minutes after generation.
  • OTP verification attempt logs: 30 days.
  • Error monitoring data: 90 days.
  • Session-scoped cache: cleared when the app is restarted or the browser session changes.
  • Local device data such as secure tokens and app settings: until app uninstall, manual deletion, or account/session cleanup.

8. Data security

We implement appropriate technical and organisational measures to protect personal data against accidental or unauthorised access, loss, destruction, or alteration:

  • TLS encryption for data in transit.
  • Role-based access controls.
  • Access logging with request-tracking identifiers.
  • Privacy-aware error reporting.
  • Session and token security controls appropriate to the platform.

9. Automated decision-making

We do not use automated decision-making, including profiling, within the meaning of Article 22 GDPR.

10. Children's data

Our service is not directed to children under 16. We do not knowingly collect personal data from anyone under 16. If we become aware that a child under 16 has provided personal data, we will delete it promptly.

11. Your rights

Under GDPR you have the following rights. To exercise any of them, use the published privacy contact channel or contact page with your full name, account email address, and a description of your request. We will respond in accordance with applicable GDPR timelines.

  • Right of access (Article 15): obtain confirmation of whether and what personal data we process about you.
  • Right to rectification (Article 16): have inaccurate or incomplete data corrected.
  • Right to erasure (Article 17): request deletion of your data where the processing purpose has ended, consent has been withdrawn, data was processed unlawfully, or deletion is required by law - subject to overriding legal obligations.
  • Right to restriction (Article 18): restrict processing while accuracy is contested, or data is needed for legal claims.
  • Right to data portability (Article 20): receive your data in a structured, machine-readable format.
  • Right to object (Article 21): object to processing based on legitimate interests for reasons relating to your specific situation.
  • Right to withdraw consent (Article 7(3)): withdraw any consent at any time without affecting the lawfulness of prior processing.
  • Right to lodge a complaint (Article 77): file a complaint with the supervisory authority.

12. Supervisory authority

You have the right to lodge a complaint with the applicable data protection supervisory authority at any time if you believe your personal data has been processed in violation of applicable data protection law.

13. Changes to this notice

We reserve the right to update this Privacy Notice to reflect changes in law or our data practices. Where a change is material or requires your consent, we will notify you through the app or by email before the change takes effect. We encourage you to review this page periodically.

Version: 1.1 - April 2026.