FS Privacy Policy

Plain-language summary. FS Pickup Spots uses personal information to open and protect accounts, quote and move shipments, verify custody and handover, collect and reconcile payments, operate FS Points and sorting centres, support customers, prevent fraud, and meet Kenyan legal obligations. We collect only information reasonably connected to those purposes, restrict access by role, and provide a process for exercising data-protection rights. This summary does not replace the detailed notice below.

1. Who we are and when this notice applies

FS Pickup Spots Ltd, trading as FS Pickup Spots (“FS”, “we”, “us” or “our”), operates a technology-enabled pickup-point, sorting, transport and last-mile delivery network in Kenya. Our network may include FS-owned sorting centres, FS-owned locations, independently operated partner FS Points, employed drivers, gig or contracted drivers, vendors, freelance sellers and approved service providers.

This Privacy Policy applies when you visit our website, use an FS mobile application, create or receive a shipment, request collection, visit an FS location, communicate with support, apply to become a vendor, driver, employee, agent or FS Point partner, receive a delivery, use a pickup code, or otherwise interact with FS. It covers customers, recipients, senders, vendors, freelance sellers, drivers, FS Point owners and agents, staff, applicants, website visitors and authorised representatives.

FS will normally act as a data controller when it determines why and how information is used to operate the FS network. In limited business integrations, FS may act as a processor on documented instructions from a vendor or other organisation. The applicable contract will identify those responsibilities.

2. Our privacy commitments

We apply the principles in the Constitution of Kenya, the Data Protection Act, 2019 and applicable regulations. Personal data should be processed lawfully, fairly and transparently; collected for explicit, specified and legitimate purposes; limited to what is necessary; accurate; retained only as long as reasonably necessary; protected with appropriate safeguards; and transferred outside Kenya only where a lawful transfer mechanism and suitable safeguards apply.

We build privacy controls into new high-risk operations and assess material changes such as systematic driver tracking, large-scale monitoring, sensitive-document processing, automated fraud controls or new cross-border technology providers before deployment.

3. Information we collect

3.1 Identity, account and contact information

• Name, preferred name, telephone number, email address, physical or postal address, language and communication preferences.
• Account role, login identifiers, encrypted password credentials, verification status, one-time-code events, device sessions and security events.
• For organisations: business name, registration details, tax or licence information, authorised contacts, ownership or management information and payout details.

3.2 Shipment and collection information

• Sender and recipient names, contacts and addresses; pickup and destination FS locations; map coordinates or delivery pins; shipment reference; invoice and receipt information.
• Declared contents, category, quantity, weight, dimensions, packaging, handling flags, declared value, delivery promise, route, charges, cash-on-delivery instructions and collection request information.
• Custody events, scans, timestamps, origin and destination, assigned driver, last verified FS location, exceptions, failed-delivery or return reasons, claims and resolution evidence.

3.3 Identity and handover evidence

Where proportionate to the risk, FS may record a masked identity-document reference, recipient signature, one-time pickup code, authorised-representative details, delivery or parcel-condition photograph, or an image captured for proof of handover. A full identity image should be collected only where the selected handover method, a claim, fraud concern or legal requirement makes it necessary. We do not use an identity image for unrelated purposes. Handover evidence is access-restricted and subject to a retention and secure-disposal process.

3.4 Location information

• Coordinates you choose or confirm for collection, delivery, an FS Point, business premises or saved address.
• Driver location during an active, assigned FS duty session, together with time, accuracy and device-session information needed for dispatch, route safety and custody verification.
• Approximate location derived from network or device information where enabled and legally permitted.

Driver tracking is not intended for continuous private-life monitoring. It should start only for an authorised duty session, be visible to the driver, stop when the session ends, and be available only to staff with a dispatch, safety, investigation or compliance need. Public tracking does not reveal precise live driver coordinates.

3.5 Payments and commercial records

Charges, payment method, transaction reference, gateway status, payer telephone suffix, invoice, receipt, wallet and ledger entries, cash-on-delivery amounts, vendor balances, commissions, settlements, registration-fee terms, payout destination and reconciliation evidence. FS does not need to store a complete payment-card number when payment is processed on a regulated provider’s hosted service.

3.6 Onboarding, workforce and partner due diligence

Application and review records, national identity or passport evidence where required, driving licence, certificate of good conduct, business permit, tax information, KRA PIN, insurance, vehicle information, qualifications, employment or contractor classification, FS Point premises and storage evidence, bank or mobile-money payout details, approval history and missing-document requests.

3.7 Communications, support and safety information

Emails, SMS delivery events, push notifications, call or chat notes, support requests, complaints, privacy requests, feedback, survey responses, claim evidence, fraud indicators, security incidents, appeal decisions and the actions taken to resolve them.

3.8 Technical and usage information

IP address, device and application identifiers, operating system, application version, browser, session references, diagnostic logs, crash information, security signals, notification token, consent or acceptance evidence, pages and functions used, and audit records of privileged changes. We use this information to protect accounts, diagnose failures and improve service reliability.

3.9 Premises security information

Where an FS location uses CCTV or access-control records, notices should be displayed at that location. Such information is used for safety, custody verification, crime prevention and investigation, not for unrelated monitoring.

4. Where information comes from

We collect information directly from you; from a sender or vendor who lawfully provides recipient details; from an authorised account administrator; from FS Points, drivers and staff recording custody events; from payment, identity, messaging, maps and hosting providers; from public or regulatory registers used for due diligence; and from fraud, safety or law-enforcement reports where collection is lawful.

If you create a shipment for another person, you must provide accurate information, use it only for a legitimate shipment, and ensure that the recipient can reasonably expect FS to contact them about delivery, collection, payment or safety. FS may send the recipient an operational notice and a link to this Policy.

5. Why we process information and our legal bases

Where we rely on legitimate interests, we consider necessity, expected benefit, potential impact and available safeguards. You may object, although we may continue processing where a compelling lawful ground or legal claim applies.

6. Who may receive information

Access is limited to what each recipient needs. We may share information with:

• FS network participants: the relevant FS Point, sorting centre, assigned driver, sender or vendor, and recipient. Each receives only the operational information required for custody, routing, communication, payment or handover.
• Payment providers: mobile-money, bank, Pesapal or other approved gateway providers involved in initiation, confirmation, refunds or reconciliation.
• Technology processors: hosting, encrypted backup, email, SMS, push-notification, mapping, route, monitoring, document-storage and customer-support providers under appropriate contractual and security controls.
• Professional advisers and insurers: auditors, lawyers, accountants, insurers and investigators where necessary and subject to confidentiality.
• Authorities: the Office of the Data Protection Commissioner, Communications Authority of Kenya, courts, law-enforcement, tax or other competent bodies when disclosure is required or lawfully requested.
• Business restructuring recipients: a lawful successor or transaction adviser, subject to confidentiality, due diligence and continuity of privacy protections.

FS does not sell personal data. We do not provide sender or recipient contact lists to third parties for their independent advertising.

7. Storage and transfers outside Kenya

Some approved providers may store or support systems outside Kenya. Before an international transfer, FS will identify a lawful transfer basis and assess appropriate safeguards, adequacy, contractual protections, security and the recipient’s purpose. Sensitive personal data will receive the additional consent and safeguard protections required by Kenyan law. Transfer records are maintained where required.

8. How long we keep information

FS maintains a governed retention schedule rather than keeping every record indefinitely. The period depends on the service purpose, regulatory and tax requirements, limitation periods, active disputes, fraud or safety investigations, backup cycles and whether a record can be anonymised. Typical classes include:

• account and profile information while the relationship is active and for a justified closure period;
• shipment, custody, delivery and claims evidence for fulfilment, complaints, compensation and legal-claim periods;
• financial, invoice, payment, commission and settlement evidence for applicable accounting, audit and tax periods;
• onboarding and due-diligence evidence for the relationship and a justified post-relationship period;
• support and complaint records until resolution and expiry of the relevant claim period;
• precise driver-location points for the shortest approved operational and investigation period, with longer retention only for an identified incident or legal hold;
• marketing consent or suppression evidence for as long as needed to honour the communication choice;
• security, access and immutable audit evidence for accountability and incident investigation.

When the approved purpose ends, information is securely deleted, anonymised, pseudonymised or access-restricted. A legal hold, unresolved claim, regulatory instruction or active investigation may temporarily suspend disposal. Backups expire through protected recovery cycles and are not used to restore deleted information except during authorised recovery.

9. How we protect information

FS uses layered safeguards appropriate to the risk, including role-based and location-scoped access, separate privileged permissions, multi-factor controls for sensitive administration, encrypted credentials and protected secrets, private document storage, transport encryption, device-session controls, rate limits, security logging, immutable financial and custody evidence, monitored queues, vulnerability and incident response, encrypted backups, off-site recovery validation, staff confidentiality and periodic access review.

No service can guarantee absolute security. Keep your password and one-time codes private, confirm the shipment reference before sharing a handover code, keep your device updated, and report suspected misuse promptly. FS will never ask you to send a pickup or login code in advance through an unsolicited call, email or message.

10. Personal-data incidents

FS records and investigates suspected personal-data breaches, contains affected access, preserves evidence and assesses risk. Where unauthorised access or acquisition creates a real risk of harm, FS will notify the Data Commissioner without delay and, where reasonably practicable, within seventy-two hours after becoming aware of the breach. FS will communicate with affected people within a reasonably practical period unless a lawful exception applies. A processor handling information for FS must notify FS without delay and, where reasonably practicable, within forty-eight hours after becoming aware; where FS acts as a processor, it will provide the corresponding notice to the responsible controller. A notice may describe the incident, likely consequences, protective actions, mitigation and a contact point. If notification is delayed, FS will retain the reasons and supporting incident timeline.

11. Your data-protection rights

Subject to Kenyan law and identity verification, you may:

• be informed about how your personal data is used;
• request access to personal data held about you;
• object to or request restriction of particular processing;
• request correction of inaccurate or misleading information;
• request deletion of false, misleading or no-longer-necessary information;
• request portability in an applicable structured, commonly used and machine-readable form;
• withdraw consent where processing depends on consent;
• opt out of direct marketing;
• request human intervention and give your point of view where a solely automated decision has a legal or similarly significant effect; and
• complain to FS or the Office of the Data Protection Commissioner.

Submit a request at https://origin.fspickupspots.com/privacy/request or contact support@fspickupspots.com. We may ask for proportionate proof of identity and authority. An authorised representative may act for you. We will acknowledge the request, explain any lawful limitation, and respond within the statutory period. A request is generally free, but the law may permit a reasonable response where a request is manifestly unfounded or excessive.

Deletion is not absolute. FS may retain information required to complete a shipment, comply with law, protect another person, preserve an immutable financial or custody record, or establish, exercise or defend a legal claim. Where deletion is not lawful, we may restrict access instead and explain why.

12. Operational notices and marketing

Shipment, security, payment, pickup-code, account and service-recovery messages are operational and may be necessary to perform the service. Marketing is separate. Each direct-marketing message should identify FS and provide a clear, simple and accessible opt-out. Opting out of marketing does not stop necessary operational notices. We maintain suppression evidence so that your choice is respected.

13. Fraud controls and automated decisions

FS may use rules to flag duplicate accounts, suspicious payment activity, unusual shipment data, repeated code attempts, prohibited items or inconsistent custody events. A flag can pause an action or send it for review; it should not by itself establish wrongdoing. Where a decision is solely automated and has a legal or similarly significant effect, we will provide required information, safeguards and a route to human review. You may explain your position and challenge inaccurate information.

14. Children

FS accounts and commercial onboarding are intended for adults and legally capable organisations. A child should not create an account, enter a commercial plan or send a shipment without a parent or lawful guardian. Where a child is a recipient, we use only the minimum information needed for safe delivery and require an adult or authorised guardian for any identity-sensitive handover. We do not knowingly market directly to children.

15. Cookies, mobile permissions and third-party links

The website may use essential cookies for login, security, language and service continuity. Optional analytics or marketing cookies should be presented separately where used. Mobile apps may request camera, photo, notification or location permissions only when a related function needs them. Device permissions can be changed in device settings, although disabling a required permission may prevent that function from working.

Third-party websites and hosted payment pages have their own notices. FS is responsible for selecting and governing its processors, but is not the controller of an unrelated third party’s independent service.

16. Changes to this Policy

Each published version displays its version number and effective date. FS retains prior versions and an administrative audit history. We may update this Policy when operations, technology, providers or law change. Material changes will be highlighted through the website, app, account notice, email or SMS as appropriate. Where a new purpose requires consent or re-acceptance, FS will request it before applying that purpose.

17. Contact and escalation

• Data controller: FS Pickup Spots Ltd, trading as FS Pickup Spots
• Physical address: The Hamza Bldg 1st Floor Suite B6, Jogoo Road Nairobi
• Privacy contact: support@fspickupspots.com
• General support: support@fspickupspots.com · +254758715596

If we do not resolve a privacy concern, you may lodge a complaint with the Office of the Data Protection Commissioner of Kenya. Courier or communications-sector complaints may also be escalated through the Communications Authority of Kenya complaints process after using the FS complaints process. These rights do not prevent you from pursuing another remedy available under Kenyan law.

18. Legal framework considered

This notice is designed with reference to the Constitution of Kenya, the Data Protection Act, 2019; the Data Protection (General) Regulations, 2021; the Data Protection (Registration of Data Controllers and Data Processors) Regulations, 2021; the Data Protection (Complaints Handling Procedure and Enforcement) Regulations, 2021; the Kenya Information and Communications Act; applicable postal and courier regulations; the Consumer Protection Act, 2012; and other applicable Kenyan law. If this Policy conflicts with a mandatory legal right, the mandatory law prevails.