Draft, to be checked by a lawyer

Privacy notice

Version 2026-10-30

1. Who is responsible

GK Coding (address: to be added) is responsible for the processing of your personal data in the Portovan apps and on app.portovan.at. Contact for privacy questions and requests: george.kassih@gkcoding.dev.

2. What is stored and why

• Account: email address, name, phone number and whether and when you verified it with a code, language. To sign you in and to let the other side of a trip contact you. Phone numbers are shown to the other side only while a trip is under way. Changing the number ends its verification; Portovan staff can also remove a verification, for example after a lost phone, and record why.
• Sign-in: a one-way hash of your password (argon2id; never the password itself) and when you set it; for each session how you signed in (email code, SMS code, password, passkey, Apple or Google), whether you chose Remember me, and when, and when you last used "Confirm it's you". For Portovan staff also the browsers they chose to trust for 30 days (only a one-way code of the browser's token, the device name and the dates) and the public keys of their passkeys. The Face ID, Touch ID or fingerprint lock of the apps happens only on your phone: Portovan never receives your face or fingerprint.
• Sign in with Apple or Google (only if you choose it): Apple or Google tells us a fixed account number for Portovan, your email address and whether it is confirmed, and your name if you share it. With Apple's "Hide my email" the address is an Apple relay address that forwards our emails to you; we store it as given. We keep the account number, that email and the dates to recognise you at the next sign-in, and for Apple a token to end the link when you delete your account. Nothing else from your Apple or Google account is read. You can unlink it in Account → Sign-in methods; deleting your account removes the link.
• Sign-in methods and codes by SMS: in Account → Sign-in methods you can add or remove Apple and Google, set a password and verify your phone number. When you connect Apple or Google, we tell you by email. A change of your sign-in methods can ask you to "Confirm it's you" with your password or a code to your email. Once Portovan sends SMS (not yet, see section 4), a verified number can also sign you in to the customer and driver apps with a code by SMS. The SMS code is valid for 10 minutes. We keep it only as a one-way hash, with the number, its purpose, the tries and the times; after 24 hours it is deleted in the nightly cleanup, and at once when you delete your account. A verified number belongs to one account: if another account verifies it (numbers get reassigned), the verification moves to that account. The earlier account can no longer sign in with the number, which stays on it unverified, and we tell it by email, without the number. To stop abuse of the SMS (for example bots sending codes to paid numbers), we count the codes for up to a day per account, number, app installation (a one-way code of its random id), IP address and network (a one-way code), and per country; codes go only to numbers in Austria and the other EU countries. If we switch on the location check, we look up the country of your IP address in a database on our own server, without passing the address on and without storing the country; a request from outside the EU (for example while travelling or with a VPN) then gets no code.
• Trips: pickup and drop-off addresses, a second stop if you add one, times, prices, the van size, your note, item photos and the items you picked in "What fits?". To carry out the order and for receipts and tax records.
• Right of withdrawal: for an order as a consumer, the version of the sentence you ticked (that the trip may start before the 14-day withdrawal period ends) and when; kept with the trip. To prove the request (FAGG).
• Location (drivers): only while you are online: the last position (to offer you orders nearby, kept 2 minutes); during a trip the route points (to show the customer the van and for disputes, kept 30 days). Never when you are offline.
• Trip chat: the messages, quick replies and photos you and your driver or customer send each other in the app during a trip, and when they were sent and read. You both can read them until 24 hours after the trip; Portovan keeps them 30 days (90 days after a report) for disputes and safety, then deletes them. To protect against fraud, harassment and going around the platform, messages with phone numbers, email addresses or external web links are blocked automatically and not sent. Our staff do not read the chat; only for a support case or a report can authorised staff open it, and every opening is logged. Push notifications never contain the words of a message. If one of you reports the chat, Portovan stores that the two of you are not matched again (until our staff lift it; deleted with either account, or 1 year after it was lifted).
• Photos: item photos, the driver's photos of the secured load before driving and of the items at the drop-off, and the delivery photo (30 days), report and support request photos (90 days). A damage claim keeps copies of the load and drop-off photos with the claim.
• Driver documents and vehicle: to check that you may drive for Portovan; stored encrypted and shown only to Portovan's admin through short-lived links.
• Payments: card brand, last 4 digits, the payment status and Stripe references; a tip you give your driver (amount, status and its Stripe reference). The full card number is entered at Stripe and never reaches Portovan.
• Driver payouts: the account holder, IBAN and BIC you give us (stored encrypted; shown to our staff only masked, in full only to authorised finance staff, and every view is logged), your monthly statements (credit notes, with the IBAN masked) and the bank transfers made to you, to pay you your earnings. A change of holder or IBAN is emailed to you and checked before the first payout to the new account.
• Driver tax details (DAC7): under the Austrian Digital Platforms Reporting Obligation Act (DPMG, the EU directive DAC7), Portovan collects your name (or company name), address, date of birth (and place of birth if you have no tax number), tax identification number, VAT number and company register (Firmenbuch) number, and uses your payout account (IBAN and holder). Once a year Portovan reports them with your earnings, Portovan's fees and the number of trips per quarter to the Austrian tax office, which may pass them to the tax authority of your EU country of residence. They are stored encrypted, shown to our staff only masked, and kept for 10 years after the end of the reporting period (§ 16 Abs 2 DPMG – 10 years). Legal basis: legal obligation (Art. 6(1)(c) GDPR, § 7 DPMG).
• Your details in the order email (drivers): when you accept a trip, the customer gets your name (or company name), your business address from your tax details, your van and its plate by email: the details of their contract partner (§ 4a FAGG; Art. 6(1)(b) and (c) GDPR).
• Ratings, reports and support requests: stars, comments, your requests and messages with their photos, our answers, and notes our support team keeps about a request or about you, to keep the service safe and to handle problems.
• Emails to our team addresses (such as support@): the sender's address and name, the subject, the text, attachments (photos and PDFs) and the email headers needed to keep a conversation together (message IDs), as a support request; our answers are sent by email to that address. Kept like support requests: 3 years after the request is closed, attachments 90 days. Email contents and addresses are never written to logs.
• Terms accepted: which version of the Terms and of this Privacy notice you accepted and when (customers in the app, drivers at sign-up, this notice when you create your account and after each new version), to show what applies to you.
• Blocked driver sign-ups: if a driver account that Portovan suspended is deleted, Portovan keeps a one-way code (HMAC) of its email address, never the address itself, so that the address cannot sign up as a driver again for 2 years; you can ask for a review of the block at the contact above.
• Driver applicants: if you apply to drive for Portovan before signing up in the app, the name, email address, phone number, city and where you heard of Portovan, the stage of your application and our notes about it. Once you sign up with the same email address, the application is linked to your driver account.
• Messages to drivers: which Portovan messages (announcements) reached you, by notification or email, and when you last read them. Drivers also get reminders by notification and email before a document expires.
• Push tokens: to send you notifications about your trips.
• News from Portovan (optional): only if you switch it on in the app (Account; off unless you do): that you agreed, when, and which version of the text you agreed to, and each time you switch it off again. Portovan then sends you offers by notification or email; every email has a link to unsubscribe at once. Which campaigns reached you is kept 1 year. No tracking pixels, no link tracking (consent, Art. 6(1)(a) GDPR; you can withdraw it at any time).
• Promo codes and invitations: the code used on a trip and its discount; your own invitation code, which invited friends took a first trip (never their name) and your reward codes. To stop rewards for inviting yourself, Portovan compares one-way codes (HMAC) of the card used and of a random id of the app installation, never the card number or the device itself.
• Business accounts: if your company invites you, your role (admin or booker), your cost centre, the invitation (your email, who invited you, its status) and which of your trips were booked under the company. The company's admins see your name and email; the company receives an invoice listing those trips with the cost centre and districts. When you delete your account, your memberships end; the business trips stay with the company's invoices.
• Portovan Delivery: when you send an item, its description, weight class, declared value and photos; the name and phone number of the recipient (and of a sender other than you) and your note for the recipient; the 4-digit handover code and a tracking link. The driver sees the names and phone numbers only while the delivery is under way, and takes a photo of the item at pickup and at a handover without the code. The tracking page shows only the status, the time window, the arrival time and the van's position on the way: no names, phone numbers, addresses or prices. Portovan sends the recipient nothing; you share the code and the link yourself. Please tell the recipient that you pass their name and number to Portovan.
• Contact persons on trips: when someone else hands over or receives for you on a move: that person's name and phone number at the pickup or the drop-off; also the floor and lift at each stop, how many people accompany their own goods and when you confirmed that people are there to carry. The driver sees the names and phone numbers only while the trip is under way, and calls the contact person when needed. You share the link to the trip yourself (with "Share trip"; it shows only what is described there); Portovan sends the contact person no SMS and no email. Please tell them that you pass their name and number to Portovan; their information is in section 2a.
• Signature at the drop-off: for business trips that ask for it and for deliveries handed over in person, the recipient signs on the driver's phone and types their name; or the driver notes that they refused (with a photo of the drop-off). The signature is stored encrypted, shown to you on the trip and the receipt, to the company on its invoice ("signed", never the name) and to Portovan staff on the trip; the driver sees it only until the trip ends. Please tell the recipient that their signature is passed to Portovan; their information is in section 2a.
• On your phone: the app keeps the email address of the account you last signed in with, on this phone only, so the sign-in page is filled in and the lock screen can show it masked; it stays after Sign out, "Not you?" removes it, and it is removed when you delete your account. Your password is saved only by your phone's password manager if you allow it, never by Portovan. When you share or open a receipt or a monthly statement, the app keeps a copy of the last one in its private storage on the phone (no other app can read it) until you share the next one or remove the app.
• Profile photo (optional): if you add one in the app, it is stored encrypted and shown to the driver of your trip while the trip is under way. You can remove it at any time in the app; it is deleted with your account. Drivers can add one in the driver app the same way; the customer of a trip sees it while the trip is under way.
• Share my trip (optional): during a trip you can send a link to anyone you choose. The page shows the driver's first name, the van (model, colour, plate), its position, the status and the arrival time, and the next stop only roughly (about 100 m): no addresses, phone numbers, your name or prices. The link ends when the trip ends or when you tap "Stop sharing". Opening the page needs no account and is not logged with personal data.
• Screenshots to support (optional): when you take a screenshot in the app, it asks whether to send it to support. Only if you tap Send is the picture of the app screen attached to your chat or request and kept like its other attachments; otherwise it is not stored or sent.
• Problems during a trip: if Portovan takes a trip off its driver, the reason, the steps and who had the items when; your answer to "Are your items with you and OK?"; a "Get help" request (its category, text and photos) as a support request. A damage claim keeps your description, the value you state, photos, the driver's answer, the outcome and the driver's insurer and policy number. The driver sees the claim and your first name; the driver is responsible for the items, Portovan records and mediates the claim. Drivers also give the insurer, policy number and expiry of their carrier liability insurance.
• Load safety (drivers): the time you confirmed "load secured" on a trip, your photos of the load, that you have straps and blankets and, if you add one, a photo of them (with your driver documents), and when staff checked your carrier liability insurance.

Legal bases: carrying out the contract (Art. 6(1)(b) GDPR), legal obligations such as tax law (Art. 6(1)(c)), and Portovan's legitimate interest in a safe service and in handling disputes (Art. 6(1)(f)).

2a. Recipients of deliveries, contact persons and signatures (Art. 14 GDPR)

If you receive a Portovan delivery, are the contact person at the pickup or the drop-off of a trip, or sign for a trip at the drop-off, Portovan did not get your data from you but from the sender (the customer who booked the delivery or the trip, or the company that booked the business trip).

• Data: your name, the drop-off address (as the contact person at the pickup: the pickup address) and your phone number; at the handover your signature and typed name, or the driver's note that you refused, a photo of the item at the drop-off, the time and the driver's position at that moment.
• Source: the sender of the delivery, the customer who booked the trip or the company that booked the trip.
• Purpose and legal basis: delivering the item, announcing it and proving the delivery (proof of delivery); on trips the handover at the pickup and the drop-off and the driver's calls when they need you; the legitimate interest of the sender, the driver and Portovan in a proper delivery and in proving it (Art. 6(1)(f) GDPR).
• Who sees it: the driver only while the delivery or trip runs; the sender or the customer; Portovan staff on the trip; a company sees on its invoice only "signed", never your name. You get the link to the trip only from the customer; Portovan sends you nothing.
• How long: name and phone number as a contact person with the trip, removed when the customer deletes their account (see section 3); signature and name 3 years after the trip for business trips and disputed trips, otherwise 90 days; the booking record without your name stays 7 years for tax law (see section 3).
• Your rights: as in section 6, including the right to object (Art. 21 GDPR); write to the contact in section 1.

2b. Fleet partners

This section applies once Portovan works with fleet partners (not started yet). Fleet partners are transport companies with several vans whose own drivers drive with the "Portovan Driver" app. If the driver of your trip belongs to a fleet partner, the company is the carrier, and the app shows "operated by" with its name. In the partner portal a partner sees only its own drivers, vans, trips and statements:

• Your trip: before it is assigned only the districts, the size, the earnings and the distance; after it is assigned, while the trip is under way, the pickup and drop-off address, your first name, the items, your note and the status, never your phone number, email address, card or the chat; after the trip the date, districts, size, amounts, driver and stars, exact addresses only for 30 days.
• Damage and reports: a damage claim about one of the partner's trips with its photos and the driver's answer (the partner is liable and handles it with its insurer); for a report about one of its drivers only the category and the outcome, not your identity.
• A partner's drivers: the partner sees their name, photo, phone number, status, the average of their ratings and the state of their documents; their position only while they are online, never the history. They do not see statements or bank details.
• Users of the partner portal: email address, name and role (manager or dispatcher), the sign-in as for Portovan staff (code or password, a required second factor stored encrypted, trusted browsers); the partner's company details and proofs are stored encrypted like driver documents. At sign-up the partner chooses the city it works in; the city decides which Portovan staff (that city's team, its office and country, and headquarters) can see the partner's data. When the bank account for the payouts is changed, the confirmation code goes to the manager who changes it, and the company's billing address is also told (without any bank details) when it is another address.
• Access log: every view of personal data in the partner portal is logged (which user, which kind of data, which record, when), kept for 1 year and used for checks. The portal has no bulk export of customer data.
• Roles: Portovan is responsible for the platform; the partner is its own controller for its staff and, as the carrier, for the trip data it receives. A data protection agreement between Portovan and each partner settles this (still being checked by a lawyer).

3. How long data is kept

4. Who receives data (processors and other recipients)

Portovan signs a data processing agreement (Art. 28 GDPR) with every processor; where data leaves the EU, the transfer relies on the EU adequacy decision for the EU-US Data Privacy Framework (Art. 45 GDPR) or on the EU standard contractual clauses (Art. 46 GDPR). The customer and the driver of a trip see the data they need for it (first name, rating, the van, addresses, phone number during the trip).

5. No tracking

Portovan uses no analytics, no advertising and no tracking tools. Logs contain no addresses, locations, phone numbers or email addresses.

6. Your rights

• Access and portability: download all your data in the app (Account → Download my data).
• Deletion: delete your account in the app (Account → Delete account).
• Correction, restriction and objection: write to the contact above.
• Complaint: you can complain to the Austrian data protection authority (Datenschutzbehörde, Barichgasse 40–42, 1030 Vienna, www.dsb.gv.at).