Privacy Policy

Agora Technologies Ltd. t/a oDeliver

Effective Date: March 1, 2026

1. Introduction

This Privacy Policy (“Policy”) explains how Agora Technologies Ltd., trading as oDeliver (“Company”, “we”, “us”, or “our”), collects, uses, processes, stores, discloses, transfers, and protects personal data in connection with its logistics, delivery, payment facilitation, wallet reconciliation, and related digital services (the “Services”).

This Policy is issued pursuant to the Data Protection Act, 2011 of the Republic of Trinidad and Tobago (“DPA”).

This Policy forms part of and must be read together with the Company’s Master Terms and Conditions of Service and all related operational policies.

By accessing or using the Platform, submitting information, or engaging the Services, you acknowledge that you have read and understood this Policy.

2. Data Controller

Agora Technologies Ltd., trading as oDeliver, is the Data Controller for personal data processed for operational, compliance, fraud prevention, security, and enforcement purposes.

Contact:
Data Compliance Unit
Agora Technologies Ltd.
Email: info@odeliver.net

We may require identity verification before responding to requests.

3. Scope of Application

This Policy applies to:

• Merchants
• Customers / Consignees
• Delivery Agents / Drivers
• Platform visitors
• Internal personnel
• Any individual whose data is processed in connection with a Shipment or transaction

4. Categories of Personal Data Collected

4.1 Merchant Data

We may collect and process:

• Full legal name and trade name
• Business registration documentation
• Director/shareholder information
• Contact information (email, phone, address)
• Bank account information for remittance
• KYC documentation and verification results
• Shipment records and declared values
• COD transaction history
• Wallet balances and remittance records
• Chargeback and dispute records
• Platform usage logs and communications

4.2 Customer / Consignee Data

We may collect:

• Full name
• Delivery address
• Phone number
• Email address (where provided)
• Delivery notes or instructions
• Proof-of-delivery information (photo, signature, timestamp, GPS)
• Payment link confirmations
• Communications relating to disputes or claims

4.3 Driver Data

We may collect:

• Identity and contact details
• Government-issued identification
• Driver credentials
• Vehicle information
• Real-time geolocation data while actively logged into the Platform
• Delivery logs and completion confirmations
• Payment and reconciliation data
• Incident reports

4.4 Technical and Usage Data

We may collect:

• IP address
• Device identifiers
• Browser or app version
• Session timestamps
• Access logs
• Security logs
• Cookie and SDK tracking data

5. Sources of Data

Personal data may be collected:

• Directly from users during registration or shipment creation
• Automatically through use of the Platform
• From Merchants submitting Customer details
• From payment processors
• From background verification providers
• From lawful third parties where required for fraud prevention or compliance

6. Legal Basis for Processing

Personal data is processed under one or more of the following lawful bases:

6.1 Contractual Necessity

Processing necessary to perform logistics, delivery, payment facilitation, and reconciliation services.

6.2 Legal Obligation

Processing required to comply with applicable laws, regulatory requirements, court orders, tax laws, and anti-money laundering obligations.

6.3 Legitimate Interests

Processing necessary to:

• Secure the Platform
• Prevent fraud and abuse
• Verify delivery completion
• Investigate disputes and chargebacks
• Protect business integrity
• Improve operational performance

6.4 Consent

Processing for optional services such as marketing communications or non-essential cookies where required. Withdrawal of consent does not invalidate prior lawful processing.

7. Purposes of Processing

7.1 Provide Logistics Services

• Create and manage Shipments
• Assign and monitor delivery agents
• Track delivery attempts
• Generate proof of delivery
• Manage returns and exchanges

7.2 Facilitate COD, Wallet, and Remittance

• Collect COD payments
• Reconcile digital wallet balances
• Process remittances
• Apply offsets and handle chargebacks
• Monitor transaction integrity

7.3 Fraud Detection and Risk Monitoring

• Identify suspicious transaction patterns
• Detect misuse or unauthorized access
• Investigate operational anomalies
• Protect against financial misconduct

7.4 Compliance and Enforcement

• Conduct KYC verification
• Monitor AML thresholds
• Respond to regulatory or law enforcement requests
• Support insurance and claim processes

7.5 Customer Support and Quality Assurance

• Resolve disputes
• Address complaints
• Improve service delivery

7.6 Business Analytics

• Analyze aggregated data for performance optimization
• Improve routing, delivery success, and fraud prevention

8. Universal Customer Database

To streamline delivery accuracy and reduce failed deliveries, oDeliver maintains a centralized customer information repository containing delivery-related contact details submitted by Merchants.

8.1 Purpose Limitation

The database exists solely for:

• Shipment fulfillment
• Autofill functionality
• Address validation
• Fraud prevention
• Dispute resolution

8.2 Access Controls

Access is restricted and subject to technical controls, including masking and role-based permissions.

8.3 Merchant Restrictions

Merchants are prohibited from:

• Extracting or copying customer data outside the Platform
• Using customer data for unrelated marketing
• Repurposing data outside delivery fulfillment

Violations may result in suspension, termination, and legal action.

9. GPS and Operational Tracking

Delivery agents may be tracked via GPS while actively engaged in delivery operations and logged into the Platform.

Tracking is used solely for:

• Route optimization
• Proof of delivery
• Fraud prevention
• Operational safety

Tracking is not conducted for unrelated surveillance purposes.

10. Payment Data

oDeliver does not store full debit or credit card numbers.

Payment links are processed through licensed third-party payment gateways and financial institutions.

We retain transaction references, timestamps, and confirmation records necessary for reconciliation and dispute handling.

11. Sharing and Disclosure

Personal data may be shared with:

• Delivery agents for fulfillment purposes
• Payment processors and financial institutions
• Insurance providers for claims verification
• Regulatory authorities where required by law
• Law enforcement agencies
• Professional advisors (legal, accounting, audit)
• Cloud infrastructure and IT service providers

We do not sell personal data.

12. International Data Transfers

Where necessary for cloud hosting or payment processing, personal data may be processed outside Trinidad and Tobago. Appropriate contractual safeguards are implemented to ensure adequate protection.

13. Data Retention

Personal data is retained only as long as necessary for:

• Service delivery
• Legal compliance
• AML/KYC requirements
• Tax and audit obligations
• Fraud prevention
• Dispute resolution
• Insurance claim processing

After expiration of retention periods, data may be anonymized or securely destroyed.

14. Security Measures

We implement administrative, technical, and physical safeguards including:

• Role-based access controls
• Audit logging and monitoring
• Encryption in transit
• Infrastructure security protections
• Vendor security oversight

No system guarantees absolute security. Users must safeguard login credentials.

15. Data Breach Response

In the event of a material data breach, we may:

• Investigate and contain the incident
• Notify affected individuals where appropriate
• Notify regulators or authorities where required
• Implement corrective measures

Notification decisions depend on severity and legal obligations.

16. Data Subject Rights

Subject to the DPA and lawful limitations, individuals may:

• Access: Request access to their personal data
• Correction: Request correction of inaccurate data
• Restriction: Request restriction of processing
• Withdraw Consent: Withdraw consent where applicable

Requests may be limited where data must be retained for legal compliance, fraud prevention, dispute resolution, financial reconciliation, or enforcement.

To exercise these rights, contact us at info@odeliver.net.

17. Cookies and Tracking Technologies

We use cookies and SDKs for:

• Platform functionality
• Security
• Analytics
• Fraud detection
• Performance monitoring

Users may manage cookies via browser settings, though some features may not function properly if disabled.

18. Marketing Communications

We may send operational communications necessary for service delivery.

Marketing communications may be sent where permitted by law. Users may opt out at any time.

19. Limitation of Liability (Privacy Context)

The Company shall not be liable for:

• Data loss caused by third-party systems outside its control
• Telecommunications failures
• User negligence in protecting credentials
• Security breaches beyond reasonable safeguards

This Policy does not create fiduciary obligations beyond those expressly provided under the Terms and Conditions.

20. No Banking or Fiduciary Status

The Company is not a bank, deposit-taking institution, or regulated financial entity. Nothing in this Policy creates a custodial or fiduciary relationship regarding funds processed through the Platform.

21. Amendments

We may update this Policy from time to time. Updated versions will be published through official channels. Continued use of the Platform constitutes acceptance.

Contact Us

For questions or concerns about this Privacy Policy or our data practices, please contact:

• Data Compliance Unit
• Email: info@odeliver.net
• Phone: (868) 777-0000
• Address: Port of Spain, Trinidad & Tobago