BagFellowDrafted for review — not yet approved by a lawyer. This is a complete working draft describing what BagFellow actually does, written so a qualified adviser can review and adapt it rather than start from a blank page. Every [HIGHLIGHTED FIELD] must be completed, and the sections marked Needs legal review raise questions only a lawyer should answer. Do not publish as-is.
Privacy Policy
Draft · 29 August 2026 · not in force
1. Who we are
BagFellow is operated by [LEGAL ENTITY NAME], a company registered in [JURISDICTION] under number [COMPANY NUMBER], with its registered office at [REGISTERED ADDRESS] ("BagFellow", "we", "us"). We are the data controller for the personal data described here.
For anything in this policy, write to support@bagfellow.com.
Needs legal review. If you have users in the EU or UK and no establishment there, Article 27 GDPR may require an appointed representative in each. Whether a Data Protection Officer is required depends on the scale of identity-document processing.
2. What we collect, and why we are allowed to
| Data | Why we hold it | Lawful basis |
|---|---|---|
| Name, email address, phone number | To create your account and reach you about a deal | Performance of a contract |
| Identity documents: passport, national ID or driving licence, with number and expiry | To confirm you are who you say you are before money or goods move | Legal obligation and legitimate interest in preventing fraud |
| Travel details: airline, flight number, dates, booking reference | To verify a trip is real before senders rely on it | Performance of a contract |
| Listings and deals: items, cities, weights, amounts agreed | To operate the marketplace | Performance of a contract |
| Messages between users | To let a deal be arranged, and to resolve a dispute if one arises | Performance of a contract |
| Date of birth | To confirm you are old enough to enter a contract, which is 18 | Legal obligation and performance of a contract |
| Payment records: amounts, currency, status, payout destination | To take payment, hold it, and pay it out | Performance of a contract and legal obligation |
| Bank or wallet details you give us for payouts: account holder name, IBAN or account number, sort or routing code, bank name | To send you the money you have earned | Performance of a contract |
| What you agreed to when you accepted a deal: the liability wording shown to you, and any customs acknowledgement you gave | So a later dispute is settled against what you were actually told at the time | Performance of a contract and legitimate interest in a fair dispute process |
| Ratings and reviews you write or receive | To let other users judge who they are dealing with | Legitimate interest in a trustworthy marketplace |
| Device and usage data: IP address, device type, app version | Security, fraud detection, and fixing faults | Legitimate interest |
We do not collect card numbers. Payments are handled by our payment providers, and card details never reach our systems.
We do not use face recognition, facial comparison or any biometric matching. Identity is checked by a person looking at the document you upload. Some platforms in this market do use face scanning; we do not, and we will tell you before that ever changes.
Your bank and wallet details are encrypted before they are stored, are never shown back to you after you save them beyond the last four digits, and are readable only by the small number of people who send payouts. Nobody at BagFellow will ever ask you for them by email or message.
Needs legal review. Identity documents may constitute special-category data in some jurisdictions, particularly if any facial comparison is introduced later. The lawful basis above should be confirmed, and a DPIA is likely required before launch.
3. Who can see your data
- Other users see only your public profile: display name, country, rating, and number of completed deliveries. Your email address, phone number and date of birth are stored in a separate table from your profile, specifically so they cannot be exposed by a mistake in profile visibility.
- The person you are dealing with sees what is needed to complete the deal.
- Our reviewers can see identity documents, trip booking references and dispute evidence, and only in order to review them. Every such action is written to an append-only audit log recording who did what and when.
- Nobody sees a handover code they are meant to scan. The sender's code and the traveller's code are withheld from the opposite party — and from our staff — because a code you could obtain without meeting would prove nothing.
- Booking references are treated as credentials. A booking reference together with a surname can be enough to view or alter a flight reservation, so it is never shown in any listing and is readable only by you and a reviewer.
4. Who we share it with
- Payment providers, to take payment and pay travellers out.
- Infrastructure providers who host the service on our behalf under contract.
- Law enforcement or regulators, where we are legally required to, or where it is necessary to investigate suspected serious wrongdoing.
- The other party to a deal, where a shipment is lost or not delivered and a debt is owed. In that situation we may pass identifying information to the person owed, or to an authority or adviser acting to recover it, to the extent the law allows. Section 10 of the Terms explains when this arises.
We do not sell your personal data, and we do not share it for advertising.
Needs legal review. Disclosing identity information to another user to pursue a private debt is a narrow and contested basis. Confirm the lawful basis, what may be disclosed and to whom, before the first recovery is attempted.
5. Where your data is held
Our database is hosted in [REGION — currently eu-central-1, Frankfurt]. Because BagFellow connects people in different countries, data will necessarily be transferred across borders to complete a deal.
Needs legal review. Transfers out of the EEA require a lawful mechanism, typically Standard Contractual Clauses plus a transfer risk assessment.
6. How long we keep it
- Financial records — for as long as accounting and anti-money-laundering rules require, typically [5–10 YEARS] after the transaction.
- Identity documents — while your account is verified, and [RETENTION PERIOD] after closure for fraud and dispute purposes.
- Messages and dispute evidence — [RETENTION PERIOD] after the deal ends.
- Profile and listings — removed when you close your account.
Closing your account removes your profile and listings. It cannot remove records we are required by law to keep.
7. Your rights
You can ask us for a copy of your data, to correct it, to delete it, to restrict or object to how we use it, or to receive it in a portable form. Write to support@bagfellow.com and we will respond within [30 DAYS].
If you are in the EU or UK you may also complain to your national supervisory authority. [NAME THE AUTHORITY FOR YOUR JURISDICTION]
8. Security
Access to your data is enforced by the database itself rather than by application code, so a bug in a screen cannot expose rows you are not entitled to. Identity documents and dispute evidence are stored privately and served only through short-lived links. Nothing that moves money is writable by a user's own session.
No system is perfectly secure, and we do not claim otherwise. If you believe your account has been compromised, contact us immediately.
9. Children
BagFellow is not for anyone under 18. We do not knowingly collect data from children, and will delete such an account if we find one.
10. Changes
If we change this policy in a way that matters, we will tell you in the app or by email before it takes effect.