PRIVACY NOTICE
DHL Express cares about your privacy.
Our mission is excellence, simply delivered while protecting you. This Privacy Notice describes
what data we and our Deutsche Post DHL Group companies collect via our different
interactions with you, why and how we use it, how long we keep it, where and how we collect
it, to whom we will pass it on and which rights you have.
Scope of this Privacy Notice
This Privacy Notice applies to all users of our services, websites, applications, features or other
services anywhere in the world, unless covered by a separate Privacy Notice.
This Privacy Notice applies to the following categories of individuals:
- Shippers: shippers, including their employees, or individuals who send a shipment
- Shipment receivers: any individual who receives a shipment
- Persons showing interest in us and our services or paying for them
- Business partners: business partners, including their employees
- Employment candidates: individuals that apply for a job with us
All the above subjects are referred to as “you” or “your”.
Our data protection practices are subject to applicable law in the places in which we operate.
This means that we engage in the practices described in this Privacy Notice in a particular
country, only if permitted by regional or local data protection laws.
Changes to this Privacy Notice
We reserve the right to change this Privacy Notice from time to time according to the changes
in our services, the processing of your data or in the applicable law. We therefore recommend
to visit our Privacy Notice periodically.
Who is responsible
The legal entity that acts as your data controller determines how and why your data is
processed:
For DHL Express Greece
DHL Express (Hellas) SA
44 Alimou Ave. & 17 Roma St.
Alimos, Athens, 174 55,
Greece
For DHL Express Global
DHL International GmbH
Charles-de-Gaulle-Str. 20
53113 Bonn
Germany
Types of data we process
We only process your data which is required for a specific purpose. In some countries,
additional data can be processed to comply with local laws.
Contact data
Information to contact you e.g. when we pick-up or deliver a package.
Such as: your name, phone number, address, email address
Employment candidate administration data
Information used in HR systems for candidates’ data.
Such as: your application, competences, work visa
User authentication and authorization
Information to identify and verify you as a user of our systems and to verify your access
to specific data e.g. On Demand Delivery application will show your pending shipments.
Such as: your login ID, password
Profile Data
Information on your DHL profile e.g. to set your delivery preferences.
Such as: your delivery preferences, order/purchase history
Contract data
Information laid down and agreed upon in contracts e.g. the contracting parties.
Such as: activity on contract, party names
Shipment data
Information enabling the pick-up and delivery of your shipment e.g. status of your
shipment.
Such as: your address, shipment documents, proof of delivery
Financial data
Information used for invoicing, financial and payment processes e.g. bank account
number which is used for payments.
Such as: your bank account, e-payment details
Identification data
Information used to identify you e.g. passport image to verify your identity.
Such as: your ID data, social security number, passport image
Characteristics
Information that is typical or noticeable related to you, which makes it possible to
distinguish you from other persons.
Such as: your signature as a proof of delivery
Telecommunication and survey data
Information communicated via you to one of our employees or by filling in an online
survey e.g. when you call our customer service.
Such as: your feedback, when applicable call recording
Why we collect your data
At DHL Express we only process your data for specific purposes and where we have a legal
basis to do so. This can either be:
- The performance of a contract or when you take steps into starting a contract with us.
- To comply with a legal obligation.
- The legitimate interests pursued and to safeguard your and our rights e.g. to increase your customer satisfaction, to deliver and improve our services for you, to facilitate your communication and interaction with us, to provide you with a more efficient, simplified and cost-effective service, to better manage our relationship with you and the opportunities that are presented with it, to optimize our routes, to better protect your data and to make sure no prohibited and unacceptable items enter our network. We will make sure that these legitimate interests are balanced. When applicable, you have the right to object.
- Consent, which you may withdraw at any time.
The following are the purposes for which we process your data:
| For you as a customer | |
| To provide our products and services, including: | |
| Purpose | Lawful ground for processing |
| To pick-up and deliver your shipment | Performance of a contract |
| To manage your shipment in our global network | Performance of a contract |
| To comply with all import and export regulations | Performance of a contract Legal obligation |
| To identify you | Performance of a contract Legal obligation Legitimate interest Consent |
| To support you with the use of our tools | Performance of a contract |
| To allow our business partners to serve you | Performance of a contract Legitimate interest Consent |
| To process financial data from you | Performance of a contract |
| To manage our relationship with you, including: | |
| Purpose | Lawful ground for processing |
| To improve your DHL experience and our products and services, e.g. events, sweepstakes, surveys | Performance of a contract Legitimate interest Consent |
| To keep you up to date on our products and services that may interest you | Legitimate interest Consent |
| To expand our products and services | Performance of a contract Legitimate interest Consent |
| To facilitate your visit on our website | Consent |
| To onboard you as a new customer | Performance of a contract Legitimate interest |
| To communicate with you | Performance of a contract Legitimate interest |
| For you as a business partner | |
| To deliver services to us, including: | |
| Purpose | Lawful ground for processing |
| To manage our relationship with you | Performance of a contract Legitimate Interest |
| For you to provide services to us | Performance of a contract Legitimate Interest |
| For you as a candidate | |
| To welcome you joining us, including: | |
| Purpose | Lawful ground for processing |
| To register you as a candidate e.g. job fairs | Performance of a contract Legitimate interest |
| To check your eligibility | Performance of a contract Legitimate interest |
| To onboard you | Performance of a contract |
| To keep you in our recruitment reserve | Consent |
| For everyone | |
| To protect and secure your data, including: | |
| Purpose | Lawful ground for processing |
| To ensure the security of our networks and information systems | Legal obligation Legitimate interest |
| To protect you | Legal obligation Legitimate interest |
Visiting our website
When you visit our websites, we capture your data which is necessary for us to make the
website accessible to you (e.g. IP address, date and duration of your visit). Further storage in
log files is performed to ensure the functionality of our websites and the security of our
systems. We therefore have a legitimate interest in processing your data. We delete your data
as soon as it is no longer needed to fulfill the purpose for which it was collected.
Shipment screening
Shipments are screened to verify their content, to match the detailed description, to check
their value and to comply with the applicable law and our Terms of Carriage. We screen all
shipments for security purposes to avoid that prohibited and unacceptable items enter our
network or to detect criminal offences or misuse. We have a legitimate interest for this
processing as it ensures the smooth operation and continuous improvement of our products
for your benefit.
Shipment exceptions
At DHL we strive to deliver your shipment with the utmost care and without undue delay. If
we cannot deliver your shipment, it will be returned to the shipper. For example, when no
address can be found, it will be handled in the DHL Found Shipment Center. We may open your
shipment to identify a return or delivery address. Therefore, we have a legitimate interest to
process your data.
Denied Party Screening
Denied Parties are individuals or entities who have been placed on a regulatory authority
denied persons list, blocked from import or export transactions, or have been sanctioned by a
regulatory authority for illegal acts such as involvement in terrorism, narcotics trafficking,
money laundering or weapons proliferation. Shipments to or from Denied Parties are often
prohibited.
Every shipment in the DHL Express network is screened for Denied Parties. Shipments to or
from potential Denied Parties may be held for further screening to verify that the shipment is
not prohibited. To facilitate the quick release of the shipment we may request a copy of your
identification document.
Based on DHL Express’ and your legitimate interest, we will process your data and we may
keep strictly necessary data for a limited period. This prevents your future shipments from
being delayed due to the screening process. Nonetheless, you have the right to object, verbally
or in writing.
If you have any questions on the regulations, trade sanctions and Denied Parties, please visit
the websites of the relevant authorities, e.g. United Nations, European Union and US
Government.
Calls and call recordings
In certain cases, DHL will call you to clarify contractual topics, to gather your feedback or for
marketing purposes. The legal basis is either performance of a contract, legitimate interest or
consent. For example, in some countries, calls for marketing purposes are only made with your
prior consent.
If you call us or we call you, the call can be recorded for shipment related matters, training
and quality assurance. We will process your call recording according to the applicable data
protection and telecommunication laws. Where the call recording is subject to consent, the
call will only be recorded after you give your consent. You can withdraw your consent at any
time. From that moment on, all communication will no longer be recorded. In countries
where the call recording is subject to legitimate interest, you may object to the recording.
Customer feedback
DHL may interact with you to capture your feedback and experience with us. Your response
will help us generate improvements in delivering our products and services. In some
countries we outsource this process to a business partner. Depending on your country, the
processing will be based on legitimate interest or on your consent.
Customs clearance
We want to ensure that your shipment arrives as quickly as possible by facilitating the customs
clearance process for you. To do this, it is necessary that you provide us with all the required
documents for customs clearance. As customs varies on country level, different legal
requirements can apply. For example, in certain countries, customs authorities require the
social security number, the national ID or a passport copy to clear the shipment. To comply
with the customs regulation and to fulfill our contractual obligations, the processing of your
data is necessary. In cases where we keep your data for future shipments, you have the right
to object.
Digital messaging
To facilitate the communication between us, we offer you to contact us via third party
communication channels of your choice (e.g. Facebook and DHL Virtual Assistant). The systems
respond with keyword-based answers or passes your request to a staff member in a live chat.
This is a quick and easy way to have answers on your shipment status or on our products and
services. DHL has a legitimate interest in processing your data for the facilitation of our
communication. If you do not wish to make use of such a channel, you are welcome to contact
our customer service. For further information on data protection practices of the
communication channel providers, please visit their websites.
Cookies and similar technologies
DHL makes use of various technologies to store your user preferences or other information to
make our services to you as convenient and efficient as possible. When you access our website,
a Privacy Preference Center will inform you that your consent is required to the use of certain
cookies, such as analytical cookies or similar technologies.
Geolocation
DHL will only collect your location directly from you. We offer you an improved user experience
on our systems by integrating mapping systems (e.g. Google Maps, Microsoft Bing Maps…).
This can be part of shipment tracking, location search and delivery to DHL Service Points in
case you have chosen to redirect your shipment. Depending on the country, this processing
can be based on legitimate interest or your consent.
Video Surveillance ‘CCTV’
DHL has installed video surveillance cameras to control the access to our buildings and specific
areas such as parking lots, as well as to perform oversight on our business operations. Video
surveillance is used to guarantee the health and safety of our visitors, personnel, and property,
as well as any monitoring of the operational processes in its facilities. Therefore, we have a
legitimate interest for security and access control purposes, which is necessary for the
management of DHL buildings.
Social media fan pages
We provide you our social media fan pages, such as Facebook, Instagram or LinkedIn to
better manage our relationship with you and to communicate with you. Therefore, we have a
legitimate interest in processing your data. For more information, please visit our Privacy
Notices on our social media fan pages.
DHL Service Points
It is possible for you to send and receive packages via Service Points. These Service Points can
be owned by DHL or by a third party business partner (e.g. your local newspaper shop). If
you choose to operate via a Service Point, DHL will process only the minimum and strictly
necessary data to perform our contractual obligations towards you. This could be the
delivery of your package to your preferred Service Point or sending your packages to your
intended recipient.
Payment partners
DHL offers you several payment options to facilitate your payment experience. We accept all
major debit and credit cards, as well as online payment systems. Your payment data will be processed in accordance with payment industry processing standards to provide the service
you request and to fulfill our contractual obligations.
How we collect your data
We primarily collect and use your data to pick-up, transport and deliver your shipment.
We may collect your data directly or indirectly. When you actively share information with us
by e.g. creating an account, contacting us or filling in a form on our website or a survey, we
receive your data directly from you. When we receive your data from an external third party
(e.g. shipper), we receive your data indirectly. In this case, it is the responsibility of the supplier
of the data to ensure the accuracy of the data and to transfer it to us in accordance with
applicable law.
Information for our business partners
We process data for you as our business partner, in order for us to manage our contracts with
you or to receive services from you.
We only collect and process the data necessary for our agreed contractual purposes and will
only share data in accordance with applicable data protection laws and limited to the agreed
purposes.
We use your services to better serve our employees and our customers. This allows DHL to
guarantee a close proximity to our customers for their pick-up and delivery, shipment data
management services, partners for safety and security, audits, payment providers and IT
hosting.
How long we keep your data
We will keep your data for as long as necessary to fulfill our purposes, to execute our contracts
and to comply with any legal obligation. The retention period may differ per country based on
applicable country laws.
To comply with applicable legal obligations, we will keep some of your data for a period up to
11 years, with variations per country as determined by applicable local laws. For example, the
storage of shipment documents required for shipment processing. We determine an
appropriate and reasonable retention period by considering the nature, the sensitivity and the
necessity of your data.
We continuously strive to minimize the retention period of data where the purpose, the law
or contracts allows us to do so. For example, in some countries data for the purpose of
customer satisfaction is kept for no longer than 3 years. The data that we collect based on your
consent will be processed until you withdraw your consent.
How we secure your data
DHL takes the security of your data very seriously. We have implemented various strategies,
controls, policies and measures to keep your data secure. We keep our security measures
under close review. We use safeguards such as firewalls, network intrusion systems and
application monitoring. Where appropriate, we secure your data by using pseudonymization
and encryption techniques when storing and transferring your data. We ensure that there are
strict physical access controls in our buildings and certified data centers.
As a part of our security strategy, we have set up auditing programs to make sure that our
systems and services comply with the DPDHL information security policy, and by extension the
ISO 27001 standard.
In addition, we are taking a number of ongoing measures to reduce risk, such as (but not
limited to) training our employees regularly and organizing incident simulation exercises by
our Cyber Defense Center.
The goal is to have a continuous IT system operation and to prevent unauthorized access.
Will your data be passed on
DHL will only share or transfer your data in the course of carrying out the purposes outlined in
this Privacy Notice, when permitted by applicable law and with appropriate safeguards.
We will transfer your data to the following category of recipients:
- DPDHL Group companies: transfer is required within the DPDHL Group to provide and improve our products and services. Transfers can also occur to manage our relationship with you, to identify you and to comply with your privacy rights
- Business partners: transfer is limited to what is required (e.g. to pick-up or deliver your package at a Service Point, in some areas to perform the pick-up and delivery or to execute customs clearance.)
- Public authorities: transfer is required by applicable law (e.g. to fulfil a legal obligation during shipment processing)
Your data is only transferred outside the European Economic Area (EEA) to other Deutsche
Post DHL Group companies, third party business partners or public authorities when permitted
by applicable data protection law. In such cases, we will make sure that appropriate safeguards
are in place to ensure the transfer of your data (e.g. our binding corporate rules, standard
contractual clauses).
The DPDHL Data Privacy Policy regulates our group-wide standards for the processing of your
data.
We respect your rights
Where applicable, data protection law provides multiple rights for you to exercise:
Right to access information
You have the right to be informed on the information we hold on you.
This includes the right to ask us supplementary information about the categories of your data
we are handling, for which purpose, the categories of business partners to whom the data may
be send to and your other rights regarding our use of your data.
We will provide you this information within one month after your request in so far we are not
affecting the rights and freedoms of another person by doing so.
Right of rectification
You have the right to request a correction of any inaccurate data about yourself.
Right to object
You have the right to challenge certain types of processing when based on legitimate interest,
such as direct marketing.
Right to withdraw your consent
You have the right to withdraw your consent at any time.
Right of portability
You have the right to port your data to another controller. We will give you an export of the
data you provided to us.
Right to erasure/be forgotten
You have the right, in certain circumstances, to request a deletion of your data. Where your
right to be forgotten is valid, and only if necessary, minimal data about you can be kept to
ensure you will not be contacted again. If you use our services again, you will be handled as a
new customer.
Right to restrict processing
You have the right to request a limitation in the way your data is used.
Right related to automated decision making including profiling
You have the right to request a review of automated processing. At this moment, DHL does
not apply any automated decision making with legal consequences for you. In case it will be
done in the future, we will do so in accordance with the applicable law.
You can direct your request based on the above rights or any other questions about this Privacy
Notice to our Data Protection Official from the country you are residing. DHL cannot handle
your request without sufficient proof of your identity. Please note that the applicable data
protection law may impose conditions on exercising the above rights.
Requests and complaints
We will handle all your requests with the care it deserves. If we fail to provide you a satisfying
answer, please contact us.
If we fail to address your concerns, you may send a complaint to your local Data Protection
Authority.
Glossary
| Business partners | Third parties who provide services to us |
| Communication channel providers | Third parties who provide us the use of their communication channels |
| Controller | The data controller determines the purpose(s) and the means of the processing of personal data |
| Data | All personal data related to a person who can be identified or identifiable directly or indirectly |
| DHL Express | DHL, we, us, our |
| DPO | The DPO ensures that the data protection rules are respected within the company |
| Processor | The data processor processes personal data only on behalf of the controller |
| Shipment receivers | The party to whom the shipment are delivered e.g. consignee, neighbors |
| Shippers | The party who initiates a shipment from one location to another via us |