Privacy policy
This policy covers all three parts of Bottle: this website, the Bottle platform you sign in to, and the driver apps for iPhone and Android. It says what we hold, why we hold it, how long we keep it and what you can ask us to do about it.
The short version. Most of the personal data inside Bottle is not ours. It belongs to the distributor who put it there, and we only handle it because they asked us to. A smaller amount is ours to decide about, such as your account, your billing and anything you send us. The difference matters, so the next section explains it before anything else.
Who we are
Bottle is delivery software for gas and fuel distributors in the United Kingdom. It is made and run by Sorteo Ltd, a company registered in England and Wales with company number 16426798, whose registered office is at 2nd Floor, 1 Church Square, Leighton Buzzard, Bedfordshire, LU7 1AE, United Kingdom. Sorteo Ltd trades as Bottle.
For anything about your data, email compliance@getbottle.app. A person reads it.
Sorteo Ltd is registered with the Information Commissioner's Office, the United Kingdom's data protection regulator. Our registration number is ZC296441. You can check our entry on the register.
The two roles we play
Data protection law separates the organisation that decides what happens to personal data, called the controller, from the organisation that handles it on the controller's behalf, called the processor. Bottle is sometimes one and sometimes the other. Which one it is changes who you ask for things and who is answerable for them, so it is worth being exact about it.
Where we are the processor
Everything a distributor puts into Bottle to run their business belongs to that distributor. Their customers' names, addresses and phone numbers, their orders and invoices, their proof of delivery, their drivers' details and the position of their vans. The distributor decides why that data exists and what happens to it. We hold it and act on their instructions.
Being the processor covers more than storing what somebody typed. It also covers the work of running the service for them, all of it on their instructions and none of it for our own purposes: providing Bottle and keeping it running, investigating and fixing faults, looking into security alerts and acting on them, helping a business get set up and move their existing records in, changing a setting because they have asked us to, and the ordinary day-to-day administration of the service. We do that work because a business subscribes to Bottle and uses it, and for no other reason.
The honest question behind all of that is whether somebody at Bottle can look at your customers' addresses. The answer is that our staff see nothing inside a business's account unless an owner or an administrator at that business grants access, which can be read-only or allow changes, and which expires. There is one exception, for our most senior staff, where an account can be opened without a grant: it requires a written reason, and it is recorded. Whichever route is used, every single request made while inside an account is written to an audit log, with who made it, what they were looking at or changing and whether it was allowed or refused. We do not record the contents of what was seen.
We do not use anything inside a business's account to train models, to build a product of our own, or for any purpose that business has not asked for.
Where we are the controller
Some data is ours to decide about, and for that we are the controller and answerable for it directly. It covers the account holder's own name and email address, how you sign in, your subscription and what you pay us, the notices the service has to send you such as a password reset or a warning that a trial is ending, replies to anyone who contacts us, anything typed into the form on this website, and any marketing we send. Marketing is sent only with your consent and you can stop it at any time, and stopping it does not affect the notices the service itself has to send.
It also covers the records of our own conduct: who at Bottle was given access to an account, who approved it and why, and the log of what they did while they were in there. Those exist so that our behaviour can be checked, which means the decision about keeping them has to be ours rather than the customer's.
Deciding how to improve Bottle is our own decision rather than something a customer instructs us to do, so it belongs here rather than on the processor side. We record which pages people signed in to the office side of Bottle use, against their name and email, as described under How the office uses Bottle, and we use it only for that.
Where drivers stand
If you drive for a business that uses Bottle, your employer is the controller of your data, not us. Your name, your account, where the van was during your round, what time you finished each drop, the cash you handed in and your time off all belong to your employer. We hold them because your employer asked us to.
That means a request to see or delete your data goes to your employer first, because the decision is theirs to make and we are not allowed to make it for them. If you write to us instead we will not ignore you: we will tell you who to ask and, if you want us to, let your employer know you have been in touch. If you believe your employer is doing something with that data they should not be, you can complain to the Information Commissioner's Office about them, and that route does not depend on us at all.
What we hold, and why
These tables are grouped by who you are, so you can find the row that applies to you. Every row is complete on its own: what the data is, why it exists, who decides about it and how long it lasts, without needing the row above or below it.
If you use Bottle to run your business
We are the controller for everything in this table, which means we decide why we hold it, and the legal basis is given against each row.
| What we hold | Why we hold it | Lawful basis | How long we keep it |
|---|---|---|---|
| Your name and email address | To give you an account, show your name to colleagues at your business, and send you what the software needs to send you, such as a password reset. | Performing our contract with you. | Closing your account blanks you in our own database: your name becomes "Closed account" and your email address is replaced with one that cannot receive mail. If you have paid us, that does not reach the record of what was paid. Those invoices are held by Stripe, who bill on our behalf, and they carry your name, email address and billing address. We have to keep records of what we were paid for six years from the end of the accounting period, so closing your account does not remove them. |
| How you sign in | To let you in and keep other people out. This is a scrambled version of your password that cannot be turned back into it, your two-step sign-in secret and backup codes if you use them, and any API keys you create, also stored scrambled so a working key cannot be read out of our database by anyone, us included. | Performing our contract with you, and our legitimate interest in keeping accounts secure. | Your stored password, your two-step sign-in secret and backup codes, and any connected apps are removed when you close your account. API keys are treated differently on purpose: a key you revoke is kept as a record that it existed and who revoked it, so the history of who had access to what still makes sense. The key itself is stored scrambled and cannot be read back or used. |
| Your sign-in sessions | So you stay signed in, and so you can see and end any session you do not recognise. Each one records the address your browser connected from and what browser it was. | Performing our contract with you, and our legitimate interest in keeping accounts secure. | Closing your account removes all of your sessions. While an account is open, a session stops working when it expires or when you sign out, and the expired record is deleted thirty days later, along with the address you connected from and the browser you used. |
| Your business and subscription | To charge you for Bottle and know what your plan allows. This is your business name, company number and registered address, which for a sole trader is often a home address, along with your plan, trial dates, renewal date and any agreed discount and the reason it was given. Your billing details and card are held by Stripe, who bill you on our behalf, and card numbers never reach us. | Performing our contract with you, and our legal obligation to keep tax records. | Your business details and the state of your subscription stay in Bottle while the business exists, and go when the business is deleted. The record of what you actually paid is a different thing and it is not kept in Bottle: those invoices are held by Stripe with your name, email address and billing address on them. We have to keep records of what we were paid for six years from the end of the accounting period, so they outlive both a cancelled subscription and a closed account. |
| When you ask us for help | To answer you, and to keep a record of it. Where you let our staff into your account to help, we record who asked, why, who approved it, what level of access was given and when it expires. | Performing our contract with you, and our legitimate interest in being able to show who was allowed into an account and on whose authority. | Kept for as long as the business exists. A request to come into an account, and the answer to it, is the evidence of who allowed what, and it is worth no less in three years than it is today. |
| What our staff did inside your account | So that if you ask what we looked at, there is a truthful answer rather than a reassurance. Every request a member of our staff makes while working inside your account is recorded: who they are, what they were looking at or changing, and whether it was allowed or refused. We deliberately do not record the contents of what they saw. | Our legitimate interest in holding our own staff to account, which we believe is plainly in your interest too. | Kept permanently, on purpose. An audit trail that expires is not much of an audit trail. |
If you are a customer of a business that uses Bottle
Your supplier is the controller for everything in this table and we are the processor, which means they decide why it is held and we act on their instructions. It is listed here so you can see exactly what the software holds about you.
| What is held | What it is for | Who decides | How long it is kept |
|---|---|---|---|
| Who you are and how to reach you | Taking your orders, delivering to you and invoicing you. This is your name or trading name, your legal name where it differs, your email address and phone number, whether you are a household or a business, your payment terms, and any notes your supplier has typed about you. | Your supplier. We hold it on their instructions and do not use it for our own purposes. | Your supplier sets this, between one and seven years after your last order, and it is seven unless they change it. They can also erase you at any time on request. Even then, your name and address stay on any invoice issued to you inside the last six years, because a VAT invoice has to show who it was issued to and tax law requires your supplier to keep it. Everything outside those invoices is removed. |
| Where you are, and how to get in | So the driver can find you and leave the gas where you asked. This is your delivery address and postcode, the map coordinates worked out from that postcode, or from the middle of its postcode district when the postcode can't be found, and where your supplier has placed one, a pin marking the exact spot the van should pull up, which is often more precise than the postcode. It also covers delivery notes, which in practice hold things like a gate code, which door to use and who to ask for, and where you have asked for cylinders to be left when you are out, whether they go to a safe place or to a named neighbour. | Your supplier. We hold it on their instructions and do not use it for our own purposes. | Your supplier's setting, up to seven years after your last order. If you ask to be erased, the address held for delivering to you is removed, but an address printed on an invoice issued inside the last six years stays on that invoice, because tax law requires your supplier to keep it as issued. Erasing you also removes the map coordinates worked out from your postcode and any pin placed by hand. |
| What you ordered and what you paid | Fulfilling your order, invoicing you, chasing late payment and keeping the accounts straight. This is your orders and what was on them, your invoices including the name and address printed on them, what you paid and how, and anything still owed. Each order also carries a tracking reference, which is the key to the page showing where the van is. If you paid by card, those details were typed on Stripe's own pages and are held by Stripe, not by us. | Your supplier. We hold it on their instructions and do not use it for our own purposes. | Six years, because tax rules require it. An invoice inside six years keeps the name and address printed on it even if you ask to be erased, because a VAT invoice has to show who it was issued to. Older ones are deleted outright. |
| Proof that the gas arrived | Settling whether a delivery actually happened, which otherwise comes down to one person's word against another's. If someone signed, the signature itself as an image and the name they wrote, which is often not the account holder but whoever was there. If cylinders were left without a signature, a photograph taken at the door showing where they were put, which can include the house and the street, and whatever the driver typed about it. Each proof has a private link so the customer can see their own photograph without signing in. | Your supplier. We hold it on their instructions and do not use it for our own purposes. | Two years, after which the signature or photograph, the name of whoever signed and the driver's note are destroyed, leaving only the fact that the delivery was proved. Asking to be erased destroys them straight away and stops the private link working. A proof also goes entirely when the order behind it is deleted at six years. |
| When a delivery did not happen | So your supplier knows what happened and can try again or talk to you about it. This records that the drop failed, the reason chosen from a short list that includes nobody being in and the delivery being refused, any note the driver typed in their own words, and the date and time. | Your supplier. We hold it on their instructions and do not use it for our own purposes. | Two years, after which the position of the door and the driver's note are removed, leaving the fact that the drop failed and the reason. Asking to be erased removes them straight away. |
If you message a business on WhatsApp
A business can connect its WhatsApp Business number to Bottle. Bottle then reads the messages sent to that number, writes them up as orders, replies from the business's number and answers questions about your account. The business is the controller for everything in this table and we are the processor. This covers anybody who messages the number, whether or not they are already a customer of the business.
| What is held | What it is for | Who decides | How long it is kept |
|---|---|---|---|
| Your WhatsApp number and name | Knowing who wrote. Bottle matches your number against the phone numbers the business holds for its customers and their contacts. The name is the one you chose for your WhatsApp profile. | The business you messaged. We hold it on their instructions and do not use it for our own purposes. | 90 days after your last message, then deleted. |
| Your messages | Taking your order and answering you. This is the text of your messages and of the replies sent to you, by Bottle or by somebody at the business, with an English translation of any message in another language and the buttons you pressed. Voice notes, photos and other files are not kept: Bottle records only that one was sent. | The business you messaged. We hold it on their instructions and do not use it for our own purposes. | 90 days, then deleted. |
| What Bottle read from them | So the business can check Bottle's work. This is a short summary of the conversation, the products and quantities Bottle read, the delivery address and day it chose, whether you said yes to the order, and anything it was unsure of. | The business you messaged. We hold it on their instructions and do not use it for our own purposes. | 90 days after your last message, then deleted. An order made from your messages is kept as orders are. |
| Your account details, when you ask | Answering a question about your own account. If you ask about a delivery, an order, your cylinders, an invoice or your balance, Bottle looks it up and can send you a copy of an invoice. It looks only at the customer records that hold the number you wrote from. That check is made by Bottle's own code on every lookup, not left to the AI, so a message from one number never reaches another customer's records. Where more than one customer has your number, Bottle asks you to confirm your delivery address rather than telling you one. | The business you messaged. We hold it on their instructions and do not use it for our own purposes. | 90 days, then deleted. |
Your messages reach Bottle through Meta's WhatsApp service, and Bottle's replies go back the same way. What WhatsApp itself does with them is covered by WhatsApp's own privacy policy. To read your messages and write replies, Bottle sends them to Anthropic, as described under Optional AI features.
Getting your messages deleted. Ask the business you messaged. They can delete your messages in Bottle straight away. If you would rather, email compliance@getbottle.app with the number you wrote from and the business you messaged, and we will pass your request to them. This does not delete the messages on your phone or on the business's phone.
What the business connects. To connect its number, an owner signs in to Meta in a Meta window. Bottle keeps the business's WhatsApp number, the business name Meta has verified, Meta's references for the number and its account, and the access Meta gives Bottle to send from the number, encrypted. These are deleted when the business disconnects WhatsApp.
If you work for one of their suppliers
A business that uses Bottle can keep a list of the people it deals with at its own suppliers. That business is the controller for these details and we are the processor.
| What is held | What it is for | Who decides | How long it is kept |
|---|---|---|---|
| Who you are and how to reach you | So the business knows who to call about an order, a delivery or an invoice. This is your name, your job, your phone number and email address, any note the business has typed, and whether you are its main, billing, orders or deliveries contact. | The business that added you. We hold it on their instructions and do not use it for our own purposes. | Until the business removes you, which deletes your details straight away. To be removed, ask the business that added you. |
If you drive for a business that uses Bottle
Your employer is the controller for everything in this table and we are the processor, which means they decide why it is held and we act on their instructions. This is the fullest list we can give you, because you have the most at stake in it and the least say over it.
| What is held | What it is for | Who decides | How long it is kept |
|---|---|---|---|
| Where the van is | Telling the office and the waiting customer when to expect the van. While a round is out the app reports the van's position at least once a minute, and each report replaces the one before it, so there is never a trail of where the van has been, only where it is now. Your employer's office staff see that position next to your name. Customers waiting for a delivery see a van on a map and are never shown who is driving it. Each report is also used to work out when you arrived at and left each stop. Only those times and how close the van was are kept from that, and never the position itself: see How your day went. | Your employer. We hold it on their instructions and do not use it for our own purposes. | Shown on maps for twenty minutes, then hidden. The last reported position stays on the record of that round and is removed after two years, with the rest of the round history. |
| How your day went | Planning rounds, telling customers when to expect a delivery, and working out how long a round really takes. This is the round you were given, the van you took, when it was issued, when you confirmed the load and when you set off, and for every drop its location and the exact minute you completed or failed it. Where the software planned a route, the line it drew along the roads is kept too. Taken together this is a record of where you were and when, to the minute, for every day you have worked with Bottle. Bottle also keeps a record of changes made to a round and of what happened at each stop, so that round planning can learn from what people change, where a business has turned that on. It says when each change happened and who made it: a person, an API key, a connected app or Bottle itself. It covers a round being made, planned, given to another driver or vehicle, given a new date, departure time, start or end location, yard or delivery window, issued, taken back or deleted, and a stop being added, moved, reordered, put on another day, completed, failed or undone, with any reason picked from the list in the app. It holds reference numbers, dates, times and those reasons, and never a name, note or address. Bottle also keeps a copy of each round as the software proposed it, as it was issued to you and as it really went, with the order you did the stops in and any stops added on the day, and why the software left an order waiting when it planned the day. These copies hold reference numbers, dates, times and fixed reasons, and never a name, note, address or map position. From the location the app already shares while the round is out, Bottle works out when you arrived at and left each stop, and how close the van was when it arrived. It keeps those times and that distance, and not the positions. They are there so that planned stop times can be made more accurate. Each night Bottle also works out from your arrival and leaving times how long you usually spend at a delivery, for each business you drive for. It records how much that varies and how many stops it is based on, and gives a time only once it has 30 stops. Each business's figure is worked out only from its own rounds, and round planning uses it. It is not shown as a figure about you. | Your employer. We hold it on their instructions. Bottle also holds it to improve your employer's own round planning, including how accurate its planned stop times are, and uses it for nothing else. | Two years. After that the line drawn along the roads, where the van last was, and the position of each door you called at are all removed, leaving the round itself as your employer's record of the day. This is the most detailed thing Bottle holds about you, which is why it has the shorter clock rather than the six years the money needs. Each entry in the record of changes is deleted two years after the change. Each copy of a round, and each reason an order was left waiting, is deleted two years after it was saved. Each arrival and leaving time is deleted two years after the arrival. Your time per delivery stays until none of those times are left, or ninety days if it stops being worked out, and is deleted when you close your account. |
| Bottle's day plans | When your employer has Bottle work out a day's plan to check before using it. A plan names you by your account number, with the vehicle, your departure time, the orders in delivery order and the weight you would carry. A plan can give you two loads in a day, if both fit within your shift on the rota. With no shift that day, you get no second load. Bottle also keeps a working copy while it plans. For a plan nobody sees, it first works out what the day would look like if nobody had planned it, and keeps that only until the plan is finished. None of this changes a round unless somebody chooses to use the plan. Plans are kept so that they can be measured against what really happened across the seasons, for that business only. | Your employer. We hold it on their instructions and do not use it for our own purposes. | The working copy is deleted 14 days after the day it planned, and the plan after two years. Erasing a customer or a person at the business deletes the plans that include them and all of that business's working copies straight away. Bottle also keeps the counts from comparing each plan with what was sent, and a record of each time Bottle works out a day's plan, for as long as the business uses Bottle. These hold no names and no orders. |
| Money you handled | Knowing how much cash is in which van and settling it when it comes back to the yard. This is each amount you took, whose door you took it at and when, then the amount you handed in, who counted it and whether they agreed with your figure. Where they did not agree, the disagreement is recorded with whatever either of you typed about it, naming both of you. | Your employer. We hold it on their instructions and do not use it for our own purposes. | Six years, including any disagreement. These are part of your employer's accounting records, which tax law requires them to keep for that long, so a shorter period is not open to them. Money nobody has counted in yet is left alone whatever its age, because it is still owed. |
| Your time off, including sickness | Running the rota, knowing who is available and tracking allowances. Each period of time off is recorded as holiday, sickness or other, with dates down to the half day, who asked, who approved or refused it and when. Each request has a free-text note, so whatever your employer types there is held too. Your holiday allowance and paid sick day allowance are held against your name, and the rota shows how many sick days you have taken this year. Recording that a named person was off sick is health information, which the law treats more carefully than ordinary personal data: your employer relies on the exemption that allows this for managing staff. Inside your employer's business, the people who run the rota, meaning owners and administrators, can see that a day off was sickness rather than holiday. Other drivers cannot: the software shows you your own month and nobody else's. | Your employer. We hold it on their instructions and do not use it for our own purposes. | Kept for as long as you work for the business, because an allowance and what has been taken from it only make sense together, and because your employer may need to show what leave was given. Ask your employer, who decides this, if you want it removed sooner. |
| Your phone and your account | Signing you in, letting the office know who is driving, and getting notifications about your round to your handset. This is your name, email address and role at the business, and for the driver app the code Apple or Google gives us to reach your handset, which platform and app version you are on, and when the app was last used. | Your employer decides your account and role. The code identifying your handset is removed by us when you sign out. | The code for your handset is removed when you sign out, or when Apple or Google tell us the handset has gone. Closing an account removes them too. |
| Your home address, where a round starts or ends there | Planning a round that begins or finishes somewhere other than the yard. Where you take the van home, the address is saved as a place a round can start or end, with its postcode and map coordinates, the same as any other location. | Your employer. We hold it on their instructions and do not use it for our own purposes. | Until your employer removes that location. It is not deleted automatically. |
If you have only visited this website
We are the controller for everything in this table, and it is much smaller than the rest of the page.
| What we hold | Why we hold it | Lawful basis | How long we keep it |
|---|---|---|---|
| The register-interest form | To contact you about Bottle: early access, launch news and the occasional question about what we should build. We do not sell, rent or pass your details to anyone else for their own marketing. This is your name, business name and email address, your phone number if you give it, how many vans you run, what you use today and how you sell online if you tell us, anything typed into the box asking what takes up most of your time, and where you came from if your browser says, such as a referring site or campaign tag. If you send the form from a chat with Rosie, the conversation goes with it, so the person who gets in touch knows what you asked. | Your consent, given by sending the form. You can withdraw it at any time by emailing us and we will delete your record. | Until Bottle launches and you either become a customer or tell us you are not interested, or twenty-four months from when you sent the form, whichever comes first. |
| Chats with Rosie, the sales assistant | To answer your questions about Bottle, and so the team can see what you asked if you register interest. Rosie is an AI assistant: how your messages reach the model is explained under optional AI features. We keep your messages and Rosie's answers, the guides she linked to, the page you asked from and when. To stop the chat being misused, we also keep a one-way scramble of the address your browser connected from, which cannot be turned back into the address, and your browser's own description of itself. If you ask for a copy, we email the conversation to the address you give and use that address for nothing else. Rosie cannot see anything held in Bottle for a business, so please do not share card or bank details with her. | Our legitimate interest in answering questions you chose to ask us, and in keeping the chat free of misuse. | Two years after the last message, then deleted. A conversation sent with the register-interest form is kept with the form, for as long as the form is. |
| A scramble of your address, to spot duplicates | To notice the same form being sent repeatedly or automatically. We keep a one-way scramble of the address your browser connected from, which cannot be turned back into the address, together with your browser's own description of itself. We do not store the address itself. | Our legitimate interest in keeping the form usable and free of automated submissions. | Alongside the form submission it belongs to, and deleted with it. |
| Visits to this website | To know which pages are useful and how people found them. Each page you open sends the page's address, the site or link that brought you here, your screen size, your browser and device type, and roughly where you are (country, region and town), worked out from your connection. Umami, on our own server, does this without keeping your internet address; Cloudflare Web Analytics does the same from Cloudflare's network. Neither sets a cookie, stores anything in your browser or follows you to other websites. | Our legitimate interest in understanding how this website is used, in figures that do not identify you. | Umami keeps the figures on our server until we delete them. Cloudflare keeps full detail for seven days and a sample after that. |
| How the office uses Bottle | To see which parts of Bottle people use, where they get stuck and what to improve. When somebody signed in to the office side of Bottle opens a page, we record the page, when, their browser and device, and roughly where they are, against their name, email address and business. Search terms, customer names and record numbers are removed from what is recorded. It is kept on our own server, set nothing in the browser, and is never shared or used for advertising. Drivers, customers and anybody using the driver apps are not recorded. | Our legitimate interest in understanding how Bottle is used so we can make it better, and in being able to help a particular person who has had a problem. | 12 months, then deleted. |
| Recordings of visits to this website | To see where pages confuse people. For some visits, Umami records how the page was used: the page, where the pointer moved, what was clicked and how far you scrolled, with the page's own text. Anything typed into a field is hidden, and the register-interest form is left out completely. Recordings are kept on our own server, are not shared with anyone, and set nothing in your browser. | Our legitimate interest in making this website easier to use. | Recordings for 30 days, and the click and scroll maps built from them for 90 days, then deleted. |
| Cookies on this website | None. This website sets no cookies at all, records no sessions and carries no advertising or chat widget. The typefaces are served from this website rather than from another company, so reading these pages tells nobody else that you were here. | Not applicable, because nothing is stored on your device. | Not applicable, because nothing is stored on your device. |
| Cookies in the Bottle platform | A cookie that keeps you signed in, which is what makes signing in work at all, and a small one remembering whether you chose the light or dark appearance. There are no advertising or analytics cookies. When a map is on screen, your browser fetches the map tiles from OpenFreeMap, who see the address your browser is connecting from and roughly which part of the country is displayed, and nothing else about you. | Strictly necessary for a service you asked for, in the case of the sign-in cookie. Your choice, in the case of the appearance cookie. | The sign-in cookie lasts until it expires or you sign out. The appearance cookie stays on your device until you clear it. |
Notifications sent to phones
When Bottle sends a notification to a phone, it travels through Apple's or Google's notification service, because that is the only way to reach a handset. Those notifications can contain a customer's name, an order or invoice reference and an amount, together with staff names and short notes typed by people at the business. They never contain a customer's address, phone number or email address, and never any payment details. Customers of a distributor never receive notifications from Bottle on their phones at all: notifications go only to people who work at the business and have signed in.
How long we keep things
This section says what happens today, not what we would like to happen. Where something is kept until an event rather than for a set time, it says which event.
Fixed periods
- Emails we sent on your behalf. The full text of every email the software sends, including invoices, is kept for one year and then deleted, so the office can answer whether a customer was actually emailed and what it said.
- Addresses that cannot receive our email. If an email the software sends is refused for good by the receiving server, or the person who gets it marks it as spam, the address goes on a list of addresses not to write to, with the reason and the date. It is kept for as long as Bottle runs, because its whole job is to stop the same address being emailed again. No name or other personal details are kept with it.
- Repeat-request records. When the software guards against the same request being sent twice, it keeps the response for seven days and then deletes it.
- Questions Bottle asks. Where a business has turned on Bottle learning how it plans, a question Bottle asks the owner, and the answer, is kept for one year and then deleted. Answers are fixed choices, such as yes or no.
- Chats with Rosie on this website. Two years after the last message, then deleted.
- WhatsApp messages. 90 days, then deleted.
- Register-interest submissions. Until Bottle launches and you either become a customer or tell us you are not interested, or twenty-four months from when you sent the form, whichever comes first.
- Invoices and orders. Six years, because that is what the tax rules require.
- Proof of delivery. Two years, after which the signature or photograph, the name of whoever signed and the driver's note are destroyed. What is left is the fact that the delivery was proved.
- Round history. Two years, after which the route line, the last reported van position and the position of each drop are removed. The round itself stays as the business's record of the day. Closing an account takes that account off its rounds.
- Changes to rounds. Two years from each change, then deleted. This is the record of who changed a round and what happened at each stop. It points to whoever made the change, including office staff and any member of our staff working inside the account. It stays if the round itself is deleted. It holds no name, note or address, so erasing a customer does not alter it. Closing an account takes that account off these records.
- Copies of rounds, and why orders were left waiting. Two years from when each was saved, then deleted. A copy shows a round as the software proposed it, as it was issued and as it really went. It names the driver by their account, and holds no name, note, address or map position, so erasing a customer does not alter it. Closing an account takes that account off these copies.
- Arrival and leaving times at stops. Two years from the arrival, then deleted. They are worked out from the location the app shares while a round is out. They name the driver by their account, and hold times, how close the van was, and whether the stop's location is exact or only known by its postcode, and never a position. Closing an account takes that account off these times.
- A driver's time per delivery. Worked out again each night from the arrival and leaving times still held. It stays until none of those times are left, or ninety days if it stops being worked out, and is deleted when the driver closes their account. Their stops still count towards the business's own figure, which names nobody.
- A customer's usual driver. Worked out again each night from the last twelve months of deliveries on finished rounds, so that the business's round planning can give a customer the driver they know. It names the driver by their account and holds how many days they delivered. It stays until those deliveries no longer count, or ninety days if it stops being worked out. It is deleted when the driver closes their account or the customer is erased. Bottle then stops working it out for that driver or that customer.
- A driver's usual order of customers. Worked out again each night from the last twelve months of finished rounds, from when each stop was finished, so that the business's round planning can arrange a driver's stops in the order they usually do them. For each business the driver works for, it names the driver by their account and holds which customers they usually serve in that order, and on how many days. It stays until those stops no longer count, or ninety days if it stops being worked out. It is deleted when the driver closes their account, and a customer comes out of it when they are erased. Bottle then stops working it out for that driver and leaves that customer out.
- A driver's usual door sales. Worked out again each night from the last three months of finished rounds, so that the business's round planning can keep room on a driver's round for the sales they usually make. For each business the driver works for, it names the driver by their account and holds how many sales they usually make on a round, how many cylinders of each kind, how long a sale takes, and how many rounds that came from. It names no customer. It stays until those rounds no longer count, or ninety days if it stops being worked out. It is deleted when the driver closes their account, and Bottle then stops working it out for them. A round also keeps the room planned for it, with no name of its own, for as long as the round is kept.
- What Bottle learns about a business. Kept while it is still useful. Once Bottle stops using something it learned, it is deleted after one year, along with where it came from. Where something it still uses came from is deleted after two years, and the record of which plans used it after one year. If the owner marks something as wrong, Bottle keeps it so that it is not learned again, until the owner undoes that or the customer or person is erased. A year after that, only the thing itself is left, without where it came from or which plans used it.
- Notifications inside the software. Ninety days, then deleted. They quote customer names and round details, and nobody reads a three-month-old notice.
- Expired sessions. Thirty days after the session expires, then deleted, along with the address you signed in from and the browser you used. A session still in use is left alone however old it is, because ending it would be a sign-out you did not ask for.
- Cash records. Six years, following the tax rules, including any disagreement about a handover. Money nobody has counted in yet is left alone whatever its age, because it is still owed.
Things we keep until something happens rather than for a set time
These have no clock, and each one has a reason.
- Time off, including sickness, for as long as somebody works for the business. An allowance and what has been taken from it only make sense together.
- Invitations, and API keys that have been revoked, so the history of who was invited and who revoked what still makes sense.
- Requests from our staff to come into an account, and the answers to them, for as long as the business exists. They are the evidence of who allowed what.
- The log of what our own staff did inside an account, kept permanently on purpose, because an audit trail that expires is not much of an audit trail.
- The record that an erasure happened, kept permanently and deliberately without the name of the person erased.
Closing your account
You can close your own account from your settings, and you have to enter your password first. Closing it removes your sessions, your stored password, your two-step sign-in secret and backup codes, any connected apps, and your membership of every business. Your name becomes "Closed account" and your email address is replaced with one that cannot receive mail.
If you paid us for Bottle, closing your account does not remove the record of what you paid. We have to keep records of money we were paid for six years from the end of the accounting period, which in practice means up to seven years, and we cannot waive that because it is a duty to HMRC rather than a preference of ours. Those invoices are held by Stripe, who bill on our behalf, and they carry the name, email address and billing address given at the time.
The account record itself stays, so that things other people did still make sense: an invitation you sent still shows who sent it, and cash you carried still shows who held it. Closing your account takes it off rounds you drove, your times at stops, copies of rounds you drove and the record of changes to rounds, and deletes the time per delivery worked out from your stops, your usual order of customers, your usual door sales and any customer's usual driver that names you. Those rounds stay with the business with no driver on them. It also deletes the driver details each business keeps about you: the name it uses for you, your licence details, your home address, your usual vehicle, and your hours and holiday settings. A home address saved as a place a round can start or end is a separate record, and stays until your employer removes it. If you are the last owner of a business, we will not let you close your account until somebody else owns it, because otherwise the business would be left with nobody able to get in.
Retention settings, and what erasing actually does
This section is for two different readers. If you run a gas or fuel business on Bottle, it is the part your own customers will ask you about, so it is written so you can answer them. If you are one of those customers, it explains what your supplier controls and what they do not.
What the business controls
Each business using Bottle sets its own rule for how long a customer who has stopped ordering is kept. There are three settings.
- Whether the sweep runs at all. It can be switched off, in which case nothing is erased automatically and records stay until somebody erases them by hand.
- How many years of no orders before a record is erased. This can be set anywhere from one year to seven years. Seven is the default and it is also the maximum: it cannot be set higher. The reason is that HMRC requires six years of records, so seven years clears that obligation with a year to spare, and keeping customer details for longer than that needs a better reason than habit.
- How much warning before it happens. Thirty days by default. The business is emailed once, before anything is erased, so somebody can step in if a record should stay.
Which date the clock runs from
The clock runs from the customer's last order. Where a customer record exists but has never had an order against it, the clock runs from the day the record was created instead. An account somebody opened and never used is still somebody's name, address and phone number, and leaving it out of the sweep would mean it stayed for ever.
Freezing a record
Any customer record can be put on legal hold, which freezes it against both the automatic sweep and the manual erase button. It still appears on the list of records that are due, marked as held, so it is not forgotten. This is what you would use during a dispute, an insurance claim or an investigation, where deleting the record would destroy something you may be required to produce.
An honest word about the default
The settings for a business are created the first time somebody opens the retention page. A business that has never looked at it is therefore running on seven years and thirty days' notice. That is a deliberate choice of default rather than an accident, but we are not going to describe it as a decision the business made, because they have not made it yet.
What erasing a customer actually does
A business can erase a customer at any time, either because the retention sweep has reached them or because the customer has asked. This is what happens.
- Orders and invoices older than six years are deleted outright, along with everything hanging off them.
- Invoices inside six years are kept whole, including the name and address printed on them. A VAT invoice has to show who it was issued to, so an invoice that has been altered is no longer a valid record. This is a legal obligation on the business, and it is the usual reason a customer cannot be removed from the accounts entirely.
- Orders inside six years keep their money but lose their personal detail. The name, address and notes on the order are removed, while the amounts stay so the books still balance.
- The customer record itself is either deleted or blanked. If nothing is left inside the six-year window, the customer, their addresses and their agreed prices are deleted completely. If something is left, the record stays but is emptied: the name is replaced with a note saying it was erased at the customer's request, and the email address, phone number and notes are removed.
- Map coordinates go with the address. The point worked out from the postcode is removed, and so is any pin somebody placed by hand to mark where the van should pull up. A coordinate identifies a house at least as precisely as the address beside it, so leaving it behind would be an erasure in name only. The position copied onto each delivery stop goes the same way.
- Signatures and doorstep photographs are destroyed. The record that a delivery was proved stays, because that belongs to the order, but the image, the name of whoever signed and the driver's note are removed, and the private link that was emailed for it stops working.
- WhatsApp messages are deleted.
- A record of the erasure is kept. It says that an erasure happened, when, why and how much was removed. It deliberately does not contain the name of the person erased, because a list of everyone who has asked to be forgotten would defeat the point.
Backups
We back up the Bottle database and the files uploaded to it, such as signatures and delivery photographs, so that a fault or a mistake cannot lose anybody's records. Backups are encrypted, held in the United Kingdom, used only to recover from a failure and deleted automatically after 90 days. Nobody looks through them, and they are not used for anything else.
Backups and erasure. When somebody is erased, or their details reach the end of their retention period, they are removed from Bottle straight away. Backups taken before then are left to expire, so within 90 days no backup holds them. If we ever have to restore from a backup, every erasure made since that backup was taken is carried out again before Bottle is back in use, so nobody who has been erased comes back.
Customers can read more about how we protect their data in our trust centre.
Who else sees it
We use a small number of other companies to run Bottle: to bill you, to send email, to send and receive WhatsApp messages for businesses that connect a number, to deliver notifications to phones, to look up postcodes, to host the software and to provide optional AI features. Every one of them is named on our third parties page, along with what reaches them and which country they are in. If a company is not on that page, it does not handle your data.
If we ever take on a new company that will handle personal data on your behalf, we will tell customers at least thirty days beforehand, so there is time to object or to leave.
A business can also use a delivery partner, another company it chooses to deliver some of its orders. When the business sends that partner a day's list, or downloads it to pass on, the list holds the order reference, contact name, address, postcode, phone, products, delivery notes and delivery date for those orders. It has no prices or payment details. The business decides this and answers for it, and the partner is not one of our suppliers.
We record on each order when it was sent or downloaded, how and by whom, with a scrambled fingerprint of those details so that an edit since can be noticed. We do not keep a copy of the file. Our record of the email holds the references of any orders taken off the list, and no names or addresses. Erasing a customer clears the fingerprints, and leaves nothing about them in our record of what was sent apart from those references, which are no longer linked to any name.
Erasing a customer cannot recall a list already sent. The partner holds its own copy, and we cannot reach it. Ask the business to ask the partner to delete it. A customer's export shows which partner had each order.
We do not sell personal data, and we do not share it for anyone else's marketing. We would disclose data if the law required it of us, for example under a court order, and we would tell the affected customer unless we were forbidden from doing so.
Optional AI features
Who runs the AI. Bottle's AI models are run by Anthropic, through its API. What we send for each feature below goes to Anthropic, which processes it in the United States. Anthropic says it deletes API inputs and outputs within 30 days, and keeps them for up to 2 years if its automated checks flag them as breaking its Usage Policy, with classification scores for up to 7 years, and longer where the law requires. Its commercial terms say it may not train models on this content. Its data processing addendum is part of those terms and applies the EU Standard Contractual Clauses and the UK Addendum to them. Help-guide embeddings are generated by Amazon Web Services in Ireland, from help-guide text and not from account records. The details are on our third parties page.
Flame AI. To answer your question, we send it and relevant conversation and help-guide text to Anthropic. We also send useful context such as your role and the page you are viewing. When your business allows account reads, the assistant can look up information you are permitted to see, such as products, customer records, orders and rounds. This can include personal details needed to answer you. It cannot change your records. Owners and administrators can turn business-data access off in Business Settings; it is on by default. Your questions still reach the model when you use the chat, so do not include information you do not want it to process.
Questions, answers and guide references are stored on Bottle's servers and deleted after 30 days without activity. You can delete a conversation sooner from Recent chats. Raw account lookup results are used for the current request and are not stored separately in the conversation or added to the shared help-guide index; any facts quoted in the answer remain part of that answer. Lookup metadata is kept for 30 days without the raw records, arguments or credentials.
Rosie, the sales assistant on this website. To answer you, we send your message, the earlier messages in the same chat, the page you asked from and relevant help-guide text to Anthropic. Rosie answers from our help guides only. She has no access to any business's data in Bottle, and she cannot agree prices or send anything on your behalf.
WhatsApp orders. When a business connects its WhatsApp number, Bottle sends Anthropic the messages in each conversation, the business's products and prices, and the names and delivery addresses of the customers whose records hold the number that wrote. When the customer asks about their account, Bottle also sends what it looked up for them: their deliveries, orders, cylinders, invoices or balance. Bottle's own code picks the customer records from the number before anything is looked up, so the AI cannot ask for anybody else's. A business can turn off answering questions in its WhatsApp settings. Messages reach Bottle through Meta, which runs WhatsApp; see our third parties page.
Bottle's day plans. When Bottle works out a day's plan, parts of the decision go to Anthropic. We send only figures and fixed codes, such as an order's weight, the stops on a round and the driving time. We do not send names, addresses, notes or record identifiers. The figures can still relate to one driver's round when read with Bottle's own records. Bottle checks each plan against its rules, and a plan changes nothing unless somebody at the business chooses to use it.
What Bottle learns about a business. When this is turned on for a business, Bottle learns from what happens on its rounds, such as moves the office makes and how deliveries went, and from what the owner tells it, to make its plans better. It can hold a fact it has worked out, such as a weekday a customer is usually out, or the driver a customer usually has, along with where that came from and which plans used it. This can name a customer or a driver. It is about jobs and places. Bottle does not score or rank drivers. Code works this out, without an AI model. It is off unless turned on, and each business's learning stays with that business. It can also hold a driver's usual time at a stop, for planning only. Nobody sees that as a figure about the driver, the owner included. The driver can see it in their account export, and it is deleted when they close their account. Only the owner can open what Bottle has learned. Apart from that time, they can see all of it, reword or delete what they told it, and mark anything Bottle worked out as wrong, so that plans stop using it and it is not learned again. When something changes overnight the owner gets an email and a notification, which they can turn off. Erasing a customer or a person removes what names them and what was worked out only from them.
What the owner tells Bottle. When learning is on, the owner can tell Bottle something or answer a few questions about how they plan. Bottle first finds the customers, addresses, drivers, vehicles and areas that plausibly match the words they typed. We send Anthropic the text they type with only those names and reference numbers, so that it can work out who and what the owner means. That can include someone with a similar name who the owner did not mean. We send only what matching needs: no address beyond its name, no contact details, notes or order history. Bottle holds back sentences with contact details or facts about a person that it recognises, but this is a pattern check and it can miss things. Bottle keeps nothing until the owner saves it, and what comes back cannot change a plan until the owner has confirmed it.
Other AI features. Product suggestions, website drafts and service-document reading send Anthropic the information relevant to that task. Documents and imported content can contain personal data.
AI can make mistakes.
Where it is held
The Bottle platform, including its database, runs with Amazon Web Services in London. Files uploaded to Bottle, such as signatures, doorstep and delivery-note photographs and invoice logos, are stored there too, apart from the database. They are private and encrypted, nobody reaches them except through Bottle, and location details are removed from photographs when they are uploaded. Our backups are held in London too, as described under Backups.
This website and the register-interest form behind it run on Cloudflare's network. We have not pinned that database to a particular country, so we cannot yet tell you which one it is in. We are finding out and this page will say so once we know.
AI model requests are processed by Anthropic in the United States, as described under Optional AI features. Some of the companies we use process data outside the United Kingdom under their own terms, and the third parties page says which.
Your rights
Under United Kingdom data protection law you can ask for a copy of the personal data held about you, ask for it to be corrected, ask for it to be deleted, ask for the handling of it to be restricted, object to it being handled, and ask for it in a portable form. Where we rely on your consent, you can withdraw it at any time.
Who to ask
- If you are a customer of a distributor, ask them, because the data is theirs and the decision is theirs. If you cannot reach them or you do not know who they are, write to us at compliance@getbottle.app and we will help you find the right person.
- If you drive for a business that uses Bottle, ask your employer for the same reason. We will help you work out who to write to.
- If Bottle is your own account, or you sent the form on this website, ask us directly at compliance@getbottle.app. We answer within one month, which is what the law allows us.
Getting a copy
A business using Bottle can export a customer's record from inside the software, and you can export your own account data from your settings. Your account export includes the changes you made to rounds, the rounds you were put on or taken off, copies of the rounds you drove, when you arrived at and left each stop, the time per delivery worked out from those times, the driver details each business keeps about you, including your licence details and home address, the customers you are named as usual driver for, your usual order of customers, your usual door sales and the rounds Bottle's day plans gave you, with the number of stops but not whose they are. It also includes the answers you gave to questions Bottle asked you, without the customer each was about.
The customer export holds their record, their addresses, their agreed prices and every order with its lines, along with their invoices, each delivery stop and what happened there, what was signed for at the door, cash taken at it, and the messages sent to them. It also shows the record of the days Bottle looked at to work out their usual driver: whether those days found one, how many days there were and when it last looked. It leaves out who the driver is, because that is a staff member's data. It also shows how many times they appear in drivers' usual orders and when that was worked out, leaving out the driver and the other customers. It also holds what Bottle's day plans said about their orders, leaving out the driver and the other stops. It also holds the questions Bottle asked about them and the answers, leaving out who answered. The account export holds the person, the businesses they belong to, their sessions and connected apps, their registered phones, their time off, cash they carried and what the bell has told them.
Two things are deliberately left out of a file, and neither is being withheld. A signature or a doorstep photograph is given as a link rather than pasted into the file, because an image inside a page of data helps nobody, and the link fetches the real thing. A phone's notification token and a password are not in there either: those are locks rather than contents, and handing them over would help somebody else more than the person asking.
Complaining
If you are unhappy with how your data has been handled, tell us first and we will try to put it right. You also have the right to complain to the Information Commissioner's Office, the United Kingdom's data protection regulator, and you do not have to come to us first. If your complaint is about a distributor rather than about us, the Information Commissioner's Office is still the right place, and your complaint is against them.
Children
Bottle is software for running a gas or fuel delivery business. It is not designed for children, not marketed to them, and we do not knowingly hold data about them. If you believe we hold a child's data, email compliance@getbottle.app and we will look into it.
Changes to this policy
We will keep this page current rather than writing it once and leaving it. When something changes that affects what we hold, why we hold it or how long we keep it, we will change this page and update the date at the bottom. Where the change is significant, such as taking on a new company that handles personal data, we will tell customers directly rather than relying on you to notice.
Sorteo Ltd, trading as Bottle. Registered in England and Wales, company number 16426798.
Registered office: 2nd Floor, 1 Church Square, Leighton Buzzard, Bedfordshire, LU7 1AE, United Kingdom.
Information Commissioner's Office registration number ZC296441.
Last updated 11 November 2026.