Information We Collect
Smart Refill collects information from water station owners, employees, riders, customers, and other users who access or interact with the platform. Information may be collected directly from users, provided by water stations, generated through platform activity, or collected automatically through the use of our services.
Water Station Information
We may collect:
- Business name
- Business address
- Owner or authorized representative information
- Contact details
- Branch information
- Delivery service information
- Billing and subscription information
- Business permits and supporting documents where required
Customer Information
Water stations may upload, import, or manually enter customer records including:
- Full name
- Mobile number
- Email address
- Delivery address
- Order history
- Delivery preferences
- Account information
- Customer notes and service history
Direct Customer Information
Customer information may also be collected directly from customers who create accounts, place orders, submit inquiries, participate in promotions, provide feedback, communicate with a water station, or otherwise interact with Smart Refill-powered websites, mobile applications, and services. Such information may include:
- Full name
- Mobile number
- Email address
- Delivery address
- Order history
- Communication preferences
- Customer support interactions
- Other information voluntarily provided by the customer
Rider Information
We may collect:
- Name
- Contact details
- Assigned deliveries
- Delivery activity records
- Location information during delivery operations
Technical Information
We may automatically collect:
- Device information
- Browser information
- IP address
- Operating system information
- Application activity logs
- Usage analytics
- Cookies and tracking technologies
- Diagnostic and crash reports
How We Use Information
We use collected information to:
- Process water delivery orders
- Manage customer accounts
- Assign and monitor deliveries
- Provide customer support
- Improve platform performance
- Generate reports and analytics
- Process subscriptions and billing
- Send notifications and communications
- Prevent fraud, abuse, and unauthorized access
- Comply with legal and regulatory requirements
- Develop and improve Smart Refill products and services
Customer Data Imported by Water Stations
Water stations may import customer databases into Smart Refill.
By uploading, importing, or entering customer information into the platform, the water station represents and warrants that:
- It has lawful authority to provide such information.
- Appropriate consent, authorization, or lawful basis exists for processing such information.
- Customers have been informed as required by applicable laws.
- The upload complies with the Data Privacy Act of 2012 and other applicable laws and regulations.
River Tech Inc. acts as a technology provider and data processor for information uploaded by water stations.
Legal Basis for Processing
Where required by law, personal information may be processed on one or more of the following legal bases:
- Consent
- Contractual necessity
- Compliance with legal obligations
- Legitimate business interests
- Protection of lawful rights and interests
Data Sharing
We do not sell personal information.
Personal information may be shared with:
- Authorized water station personnel
- Assigned riders and delivery personnel
- Payment processors
- Cloud hosting providers
- SMS and email service providers
- Analytics and reporting providers
- Customer support providers
- Government authorities when legally required
- Professional advisers and auditors where necessary
Information is shared only to the extent reasonably necessary to provide services or comply with legal obligations.
Third-Party Services
Smart Refill may utilize third-party service providers to operate, maintain, and improve the platform, including but not limited to:
- Cloud hosting and infrastructure providers
- SMS and messaging providers
- Email delivery providers
- Payment processing providers
- Analytics providers
- Customer support tools
- Security and monitoring providers
These service providers may process personal information solely on behalf of River Tech Inc. and only to the extent necessary to provide Smart Refill services.
International Data Transfers
Some personal information may be stored, processed, or transferred outside the Philippines through third-party service providers and cloud infrastructure.
By using Smart Refill, users acknowledge and consent to such transfers, provided that River Tech Inc. implements reasonable and appropriate safeguards to protect personal information in accordance with applicable laws.
Rider Location Data
Smart Refill may collect and process location information from riders when location services are enabled and authorized.
Location information may be used to:
- Facilitate deliveries
- Assign deliveries
- Optimize routes
- Verify delivery completion
- Improve operational efficiency
- Provide delivery status updates
Location information is collected only when necessary for delivery-related functions.
SMS, Email, and Notifications
Smart Refill may send communications related to:
- Order confirmations
- Delivery updates
- Account activities
- Billing notices
- Subscription information
- Security alerts
- Service announcements
- Customer support matters
Users may opt out of non-essential marketing communications where permitted by law. Service-related notifications may continue to be sent as necessary for platform operation.
Data Controller and Data Processor Roles
For customer information uploaded, imported, or managed through Smart Refill:
- The water station acts as the Data Controller and remains responsible for obtaining any required consent, notices, permissions, or other lawful basis for collecting and processing customer information.
- River Tech Inc., through Smart Refill, acts as the Data Processor and processes personal information solely for the purpose of providing software, operational, and technology services.
Nothing in this Privacy Policy transfers ownership of customer information to River Tech Inc.
Customer Data Import Responsibility
By uploading, importing, or entering customer information into Smart Refill, the water station acknowledges and agrees that:
- The information was collected lawfully.
- Appropriate consent, authorization, or lawful basis exists.
- The information may be lawfully processed through Smart Refill.
- The upload complies with the Data Privacy Act of 2012 and other applicable laws.
The water station agrees to defend, indemnify, and hold harmless River Tech Inc., its officers, directors, employees, affiliates, and agents from claims, liabilities, penalties, damages, losses, or expenses arising from the unlawful collection, use, disclosure, upload, or processing of customer information by the water station.
Data Security
River Tech Inc. implements reasonable technical, organizational, and physical safeguards to protect personal information, including:
- Encrypted communications
- Access controls
- Authentication mechanisms
- Security monitoring
- Activity logging
- Backup procedures
- Disaster recovery measures
While we strive to protect personal information, no system can guarantee absolute security.
Data Breach Notification
In the event of a personal data breach that may affect personal information, River Tech Inc. will take appropriate measures in accordance with applicable laws, including notification to affected individuals and relevant authorities where legally required.
Data Retention
We retain personal information only for as long as necessary to:
- Provide services
- Fulfill contractual obligations
- Comply with legal requirements
- Resolve disputes
- Enforce agreements
- Protect legitimate business interests
When information is no longer required, it may be deleted, anonymized, or securely destroyed.
User Rights
Subject to applicable laws, users may request:
- Access to personal information
- Correction of inaccurate information
- Deletion of personal information
- Withdrawal of consent
- Restriction of processing
- Data portability where applicable
- Information regarding processing activities
Requests may be submitted through Smart Refill support channels or via our User Data Deletion page at /data-deletion (email privacy@smartrefill.io).
Children's Privacy
Smart Refill is intended for business users and individuals who are at least eighteen (18) years of age.
We do not knowingly collect personal information from children without appropriate consent or legal authorization. If we become aware that personal information has been collected in violation of applicable laws, we will take reasonable steps to remove such information.
Changes to This Privacy Policy
River Tech Inc. may modify or update this Privacy Policy at any time.
Changes will be posted through Smart Refill websites, applications, or official communication channels. Continued use of Smart Refill after publication of updates constitutes acceptance of the revised Privacy Policy.
Contact Information
For general privacy-related inquiries, please contact:
River Tech Inc.
privacy@smartrefill.ioData Protection Officer
For privacy concerns, requests, complaints, or inquiries regarding personal information processing, users may contact:
Ownership and Control of Customer Data
Customer information uploaded, entered, imported, or generated through the use of Smart Refill remains the property of the respective water station and/or the customer to whom the information relates.
River Tech Inc. does not acquire ownership rights over customer information by virtue of providing the Smart Refill platform.
River Tech Inc. may access, process, store, transmit, backup, and otherwise handle customer information solely as necessary to:
- Provide Smart Refill services
- Maintain platform functionality
- Perform technical support and troubleshooting
- Protect platform security and integrity
- Comply with legal obligations
- Enforce contractual rights and obligations
Upon termination of services, River Tech Inc. may retain certain information as required by law, for security investigations, dispute resolution, backup recovery, regulatory compliance, or legitimate business purposes.
Account and Platform Security
Users are responsible for maintaining the confidentiality of their login credentials and for all activities occurring under their accounts.
Users agree to:
- Use strong passwords
- Restrict unauthorized access to their accounts
- Promptly notify River Tech Inc. of suspected unauthorized access
- Maintain accurate account information
River Tech Inc. shall not be responsible for losses resulting from a user's failure to safeguard account credentials.
Consent to Operational Communications
By creating an account, placing an order, submitting information, uploading customer records, or using Smart Refill services, users consent to receive communications related to:
- Order confirmations
- Delivery updates
- Customer support
- Account verification
- Billing and payment notices
- Security alerts
- Service-related announcements
- Platform maintenance notifications
These communications are considered essential to the operation of Smart Refill and may not be opted out of while maintaining an active account.
