Privacy Policy

Smart Refill Privacy Policy

Effective: July 2026Updated: July 2026

Smart Refill ("Smart Refill", "we", "our", or "us"), operated by River Tech Inc., respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, store, process, disclose, and protect personal information through the Smart Refill platform, including its websites, mobile applications, software, and related services.

By using Smart Refill, you acknowledge that you have read and understood this Privacy Policy.

01

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
02

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
03

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.

05

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.

06

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.

07

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.

08

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.

09

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.

10

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.

11

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.

12

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.

13

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.

14

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.

15

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).

16

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.

17

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.

18

Contact Information

For general privacy-related inquiries, please contact:

River Tech Inc.

privacy@smartrefill.io
19

Data Protection Officer

For privacy concerns, requests, complaints, or inquiries regarding personal information processing, users may contact:

Data Protection Officer

River Tech Inc.

privacy@smartrefill.io
20

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.

21

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.

22

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.