Privacy Policy & Data Processing

(Philippines – RA 10173 Compliant)

At **Smart Refill**, we are committed to protecting your privacy and ensuring the security of your personal data. This document outlines our practices regarding data collection for website visitors, app users, and our formal Data Processing Agreement (DPA) for business clients.

River Tech Inc., doing business under the trade name Smart Refill, operates as both a **Controller** (for our own users) and a **Processor** (for the customers of our partner water stations).

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PART I: USER PRIVACY POLICY

This section applies to all visitors of our website and users of our mobile applications.

We collect information you provide directly (such as when you create an account) and information collected automatically through cookies and analytics tools like Google Analytics and our internal tool, DataForge.

Your data is used to provide, maintain, and improve our services, and to communicate with you about updates and promotions.

1. Information We Collect

We collect several types of information:

  • <strong>Account Data:</strong> Name, email, phone number, and business details.
  • <strong>Usage Data:</strong> IP address, browser type, pages visited, and time spent.
  • <strong>Transaction Data:</strong> Details of orders and services used on the platform.

2. How We Use Information

  • To operate and stabilize the Smart Refill platform.
  • To provide customer support and process transactions.
  • To analyze usage patterns using <strong>DataForge</strong> and improve AI features.
  • To send transactional messages (SMS/Email) regarding orders.

3. Data Sharing and Disclosure

We do not sell your personal data. We share information only with trusted service providers (e.g., Firebase, Google Cloud) and as required by law.

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PART II: DATA PROCESSING AGREEMENT (B2B)

This section governs the relationship between Smart Refill and Water Refilling Stations (WRS) regarding the processing of their customers’ data.

4. Definitions

“Controller” means the party who owns and decides the purpose of data processing (the refilling station or business using Smart Refill).

“Processor” means the party who processes data on behalf of the Controller (River Tech Inc., d/b/a Smart Refill).

5. Processor Obligations

  • Process Personal Data only in accordance with the Controller’s instructions.
  • Implement appropriate technical and physical security measures.
  • Notify the Controller within 72 hours of any data breach.
  • Assist the Controller in complying with RA 10173 obligations.

6. Security Measures

  • Encryption of data in transit and at rest.
  • Role-based access controls.
  • Regular security testing and vulnerability monitoring.
  • Daily backups with disaster recovery procedures.

7. Contact Us

For privacy inquiries or to reach our Data Protection Officer:

  • privacy@smartrefill.io
  • Company: River Tech Inc.
  • Address: BF Homes, 410 El Grande Ave, Parañaque, 1720 Metro Manila