1. Introduction to Epump

Epump is a comprehensive cloud-based forecourt automation solution designed for the Downstream Oil and Gas Sector, serving both Corporate Organizations and Independent Owners. It provides station owners with an overall view of their station's operations, including daily income and expenditures and facilitates efficient management through features such as:

• Remote Monitoring: Real-time oversight of station activities.
• Price Change: Efficient management of fuel pricing.
• Accurate Reports: Generation of precise operational and financial reports.
• Prompt Notifications: Timely alerts regarding critical events.
• Loyalty and Rewards: Programs to engage and retain customers.
• Strategic Proposition: Efficient planning, budgeting, and expensing, integrated with strategic expense points like fuel pumps, diesel delivery, and transportation.

Our value proposition is to put station owners and management in the helm of affairs of their stations, empowering them with data-driven insights.

2. Data Controller and Processor

Fuelmetrics Ltd. acts as the Data Controller for certain personal data collected directly through our website (e.g., contact information for inquiries).

For the operational and personal data processed through the Epump solution on behalf of our clients (fuel station owners), Fuelmetrics Ltd. acts as a Data Processor, while our clients act as the Data Controllers.

3. Data We Collect

We collect various types of data to provide and improve our Services.

3.1 Personal Data

Personal Data refers to any information that can be used to identify an individual. This may include:

• Contact Information: Name, email address, phone number, physical address (e.g., when a user signs up, requests support or provides details for loyalty programs).
• Account Information: Usernames, passwords and other credentials used to access Epump Services.
• Billing and Payment Information:Details necessary for processing payments for our services (e.g., debit/credit card details, bank account information).
• Communications: Records of your interactions with us, including customer support inquiries, feedback and survey responses.
• Loyalty and Rewards Data: If you opt into or use loyalty programs managed through Epump, we may collect customer names, contact details, transaction history and reward redemption details.
• Employee Data: (from Clients) Our clients may input data about their employees (e.g., shift managers, cashiers) for operational purposes, such as tracking performance or access control.

3.2 Operational and Non-Personal Data

This includes data generated through the use of the Epump platform, which may not directly identify an individual but is crucial for the service functionality.

• Transaction Data: Sales records, fuel pump readings, payment methods, product quantities, timestamps of transactions.
• Inventory Data: Fuel levels, stock movements, delivery records.
• Pricing Data: Current and historical fuel prices, price change logs.
• Financial Data: Income, expenditures, daily summaries, reconciliation data.
• System Usage Data: Logs of access to the platform, feature usage, error reports, performance metrics.
• Device and Network Information: IP address, browser type, operating system, device identifiers, referring URLs.
• Location Data: General location data derived from IP addresses or specific location data if enabled by the user/client for features like remote monitoring (e.g., geographical location of fuel stations).

4. How We Collect Data

We collect data through the following methods:

• Directly from You/Your Organization: When you register for an Epump account, configure your station's settings, input operational data, contact customer support, or participate in surveys.
• Automatically through the Epump Platform: As data is generated by your fuel station's operations (e.g., pump transactions, inventory updates, sensor data) and fed into the Epump system.
• Through Cookies and Tracking Technologies: When you interact with our website and the Epump platform (see Section 8 for more details).
• From Third Parties as authorized by clients: We may receive data from integrated third-party systems as authorized by our clients (e.g., payment gateways, accounting software).

5. How We Use Your Data

We use the collected data for the following purposes:

• To provide and maintain services:
  • To operate and deliver the core functionalities of Epump, including remote monitoring, price change management, accurate reporting and prompt notifications.
  • To facilitate planning, budgeting and expense tracking.
  • To integrate with strategic expense points (fuel pumps, diesel delivery, transportation).
  • To manage loyalty and rewards programs.
  • To process transactions and manage accounts.
  • To provide customer support and respond to inquiries.
• To improve and develop services:
  • To understand how users interact with Epump and identify areas for improvement.
  • To research and develop new features and functionalities.
  • To enhance the user experience and interface.
• For security and fraud prevention:
  • To protect the integrity and security of our systems and data.
  • To detect and prevent fraudulent activities, unauthorized access, and other malicious acts.
• For analytics and performance monitoring:
  • To monitor the performance and stability of our Services.
  • To conduct data analysis to understand trends and usage patterns.
• For legal and regulatory compliance:
  • To comply with applicable laws, regulations, and legal processes (e.g., tax, audit, data protection laws).
  • To enforce our terms of service and other agreements.
• For communication, including marketing (where consented):
  • To send service-related announcements, technical notices, security alerts, and administrative messages.
  • To provide marketing and promotional communications about Epump and Fuelmetrics products, where you have consented to receive them.

6. Data Sharing and Disclosure

• With your consent: We may share data with third parties when we have your explicit consent to do so.
• With our clients (Data Controllers): As a data processor, we share the operational and personal data collected through the Epump platform directly with our clients (the fuel station owners who are the data controllers) as part of the Service delivery.
• With service providers: We engage trusted third-party companies and individuals to perform services on our behalf (e.g., hosting, data analytics, payment processing, IT support, customer service). These service providers are granted access to your data only to perform their specific tasks and are contractually obligated to protect your data and use it only for the purposes for which it was disclosed.
• For legal reasons: We may disclose data if required by law or in response to valid requests by public authorities (e.g., a court order or government agency).
• Business transfers: In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your data may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal data.
• To protect our rights: We may disclose data when we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the physical safety of any person, or as evidence in litigation in which Fuelmetrics Ltd. is involved.
• With affiliates: We may share data with our parent company, subsidiaries, and other affiliates of Fuelmetrics Ltd. for purposes consistent with this Privacy Policy.

7. Data Security

We implement robust technical and organizational security measures to protect your data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption: Data is encrypted both in transit (using TLS/SSL) and at rest.
• Access controls: Strict access controls and authentication mechanisms are in place to limit access to data to authorized personnel only.
• Regular security audits: We conduct regular security assessments, vulnerability scans, and penetration testing to identify and address potential weaknesses.
• Employee training: Our employees receive regular training on data protection best practices and security protocols.
• Data minimization practices: We only collect and retain data that is necessary for the purposes outlined in this policy.
• Backup and recovery systems: Regular backups are performed to ensure data availability and rapid recovery in case of an incident.

Despite our best efforts, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security.

8. Cookies and Tracking Technologies

WWe use cookies and similar tracking technologies (like web beacons and pixels) on our website and within the Epump platform to collect information about your browsing activities.

• What are Cookies? Cookies are small text files placed on your device by websites that you visit. They are widely used to make websites work more efficiently and to provide information to the site owners.
• Analytical/Performance Cookies:
  • Essential Cookies: Necessary for the operation of our website and Epump platform, enabling core functionalities like secure login, navigation, and access to certain areas.
  • Analytical/Performance Cookies: Allow us to recognize and count the number of visitors and see how visitors move around our website when they are using it. This helps us to improve the way our website works.
  • Functional Cookies: Used to recognize you when you return to our website, enabling us to personalize our content for you, greet you by name, and remember your preferences.
• Your Choices: You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

9. Data Retention

We retain personal and operational data only for as long as necessary to fulfil the purposes for which it was collected, including for the purpose of satisfying any legal, accounting, or reporting requirements.

The retention period is determined by:

• Contractual Obligations: Data related to your Epump account and service usage will be retained for the duration of your contract with Fuelmetrics Ltd. and for a period thereafter as required for administrative, legal, or audit purposes.
• Legal Requirements: Certain data may be retained for longer periods to comply with applicable laws (e.g., tax laws, anti-money laundering regulations).
• Operational Needs: Data may be retained for business operations, service improvement, fraud prevention, and to resolve disputes.
• Data Minimization: Once data is no longer required, it will be securely deleted or anonymized.

10. International Data Transfers

As a global solution, data collected through Epump may be stored and processed in any country where Fuelmetrics Ltd. or its service providers operate. This means your data may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

When transferring data across international borders, we ensure that appropriate safeguards are in place to protect your data, such as:

• Utilizing Data Processing Agreements (DPAs) with standard contractual clauses approved by relevant authorities.
• Ensuring that the recipient country has been deemed to provide an adequate level of data protection by relevant authorities such as Nigeria's NITDA for transfers from Nigeria.

By using the Epump Services, you acknowledge and agree to such transfers.

11. Your Data Protection Rights

Depending on your jurisdiction and the nature of the data, you may have the following rights regarding your personal data:

• Right to Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you have the right to request the deletion of your personal data.
• Right to Restrict Processing: You have the right to request that we limit the way we use your personal data.
• Right to Object to Processing: You have the right to object to the processing of your personal data for certain purposes, such as direct marketing.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
• Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint (NITDA): You have the right to lodge a complaint with the relevant data protection authority - The National Information Technology Development Agency (NITDA) in Nigeria.

To exercise any of these rights, please contact us using the details provided in Section 13. We will respond to your request in accordance with applicable data protection laws. Please note that for data where our clients are the Data Controllers, you may need to direct your request to them first.

12. Children's Privacy

Our Services are not directed to individuals under the age of 18 ("Children"). We do not knowingly collect personal data from Children. If you are a parent or guardian and you become aware that your Child has provided us with personal data, please contact us. If we become aware that we have collected personal data from Children without verification of parental consent, we take steps to remove that information from our servers.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The "Last Updated" date at the top of this policy will indicate when it was last revised. We encourage you to review this policy periodically for any changes. If we make significant changes, we will notify you through a prominent notice on our website or through other direct communication channels. Your continued use of the Services after such updates signifies your acceptance of the revised policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy and Data Protection Policy or our data practices, please contact Fuelmetrics Ltd. at:

Fuelmetrics Ltd 18 Ilupeju Byepass, Ilupeju, Lagos, Nigeria
Email: info@fuelmetrics.com.ng
Website: www.epump.africa

For specific requests related to your data protection rights, please mark your email subject as "Data Protection Request."