Version 1.0 · Operated by ClearFlow Solutions Ltd.
DRAFT FOR LEGAL REVIEW. This document was prepared as a technical placeholder so the app, portal and website have real content to display and so consent records can be versioned. It has not been reviewed by an attorney. ClearFlow's legal advisor must review and approve it before public launch, and the version number must be bumped in Settings when it changes.
1. Who we are
WataBox is operated by ClearFlow Solutions Ltd. ("ClearFlow", "we", "us"), a
company registered in Jamaica. We operate purified water refill stations and
the WataBox mobile application.
For privacy questions, contact us using the support details published in the
app and on our website.
2. What we collect
We collect only what we need to run the service:
- Account details — your name, mobile number, and optionally your email address.
- Verification records — one-time codes we send you, and whether they were used.
- Transaction records — the station, product, volume, amount, payment method,
date and time of each refill.
- Support records — messages you send us and our replies.
- Device information — the notification token for your phone, your platform
(Android or iOS), and the app version.
- Approximate location — only if you grant permission, and only to sort
stations by distance. We do not store your location.
We do not collect identity documents, and we do not store full card
numbers, card security codes, or cardholder names.
3. Why we use it
- To create and secure your account, and to verify your mobile number.
- To operate refills and give you receipts and purchase history.
- To answer support requests and resolve payment or dispensing problems.
- To monitor machine health and keep stations in service.
- To meet our accounting, tax and regulatory obligations.
- To send service notices, and — only if you opt in — promotions.
4. Payments
Payment is taken at the machine. Where a payment provider is involved, that
provider processes your payment details under its own privacy terms. ClearFlow
receives only a payment reference, the amount, and the outcome.
5. Sharing
We share personal data only where necessary:
- Our machine supplier, to operate and service the stations. Supplier
systems may process data outside Jamaica.
- Service providers for messaging, notifications and hosting.
- Professional advisors, regulators or law enforcement, where we are
legally required to do so.
We do not sell your personal data.
6. How long we keep it
- Account records — for as long as your account is active.
- After deletion — identifying details are removed and the remaining
transaction records are retained for the period configured in our systems
(currently three years) to meet accounting obligations.
- Support records — retained alongside the related account.
- Audit logs — retained for security and compliance purposes.
7. Your rights
You may:
- Access and export your data — from the app, under Account.
- Correct your details — from the app, under Edit profile.
- Delete your account — from the app, under Account. This removes your
personal details. Transaction records are retained as described above but are
no longer linked to you.
- Withdraw marketing consent at any time.
You may also contact us directly to exercise any of these rights.
8. Security
We protect your data with encrypted connections (HTTPS/TLS), hashed passwords,
role-based access controls for staff, session expiry, rate limiting, and audit
logging of administrative actions. Supplier and payment credentials are held
server-side only and are never included in the mobile app.
No system is perfectly secure. If a breach affects your personal data, we will
follow our incident response procedure and notify affected users and the
relevant authority where required.
9. Children
WataBox is not directed at children under 16, and we do not knowingly collect
their personal data.
10. Changes
We may update this policy. The version number shown in the app will change, and
we will ask you to accept a materially updated version.
11. Jamaica Data Protection Act
ClearFlow intends to meet its obligations as a data controller under Jamaican
data protection law, including registration where required, and handling of
data subject requests.
Last updated: on publication. Awaiting legal review.
Questions about this document? Contact ClearFlow Solutions Ltd. by phone on +1 876 000 0000 or by email at support@wataboxja.com.