ETSIN FLO NAOERO — Privacy Policy

Last updated: 17 June 2026

This Privacy Policy explains how ETSIN FLO NAOERO collects, uses, and protects your information.

1. Information We Collect

Account information. Phone number or email, password (stored hashed), display name, language preference.
Transaction information. Meter numbers, denomination, payment reference, order status, and tokens delivered.
Payment verification information. Bank transfer receipts, screenshots, emails forwarded to our verification system, and amounts received.
Device and usage information. Device type, browser, IP address, and app interactions used for fraud prevention and reliability.
Communications. SMS, email, or in-app messages exchanged between you and ETSIN FLO NAOERO representatives.

2. How We Use Your Information

To deliver prepaid electricity tokens to your meter.
To verify payments and detect fraud.
To send transactional notifications (tokens, receipts, status updates).
To investigate disputes, refunds, and abuse.
To improve reliability and performance of the service.

3. Automated Verification

Payment evidence is processed by automated systems ("Sparky") that read receipts, compare amounts against your order, and flag anomalies for human review.

4. Service Providers & Cross-Border Processing

ETSIN FLO NAOERO may use trusted cloud, messaging, email, payment, and infrastructure providers located outside Nauru to deliver the service. These providers process information on our behalf under contractual confidentiality obligations and only for the purposes described in this Policy.

5. Information Sharing

We share information only as needed to deliver the service:

With Nauru Utilities Corporation (NUC) systems to load tokens onto your meter.
With SMS and email providers to deliver notifications.
With payment and banking systems to verify transfers.
With law enforcement where required by valid legal process.

We do not sell your personal information.

6. Security

We use industry-standard safeguards including encryption in transit, restricted access, and access logging. No system is perfectly secure; we encourage you to use a strong password and to keep your account credentials confidential.

7. Your Rights

You may request access to, correction of, or deletion of your personal information by contacting an ETSIN FLO NAOERO representative through the in-app support channels, subject to legal and operational record-keeping requirements.

8. Retention

We retain transaction records for up to seven (7) years to meet financial, audit, and dispute-resolution obligations. Other personal information is retained only for as long as needed for the purposes set out above.

9. Changes to This Policy

We may update this Policy from time to time. Material changes will be communicated through the app.

10. Contact

For privacy questions, an ETSIN FLO NAOERO representative can assist you through the in-app support channels.