Last Updated: June 2023
Fewlr L.L.C. (“Fewlr”, “we”, “us”, or “our”) respects the privacy of our users. This Privacy Policy explains the type of personal information that we collect and how we collect, use, access, disclose, safeguard, store and otherwise process your personal information (i.e. any information that personally identifies you such as your name and contact information) when you use or access our customer service platform that is available through our website (the “Website”) and our mobile application (the “App”) that links to or references this Privacy Policy. Through the Site and the App, we provide a network that connects heating fuel dealers that will sell and deliver heating fuel to a property (the “Fuel Connection Services”) and provide customer service and support related to the Fuel Connection Services (the “Customer Support Services”, and together with the Site, the App, and the Fuel Connection Services, the “Services”).
Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access or use the Services. Your clicking to accept these terms in our App or use of the Services is your acknowledgement and agreement (i) to the terms of our Privacy Policy and any other applicable agreement that may be provided together with the Services, and (ii) that we have your permission to collect and process your information as described in this Privacy Policy. If you’re agreeing to this Privacy Policy on behalf of an organization or entity, you represent and warrant that you are authorized to agree to this Privacy Policy on behalf of that organization or entity and to bind them to these provisions (in which case, the references to “you” and “your” in this Privacy Policy, except for in this sentence, refer collectively to you personally and to that organization or entity).
We may need to make changes to this Privacy Policy as privacy laws change, our Services evolve, or we add or change service providers among other things. As a result, we reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. If you have an account, we will also attempt to notify you via email or through the App should a material change occur. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy to our App or Website, and you waive the right to receive specific notice of each such change or modification. Your continued use of the Services following the posting of changes to these terms means you accept the updated Privacy Policy.
INFORMATION WE COLLECT
1) Categories of information we may collect directly from you:
- Personal Information that identifies you, such as your name, contact details including phone number, email address, postal address, telephone or fax number;
- Account Registration Information, such as information provided by you when you register for an account to use the Services, including User ID, log-in details, security questions and answers, and passwords;
- Fuel information, such as fuel type and delivery information;
- Financial, Payment and Commercial Data, such as name, billing address and payment card details, including credit card numbers, expiration dates, and security codes (which are collected by our third-party payment processor on our behalf) as well as any history and records of fuel orders submitted and/or fulfilled through our Services;
- Audiovisual Materials, such as photographs that you upload to identify a property and assist in fuel delivery;
- Marketing and Communications Data, including your marketing preferences or your interest in our Services; and,
- Other personal information you submit to us through communications, customer support exchanges, our “Contact Us” link, surveys, a competition, reporting a problem, email, or otherwise.
2) Categories of Information we may obtain about you from your usage, from others or by automated means:
- Derivative Data, such as technical information, including device name and type, IP address, operating system, browser type, access times, pages viewed directly before and after accessing the App or Website, other interactions with the App or Website which are automatically collected and stored in log files;
- Data from Social Media Sites, such as items, comments, feedback or content posted on our social media pages;
- Geolocation and GPS Data, including physical location of properties to where fuel is delivered;
- Audiovisual Materials, such as other audio, video captured during marketing/public filming events that you consented to including recording of virtual or live workshops or similar events;
- Information We Obtain from Third-Parties and Service Providers, such as payment services, e.g., Integrity Merchant Solutions;
- Information We Collect from Publicly Available Sources, including registers, the internet, public authorities, previous employers, educational institutions, suppliers and vendors without obligations of confidentiality;
- Market and Research Information, such as IP address, social media handle, or other online identifiers of a person, email address/mobile number if used for direct marketing and name and address, demographic data, (e.g., income, family status, age bracket, gender, interests, pets, home ownership, health, current service providers); and
- Cookies, web server logs, web beacons and other technologies (See also Cookies Section below).
WHY AND HOW WE USE THE INFORMATION WE COLLECT
We use your personal and other information to:
- Manage our contractual relationship with you, including providing you with information regarding the Services, billing and order information, handling claims, troubleshooting, hosting and providing customer support services;
- Set up and manage your account and profile; including to maintain your access to any Services and contact you regarding your account, fuel orders, or fuel delivery;
- Provide, develop and improve our Services, including delivering our Services to you and for additional purposes that help us to develop and improve the quality of our Services (including as part of the development of any new products and services);
- Facilitate communication, between you and us, as well as between the fuel consumer and Fewlr Authorized Supplier;
- Comply with a legal, regulatory or relevant industry standard obligation, including this Privacy Policy, intellectual property infringement, or enforcing our Terms of Service, or other contracts you have entered into with us;
- Protect against, identify and prevent fraud or other criminal activity, claims and other liabilities, that we may notice based upon any activity on your account or your use of the Services;
- Improve the security and other related system and network functions including preventing misuse;
- Perform analytics, including trend and financial analysis, market and consumer research, anonymization and aggregation of personal information; and
- Conduct marketing activities in accordance with applicable laws and in accordance with your preferences indicated when you register for an account, update your preferences in your account or unsubscribe from emails you receive from us.
HOW WE SHARE YOUR INFORMATION
1 ) We share the following categories of personal information in limited situations and only for the purposes addressed in the WHY AND HOW WE USE THE INFORMATION WE COLLECT Section above:
- Your contact details including name, phone number, postal address, and email address;
- Your account registration information;
- Your fuel information;
- Your financial, payment and commercial data;
- Your photographs;
- Your marketing and communications data;
- Derivative Data;
- Geolocation and GPS Data; and
- Cookies.
The categories of personal information are shared with the following third-parties for the purposes addressed in the WHY AND HOW WE USE THE INFORMATION WE COLLECT Section above:
- Affiliates, other Fewlr companies that comply with this Privacy Policy;
- Authorized Users, that you invite;
- Third-Party Business Partners, such as an Fewlr Authorized Supplier;
- Third-Party Advertisers, for marketing purposes from which you can opt out at any time;
- Our Service Providers, who provide some of our Services to you including processing, storage, and technical assistance whereby we have entered into contracts with such service providers which include limitations on their use of certain of your information and only as necessary to provide these Services to us/you;
- Third-Party Service Providers for Website and App Analytics, including automated technology to collect and analyze your information, including personal information to help us understand your use and optimize your customer experience (please see our section on Cookies and our separate Cookie Notice to learn more);
- Professional Advisors and Governmental Authorities, if we believe in good faith that disclosure, access, use or preservation of such information is necessary to (i) meet any applicable law, regulation, legal process or governmental request; (ii) enforce or investigate your compliance with the terms of any of our contracts or policies we have with you for potential violations; (iii) protect against physical, financial or other harm against the rights, safety or property of you, us, or any third-party; and, (iv) investigate fraud, technical, security or other operational issues; and
- In connection with Corporate Transactions, meaning changes to our corporate structure due to sale, transfer, merger or other reorganization of our company during which your personal information may be among the items sold or transferred.
2 ) We may share your non-personal information with:
- Affiliates, and
- Third-Party Business Partners.
Note: Our Privacy Policy does not cover any information that you provide to a third-party that you may access through the Services through clicking on a link provided in our Services. If third party links are presented through our Services and you choose to access such link, we encourage you to review the third party’s privacy policy. Their use of your personal information will be covered by their respective privacy policy.
Any data that Fewlr receives from third-parties will be processed and stored by Fewlr in accordance with the terms of this Privacy Policy.
HOW WE SECURE YOUR INFORMATION
The security of your information is important to us. We practice industry standard security methods to address appropriate technical, administrative, electronic, and organizational safeguards to protect your information from unauthorized use, disclosure, and loss. Encryption technology, including current industry-standard encryption protocols, is used to protect personal information. As a matter of security, we do not disclose the specific details regarding our security posture as this information could be used by criminals and other bad actors. For more information on our security practices, please contact us.
Despite our efforts to secure your information, we cannot be responsible for the security of the information you transmit over networks that we do not control including the Internet and wireless networks whether they are yours or others.
WHERE YOUR PERSONAL INFORMATION IS USED OR ACCESSIBLE INCLUDING ANY INTERNATIONAL TRANSFERS
Fewlr is located in the state of Connecticut in the United States. All personal information will be accessed and stored in the United States. We do not engage or allow for the international transfer of your personal information. If in the event of an international transfer of your personal information, we will transfer such personal information in accordance with the applicable data privacy laws.
RETENTION OF YOUR PERSONAL DATA
We retain your personal information as follows:
The period during which we store your personal information varies depending on the purpose for the processing:
- For the provision of our Services, for so long as you use the Services or have an account with us.
- For marketing purposes, until you have opted out of receiving further direct marketing communications in accordance with applicable law.
- In all other cases, we store your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy or such retention period as required by law, following which time it is either anonymized (where permitted by applicable law), deleted or destroyed.
The applicable information, and location and infrastructure where your personal information is stored or can be accessed is as follows:
- Within Fewlr’s infrastructure, such as on our or our service provider’s servers or cloud environment, where we may store your personal information including but not limited to photos, email address, password, account profile information, until you delete it, edit it, or for as long as you have an account with us or for such period for us to meet a legitimate interest, resolve dispute, legal defense, enforce agreements, conduct audits and comply with laws. Further, you can request that we provide you with access, amend or delete your information on our servers in certain cases.
USE OF COOKIES AND OTHER DATA COLLECTION TOOLS
Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information.
- “Cookies” are small text files that are placed on your device by a Web server when you access a website. To enable our systems to recognize your browser or device and to provide and improve the Services, we may use both session Cookies and persistent Cookies. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize our Services. Unlike persistent Cookies, session Cookies are deleted when you log off and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party service providers that we engage (including third-party advertisers) may also place their own Cookies on your device. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third-parties.
- “Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be used for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Site, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
For more information about cookies and how we use them, please read our Cookie Notice.
WEB BROWSER SETTINGS
You can opt out of our use of cookies to recall information about you by setting your browser not to accept cookies or to disable cookies. Most browsers also offer additional built-in tools to help you manage, control, and delete cookies, including cookies used for advertising.
We support the development and implementation of a standard “do not track” browser feature that provides customers with control over the collection and use of information about their web-browsing activities.
MINORS
You must be at least 18 years old (or equivalent minimum age in the jurisdiction where you reside) to use the Services. Our Services are not directed to minors under the age of 18 years and we do not knowingly collect personal information from minors. If we learn that we have collected personal information of a minor we will take steps to delete such information from our files as soon as possible.
CONTACT US
If you have any questions about this Privacy Policy or if you would like us to update information we have about you, change your preferences, or exercise applicable data protection rights, please contact us by e-mail at hmuhlhauser@fewlr.com or write to us at:
Fewlr L.L.C.
1 Technology Dr.
Tolland, CT 06084
