DRAFT FOR THE LAWYER, 20 September 2026
Consent texts and in-app notices
Version [1.0] of [DATE]
1. What this document holds and how it is used
1.1. The document gathers every text the User taps or receives: consents and active acceptances (C), notices and information notes (N), messages by SMS and by e-mail (M), and the declarations for the app stores (S). The identifier of each text is its key in the App. An identifier never changes, so the order of identifiers does not always follow the order of the chapters.
1.2. Each text carries a short table and the text displayed. The table says where the text appears, whether it is an active acceptance or a notice, what the Seller keeps as proof, and the legal basis. The text displayed is set as a quotation and is taken word for word.
1.3. The texts on screen address the User in the second person plural, are short, and name things in everyday words. Defined terms are written in lower case inside them, apart from proper names, because a telephone screen is not a contract. In the tables, in the headings and in the explanations written for the lawyer, defined terms keep their capital.
1.4. The design rules kept in every text are these: a) a consent is asked by a separate act, and the box is never ticked in advance; b) refusing an optional consent closes no account and switches off no service; c) withdrawing a consent is as simple as giving it; d) a warning about money appears before the act that cannot be undone.
1.5. A change is made in this document first and in the App afterwards. The Romanian version governs. The Russian and the English versions say the same, text by text.
1.6. What stands in square brackets is replaced by the App with the real value. The sentence is built so that the value follows a colon or stands on a line of its own, which keeps the text grammatical in all three languages. Amounts are shown with two decimals and with the currency written out; "about every 30 seconds" stays as it is, being a technical figure.
1.7. Every text exists in Romanian, in Russian and in English. The User sees it in the language chosen in the App, and the language of display goes into the record of clause 2.1.
1.8. No text carries an exclamation mark and none uses decorative symbols. The Seller does not write about money in the voice of an advertisement and does not apologise on a screen.
2. Proof of acceptance
2.1. For each acceptance and for each consent the Seller creates a record that is never altered. It holds: a) the identifier of the User or of the Company staff member; b) the document and the version accepted, with a fingerprint of the text displayed; c) the language of display; d) the date and the time, with the time zone; e) the channel and the method of acceptance, and for the SMS code only the record of its verification; f) the consent asked and the answer given; g) an unchanged copy of the screen shown; h) the App version and the kind of device.
2.2. The withdrawal of a consent is recorded with the same data as the giving of it.
2.3. The record of the acceptance and the copy of the screen under letter g) are kept for as long as the accounting documents of the operations the acceptance may relate to. The periods are those of the Privacy policy, chapter 8. A dispute about a purchase of three years ago is decided under the Terms as they stood then, so the Seller also keeps the whole text of every published version.
2.4. Law No. 195 of 25.07.2024 on the protection of personal data, art. 7 para. (1), requires the data controller to be able to demonstrate the consent. The Civil Code of the Republic of Moldova No. 1107 of 06.06.2002, art. 1015 para. (9) and art. 1019 para. (1), puts on the professional the burden of proving that it met its information duties.
2.5. The Civil Code, art. 1054 para. (4), puts on the consumer the burden of proving a withdrawal. For that reason the records of clause 2.1 are kept for account closure requests as well.
3. Consents and active acceptances (C)
C-01. Acceptance of the Terms of use at registration
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| The registration screen, after the number has been confirmed with the SMS code and after the name, before the account is opened | Active acceptance; the box is not ticked in advance and the account does not open without it | The record of clause 2.1 | Civil Code, art. 1070 para. (3): a reference to a text, even an accepted one, does not draw a consumer's attention, so the unexpected rules sit on the screen. Art. 1015 para. (1) letter h) requires the withdrawal right to be stated before the contract is concluded. Terms of use, clause 4.2, fixes the six rules and their order, and clause 1.12 requires the full text of the Campaign rules to be made available in textual form on this screen |
3.1. The text displayed:
Six rules you accept now.
The balance is an advance paid to SRL "DII-TEH-GROUP" for the goods and services of the network. It is not a bank deposit. The service is not supervised by the National Bank of Moldova, and you do not have the protection given to users of payment services. The balance does not expire and does not shrink with time.
Money is not withdrawn in cash and is not sent to another person. You get it back when the account is closed: in cash, at the office at [OFFICE ADDRESS], on an identity document in the name of the account. In the cases written in the Terms of use, chapter 11, money also comes back by a refund or by the return of a mistaken top-up.
The ePay discount may change. The rate in force is shown before every payment, and a payment already confirmed keeps its price.
The Terms of use have versions. We tell you at least [15] (fifteen) days beforehand. A new version is accepted before the next top-up or payment, and if you do not accept it you close the account free of charge and receive the whole balance.
You have 14 (fourteen) days from the day after the account is opened in which you may withdraw from the contract, without giving a reason, using the form in annex no. 1 to the terms. [Read the withdrawal form]
When the account is closed, stamps and coupons are cancelled.
☐ I accept the Terms of use, version [x.y], and the Campaign rules: Stamps and Coupons, which form part of them. [Read the Terms] [Read the Campaign rules]
Your data is processed under the Privacy policy. [Read the policy]
[Open the account]
C-02. Confirmation of 18 years
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| The registration screen, under C-01, as a second box | Active acceptance, separate from C-01, never ticked in advance | The record of clause 2.1 | The full capacity to contract that the Civil Code requires for a contract creating a duty to pay, and the Terms of use, clause 4.5. The Seller does not offer the service to persons under 18 |
3.2. The box carries the text:
☐ I confirm that I am 18 years old or older.
C-03. True name and surname
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| The registration screen, above the name fields | Active acceptance, never ticked in advance | The record of clause 2.1 and the name written then | Civil Code, art. 1071 para. (1): the consequence of a wrong name must be known beforehand and not at the counter |
3.3. Above the fields stands the text:
Write your name and surname as they stand in your identity document. When the account is closed, the money is paid only to the person with this name and only against an identity document. If the name does not match, payment follows once you prove that the account is yours; the money is not lost. A wrong name is corrected only by support.
☐ I confirm that the name and surname are those in my identity document.
C-04. Offers and news about Campaigns
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| The registration screen, after C-01, C-02 and C-03, and at any time under Profile, Notifications | Consent, given separately for each channel; every box is empty when the screen opens | The record of clause 2.1 for each channel with the answer given, and the same for each withdrawal | The law on electronic communications No. 241-XVI of 15.11.2007, art. 80 para. (1) and (3): direct promotion needs prior consent. An SMS falls within the notion of electronic mail of art. 2 of the same law |
3.4. The screen shows:
Do you want offers and news about campaigns? The choice is free and changes nothing in your account.
☐ By notifications in the app
☐ By SMS
☐ By e-mail, to the address [field]
You may change the choice at any time under Profile, Notifications. Messages about top-ups, payments, coupons and account security are not offers and come whatever you choose here.
N-35. The announcement of a new version of the Terms of use
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| In the App and, at the same time, by SMS or by e-mail, at least [15] (fifteen) days before the day the new version starts to apply | Notice; it precedes the C-05 screen and is not replaced by it | The announcement, the date it was sent, the channel and the version it relates to | Terms of use, clause 20.2. Civil Code, art. 1077 para. (1) point 10) and art. 1078 letter o): without a prior announcement and a free exit a unilateral change is not valid |
3.5. In the App the announcement carries the text:
The Terms of use change from [date]. The new version is [x.y].
What changes: [short list of the changes].
[Read the whole text]
If you do not accept, you close the account free of charge and receive the whole balance, in cash, at the office at [OFFICE ADDRESS], within [10] (ten) working days.
3.6. By SMS or by e-mail the short form goes out:
The ePay Terms of use change from [date]. What changes, and the whole text: [link]. If you do not accept, you close the account free of charge and receive the whole balance.
C-05. Acceptance of a new version of the Terms of use
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| When the App is first opened after the day the version takes effect, and in any case before the first top-up or payment after that day | Active acceptance; the window does not close on a tap outside it and carries no postpone button | The record of clause 2.1, with the old version and the new one | Civil Code, art. 1070 para. (3): the same attention as at the first acceptance. Terms of use, clause 20.4 |
3.7. The window shows:
The Terms of use have changed. Version [x.y] is in force from [date].
What changed: [summary of the changes, three lines at most].
[Read the whole text]
Until you accept, you cannot top up the balance and you cannot pay. The balance, the coupons, the stamps and the payments already confirmed are untouched, and history and support stay open.
If you do not accept, you close the account free of charge. The payout is made in cash, at the office at [OFFICE ADDRESS], against an identity document, within [10] (ten) working days.
[Accept] [Close the account and receive the balance]
C-06. The cookie choice on the public site
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| On the first visit to https://epay.e-gaz.md, on a panel that covers part of the page and does not hinder the reading of the legal texts | Consent, given separately for each purpose; no purpose is chosen in advance, and the buttons "Accept all" and "Refuse all" are of the same size, the same look and the same visibility | The record of clause 2.1, without tying the choice to a named User | Cookie notice, clause 6.1. Law No. 241/2007, art. 72 para. (5): storage the requested service does not need calls for a consent preceded by clear information. Law No. 195/2024 (Monitorul Oficial No. 367-369 of 23 August 2024, art. 574, in force from 23 August 2026), art. 7 para. (3): the right to withdraw is stated beforehand |
3.8. The panel carries the text:
The site uses cookies. The necessary ones keep the site working and cannot be switched off.
For the other purposes we need your consent, and we ask for each one on its own. No purpose is chosen in advance.
☐ Audience measurement ☐ The embedded map of the sites
You may change the choice at any time, from the foot of the page.
[Read the cookie notice]
[Accept all] [Refuse all] [Let me choose]
C-07. Acceptance of the Cabinet terms by a Company
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| When the invitation to the Cabinet is activated, for the person who signs for the Company, and at every new version of those terms | Active acceptance, given by a named person for the Company | The record of clause 2.1, with the person's name, the role and the Company's name | Civil Code, art. 1070 para. (2): terms that were not negotiated are made available in textual form. The Cabinet opens access to the Company's money |
3.9. The box carries the text:
☐ I accept the Cabinet terms of use, version [x.y], on behalf of [COMPANY'S NAME], and I confirm that I may act for it.
[Read the text] [Activate the cabinet]
C-08. The request that the service begin inside the withdrawal period
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| Once, on the screen of the first top-up, above the payment button | Active acceptance; the box is not ticked in advance and is not folded into C-01 | The record of clause 2.1, with the date of the first top-up and the period left at that moment | Civil Code, art. 1017 para. (10): performance begins inside the withdrawal period only on the consumer's express request. Art. 1015 para. (1) letter j): what he pays if he withdraws after that request |
3.10. While the period runs, the screen shows:
The withdrawal period of 14 (fourteen) days runs from [date]. Days left: [x].
To top up the balance and pay today, ask for the service to begin inside this period.
☐ I ask for the service to begin at once, before those 14 days end.
If you withdraw after this request, you pay for the part of the service already received, and the rest of the balance is returned to you when the account is closed. If you do not ask for this, you top up and pay once the 14 days have passed, and the account stays open until then.
3.11. Once the period has run out the box is no longer shown, and a line stands in its place:
The withdrawal period of 14 days ended on [date].
C-09. The first top-up of a Company card by the User
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| At the first Top-up by user on each Company card, under the text of N-13 | Active acceptance, asked once for each Company card, never ticked in advance | The record of clause 2.1, with the card number and the Company's name | Terms of use, clause 10.4. Civil Code, art. 1070 para. (1) and (3): a User paying his own money does not expect the right to that amount to pass to the Company |
3.12. Under the text of N-13 stands the box:
☐ I have read the text above and I know that the amount becomes the advance of the company [COMPANY'S NAME], not my balance.
4. Topping up the balance (N)
N-01. The top-up screen
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| When the top-up button is tapped, on the card chosen | Notice; the boxes C-08 and C-09 are added where they apply | The payment, the amount, the card and the text of the limits in force at that moment | Civil Code, art. 1017 para. (4): the button that creates the duty to pay carries an unambiguous wording. Art. 1017 para. (2): the price, the duration and the absence of a minimum obligation sit next to the button. Terms of use, clause 6.4 |
4.1. The screen shows:
Top-up of the balance. Card: [card].
The minimum of one top-up: [50.00] lei. The maximum: [ONE TOP-UP LIMIT] lei. The balance may not pass [MAXIMUM BALANCE] lei, and in one month you may top up by no more than [MONTHLY LIMIT] lei.
We take no commission: 100.00 lei paid means 100.00 lei on the balance. Your own bank may have its charges.
The amount is an advance for the goods and services of the network. The contract runs for an indefinite time and you take on no minimum obligation. Money comes back in the cases written in the Terms of use, chapters 11, 12 and 13, and when the account is closed, in cash, at the office.
The money reaches the balance after the bank confirms the payment. For every top-up through MIA you receive an advance confirmation, under History.
Nobody has to top up the balance. At any site you may also pay in the usual way.
[I pay [amount] lei]
N-02. Topping up the amount that is short
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| In place of the payment result, when the balance does not cover the purchase | Notice; the User does not type the amount, because the App works it out | The order, the amount that was short, the amount proposed and the reason the minimum applied | Civil Code, art. 1071 para. (1): an amount asked of a consumer is explained in his own words. Art. 1017 para. (2) and (4) apply to the button here too. Terms of use, clause 6.9 |
4.2. The sheet shows:
You are [x] lei short. Top up the balance by [y] lei through MIA and come back to the payment.
The amount proposed is [y] lei, because the minimum of one top-up is [50.00] lei.
The amount is an advance. The contract runs for an indefinite time, with no minimum obligation, and money comes back in the cases written in the Terms of use, chapters 11, 12 and 13.
You may also top up in cash, at the till of a site that takes cash.
If the bank does not confirm the payment within [10] (ten) minutes, this purchase is cancelled. Money that arrives later stays on the balance.
[I pay [y] lei] [I top up at the till] [Cancel]
N-03. Waiting for the bank
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| After the return from the bank's application or from MIA, while the confirmation has not arrived | Notice | The payment, the time the wait began and the time of the bank's answer | Civil Code, art. 1071 para. (1): a consumer who cannot see what is happening to his money pays twice. Terms of use, clause 6.6 |
4.3. The waiting screen shows:
We are waiting for the bank to confirm. You may close the app: we will tell you when the money is on the balance. If the bank does not answer within [10] (ten) minutes, the purchase is cancelled.
[Cancel the purchase]
N-04. Money credited after the waiting time ran out
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, when the bank confirms a payment after the purchase tied to it has been cancelled | Notice | The payment, the time of the bank's confirmation, the cancelled order and the credit | Terms of use, clause 6.6. Law No. 105 of 13.03.2003 on consumer protection, art. 33 para. (2): complete and correct information to the consumer |
4.4. The notification carries the text:
The bank confirmed the payment of [amount] lei after the waiting time had run out, and the purchase of that moment was cancelled. The amount is now on the balance of card [card] and you may use it at any time. The purchase has to be made again.
N-05. The cash top-up: what the cashier sees
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| On the back of the card, when the User turns it round to show it at the till | Notice | The reading of the code, the Site, the cashier and the time | Law No. 195/2024, art. 13: who is shown which data is stated before it happens. Terms of use, clause 6.8 |
4.5. On the back of the card stands the text:
Show this code to the cashier. The cashier sees your name, your surname and the last digits of your telephone number, and the cards you may top up. He does not see the balance of the ePay card and does not see your payments.
The code changes about every 30 seconds. A photograph of it is of no use to anybody.
N-06. The cash has been credited to the card
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, at once after the top-up | Notice | The top-up, the number of the till receipt, the cashier and the Site | Law No. 105/2003, art. 9 letter f): the document confirming the purchase. Terms of use, clauses 6.7 and 6.8 |
4.6. The notification carries the text:
We received [amount] lei in cash. Site: [site]. Till receipt: no. [number].
The balance of card [card] is now [balance] lei. The fiscal receipt of the till is the document of this top-up and stays with you.
N-07. The cashier cancelled the top-up
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, when the cashier cancels his own top-up | Notice | The cancellation, the reason, the cashier and the time; a letter goes to the Seller's accountant | Civil Code, art. 1071 para. (2): an amount taken away with no explanation would be a term failing the transparency duty. Terms of use, clause 6.8 |
4.7. The notification carries the text:
The cashier cancelled the top-up of [amount] lei made at [time]. Site: [site]. Reason: [reason].
The cashier must hand you back [amount] lei in cash, at the till. A cancellation is possible only within [15] (fifteen) minutes of the top-up, with your agreement, and only if the money has not been spent.
The balance of card [card] is [balance] lei. If you did not receive the money, call the manager of the site at once and write to us from this operation.
5. Payment (N)
N-08. Confirming the payment on the telephone
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| When the payment button is tapped, above the window of the telephone's system | Notice; the confirmation itself is the moment of payment | The order, the method of confirmation and the time; the biometric data stays in the telephone | Civil Code, art. 1017 para. (3): the User fixes for himself the moment at which he takes on the duty to pay. Terms of use, clause 5.4 |
5.1. Above the system window stands the text:
Confirm the payment of [amount] lei by face recognition, by fingerprint or with the device code. Site: [site].
5.2. On a telephone with no screen lock, in place of the text above:
Your telephone has no screen lock, so the payment is confirmed by a single tap. A telephone left unlocked is your responsibility. You may switch the lock on in the telephone's settings.
[I pay [amount] lei]
N-09. The Hold during fuelling
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| On the fuel payment screen, before the confirmation, and at the end of the fuelling | Notice | The Hold, the amount charged, the amount released and the time of each | Civil Code, art. 1070 para. (3) and art. 1071 para. (1): an amount blocked is shown beforehand, in figures. Terms of use, clause 7.4 |
5.3. When the User picks an amount, the screen shows:
We set aside [amount] lei from card [card] for this fuelling. The amount set aside cannot be spent anywhere else until the fuelling ends. You pay only for the fuel dispensed, and the rest is released straight after that.
5.4. When the User picks a full tank, the screen shows:
For a full tank we set aside the whole balance, but no more than [HOLD CEILING] lei. You pay only for the fuel dispensed, and the rest is released straight after that.
5.5. At the end of the fuelling the notification goes out:
Fuelling finished. Site: [site]. Pump: [number]. Quantity: [litres] l. Amount: [amount] lei, with the ePay discount of [rate].
Of the Hold of [hold] lei, [difference] lei were released. The balance of card [card] is [balance] lei.
N-10. The warning about the amount at the wash
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| On the wash payment screen, above the payment button, as a visible block, before every confirmation | Notice; tapping the payment button is the agreement to the immediate start | The amount chosen, the post, the time of the start and the automatic refund, where it happens | Terms of use, clauses 7.5 and 12.5. Civil Code, art. 1017 para. (10) and art. 1064 para. (6); art. 1065 para. (1) letter a) applies to a wash actually completed |
5.6. The warning block carries the text:
The post starts for the amount you choose. Time not used is not refunded, so choose the amount you will really use.
The wash begins as soon as the payment is confirmed. It is bought and carried out at the site, so it is not a distance contract: once the wash is over you have no withdrawal right over it.
If the post does not start, the amount comes back to the balance by itself, with no request from you.
N-11. A Site has read the card
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| As a window on the telephone screen, when equipment of the Network has read the card's code | Notice with a compulsory answer; without an answer nothing happens | The reading, the equipment, the Site, the time and the answer | Civil Code, art. 1017 para. (3): no step towards a payment starts against the User's will. Terms of use, clause 7.2 |
5.7. The window shows:
Your card was read at [time]. Site: [site]. Pump: [number]. Is this you?
[Yes, carry on] [This is not me]
"This is not me" stops the request, and we ask you at once whether to freeze your cards.
N-12. Payment with a Company card
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| On the payment screen, every time the card chosen belongs to a Company | Notice; the Company's visibility does not rest on the User's consent | The display of the text at each payment | Law No. 195/2024, art. 7 para. (4): a consent asked by an employer is not freely given, so the User is informed. Terms of use, clause 10.7 |
5.8. The screen shows:
You are paying with a company card. Company: [company name].
The money on this card belongs to the company. The company sees the date, the time, the site, the service and the amount. A payment with a company card earns no stamps.
N-13. Top-up by user
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| Every time the User tops up a Company card, above the payment button; at the first top-up of each card the box C-09 is added to it | Notice at every top-up; active acceptance at the first | The top-up, the Company, the card and the text displayed | Terms of use, clauses 10.4, 10.5 and 10.6, which fix the text displayed. Civil Code, art. 1017 para. (4) for the button and art. 1070 para. (3) for the text |
5.9. Above the button stands the text fixed by the Terms of use, clause 10.4, followed by the whole rule:
The money goes to the company [COMPANY'S NAME]. The amount becomes that company's advance, not your balance. You cannot get it back from the Seller, neither in cash, nor to the balance, nor when the account is closed. The company settles with you outside ePay.
The amount is kept on this card as the user part and is spent before the company's money. While the card is live, the company can neither take it back nor move it to another card.
When the card is deleted or you cease to be a company user, the amount is set aside. It passes to the company account [30] (thirty) days after the deletion, unless the company asks in writing, within that period, for it to stay on your card. Your claim over this amount lies against the company.
[I pay [amount] lei for the company [COMPANY'S NAME]]
6. The Company card held by the User (N)
N-36. The first information given to a Company user
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| As the first screen the person invited by a Company sees, straight after the link of M-02 is opened and before registration | Notice; it is not ticked and not signed | The display, the date and time, the version of the text | Law No. 195/2024, art. 14: a person whose data came from somebody else is informed at the latest at the first communication. Art. 21 para. (4): the right to object is shown clearly and apart. Privacy policy, clause 12.3 |
6.1. The first screen carries the text:
The company [COMPANY'S NAME] gave us your telephone number and the label it put on you, so that it can give you a company card.
There are two controllers. The company decides for the data of its cards and for the cabinet reports. SRL "DII-TEH-GROUP" decides for your account in the app, for the ePay card and for the balance.
What we use the data for: payment at the sites of the network, accounting and the security of the account. How long we keep it: while you are a company user, and the accounting records for the periods the law requires.
Your rights: access, rectification, erasure, restriction, portability and objection. You exercise them at dev@e-gaz.md, and for the data the company entered, at the company. You may complain to the National Centre for Personal Data Protection.
You may object at any time to the use of your data for promotional messages. [I object to promotional messages]
[Read the whole notice]
N-14. The company has given you a card
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, when the card is issued | Notice | The issue, the Company, the kind of card and the time | Law No. 195/2024, art. 14. Terms of use, clauses 10.1 and 10.7 |
6.2. The notification carries the text:
You have been given a company card. Company: [company name]. Kind of card: [kind].
The money on it belongs to the company, and payments with it are seen by the company: the date, the time, the site, the service and the amount. Your telephone number the company sees masked.
Your data was given to us by the company. We keep it while you are a company user, and the accounting records for the periods the law requires. You exercise your rights over that data towards the company, and for the account in the app at dev@e-gaz.md. [Read the whole notice]
The rules for using the card come from the company. The card is in the app, next to the ePay card.
N-15. The company took money back from the Company part
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, at once after the operation | Notice | The operation, the amount, the Company and the time | Civil Code, art. 1071 para. (1): a fall in the amount on a card is explained the same day. Terms of use, clause 10.2 |
6.3. The notification carries the text:
The company took back [amount] lei from card [card]. Company: [company name].
This is the company part. The part you paid yourself, [amount] lei, was not touched. The balance of the card is [balance] lei. Questions about this money go to the company.
N-16. The Company card has been stopped
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, when the Company stops the card without deleting it | Notice | The stopping, the time and who asked for it | Terms of use, clause 10.2: the Company may block the card without the User's agreement, and the money stays where it is |
6.4. The notification carries the text:
The company card has been stopped. Company: [company name].
You cannot pay with it while it is stopped. The money on the card stays where it is: neither the company part nor the part you paid yourself moves. If you want it switched on again, ask the company.
N-37. The Company card has been deleted
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, when the card is deleted or when the person ceases to be a Company user | Notice | The deletion, the day the period starts, the amount set aside and the decision at the end | Terms of use, clause 10.6. Civil Code, art. 1071 para. (1) and art. 1107: an unclear term about money is read against the one who wrote it |
6.5. The notification carries the text:
The company card has been deleted. Company: [company name]. Day of deletion: [date].
The company part has gone back to the company account. The part you paid yourself, [amount] lei, is set aside. It passes to the company account on [date + 30 days], unless the company asks us in writing, before that day, for the amount to stay on your card.
The company sends that request to dev@e-gaz.md. You may also write to the company from this operation. [Write to the company]
The Seller does not pay you this amount. Your claim lies against the company.
7. Refunds and corrections (N)
N-17. Refund
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, at once after the operation | Notice | The Refund, the order, the reason shown to the User, the accountant and the time | Terms of use, clauses 11.1 and 11.2. Law No. 105/2003, art. 9 letters g) and j) and art. 10 letters i) and j) |
7.1. The notification carries the text:
We have refunded [amount] lei to you on card [card]. Reason: [reason].
The balance of the card is [balance] lei. Money always goes back to where it left from.
N-18. Correction
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, at once after the operation | Notice | The Correction, the reason shown to the User, the internal note, the accountant and the time; the internal note never leaves for the User or for the Company | Terms of use, clause 11.7, which fixes the two cases of a Correction and the written reason. Clause 13.5: the Seller never retains the Balance. Civil Code, art. 1071 para. (2) |
7.2. Where the Correction adds money, the notification carries the text:
We have put right a mistake in our records. We added [amount] lei to card [card]. Reason: [reason]. The balance of the card is [balance] lei.
7.3. Where the Correction takes off an amount credited by mistake, the notification carries the text:
We have put right a mistake in our records. We took [amount] lei off card [card], credited there by mistake on [date]. Reason: [reason].
A correction cannot take off more than the amount credited by mistake, and it does not touch the money you paid yourself. The balance of the card is [balance] lei.
If you do not agree, make a complaint from this operation. We answer within 14 (fourteen) calendar days at most, and a refusal is given in writing, with the reason.
N-19. The request to return a mistaken top-up
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| Under History, on the top-up operation, while the return is still possible | Notice; the request is an act of the User | The request, the time, the reason shown to the User and the result | Terms of use, clauses 11.4 and 6.8. Law No. 105/2003, art. 25 para. (6): a refusal is given in writing |
7.4. The request screen shows:
We return a mistaken top-up only in full, only if its money has not been touched and only if [3] (three) days have not passed since it was made. The money goes back through the bank, to the account it came from.
A cash top-up does not come back this way. Only the cashier cancels it, within [15] (fifteen) minutes of the top-up and at the same site. After that the money stays on the balance and you may spend it in the network.
[Send the request]
7.5. When the request is met, the notification goes out:
The top-up of [amount] lei of [date] has been returned to the account it came from. The balance of card [card] is [balance] lei.
7.6. Where the request cannot be met:
We cannot return the top-up of [amount] lei of [date]. Reason: [reason]. The money stays on the balance and you may use it in the network at any time.
N-20. Moving a top-up between the User's cards
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, after the accountant has made the move | Notice | The move, both cards, the reason shown to the User, the accountant and the time | Terms of use, clause 11.5, and Civil Code, art. 1071 para. (1), for the money. Law No. 195/2024, art. 13, for what the Company sees |
7.7. The notification carries the text:
We have moved the top-up of [amount] lei of [date], at your request. From card: [first card]. To card: [second card]. Reason: [reason].
The balances are now [first balance] lei and [second balance] lei. If one of the cards belongs to a company, the move is visible in that company's list of operations.
8. Stamps and Coupons (N)
N-21. A Stamp received
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, after a payment with the ePay card | Notice | The Stamp, the payment that produced it and the time | Law No. 284 of 22.07.2004 on information society services, art. 22 para. (2) letter c): the conditions of a promotional offer are stated clearly and without ambiguity. Terms of use, clause 9.1 |
8.1. The notification carries the text:
You have received a stamp for the payment of [amount] lei. Site: [site]. You have [x] stamps out of [y] for [reward]. Payments with a company card earn no stamps.
N-22. A Coupon issued
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App | Notice | The issue, its ground, the last date and the redemption | Law No. 284/2004, art. 22 para. (2) letter c). Terms of use, clause 9.2 |
8.2. The notification carries the text:
You have received a coupon. Reward: [reward]. Valid until: [date]. Service line: [line].
Show the code to the cashier; the code changes about every 30 seconds. The coupon is yours, is redeemed once and is not exchanged for money.
N-23. The Coupon is about to end
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, [3] (three) days before the last date | Notice | The sending and the time | Law No. 284/2004, art. 22 para. (2) letter c) |
8.3. The notification carries the text:
The coupon [reward] is valid until [date]. After that date it can no longer be used and is not extended.
9. The account and its security (N)
N-24. Telephone lost, cards frozen
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| Under Profile, Freeze the cards, and as a notification once the request has been carried out | Notice with an act of the User | The request, the channel it came through, the exact time and the list of cards stopped | Terms of use, clauses 5.5 and 5.7: the time of the request divides the payments that stay with the User from those that pass to the Seller's risk |
9.1. Before the act the screen shows:
Freezing stops all your cards, the personal one and the company ones, and closes the sessions open on any device. The money stays where it is.
Payments confirmed before your request stay yours. Payments confirmed after it are not charged to you.
[Freeze the cards]
9.2. Once it has been carried out the notification goes out:
Your cards have been frozen since [date and time]. To use them again, sign in to the app on your telephone and write to us from the app or on [SUPPORT TELEPHONE].
N-25. Sign-in on a new device
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App, on every device | Notice | The session, the kind of device and the time | Law No. 195/2024, art. 13. Terms of use, clause 5.2: only the User can recognise a device that is not his |
9.3. The notification carries the text:
Somebody signed in to your account at [date and time]. Device: [device].
If it was you, there is nothing to do. If it was not, freeze the cards under Profile and write to us on [SUPPORT TELEPHONE].
N-26. Change of telephone number
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| On the number change screen, before the code is sent | Notice | The old number, the new number, the method of confirmation, the time and the support member, where one helped | Terms of use, clauses 5.6 and 13.1: a closure request may be sent at any time. Civil Code, art. 1071 para. (1) |
9.4. The screen shows:
We will send a code to the number [new number] and ask for a confirmation on this device, by face recognition, by fingerprint or with the device code.
After the change, the account, the balance, the cards and history stay the same. The old number no longer opens the account.
If the change is made through support, because you no longer have the old device, you may send a closure request at any time. The payout of the balance and the moving of money between cards are made [24] (twenty-four) hours after the account is recovered, to protect your money.
[Send the code]
N-34. Suspension of the account or a freeze on security grounds
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| A notification on the telephone and in the App as soon as the measure is taken, and as a block on the main screen while it lasts | Notice | The measure, the category of the reason, the time, the member of staff who took it, the challenge and the answer | Terms of use, clauses 15.2, 15.3 and 15.4. Law No. 195/2024, art. 13. The measure is decided by a member of staff and not by a program, under the Privacy policy, clause 9.2 |
9.5. The notification carries the text:
We have limited the use of your account for a time. Category of the reason: [reason]. Date: [date].
The balance stays yours and is untouched. You may ask at any time for the account to be closed and the balance paid out.
The check takes no more than [10] (ten) working days and is made by a member of staff, not by a program. If the measure turns out to be unfounded, we lift it and restore your stamps and coupons.
You may challenge the measure from this notification, at dev@e-gaz.md or in writing at [OFFICE ADDRESS]. We answer within 14 (fourteen) calendar days at most.
[Challenge the measure]
10. Closing the account (N)
N-27. The request for account closure and balance payout
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| Under Profile, Close the account, before the request is sent | Notice, with an active acceptance of the cash payout; the box is never ticked in advance | The request, the time, what delayed it, the type of the identity document, its series and its last 4 (four) characters; in the cash order, the name, the number, the issuer and the date of issue of the document; no copy of the document is made | Terms of use, clauses 13.1 to 13.6. Civil Code, art. 1078 letter k): a term that burdens the exit from a contract is unfair |
10.1. The screen shows:
Account closure and balance payout.
What happens from this moment: you can no longer top up the balance. You may go on paying until the day of the payout, and the amount paid out is the balance of that day.
Stamps and coupons stop now and are cancelled when the balance is paid out. If you drop the request, they come back.
Where you come: to the office at [OFFICE ADDRESS], on the days and hours [OFFICE HOURS].
What you bring: the identity document in the name and surname of the account, and the telephone with the number of the account, because at the office you confirm a code sent by SMS.
How you get the money: the whole balance, in cash, against a cash document that you sign.
How long it takes: [10] (ten) working days at most from your request.
Company cards are deleted. The company part goes back to the company, and the part you paid yourself is set aside and follows the rule of clause 10.6 of the Terms of use. We show you the amount and the period before you send the request.
Closing costs nothing. You may drop the request at any time before the payout.
☐ I agree to receive the amount in cash at the Seller's office.
[Send the request] [Cancel]
N-28. Closing the account with a zero balance
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| In place of the text of N-27, when the Balance is zero | Notice with an act of the User | The request, the time, the end of the cooling-off period and the deletion | Law No. 195/2024, art. 17, the right to erasure. Privacy policy, clauses 11.1 and 11.5 |
10.2. The screen shows:
The balance is zero, so there is no need to come to the office. The account is deleted 14 (fourteen) days after the request, and until then you may change your mind with a single tap. Stamps and coupons are cancelled.
The accounting records of the operations are kept for the periods the law requires, with an identifier in place of the name and the telephone number.
[Send the request] [Cancel]
N-38. The deletion of the account is held up
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| In place of the send button, when something holds up the deletion | Notice | What holds up the deletion and the time it ended | Privacy policy, clause 11.2, which requires the App to show the User what is holding him up. Terms of use, clause 13.4 |
10.3. The screen shows:
The account cannot be deleted yet. What holds it up: [circumstance].
We will tell you as soon as it ends. If there is money on the balance, the account is closed with the balance paid out, at the office.
11. Complaints (N)
N-29. The complaint screen
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| Under the complaint form in the App | Notice | The complaint, the time it arrived, the registration number, the answer and its time | Law No. 105/2003, art. 9 letters g) and j) and art. 10 letters i) and j): the taking, the registration and the 14 calendar day period. Art. 25 para. (6): a refusal in writing, and silence within the period is a refusal. Art. 70 and chapter IX: the out-of-court procedure |
11.1. Under the form stands the text:
Write what happened and, if you can, pick the operation. We answer within 14 (fourteen) calendar days at most from the day the complaint reaches us. A refusal is given in writing, with the reason. If you receive no answer within the period, that is a refusal.
Money that is approved goes back to where it left from: to the balance of the ePay card or to the company card.
If the answer does not satisfy you, you may turn to the State Inspectorate for the Supervision of Non-Food Products and Consumer Protection, or to the court. You may choose the court of your own domicile. You may also ask for the out-of-court procedure, free of charge, which is run inside that same Inspectorate.
12. Information before access to the camera, to notifications and to location. The right to object (N)
12.1. The notes N-30, N-31 and N-39 appear on a screen of the App before the window of the telephone's system. The button that carries on opens the system window, and putting it off blocks nothing else in the App.
N-30. The camera
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| On a screen of the App, before the window of the telephone's system | Notice, followed by the permission given in the system window | The display of the note and the answer given in the App | Law No. 195/2024, art. 13: the purpose is named before the processing. The rules of the app stores require an explanation of the Seller's own before the system window |
12.2. The note carries the text:
The camera reads only the code on the pump, on the wash post or at the till. The images are not stored and do not reach us. If you do not give access to the camera, you may type the equipment code by hand.
[Carry on] [Not now]
N-31. Notifications
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| On a screen of the App, before the window of the telephone's system | Notice, followed by the permission given in the system window | The display of the note and the answer | Law No. 241/2007, art. 80: service messages are not direct promotion, and the text states that difference. Terms of use, clause 16.1 |
12.3. The note carries the text:
We send notifications about top-ups, payments, coupons and account security. Offers are sent only if you asked for them under Profile. You may switch notifications off at any time in the telephone's settings, and the messages stay in the app.
[Carry on] [Not now]
N-39. Location
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| On a screen of the App, before the window of the telephone's system | Notice, followed by the permission given in the system window | The display of the note and the answer | Law No. 195/2024, art. 13. Privacy policy, clause 4.3: the coordinates never reach the Seller's servers |
12.4. The note carries the text:
The position of the telephone is used only on your telephone, to sort the list of sites by distance. The coordinates are not sent to us and are not stored. If you do not give access, the list stays in alphabetical order and nothing else changes.
[Carry on] [Not now]
N-33. The right to object to promotional messages
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| On its own, apart from any other information, at the first communication with the User, and at any time under Profile, Notifications; a Company user sees the text earlier, in M-02 and in N-36 | Notice; the objection is an act of the User | The record of clause 2.1 for the objection and its time | Law No. 195/2024, art. 21 para. (2) and (4): the right to object is brought to the person's attention clearly and apart, at the latest at the first communication with him |
12.5. The text displayed:
You may object at any time to the use of your data for promotional messages. The objection takes effect at once and changes nothing else in your account.
[I object to promotional messages]
13. The information a Company gives the User (N)
N-32. Model information about Company cards
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| The Company hands it to each person, on paper, by e-mail or through its internal rules, before it adds him as a Company user | Notice given by the Company; it is not ticked and not signed | The Company keeps the proof that it handed the text over; the Seller keeps the proof that it put the model at the Company's disposal | Law No. 195/2024, art. 14, including para. (1) letter f) on transfers out of the country and para. (2) letter f) on the source of the data. Art. 7 para. (4): no consent is asked here |
13.1. The text given to the User:
Information about ePay company cards
[COMPANY'S NAME] gives you one or more company cards in the ePay app, to pay for the goods and services of the [NETWORK NAME] network at the company's expense.
Who processes the data. The company is the controller of the data about the company cards and uses it to run its vehicles, to control spending and to settle accounts. SRL "DII-TEH-GROUP" processes that data for the company and, separately, runs your account in the app as a controller in its own right.
Where we got the data. Your telephone number and the label came to us from the company. The rest of the data arises from your use of the app.
Which data. The telephone number; the label the company gives you, for example a name or a vehicle number; the company cards and the amounts on them; each payment with a company card, with the date, the time, the site, the equipment, the service and the amount.
What the company sees. Every payment made with the company cards it has issued. The company does not see your ePay card, your personal payments, your stamps, your coupons or cards issued by other companies. It sees your telephone number masked.
If you top up a company card yourself. The amount becomes the company's advance, not your balance. You will not get it back from the seller, neither in cash, nor to the balance, nor when the account is closed. The company settles with you outside ePay, and your claim lies against the company.
Where the data goes. Notifications on the telephone pass through the notification supplier and through Apple or Google, in the United States of America. The rest of the data stays on servers in the Republic of Moldova.
Ground and period. Your employment or service relationship with the company and its interest in controlling its own spending. The data is kept while you are a company user and, for accounting, for the periods the law requires.
Your rights. Access, rectification, erasure, restriction, portability and objection. You exercise them towards the company at [COMPANY CONTACT]. For the account in the app, write to dev@e-gaz.md. You may complain to the National Centre for Personal Data Protection.
What you have to do. Tell the company at once if you lose your telephone or access to your telephone number, so that it can stop the card.
14. Messages by SMS and by e-mail (M)
M-01. The SMS with the one-time code
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| By SMS, from the sender "ePay" | Service message with no marketing consent | The sending and the verification of the code, never the code itself | The message belongs to the conclusion of the contract and to the security of the account, so Law No. 241/2007, art. 80, does not apply to it |
14.1. The text of the message:
ePay code: [123456]. Valid for [5] (five) minutes. Do not give it to anybody. Our staff never ask for it.
M-02. The SMS inviting a User from a Company
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| By SMS, from the sender "ePay", at the Company's request | Service message, with no offer in the text | The Company's request, the number, the time of sending and the text | Law No. 195/2024, art. 14 and art. 21 para. (4): the source of the data and the right to object are stated at the first communication. Privacy policy, clause 12.3 |
14.2. The text of the message:
The company [COMPANY'S NAME] has given you an ePay company card. Install the app: [link]. The account opens on this telephone number. The number came to us from the company; how we use the data and how to object to promotional messages: https://epay.e-gaz.md/confidentialitate. Sender: SRL "DII-TEH-GROUP".
M-03. The letter inviting a person to the Cabinet
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| By e-mail, to the address given by the Company | Service message | The invitation, who sent it, the time and the activation | The message performs the contract with the Company; the Cabinet terms are accepted on screen C-07 |
14.3. The subject is "Invitation to the ePay company Cabinet, [COMPANY'S NAME]", and the text:
[Name of the person inviting] has invited you to the Cabinet of the company [COMPANY'S NAME], in the role of [role]. Activate the account within [7] (seven) days: [link].
On activation you will accept the Cabinet terms of use and set a password.
If you are not expecting this invitation, do not open the link and write to us at dev@e-gaz.md.
M-04. The letter for a new password
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| By e-mail, at the request of the Company staff member | Service message | The request, the time and the use of the link, never the password | The security of the account; the message carries no offer |
14.4. The text of the message:
You have asked for a new password for the ePay company Cabinet. The link is valid for one hour: [link]. If you did not ask for it, do nothing: the password stays as it is.
M-05. A message with an offer
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| Only on the channel for which the User gave the consent C-04 | Direct promotion message | The consent for the channel used, the time of sending, the text and any withdrawal | Law No. 241/2007, art. 80 para. (1) and (3): prior consent, and a refusal costs nothing. Para. (4): the sender's identity and a real address for stopping the messages |
14.5. The text of the message:
[Text of the offer, 140 (one hundred and forty) characters at most]. No longer want such messages: Profile, Notifications, reply STOP, or write to dev@e-gaz.md. SRL "DII-TEH-GROUP", https://epay.e-gaz.md.
15. The declarations for the app stores (S)
S-01. What data the App collects
| Where it appears | Kind | What is stored | Legal basis |
|---|---|---|---|
| In the privacy sections of the app stores, at every published version of the App | Notice; the declarations are given to the stores | The table declared and the date of the declaration, for every published version | Law No. 195/2024, art. 13: the information about the same processing is the same wherever it is given. Law No. 105/2003, art. 33 para. (2): a mismatch is incorrect information |
15.1. The table declared must say the same as the Privacy policy:
| Data category, as the stores name it | Collected | Linked to identity | Purpose | Passed to others |
|---|---|---|---|---|
| Telephone number | yes | yes | the account and the working of the App | no; the SMS supplier works for the Seller |
| Name and surname | yes | yes | the account, the payout of the balance at closure | no |
| E-mail address | yes, if the User adds one | yes | documents, the second verification step, the offers asked for | no; the e-mail supplier works for the Seller |
| History of purchases and payments | yes | yes | performance of the contract, accounting | the bank, only the amount and the reference; the issuing Company, only the operations on its cards |
| The Balance and its operations | yes | yes | performance of the contract | no |
| Device identifier for notifications | yes | yes | notifications | the notification supplier [Expo], Apple and Google, to deliver the notification |
| Location | no; the App sorts the list of Sites by distance on the telephone only and sends no position to the Seller's servers | not applicable | not applicable | not applicable |
| Photographs and camera | no; the code is read without keeping the image | not applicable | not applicable | not applicable |
| Biometric data | no; the face and the fingerprint stay in the telephone | not applicable | not applicable | not applicable |
| Crash reports | [yes / no] | no | stability of the App | no; the reports stay on the Seller's own server |
| Usage analytics | no | not applicable | not applicable | not applicable |
| Bank card data | no; the User enters no card in the App | not applicable | not applicable | not applicable |
15.2. The stores ask for these declarations as well: a) account deletion is requested in the App, under Profile, and from the page https://epay.e-gaz.md/delete-account; b) the Privacy policy sits at https://epay.e-gaz.md/confidentialitate, as a web page; c) nothing is sold inside the App, because the goods and services are received at a Site; d) the App starts payments through payment suppliers and grants no credit.
15.3. The table is checked with the engineers at every version of the App, above all the crash reports row, which depends on that function being switched on.