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Privacy Policy

Privacy Policy

Last updated: 11/2020

This privacy policy informs about the purpose, scope, processing term and rights of the data subject (“User”) of personal data processing, arising from using the online store (“Website”) and registering in it.

We care about the protection of your privacy rights and personal data and therefore process personal data in accordance with the applicable legislation – Regulation (EU) 2016/679 of the European Parliament and of the Council (April 27, 2016) on the protection of natural persons with regard to the processing of personal data and free movement of such data and which repeals Directive 95/46/EC (General Data Protection Regulation) (“Regulation”), as well as other laws governing privacy and data processing issues.

Manager and its contact information

The controller of personal data is SIA “ADE” (Reg. No. 40003072265), Lāčplēša iela 87a, Riga, LV-1011 (“we, us”).

A complaint or question about the processing of personal data can be sent to our data protection officer by sending it to:

Categories of personal data

The categories of personal data that the Website mostly collects and processes are:

For purchase registration and product delivery:

  • identification data – name, surname;
  • contact information – delivery address, telephone number, e-mail address;
  • IP address.
  • By visiting and using the features offered by the Website:
  • IP address;
  • Name and e-mail for communication at the user’s request.

Why do we store and process your data?

Your data is processed for the following purposes:

  • Account registration;
  • Delivery of ordered products;
  • Signing up to receive news;
  • Preparation of anonymous statistics on the use of the Website;
  • Maintaining and improving the website;
  • Marketing communication needs;
  • Handling of complaints, suggestions and questions.

When processing User data, we use the latest modern technological possibilities, evaluate privacy risks and apply the organizational, financial and technical resources available to us, which are necessary for safe processing of personal data in accordance with the principles set out in the Regulation.

Our employees and contractors use the data only for the above purposes.

Basics of personal data processing

The website processes Users’ personal data only on the basis of the following legal grounds for data processing:

  1. User’s consent to the processing of their personal data for one or more specific purposes;
  2. data processing is necessary for concluding a contract with the User or for its execution, or for taking measures at the User’s request before concluding the contract;
  3. data processing is necessary to fulfill a legal obligation applicable to the Website;
  4. data processing is necessary to protect the vital interests of the User or another natural person;
  5. Data processing is necessary to fulfill a task carried out in the public interest or in the exercise of official powers legally granted to the Site;
  6. Data processing is necessary for the legitimate interests of the Website or a third party.

Period of storage of personal data

The obtained personal data will be stored in secure cloud computing and server solutions that ensure data processing in the EU and EEA territories.

We store the obtained personal data until:

  • the data is necessary for the purpose for which it was received;
  • The User or the Website can realize their legitimate interests in accordance with the procedures specified in the regulatory enactments (submit objections or file a lawsuit);
  • there is a legal obligation to store personal data;
  • the User’s consent to the relevant personal data processing is valid, if there is no other legal basis for data processing.

We store User accounts registered on the Website, as well as data posted in them in accordance with the regulations, as well as for 7 years after the User’s last order. At the end of the mentioned term, the Website sends a warning to the Users about the deletion of the personal data in the account and/or the created account.

Transfer of data to third parties

We do not disclose Users’ personal data to third parties, except for:

  • in accordance with the clear and unequivocal consent of the User;
  • for the persons provided for in the regulatory acts, in the manner and to the extent specified in them;
  • for the protection of legitimate interests in cases specified in regulatory acts.

We guarantee that we always cooperate only with reliable partners that ensure compliance with the requirements of the Regulation.

Personal data processors who process User data when providing services to us:

Type of service

Data types

Transfer of data to third countries


Online store platform

All data entered by Users

Data is transferred outside the EU:

US: insufficient level of protection provided (repealed EU-U.S. Privacy Shield Framework)

Online store and delivery provider

All data entered by Users

Data is not transferred outside the EU

Payment system

Data required for payment

Data is not transferred outside the EU

Administrative process and record keeping solution

All data entered by users

Data is transferred outside the EU:

US: insufficient level of protection provided (repealed EU-U.S. Privacy Shield Framework)

Newsletter Marketing Tool

IP address, email

Data is transferred outside the EU:

US: insufficient level of protection provided (repealed EU-U.S. Privacy Shield Framework)

Taking into account the changing composition of personal data processors, the Website does not publish a list of such service providers, but you have the right to contact the Website with a request to provide such information (see “Questions, submissions and complaints handling” section).

How can you access, verify and correct your data?

You have the right to request information about your personal data at any time, check the correctness of the stored information and/or correct or update this information. You can also ask for the complete deletion of your personal data if they are not required for further processing.

We will use commercially reasonable efforts to provide you with appropriate access to any of your personal data within 1 month of receiving your request.

To protect your privacy and security, we will take appropriate steps to verify your identity before providing information about your requested personal data.


“Cookies” are small pieces of information that a website stores on your computer or mobile device when you visit a website. It allows the server to collect information from your browser, so you don’t always have to re-enter the data when you return to the website or move from one page to another. More information about how cookies work is available at

How do we use cookies?

Our Website uses cookies to improve the quality of the services offered, as well as to perform anonymous statistics on the use of the Website and the analysis of the obtained data for marketing purposes. We use mandatory cookies, session cookies and analytical cookies (first and third party (partner) cookies) to:

  • ensure the security of the Site and manage it;
  • remember whether you have (or have not) consented to the use of cookies on this website;
  • help measure the effectiveness of the marketing campaign;
  • collect Website usage information that allows us to measure how well the Website meets Users’ needs, its effectiveness and to make any necessary improvements;
  • analyze which pages of the Website you visit.

Some cookies may be placed by third parties – a service provider that performs certain functions for our needs (e.g. Facebook, Google, Yandex Metrics).

Personal data and its transfer

Information related to cookies is not used to identify you personally. These cookies are not used for any purposes other than those described here.

We may provide your data to third parties who provide us with services, for example for Website analytics or customer service. These persons are authorized to use your data only to the extent necessary to provide us with these services.

We will provide your data to third parties only as described in this Privacy Policy. We do not sell your data to third parties in any way.

How to control cookies?

You can control and manage cookies in your browser settings. You can delete or block any cookies that are already on your computer, but if you do, certain features of this Site may not work as intended and you may have to manually adjust certain preferences each time you visit the Site.

If the user does not agree to the use of cookies for the Website’s marketing and analytics purposes, the Website does not process this information, however, we inform you that the Website also uses cookies that do not require the user’s consent.

Consideration of questions, submissions and complaints

Users can send their questions about general data protection issues or about the processing of their personal data to the Site’s data protection specialist to:

We will inform you without undue delay and in any case within 1 month after receiving the User’s request about the action performed at the User’s request in accordance with the requirements of the law. If necessary, the mentioned period can be extended for another two months, taking into account the complexity and number of requests.

Data State Inspectorate

If you believe that we violate your legal rights or the rules of processing your personal data, you can file a complaint with the State Data Inspectorate, located at the address: Blaumaņa iela 14, Rīga, tel. 67223131, e-mail:

Privacy Policy

This Privacy Policy explains our data processing practices and your rights regarding the ways in which personal data is collected and used.

By installing our mobile application or in any way using or accessing our Services, you accept the terms and conditions of this Privacy Policy and the processing of your personal data.

Data transfer

With the services you need, we can transfer your data to individuals and legal entities (data controllers) to perform separate processing operations on our behalf.

Usually, we do not transfer your data to third parties, but in cases where you express your consent, we may transfer your data to our trusted partners.

In the cases provided by law, your data may be disclosed to law enforcement authorities and other competent state or local authorities upon request, or in defense of our legal interests, in relation to claims against us.

Protection on personal data

Privacy policy on protection of personal data have been developed and implemented based on Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (hereinafter referred to as the Regulation).

The purpose of the data processing – PickAqua application services.

Your data are collected to:

•        enable the personalization of your access to the system;

•        enable PickAqua to answer your enquiries and give you information;

•        prepare anonymous statistics on the usage of the website;

•        provide the Services;

•        renew subscription services;

•        provide customer support;

•        analyze the characteristics of our users in order to understand the user and his needs, to design and develop new services, and for marketing communications.

•        When you purchase from we need to know your name and mailing address and credit or debit card number and expiry date, and your e-mail address and telephone number, together with any other information that we need to process your transaction.

•        From time to time, we may also use your information to contact you for market research purposes.

Collected personal data are treated according to the policy described in the Regulation.

Data will be used only for the above purposes.

Who is responsible for the processing of your data?

The Controller responsible for the processing of personal data is a legal or natural person which entered into Agreement with Pick Aqua by signing the contract or by accepting all terms and conditions available on Pick Aqua in order to receive services provided by Pick Aqua.

What data do we collect?

Registered user name, email, height, weight, date of birth, gender, first and last name/company name, IP, identification number of device, IP-address etc.  location. If you purchase something from Pick Aqua we will collect all necessary data to fulfill your order.

In an ongoing effort to improve our Services, additional personal data may be collected from you. It follows from the nature of the Services that we must process such data that you upload to the Services to enable the Services, for example, we will process your weight data and calorie intake to enable the hydration monitoring and presentation of your personal goals. This processing is a pre-requisite for our water calculator being able to offer the Services to you.

If you connect to the Services using a Third-Party Application (e.g., Apple HealthKit, Facebook) Pick Aqua will collect and use your personal information from such Third Party Applications such as your username, name, profile picture, country, hometown, email address, date of birth, gender as well as such health data that you choose to synchronize with Pick Aqua Services.

Some of the data mentioned above, collected from you and processed by Pick Aqua for certain features of the Services, is possible for us to delete and cease processing for the future if you so require, without you having to terminate your use of the entire Services, i.e., not all data (submitted over time by you to us either directly or through third-party services) is required for you to still be able to use the Services. If you want us to cease processing certain data about you under this category, we will inform about the consequences of such cease, i.e., how it will affect your use of the features of the Services.

Barcode Scanner 

This section is used for quick search of specific water using a barcode on the bottle. In order for this feature to work properly, we need to access your smartphone’s camera at the moment when the bottle is being scanned. The camera only scans the barcode on the bottle and identifies it with a certain brand of water by comparing the scanned barcode in our database. No photo or video content is being collected.


Pick Aqua uses cookies in order to function properly. We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device for a set period of time or until you delete them).

If your internet browser is set and configured to accept cookies, you consent to the use of cookies.

A cookie is a small text file which is created by the websites you visit and may contain information about you as a visitor. These text files are stored on your computer and, for instance, keep you from having to remember your password. Information from cookies may be used to improve the user experience and/or the Services and to target marketing campaigns and offers to our customers.

If you do not accept cookies, you can prevent cookies from being saved on your computer by changing the settings of your web browser. You can also delete cookies which have been previously stored. In such cases, please refer to the help section of your internet browser. If you choose not to accept cookies, you can still use our Services, but their functionality may be somewhat limited.

Marketing – legitimate interest

Pick Aqua may use your personal data for profiling and marketing purposes via emails, notifications, or other messages, by Pick Aqua or Pick Aqua selected business partners. Profiling will be used for marketing purposes to enable personalized and relevant offers to you, based on your preferences. The use of personal data for marketing purposes will only concern such offers that have a close relation to your use of the Service and the offers will be sent to you by Pick Aqua.

Opt-out from marketing

In case you do not want Pick Aqua to use your personal data for the purpose of marketing, you may at any time unsubscribe from any further messages by clicking the “unsubscribe” link at the bottom of such a message, or by using such opt-out features as are available in the app settings in the Services.

How long do we store your data?

We will retain personal information, customer and business information for as long as it is required by law and needed to:

•        Provide services and information that you or your company have requested;

•        To communicate with you about a request you have submitted to us;

•        To manage your choices and rights you have exercised pursuant to this Privacy Policy.

How can you access to your data, check its accuracy and correct it?

You have the right to request a copy of your personal details at any time, to check the accuracy of the information held and/or to correct or update this information. You may also ask your personal information to be deleted completely if you are not using Pick Aqua services anymore or no enquiry from you or the company you are working for is in progress by sending an email to

To protect your privacy and security, we will take reasonable measures to verify your identity before providing you the requested information on personal data.

How we share your personal information?

Your privacy is important to us and we will only process your personal data in accordance with this Privacy Policy and relevant personal data regulation.

We may make your personal information, customer information, or business information available to companies that provide services to help us with our business activities, such as website analytics or offering customer service. These companies are authorized to use your personal information, customer information, or business information only as necessary to provide these services to us.

We will share your personal information or business information with third parties only in the ways that are described in this Privacy Policy. We do not otherwise sell your personally information to third parties. We choose only trustful partners with whom we sign the contracts considering conditions specified herein.

What are the contact points for questions or complaint?

The Processor responsible for processing personal data to whom inquiries or complaints in case of conflict can be addresses –

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