Privacy Policy
waterdrop® Hydration App
Last updated: September 2023
This Privacy Policy describes our policies and procedures for collecting, using, and disclosing your personal information when you visit and use our waterdrop® Hydration App It aims to inform you about your privacy rights and how the law protects you.
Our General Privacy Policy, which specifically describes our policies and procedures for collecting, using, and disclosing your personal information (collected when you use our website, are interested in our products, or make a purchase as a customer), can be found at: https://waterdrop.sg/pages/terms-conditions
Controller
Name and Contact Details
The controller within the meaning of the GDPR (General Data Protection Regulation), the national data protection laws of the member states and other data protection legislation is the:
Waterdrop Microdrink GmbH
Erika-Krenn Promenade 15
1100 Vienna
Austria
Email: info@waterdrop.com As a matter of principle, we only collect and use personal data of our users to the extent necessary to provide a functional waterdrop® Hydration App and to provide our services with its contents. We use your personal data to provide our services, to inform you about news and offers, to answer your questions and to operate and improve our waterdrop® Hydration App. Collection and use of your personal data when using the waterdrop® Hydration App
If you wish to make use of content and services offered by us on the waterdrop® Hydration App, it is necessary to provide personal data for this purpose. Details can be found below in the description of the specific data processing procedures.
VII Registration
The prerequisite for using the waterdrop® Hydration App is the User's membership in the waterdrop® Club (see Item 5.3. of the waterdrop® Hydration App Terms of Use). Membership is free of charge. You can register directly in the waterdrop® Hydration App and create a waterdrop® Club account. During registration in the waterdrop® Hydration App, you will be asked to accept the waterdrop® Club as well as the waterdrop® Hydration App's Terms of Use and give your consent to mandatory data processing operations (see item X.b.). These processing operations are necessary for us to provide the functionality of the waterdrop® Hydration App (in particular calculation of the personal hydration target and hydration tracker). If you do not want to give your mandatory consent, we unfortunately cannot offer you with the services of the waterdrop® Hydration App.
When registering in the waterdrop® Hydration App, you will be asked to provide your first and last name, email address, password and to select your waterdrop® Club. When you create your account, this required data is entered by you in an input mask, transmitted to us and stored.
We use this data to allow you to use the waterdrop® Hydration App and to provide the associated benefits and content. The personal data you disclose as part of the registration process is processed for the purposes of user verification, user profile management, data creation, management and updating.
The processing of your personal data within the scope of registration is based on the fulfillment of the contract (Terms of Use of the waterdrop® Hydration App) pursuant to Art 6 para 1 lit b DSGVO as well as legitimate interest pursuant to Art 6 para 1 lit f DSGVO (user support).
The data processed for the purposes of creating, managing and updating master data from the current membership in the waterdrop® Club will generally be stored for the duration of the current membership in the waterdrop® Club. After termination of membership, only data that is absolutely necessary due to the applicable legal provisions or retention obligations (UGB, ABGB, etc.) shall be stored.
VIII. Waterdrop® Club
Members of the waterdrop® Club not only get to use the waterdrop® Hydration App, but also receive exclusive offers and benefits such as club-only vouchers, collect points that can be redeemed for rewards such as unique and high-quality accessories when ordering products, and participate in exclusive competitions and challenges. The account also allows you to manage your addresses and view your purchase and order history.
For more information, please refer to our General Terms and Conditions, waterdrop® CLUB, available at https://waterdrop.sg/pages/terms-conditions
During the course of your membership in the waterdrop® Club, we collect additional data when you use your account either through our website or through the waterdrop® Hydration App (regardless of whether you have registered for the waterdrop® Club through the waterdrop® Hydration App or through our website). The following personal data is processed:
- First name, Last name
- Birthday (optional) - Email Address
- Delivery address
- Billing address
- Telephone number
- Purchase and order history, including merchandise exchange data and other order data (e.g., transaction data)
- Your personal hydration goal in the waterdrop® Hydration App
- Your hydration tracker data (drink type and quantity) in the waterdrop® Hydration App
- Loyalty points
- Payment method
- IP address of the requesting computer
- Date and time of registration (login and respective access) and password
- Usage behavior (e.g. opening and click-through rates of newsletters, responses to campaigns, use of our website) IX. Login verification
If you already have a waterdrop® Club Account, no further registration in the waterdrop® Hydration App is required. Instead, you can log in directly in the waterdrop® Hydration App using your waterdrop® Club Account login data. For this purpose, the data you enter (email address and password) will be matched with our customer database and stored.
The processing of your personal data within the scope of the login is based on the fulfillment of the contract (terms of use of the waterdrop® Hydration App) pursuant to Art 6 para 1 lit b DSGVO as well as legitimate interest pursuant to Art 6 para 1 lit f DSGVO (user support).
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. They will therefore only be stored as long as your membership in the waterdrop® Club is valid. After termination of membership, only data that is absolutely necessary due to the applicable legal provisions or retention obligations (UGB, ABGB, etc.) will be stored.
X. Individual Hydration Target/ Logging and measurement of individual drinking behavior
a) Individual Hydration Target
We customise your app experience and personal hydration goal to you individually. After registration/login, you will therefore be asked to provide the following personal data:
- Your weight
- Your date of birth
- Your gender
The data entered will be used to provide you with an accurate calculation of your personal daily hydration needs. Providing this data is optional. The more of the data is disclosed, the better the individual fluid target can be set. The data processing shown is required for the use of the waterdrop® Hydration App through its disclosed data.
The processing of personal data is based on your consent pursuant to Art 6 para 1 lit a DSGVO. The processing of your personal data by us is further based on the performance of the contract (terms of use of the waterdrop® Hydration App) pursuant to Art 6 para 1 lit b DSGVO.
The following additional information (lifestyle options) is voluntary and helps to make the individual hydration target in the waterdrop® Hydration App even more precise.
- Pregnancy (Yes/No)
- Sport (Duration)
- Breastfeeding (Yes/No)
- Intake of dehydrating drinks
- Heat
Providing this data is optional. If you provide us with this information, it will be used to adjust your personal hydration goal based on the information provided to create an even more accurate, individualised goal for you. The data processing of the disclosed data described above is required for the use of the waterdrop® Hydration App.
If the data disclosed consists of health data and thus sensitive personal data, the legal basis for the processing of this information is your express consent (Art 9 para 2 lit a DSGVO), which you give separately in the course of registering in the waterdrop® Hydration App. You can withdraw your consent or delete your contribution at any time free of charge by sending an email to privacy@waterdrop.com without stating a reason. This does not affect the lawfulness of the processing that took place until the point of consent withdrawal. Please note that further use of the waterdrop®Hydration App is no longer possible after a revocation. The aforementioned processing operations of health data are necessary for us to provide the function of the waterdrop® Hydration App (in particular, the calculation of the personal hydration target and hydration tracker).
The processing of personal data is based on your consent pursuant to Art 6 para 1 lit a DSGVO. The processing of your personal data by us is also based on the fulfilment of the contract (terms of use of the waterdrop® Hydration App) pursuant to Art 6 para 1 lit b DSGVO.
The data processed for the purposes of determining the individual hydration goal and recording the amounts of liquids are deleted as soon as they are no longer required to achieve the purpose for which they were collected. Accordingly, they are stored for as long as your membership of the waterdrop® Club remains valid. After termination of membership, only data that is absolutely necessary due to the applicable legal provisions or retention obligations (UGB, ABGB etc.) will be stored.
b) Hydration Tracker
The waterdrop® Hydration App provides a hydration tracker. In this hydration tracker, you can enter your hydration data, have an overview of your current hydration status at any time and of the amounts of fluid consumed, as well as lifestyle options that influence the fluid requirement.
Furthermore, the waterdrop®Hydration App provides user-specific evaluations of hydration data broken down by week, month and year. You can also collect so-called "levels" and "badges" based on your drinking behaviour, which in turn earns you waterdrop® Club points.
For this purpose, we store and process the data recorded by you or transmitted via LUCY® Smart Cap on the liquids drunk and the type of drinks (type, quantity and time). The hydration tracker is one of the basic functions of the app. When processing personal data necessary for the performance of a contract to which the data subject is a party, Art 6 (1) lit b DSGVO serves as the legal basis.
The data processed for these purposes will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. They will therefore be stored for as long as your membership of the waterdrop® Club remains valid. After termination of membership, only data that is absolutely necessary due to the applicable legal provisions or retention obligations (UGB, ABGB etc.) will be stored.
XI. LUCY® Smart Cap The Lucy® Smart Cap purifies water using innovative UV-C light technology, automatically tracks water consumption with a special sensor and gently flashes to remind you to drink.
The Lucy® Smart Cap only works in combination with the waterdrop® Hydration App.
If the Lucy® Smart Cap is used to track water consumption, the data on the amounts drunk (quantity, time) is transferred directly to the waterdrop® Hydration App via a Bluetooth connection and processed there in the same way as hydration data entered directly in the App (see point X.b).
XII. Apple Health
You can voluntarily activate a link to Apple Health in the waterdrop® Hydration App in the App settings. If you activate the link, we will analyse the duration of your training sessions recorded in Apple Health in order to automatically adjust the sport mode (lifestyle data) in the waterdrop® Hydration App and subsequently, your personal hydration target. Similarly, data from the waterdrop® Hydration App (amounts drunk) is also shared with Apple Health.
When activating the link, you will be redirected to the Apple Health page and asked for your consent to share and read the mentioned data. If data (training sessions completed) is received through linking with Apple Health, it will be processed in the same way as the lifestyle data entered directly in the waterdrop® Hydration App (see point X.a).
The processing of personal data is voluntary and based on your consent in accordance with Art 6 Para 1 lit a DSGVO. You can withdraw your consent at any time by removing the link between the waterdrop® Hydration App and the Apple Health App in your app.
The Apple Health privacy policy is available at: https://www.apple.com/de/legal/privacy/data/de/health-app/.
XIII Monitoring and Analysis
Firebase Crashlytics:
In order to detect, analyse and fix bugs in the App, we use Firebase Crashlytics, a service provided by Google Ireland Limited, Gordon House, 4 Barrow Street, D04 E5W5 Dublin, Ireland ("Google").
Firebase Crashlytics receives real-time crash reports detailing the state of the app, code locations, device information and recent log file messages. This information helps us to facilitate app maintenance and improve stability. If the app crashes, certain information about the crash such as time of crash, device type, operating system, and other technical data from your mobile device is sent to Firebase Crashlytics. These crash reports do not contain IP addresses or other personal data.
These services and technologies are necessary to ensure central functions of the waterdrop® Hydration App, as well as the fulfilment of contracts with users. Furthermore, we have a legitimate interest in the use of these technologies for the technically error-free and optimised provision of our service. The use is based on the legal grounds of Art 6 (1) (b) (fulfilment of contract) and Art 6 (1) (f) DSGVO (overriding legitimate interests).
Google acts as an order processor and we have concluded a corresponding contract with Google. The user ID generated by Firebase Crashlytics is usually transferred to a Google server in the USA and processed there. For these cases, Google has, according to its own statements, imposed a standard on itself that corresponds to the former EU-US Privacy Shield and has promised to comply with applicable data protection laws in the international transfer of data. Google has also voluntarily joined the EU-U.S. Data Privacy Framework, a data protection agreement between the EU and the U.S. for which the European Commission has issued an adequacy decision. We have also agreed on so-called standard contractual clauses with Google, the purpose of which is to ensure compliance with an adequate level of data protection in the third country (see point XV).
Further information on data processing when using Firebase Crashlytics can be found in the Google Firebase privacy policy: https://firebase.google.com/support/privacy?hl=de.
XIV. Categories of recipients
IT service provider
We work with technical service providers and IT tool providers to deliver our services to you. These service providers include, for example, external IT service providers that enable the technical provision of our website and customer management (e.g. Shopify), as well as providers of various IT tools and software as a service (e.g. Klaviyo). The main service providers or suppliers are:
Web presence and customer management:
- Shopify: Our web presence, including provision of the website and web shop, as well as customer management is operated through Shopify. Shopify offers a complete e- Customer Management and Support:
- Klaviyo: for customer management, sending messages by email and user analysis we use the services of Klaviyo, Inc, 125 Summer Street, Boston MA, 02111, USA ("Klaviyo"). More information about the provider can be found at https://www.klaviyo.com/legal.
Klaviyo helps us analyse the use of our waterdrop® Hydration App. Certain usage data, such as information about individual hydration goals, usage patterns, records of quantities drunk and types of drinks, purchase and order history in the web shop, as well as details about how individuals interact with our emails (e.g. whether the email is opened and which links in the email are clicked on), are linked to you (e.g. after entry in a registration form) and stored in our customer database ("CRM"). This enables us to send you information and offers tailored to your interests. This transfer is carried out in accordance with Art 6 (1) f DSGVO and serves our legitimate interest in the use of an effective, secure and user-friendly customer management and newsletter system. In the process, your personal data may also be forwarded to Klaviyo servers in the United States (USA). In order to ensure an appropriate level of protection for your data in the USA, we have concluded a data processing agreement with Klaviyo, in which Klaviyo undertakes to protect the data of our users, to process it only on our behalf and, in particular, not pass it on to third parties. The standard contractual clauses of the EU Commission are part of the data processing agreement (see point XV.). In addition, Klaviyo undertakes to implement supplementary measures. Klaviyo has also voluntarily joined the "EU-U.S. Data Privacy Framework", a data protection agreement between the EU and the USA, for which the European Commission has issued an adequacy decision.
More information on the collection and use of personal data can be found in Klaviyo's Privacy Policy at https://www.klaviyo.com/legal/privacy/privacy-notice, as well as in the Data Processing Agreement at https://www.klaviyo.com/legal/data-processing-agreement. An overview can be found in Klaviyo's Privacy Center: https://www.klaviyo.com/legal/privacy.
- Firebase Cloud Firestore: For the transfer of data into the Klaviyo customer management tool, we use Firebase Cloud Firestore, a web hosting and backend service provided by Google Ireland Limited, Gordon House, 4 Barrow Street, D04 E5W5 Dublin, Ireland ("Google").
Google acts as a processor and we have entered into a contract with Google to this effect. Your personal data may be transmitted to a Google server in the USA and processed there. For these cases, Google has, according to its own statements, imposed a standard on itself that corresponds to the former EU-US Privacy Shield and has promised to comply with applicable data protection laws when transferring data internationally. Google has also voluntarily joined the EU-U.S. Data Privacy Framework, a data protection agreement between the EU and the U.S. for which the European Commission has issued an adequacy decision. We have also agreed on so-called standard contractual clauses with Google, the purpose of which is to ensure compliance with an adequate level of data protection in the third country (see point XV).
The data processing and security provisions of Firebase Cloud Firestore can be found here: https://firebase.google.com/terms/data-processing-terms.
Marketing partner
- LoyaltyLion: to enable you to join the loyalty programme, which is part of the waterdrop® Club, we use a service provided by LoyaltyLion Ltd, a UK provider with registered offices at 165 Fleet Street London, UK ("LoyaltyLion"). LoyaltyLion is a tool through which we provide loyalty points and give our customers the opportunity to receive rewards. For more information, please visit https://loyaltylion.com/terms-of-service.
For this purpose, the data provided by you and other data required to manage your loyalty points will be passed on to LoyaltyLion so that XXI. Relevance and Amendment of this Privacy Policy
This Privacy Policy is current as of September 2023. We may update our Privacy Policy from time to time. Changes may be necessary due to the further development of our websites, apps and offers or due to changes in legal or regulatory requirements.
We will notify you of any changes by posting the new version of the Privacy Policy on this page. You can access and print out the current version of the data protection regulations at any time on this page. The date of the "last update" can be found at the beginning of the data protection regulations.
We will inform you by email and/or by means of a clearly visible notice on our service if there are significant changes to this data protection regulation before the change comes into force. We encourage you to periodically review this Privacy Policy for changes. Changes will take effect from the time they are posted on this page.
