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Privacy Policy

DrinkThis… Mobile Application

Brand: DrinkThis…

Company: Reso Health Ltd

Effective date: 4th March 2026

1. Introduction

Reso Health Ltd ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use the DrinkThis… mobile application (the "App").
This Privacy Policy should be read together with the DrinkThis… App Terms and Conditions, which govern your use of the App. Capitalised terms not defined in this Privacy Policy have the meanings given to them in the Terms and Conditions.
This Privacy Policy applies to users located in Ireland, the European Union (EU), and the United Kingdom (UK).

2. Data Controller

For the purposes of applicable data protection law, including the EU General Data Protection
Regulation (EU GDPR) and the UK GDPR, the data controller is:
Reso Health Ltd
Unit 1 Riverstown Business Park, Tramore, Co. Waterford, X91 A6NT
Company Registration Number: 700050
Email: privacy@drinkthis.ie

3. What Personal Data We Collect

3.1 Account and contact information
We may collect your name, username, email address, account identifiers, sign-in details, and records relating to your account.


3.2 One-time editable assessment information
We may collect information you choose to provide when creating or updating your Drink This baseline or profile, including demographic information, lifestyle information, diet and activity information, preferences, goals, and other profile inputs that help us understand who you are for Drink This purposes.


3.3 Daily calibration information
We may collect information you choose to provide in daily calibration or similar check-ins that helps us understand how you are at a particular point in time, including current-state inputs, recent activity inputs, preferences, responses, and related calibration data.
 

3.4 Personalised output and dispense information
We may collect records of personalised outputs, recommendation history, dispense selections, dispense events, formulation parameters, and related service history linked to your account or device.

3.5 Machine pairing and hardware interaction information
When you use compatible dispensing hardware, we may process QR scan results, NFC scan results, machine identifiers, pairing session identifiers, timestamps, and other technical records required to pair your mobile device with the machine and enable dispensing.

3.6 Camera and QR pairing data
If you choose to use QR pairing, the App may access your device camera to scan a QR code displayed on compatible Drink This dispensing hardware. We use the scan result to pair your mobile device with the machine. We do not retain raw camera images after the QR code has been read. We may retain the result of the scan, such as the machine identifier, time of pairing, and related session logs.


3.7 NFC pairing data
If you choose to use NFC pairing, the App may access your device's NFC hardware to scan a compatible NFC tag on Drink This dispensing hardware. We use the scan result to pair your mobile device with the machine. We may retain the result of the scan, such as the machine identifier, time of pairing, and related session logs.


3.8 Information collected automatically
We may collect technical and usage information such as device model, operating system, app version, IP address, approximate location derived from IP, timestamps, crash reports, diagnostics, error logs, and in-app usage events.


3.9 Support and communications
We may collect information you provide when contacting support, completing surveys, participating in pilots, or otherwise communicating with us.


3.10 Information from third parties
If you choose to connect or use third-party services with Drink This, we may receive limited information from those services to support the relevant feature. We will tell you about that data flow at the point of connection where required.

4. How We Collect Personal Data

We collect personal data directly from you when you create an account, complete the one-time editable assessment, submit daily calibration inputs, use camera or NFC pairing, contact support, or otherwise interact with the App.
We also collect certain technical and usage data automatically through the App, backend services, logs, and software development kits used for security, analytics, and service operation. In some cases, we may receive data from trusted service providers or optional integrations that you
choose to connect.

5. How We Use Personal Data

We use personal data to:

  • Create and manage your account;

  • Create and maintain your baseline or profile;

  • Process daily calibration inputs;

  • Generate and update personalised precision nutrition outputs, including suggested nutrients, minerals, botanicals, and related formulation or dispense outputs;

  • Pair your mobile device with compatible dispensing hardware using QR or NFC;

  • Provide dispense history, service history, and app functionality;

  • Operate, maintain, troubleshoot, secure, and improve the App and related services;

  • Respond to support requests and service communications;

  • Monitor performance, reliability, fraud, misuse, and abuse; and

  • Comply with legal and regulatory obligations.

6. Automated Processing and Personalisation

This App uses your one-time editable assessment together with your daily calibration to create, update, and apply your Drink This baseline and current-state profile. We use rules-based and/or automated processing to generate personalised precision nutrition outputs and related drink recommendations or dispensing outcomes. In practical terms, this means the information you provide affects what the App recommends or dispenses for you. At present, this personalisation is not intended to make decisions that produce legal effects or similarly significant effects on you. If that changes, we will update our notices and controls as required by law. If you want us to review baseline inputs, update your daily calibration inputs, or explain available choices in the App, you can do that through the App experience or by contacting us.

7. Legal Bases for Processing

Depending on the context, we rely on one or more of the following legal bases:

  • Performance of a contract: to provide the App, account features, profile creation, calibration, personalisation outputs, hardware pairing, and related service you ask us to provide;

  • Consent: for optional permissions and features, including camera access, NFC access, optional marketing where used, and any processing where consent is required by applicable law;

  • Legitimate interests: to keep the service secure, prevent misuse, improve reliability, understand app performance, operate our business, and provide support, provided our interests are not overridden by your rights and freedoms; and

  • Legal obligation: where we must process personal data to comply with applicable law, regulatory requirements, court orders, or lawful requests.

8. Sensitive Personal Data and Explicit Consent

Some information you choose to provide through baseline creation, daily calibration, preferences, or personalised outputs may be sensitive personal data under applicable law, or may permit sensitive inferences about you depending on the content and context. Where applicable law requires it, we will rely on your explicit consent before processing that information for the relevant purpose. You can withdraw consent at any time through in-app settings where available, by changing device permissions, or by contacting us at privacy@drinkthis.ie. If you withdraw consent, this will not affect processing already carried out lawfully before withdrawal, but it may limit features that depend on that information.

9. Sharing of Personal Data

We do not sell your personal data.
We may share personal data with the following categories of recipients where necessary:

  • Cloud hosting, database, storage, authentication, and infrastructure providers;

  • Analytics, diagnostics, customer support, communications, and security providers;

  • Professional advisers such as lawyers, auditors, and insurers;

  • Regulators, law enforcement, courts, and other public authorities where required by law or to protect legal rights;

  • A buyer, investor, or successor organisation in connection with a merger, acquisition, financing, or business transfer, subject to appropriate confidentiality and data protection safeguards.

 

Where we share data with processors or service providers, we require them to process the data only on our documented instructions and to protect it to a standard consistent with this Privacy Policy and applicable law.

10. International Transfers

Some of our service providers may process personal data outside Ireland, the EEA, or the UK. Where personal data is transferred internationally, we use appropriate safeguards as required by applicable law, such as adequacy regulations, standard contractual clauses, the UK International Data Transfer Agreement or addendum, or another lawful transfer mechanism.

11. Data Retention

We keep personal data only for as long as needed for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Our standard approach is to retain:

  • Account and profile data while your account remains active and for a limited period afterwards to complete deletion requests, resolve disputes, or comply with legal obligations;

  • Daily calibration, personalised output, and dispense history while needed to provide the service and maintain your account experience;

  • Pairing, security, and technical logs for a limited period appropriate for security, troubleshooting, fraud prevention, and audit requirements;

  • Support records for as long as needed to manage the support issue and related follow-up.

 

Where possible, we delete or anonymise personal data when it is no longer needed.

12. Analytics, Tracking, and Marketing

We may use analytics and diagnostics tools to understand how the App performs and how users interact with core features. We do not use baseline, calibration, personalised output, camera-derived, or NFC-derived data for targeted advertising or sale to data brokers. Where tracking, optional analytics, or direct marketing consent is required by law, we will ask for it and provide a way to manage your choices.

13. Your Choices and Rights

Subject to applicable law, you may have the right to:

  • access your personal data;

  • correct inaccurate or incomplete personal data;

  • request deletion of personal data;

  • restrict or object to certain processing;

  • request portability of data you provided to us;

  • withdraw consent at any time where we rely on consent;

  • request information about automated processing where applicable; and

  • lodge a complaint with a supervisory authority.

 

For users in Ireland, the supervisory authority is the Data Protection Commission. For users in the UK, the supervisory authority is the Information Commissioner's Office.

14. Account Deletion and Data Deletion

If you have an account, you may request account deletion within the App or by contacting us.
Deleting your account will remove or anonymise personal data associated with the account unless we need to keep certain data for legal, security, fraud prevention, accounting, or dispute-resolution reasons. If some information must be retained, we will keep it only for the period and purpose permitted by law.

15. Security

We use appropriate technical and organisational measures designed to protect personal data, including access controls, encryption in transit, secure secret handling, role-based access, environment separation, logging controls, private-by-default storage where applicable, and ongoing security and vulnerability management. No transmission or storage is completely secure, so we cannot guarantee absolute security.

16. Children

The App is intended for adults and is not directed to children under 18 years of age. We do not knowingly collect personal data from children. If you believe that a child has provided personal data to us, please contact us and we will take appropriate steps.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the App, by email, or by another appropriate method before or when the change takes effect. The effective date at the top of this Privacy Policy shows when it was last updated.

18. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact:
Reso Health Ltd
Email: privacy@drinkthis.ie

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