Privacy Policy

1. General

What is this privacy policy and who is your data controller?

In this privacy policy (the "Privacy Policy") we, UAB "Spine Revolution", company code 306210193 ("Company", "we", "us" or "our"), explain how we, as a data controller, handle your Personal data (the "Personal data") when you visit our website/websites (the "Website"), use our mobile app/apps (the "Mobile App"), contact us through our official social media pages or email, and/or use our services.

If you purchase multiple products through our website, please note that the privacy policies of all such products will apply. In the event of any discrepancy or conflict between this Privacy Policy and the privacy policy of any specific product, the terms of the product-specific privacy policy shall take precedence with respect to that product.

What are personal data?

We care about the safety and security of your Personal data and make every effort to ensure it. Personal data refer to any information relating to an identified or identifiable natural person (e.g. your name, email address, etc.).

When processing your Personal data, the Company is guided by and complies with General Data Protection Regulation 2016/679 (the "GDPR"), California Consumer Privacy Act and any other applicable statutory regulations governing the protection of your Personal data.

All the definitions used in this Privacy Policy have the same meaning as prescribed in the Company's General Terms and Conditions unless expressly provided otherwise in this Privacy Policy.

Do you have any questions or inquiries related to privacy?

In case of any questions or inquiries, or in case you would like to exercise any of your rights provided in this Privacy Policy, you may submit such inquiries and requests by means provided in the Contacts section of this Privacy Policy and/or you may also contact our Data Protection Officer regarding all privacy related issues by email: team@pickcell.gg

2. What Information Will You Find in This Privacy Policy?

In this Privacy Policy you will find information about:

• Personal data processing principles we follow (Section 3);
• Personal data we collect, processing purposes, legal grounds and retention periods (Section 4);
• Personal data retention periods (Section 5);
• To whom we provide your Personal data (Section 6);
• Direct marketing and other marketing operations (Sections 7 and 8);
• AI tools (Section 9);
• Security of your Personal data (Section 10);
• Your rights related to Personal data you possess (Section 11);
• Other privacy matters that you should take into account (Sections 12–18).

3. What Data Processing Principles Do We Follow?

We adhere to the general data processing principles established in the relevant privacy legal acts, including, but not limited to the following principles:

Lawfulness, fairness and transparency – we process Personal data in a lawful, fair and transparent manner.

Purpose limitation – we process Personal data for specified, explicit and legitimate purposes and we do not further process in a manner incompatible with those purposes.

Data minimization – we process Personal data that are appropriate, relevant and only necessary for the purposes for which they are processed.

Accuracy – we process accurate and updated Personal data.

Limitation of storage period – we keep Personal data in a form which permits identification of you for no longer than is necessary for the purposes for which the Personal data are processed.

Integrity and confidentiality – we process Personal data in such a way as to ensure, through appropriate technical or organisational measures, adequate security of Personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.

4. Personal Data We Collect, Purposes, Legal Grounds and Retention Periods

We process the following Personal data for the purpose of:

Personalized plan: To offer a personalized plan for you, we may process test quiz data (such may include sensitive Personal data related to your health, your age, height, weight, target weight). We obtain such data directly from you. The legal basis is your consent (Art. 6(1)(a) GDPR). You may withdraw consent at any time. Data retained for no longer than 2 years following your last account update or until you withdraw consent.

Subscription and service provision: We may process your name, surname, email address, phone number, certain bank account details and transaction details, purchase history, and other data you provide while registering. The legal basis is performance of a contract (Art. 6(1)(b) GDPR). Data retained for no longer than 5 years following the end of the respective services, unless law requires longer retention.

Email messages and newsletters: We may process your email address and purchase history. The legal basis is your consent (Art. 6(1)(a) GDPR). You may withdraw consent at any time. Data retained for no longer than 2 years following consent or end of services.

Customer service: We may process your email address, content of requests, metadata, and other account information necessary to fulfill your request. The legal basis is your consent (Art. 6(1)(a) GDPR) or our legitimate interest (Art. 6(1)(f) GDPR). Data retained for no longer than 3 years following consent or as long as necessary for legitimate interest purposes.

We may utilize third-party AI tools to automate and optimize the processing of customer requests submitted through email or a customer support chatbot. These tools may analyze and interpret the information provided by customers, categorize support requests, and generate answers. By contacting our customer support, you acknowledge and agree to the processing of health-related information through AI tools for effective customer support.

We may employ automated decision-making processes (including refund requests). You have the right to request human intervention in the decision-making process.

Social media: We may process profile names, photos, and reactions to our content from users who interact with us through social media pages. The legal basis is your consent (Art. 6(1)(a) GDPR) or our legitimate interest (Art. 6(1)(f) GDPR). Data retained as long as the relevant social network account is valid.

Website and App administration: We may process device data including IP address, geographical location, browser type and version, operating system, device type, screen resolution, and usage information. We obtain such data using cookies and similar technologies. The legal basis is your consent (Art. 6(1)(b) GDPR) or our legitimate interest (Art. 6(1)(f) GDPR). Data retained for no longer than 2 years.

Legal claims: We may process Personal data necessary for the establishment, exercise or defence of legal claims. The legal basis is legal obligation and/or our legitimate interests (Art. 6(1)(e), Art. 6(1)(f) GDPR). Data retained as long as necessary.

Insurance and risk management: We may process Personal data necessary for obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis is our legitimate interests (Art. 6(1)(f) GDPR) and/or legal obligation (Art. 6(1)(e) GDPR).

Legal compliance: We may process Personal data necessary to comply with specific legal obligations (Art. 6(1)(e) GDPR). Data retained as long as required by applicable legal acts.

5. How Long Do We Store Your Personal Data?

Your Personal data shall not be kept longer than is necessary for the specific purpose. Specific retention terms are specified in Section 4 of this Privacy Policy.

After the end of the applicable retention period, or upon your request, Personal data are destroyed using overwriting or physical destruction methods.

We may aggregate, anonymize or de-identify your Personal data so that it cannot reasonably be used to identify you. Such data is no longer personal and we may use it without restriction.

We may retain your Personal data where retention is necessary for compliance with a legal obligation or to protect our interest (e.g. exercise or defense of legal claims).

6. To Whom Do We Provide Your Personal Data?

We may disclose your Personal data to any member of our group of companies insofar as reasonably necessary for the purposes set out in this Privacy Policy.

Subject to your consent or on the basis of the performance of a contract, we may share your account data across different products within our Group of companies.

We may disclose your Personal data to our insurers, bailiffs, auditors, attorneys, notaries and/or other professional advisers insofar as reasonably necessary.

We may disclose your Personal data to anti-fraud, risk and compliance providers insofar as reasonably necessary for protecting your Personal data and fulfilling legal obligations.

We may disclose your Personal data to AI service providers insofar as reasonably necessary for AI chatbot or customer support functionalities.

We use third-party payment processor services. We do not collect and store card information. Your card information will be directly received by the specific payment service provider as a data controller. We only receive payment status and store only the last 4 digits of your card.

We may disclose your Personal data to other service providers insofar as reasonably necessary to provide specific services. We conclude necessary data processing agreements with those third parties.

We may disclose your Personal data where such disclosure is necessary for compliance with a legal obligation (e.g., by lawful request of law enforcement authorities).

Persons indicated in this Section may be established outside the Republic of Lithuania, the EU and the EEA. In such cases, we will take all necessary measures to ensure your privacy remains properly secured, including where appropriate, signing European Commission approved Standard Contractual Clauses.

7. Direct Marketing Communication

We may contact you via email or phone to inform you about our products and services, special offers, and marketing campaigns. You have a right to object to such processing at any time.

We may share your contact information with our group companies for direct marketing purposes.

We may use your Personal data to personalize marketing messages and advertisements presented to you. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR).

You may opt out of receiving marketing communications at any time by choosing the relevant link in our marketing messages or contacting us via email. The opt-out will not stop communications directly related to the provision of services.

8. Other Marketing Operations and Cookies

We may use marketing tools of social media platform operators (e.g. Google LLC, Meta Platforms Inc.) or other third parties and share your Personal data relevant for marketing operations.

For EU residents: Social media platform operators may be established outside the EU and EEA. Your Personal data will be protected by Standard Contractual Clauses approved by the European Commission.

We also use cookies. More information about cookies can be found in our Cookie Policy, accessible via our Website.

Telemarketing: We may contact you via phone on the basis of Established Business Relationship Rule (TCPA § 310.4(b)(iii)(B)) to check on your order status. Phone calls may be automatically recorded, and the record will be stored for 5 years as required by applicable legislation. You may opt-out from telemarketing calls at any time.

9. AI Tools

If you consent, we will use your Personal data to enhance your experience with our AI assistant. This includes tracking your logged meals to provide personalized nutrition summaries and coaching. By analyzing your meal data, medical conditions, allergies, and dietary preferences, the AI assistant can offer tailored nutrition tips and recommendations.

The in-app chat assistant is powered by third-party service providers. These third-party providers adhere to strict data protection regulations and contractual obligations.

Data collected by the in-app chat assistant may be shared with third-party providers powering the functionality, including but not limited to OpenAI. We ensure that these providers adhere to data protection laws.

The in-app chat assistant does not operate with and does not provide final answers regarding refund or subscription management requests, as well as data subject rights requests. For these, please contact our customer support.

Data processed in the context of chat assistant conversations will be retained for up to 12 months from your last consent renewal.

10. Security of Your Personal Data

We use appropriate technical and organisational measures to protect your Personal data. Organisational measures include restricting access solely to authorised persons, signing confidentiality agreements, arranging training, and implementing relevant policies. Technical measures include online security, access control and authentication tools, and physical security.

Personal data is stored either on the servers of the Company or of our contractors, who are bound by specific contractual clauses and confidentiality obligations.

Regardless of measures taken, we cannot objectively guarantee the full security of your Personal data.

11. Your Rights

Your principal rights under data protection law include:

Right to be informed – You have the right to obtain information about the Personal data processed by us, the sources, purposes, legal grounds, retention period, data recipients, and your rights.

Right to access – You have the right to confirmation as to whether or not we process your Personal data and, where we do, access to it together with additional information. The first copy will be provided free of charge.

Right to rectification – You have the right to have any inaccurate Personal data rectified and any incomplete Personal data completed.

Right to erasure – In some circumstances, you have the right to erasure of your Personal data. Exclusions apply when processing is necessary for exercising freedom of expression, compliance with legal obligation, or establishment of legal claims.

Right to restrict processing – In some circumstances, you have the right to restrict the processing of your Personal data.

Right to object – You have the right to object to our processing of your Personal data on grounds relating to your particular situation.

Right to object to direct marketing – You have the right to object to our processing of your Personal data for direct marketing purposes.

Right to data portability – Where the legal basis is consent or performance of a contract, you have the right to receive your Personal data in a structured, commonly used and machine-readable format.

Right to lodge a complaint – If you consider that our processing infringes data protection laws, you may lodge a complaint with a supervisory authority. Our data processing is supervised by the State Data Protection Inspectorate of the Republic of Lithuania (L. Sapiegos St. 17, LT-10312 Vilnius, email: ada@ada.lt, www.vdai.lrv.lt).

Right to withdraw consent – Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Right regarding automated decision-making – You have the right to request not to be subject to a decision based solely on automated processing which produces legal effects concerning you.

You may exercise any of these rights by contacting us by email at team@pickcell.gg. We will respond within 1 month, extendable by 2 months for complex requests.

12. Third Party Websites

On the website you may find links to partner sites, information sources, and related party websites. Such third-party websites have their own privacy policies and we take no responsibility regarding them. We recommend familiarising yourself with their privacy policies before providing any Personal data.

13. Children's Personal Data

Our Website and Mobile App are targeted only at people over the age of 18. If we have reason to believe that we hold Personal data of a person under that age without parental consent, we will delete that Personal data. If you become aware that your child has provided us with Personal data without your consent, please contact us via email at team@pickcell.gg.

14. California Privacy Addendum

If you are a California consumer or resident, you may have additional rights under the California Consumer Privacy Act:

• We do not knowingly sell personal information nor share it with third parties for direct marketing purposes.
• We will retain, use, or disclose personal information only for the purposes described in this Privacy Policy.
• You have the right not to be subject to discrimination if you exercise any of your rights.
• We do not currently recognize or respond to browser-initiated Do Not Track signals.

15. Right to Complaint

If you believe that your rights have been violated, you may always contact us by email at team@pickcell.gg. You may also file a complaint with the supervisory authority in the EU member state of your habitual residence. Our data processing is supervised by the State Data Protection Inspectorate of the Republic of Lithuania (L. Sapiegos St. 17, LT-10312 Vilnius, email: ada@ada.lt, www.vdai.lrv.lt).

16. Data Scraping

Automated data collection (data scraping) from our Website is strictly prohibited without explicit written consent from us. This includes the use of software, bots, scripts, or any other automated methods to collect, extract, or replicate content, data, or information from our Website.

17. Updating Your Data

Please let us know if the personal information that we hold about you needs to be corrected or updated by contacting us at team@pickcell.gg.

18. Changes to the Privacy Policy

We reserve the right to change this Privacy Policy at any time. Any changes will be published on the Website and, in case of material changes, we may inform you via email or other means.

Any changes shall come into force from the date of their publication on the Website. In the event this Privacy Policy is translated into other languages, the English version shall prevail.

Contacts

In case of any inquiries or if you would like to exercise any of your rights provided in this Privacy Policy, you may contact us at: team@pickcell.gg or visit our Support page.

1. What Are Cookies?

Cookies are small text files that are placed on your device when you visit a website. They are widely used to make websites work more efficiently and to provide information to the owners of the site.

2. How We Use Cookies

We use cookies and similar technologies to enhance your experience on our website. The types of cookies we use include:

Strictly Necessary Cookies

These cookies are essential for the functioning of our website and cannot be turned off in our systems. They are usually set in response to actions you take, such as setting your privacy preferences, logging in, or filling in forms. Without these cookies, the website cannot function properly.

Functional Cookies

These cookies allow us to remember the choices you make and provide enhanced features and personalized content. They may be set by us or by third-party providers whose services we have added to our website. If you do not allow these cookies, some or all of these features may not function properly.

3. Managing Cookies

You can manage or disable cookies through your browser settings. Most browsers allow you to refuse or accept cookies, delete existing cookies, and set preferences for certain websites. Please note that disabling cookies may affect the functionality of our website.

4. Types of Cookies We Use

Advertising (Marketing) Cookies

These cookies are utilized to monitor users' online behavior and enhance marketing campaigns based on that data. Advertising cookies may be placed on our website by our advertising partners, who may use them to create a profile of your interests and display relevant ads on other websites. These cookies can uniquely identify your browser and internet device. If you choose not to accept these cookies, you may see less targeted advertising.

Analytics Cookies

These cookies enable us to track visits and traffic sources, allowing us to assess and enhance the performance of our website. They provide insights into which pages are most and least popular and how visitors navigate the site. The data collected by these cookies is aggregated and anonymous. If you do not consent to these cookies, we won't be able to monitor the website's performance.

Google Analytics is a tool provided by Google LLC to collect and process information about your use and other interactions with the Website. The information collected by Google Analytics is transmitted to and stored with Google (the US). For more information, please read Google LLC's privacy policy. If you want to opt out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on.

5. Changes to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in our practices or for legal compliance. We will notify you of any significant updates.

6. Contact Us

If you have any questions, inquiries or concerns about our Cookie Policy, please contact us at team@pickcell.gg. For more detailed information about our data handling practices, please review our Privacy Policy.