Mobile App - Privacy Policy

Mobile Application

Privacy Notice

Last updated: 21/03/2022


The following definitions shall have the following meaning when used in these terms and conditions.

App” shall mean the mobile application run by the Company.

Customer”, “you” shall mean anyone that downloads our App.

Company”, “us”, “our” and “we” shall mean The Ocean Bottle Ltd, company number is 11235061 (registered office address: 20-22 Wenlock Road, London, England, N1 7GU).

Refill Station” means the businesses who provide drinks to Customers by way of the App.

Refill” means when you purchase a drink at a Refill Station using your refillable bottle.


Please read this privacy policy (“Privacy Policy”) carefully before you use our App and the affiliated services (the “Service”). Your access to and use of our App and the Service is conditional on your acceptance of and compliance with this Privacy Policy.

This Privacy Policy applies to all visitors, users and others who access or use the App. By accessing or using the App, you agree to be bound by this Privacy Policy. If you disagree with any part of the terms, then you may not access the Service.

You warrant that you are legally capable of entering into binding contracts and you are at least 16 years old.


We collect or receive personal information in a few different ways via the App. Often, you choose what information to provide, but sometimes we require certain information for you to use, and for us to provide you with, the App and the experiences you reserve or access through the Site.

  • Data You Provide To Us.
    There are a variety of different ways you may provide data to us, such as:
    • Account Creation. To create an account, you need to provide data including information such as your name, email address, phone number and a password. You can choose to add further information to your account, such as birthdate, gender, photo and address.
    • Posting and Uploading. We collect personal information from you when you provide, post or upload it to our App, such as when you respond to a survey or provide a photo.
    • Third Party Data. You may not provide information to us about someone else unless you have obtained the prior consent of the other person for us to receive and use their information, such as for emergency contact or referral purposes.
  • Data Collected Automatically Through Your Use of the App.
    • We log usage data when you visit or otherwise use our App, such as when you view or click on content or ads (on or off our App), perform a search, browse and install or update our App. Specifically, the information we collect automatically may include information like internet protocol (“IP”) address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), language and marketing preferences and other technical information. We may also collect information about how your device has interacted with our App, including the pages accessed and links clicked.
    • We may also collect precise geolocation data pertaining to your mobile device, if you have consented to providing this to us through your device settings. We may use this information to provide, promote, and improve our services (for example, by showing you Refill Stations that are close to your location) and for related reasons, such as fraud prevention and security purposes. Please note that if you do not consent to providing your geolocation data, certain features of the mobile application may not work.
  • Data Collected When You Connect To A Third Party Network.

Where we make this available, you may choose to sync your account details with a third-party network, such as Facebook. If you do this, we will receive some of your Facebook account information. Exactly what information we receive will depend on your settings with the third-party network, but typically we receive your basic public profile information such as your username, email address, age range, gender, chosen language, country, friends list and any other public information.


We use personal information we receive for several purposes:

  • App: To operate and maintain our App and the products and services offered through our App. For example, we use personal information to record your Refills and to customize your experience on our App, such as by tailoring the content or experiences we show you.
  • Communication: To contact you through email, notices and/or push notifications posted on our App, and other ways. We will send you messages about the availability of our App, security, customer service, or other service-related issues. We also send messages about the App, updates, reminders, and promotional messages in accordance with your communications preferences. You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.
  • Customer Support: In connection with customer service inquiries and matters, such as to investigate, respond to and resolve complaints and service issues.
  • Social: To provide features which allow you to connect with, and be found by, other users.
  • Marketing: For marketing purposes, such as to develop our marketing strategy and offer contests, sweepstakes, or other promotions and to fulfil any related awards or discounts.
  • Research and Development: For research, analytical, recordkeeping, and reporting purposes; to develop and test new products, features and ideas; to learn about our customer base and App and to evolve and improve our App, products and services.
  • Security and Investigations: We use your information to maintain the security of our App, including to verify your identity, to investigate or prevent possible fraud or other violations of our Terms and Conditions or this Privacy Notice and/or in connection with possible attempts to harm our users, Refill Stations or other third parties.
  • Other: For any other purpose identified at the point of collection or otherwise with your consent.

    1. If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.
    2. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.


We may disclose your personal information to the following categories of recipients or in the following circumstances:

  • third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our App, payment card processors, customer support vendors, hosting vendors, scheduling providers and market research and marketing vendors), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
  • to any Refill Station that makes available a Refill as promoted on our App (we won’t share your name or location, just the information that a refill was recorded at that location);
  • your name, photo and other information associated with your account will be visible to other users of the App. You can prevent other users from being able to search for you by updating your preferences via the Privacy tab in your Account Settings;
  • If you sync your account to a third-party network, such as Facebook, or provide us with your contacts, such as those stored on your mobile device, you will be able to see which of your contacts are using the App. If those contacts are users of the App, they will also be able to see that you are using the App;
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary as a matter of applicable law or regulation, to exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person;
  • in connection with an actual or potential merger, sale, acquisition, investment, assignment, reorganization, joint venture, or transfer of all or part of our business, assets, affiliates, including if we should ever file for insolvency or a related proceeding, provided that we inform the relevant third party it must use your personal information only for the purposes disclosed in this Privacy Notice;
  • to any other person with your consent to the disclosure or otherwise in accordance with applicable law.


We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We monitor our systems for possible vulnerabilities and attacks. However, we cannot guarantee 100% security of any information that you send us.


Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). Specifically, our App servers are located in the European Union, Refill Station providers and partners operate around the world. This means that when we collect your personal information, we may process it in any of these countries.


We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so by contacting us as explained below.
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or via our preference centre. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us.
  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.)

You may contact us as explained in the “How to contact us” heading below. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.


Our App may contain links to third-party websites or mobile apps, including social sharing features and other related tools. Please be aware that we do not control these linked websites or apps and that this Privacy Notice does not apply to any information you give to the owner of these websites or apps. We encourage you to read the privacy policy of any third-party website or app that you visit before you provide them with any information.


We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.


If you have any questions or concerns about our use of your personal information, please contact The Ocean Bottle Ltd (the data controller) by emailing


These Terms are subject to the laws of England and Wales, and any dispute arising from this Privacy Notice shall be subject to the exclusive jurisdiction of the courts of England and Wales.


We reserve the right, at our sole discretion, to modify or replace this Privacy Notice at any time. If a revision is material, we will try to provide at least 30 days’ notice prior to any new terms taking effect, however, we are not bound to provide you with any notice. What constitutes a material change will be determined at our sole discretion.

If you have any questions about this Privacy Notice, please contact us at