Privacy policy

Privacy Policy
Last updated: October 2026

1. Identity of the data controller
ADPTGN Group B.V.
Based in Amsterdam, the Netherlands
Website: drinkadptgn.com
Email: info@drinkadptgn.com
Chamber of Commerce (KVK) number: 93066820

ADPTGN Group B.V. is the data controller for the processing of personal data via drinkadptgn.com. This privacy policy has been drawn up in accordance with the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and the Dutch GDPR Implementation Act (Uitvoeringswet AVG).

2. What personal data we process
We only process the data that is necessary for the purpose for which it is collected.

When placing an order via drinkadptgn.com: first and last name, email address, delivery address, phone number (optional) and payment method. Payment details are not stored by us; these are processed by a certified payment provider (PCI-DSS compliant).

When subscribing to a product subscription: the data above, plus the details needed to charge your subscription on a recurring basis.

When subscribing to our newsletter: email address and, optionally, name.

When visiting drinkadptgn.com: if you accept analytics cookies, we process your browser type, device type, pages visited, products viewed or added to your cart, session duration and referring URL. Google Analytics 4 does not store IP addresses. If you accept marketing cookies, we also share your actions on our website (such as viewing a product, adding it to your cart, starting checkout and completing a purchase) with Meta, together with online identifiers such as cookie IDs, so that Meta can measure our advertisements and show them to relevant people. If you decline, we do not place analytics or marketing cookies.

When contacting us by email or through our contact form: name, email address and the content of the message.

3. Purposes and legal grounds
We process your personal data on the basis of the following legal grounds under Article 6 GDPR:

Performance of a contract (Article 6(1)(b) GDPR): processing orders and subscriptions, sending order and shipping confirmations, and handling returns.

Consent (Article 6(1)(a) GDPR and Article 11.7a of the Dutch Telecommunications Act): sending our newsletter and marketing emails, placing analytics and marketing cookies on your device, and measuring and showing our advertisements on Facebook and Instagram. You can withdraw this consent at any time via the unsubscribe link at the bottom of every email, via the “Cookie settings” link in the footer of our website, or by contacting us at info@drinkadptgn.com.

Legitimate interest (Article 6(1)(f) GDPR): improving our services and preventing fraud.

Legal obligation (Article 6(1)(c) GDPR): retaining order data for tax purposes under Article 52 of the Dutch General Tax Act (Algemene wet inzake rijksbelastingen).

4. Retention periods
Order data and invoice information: 7 years, under the Dutch statutory tax retention obligation (Article 52 AWR).
Email addresses for the newsletter: until you unsubscribe or withdraw consent.
Contact requests: a maximum of 1 year after being handled.
Website analytics data (Google Analytics): 14 months.
Advertising cookies: the cookies of the Meta Pixel are stored for up to 3 months. Data that Meta receives is retained by Meta in accordance with its own privacy policy.
We do not retain personal data for longer than necessary for the purpose for which it was collected.

5. Recipients of personal data
We never share your personal data without good reason, and never sell it to third parties. We work with the following categories of processors and other recipients. Where a provider processes data on our behalf, we have agreed on a data processing agreement in accordance with Article 28 GDPR.

Webshop and checkout platform (Shopify): for running our webshop, checkout and customer accounts.
Delivery and fulfilment partners: for packing and delivering orders.
Payment providers: for processing payments.
Subscription management platform (Shopify Subscriptions): for processing recurring subscription orders and payments.
Email marketing platform (Klaviyo): for sending newsletters and order-related emails.
Web hosting provider: for running drinkadptgn.com.
Analytics provider (Google Analytics): for measuring website traffic, only with your consent.
Advertising platform (Meta): for measuring and showing our advertisements on Facebook and Instagram, only with your consent. For the Meta Pixel, ADPTGN Group B.V. and Meta Platforms Ireland Limited are jointly responsible for the collection and transmission of your data to Meta. Meta is responsible for the processing that follows, as described in Meta’s privacy policy.

Some of our providers, such as Google, Meta, Shopify and Klaviyo, may process data outside the European Economic Area, including in the United States. In that case, we rely on the safeguards these providers use for such transfers, such as the EU-US Data Privacy Framework or standard contractual clauses approved by the European Commission, in accordance with Chapter V GDPR.

6. Cookies
Drinkadptgn.com uses cookies and similar technologies, such as local storage. When you first visit our website, a cookie banner asks for your choice. Until you make a choice, we do not place analytics or marketing cookies. You can accept or reject each category, and you can change your choice at any time via the “Cookie settings” link in the footer of our website. Your choice is stored in your browser.

Strictly necessary
These are required for the website to work, such as your shopping cart, your session, security, and remembering your cookie choice. No consent is required for these under Article 11.7a of the Dutch Telecommunications Act (Telecommunicatiewet). Our checkout is provided by Shopify, which places strictly necessary cookies for the cart and checkout.

Analytics (only with your consent)
We use Google Analytics 4, provided by Google Ireland Limited, to understand how visitors use our website, for example which pages are viewed and which products are added to the cart. Google Analytics places the cookies _ga and _ga_5DNC3VF48T, which are stored for up to 2 years. Analytics data is kept for 14 months.

Marketing (only with your consent)
We use the Meta Pixel, provided by Meta Platforms Ireland Limited, to measure the results of our advertisements on Facebook and Instagram and to show our advertisements to relevant people. The Meta Pixel places the cookie _fbp, which is stored for up to 3 months. If you arrive on our website through a Meta advertisement, the cookie _fbc may also be placed, which is stored for up to 3 months. Information about your purchase may also be sent to Meta from our webshop platform (Shopify), also based on your consent. Meta and ADPTGN Group B.V. are jointly responsible for the collection and transmission of this data to Meta. You can read more in Meta’s privacy policy at facebook.com/privacy/policy.

Email marketing
We use Klaviyo to send our newsletter and to show our signup forms. Klaviyo loads a script on our website and may use cookies or local storage to recognise visitors who subscribe or who click through from one of our emails.

Before you make a choice
Before you make a choice, analytics and marketing cookies are not placed. Google Analytics may still receive a limited signal without cookies, such as the page you visit and technical browser information, which does not use cookies or store identifiers on your device.

You can also delete or block cookies in your browser settings. If you block strictly necessary cookies, parts of the website, such as the shopping cart, may no longer work.

7. Your rights under the GDPR
Under the GDPR, you have the following rights:

Right of access (Article 15 GDPR): you can request which personal data we process about you.
Right to rectification (Article 16 GDPR): you can have inaccurate or incomplete data corrected.
Right to erasure (Article 17 GDPR): you can request that your data be deleted, unless we have a legal obligation to retain it.
Right to restriction of processing (Article 18 GDPR): you can request that processing be temporarily limited.
Right to object (Article 21 GDPR): you can object to processing based on legitimate interest.
Right to data portability (Article 20 GDPR): you can request your data in a machine-readable format.
Right to withdraw consent: applicable to processing based on consent.

To exercise these rights, send an email to info@drinkadptgn.com, stating your name and request. We will respond within 1 month. We may ask you to verify your identity before handling the request.

8. Security
We take appropriate technical and organisational measures to protect your personal data against loss, misuse, unauthorised access, disclosure or alteration. Drinkadptgn.com uses TLS encryption (HTTPS). Access to customer data is limited to employees who need it for their work. In the event of a data breach that is likely to pose a high risk to your rights and freedoms, we will inform you as soon as possible in accordance with Article 34 GDPR.

9. Complaints
Do you have a complaint about the way we process your personal data? Please contact us first at info@drinkadptgn.com.

You also have the right to lodge a complaint with the supervisory authority:
Autoriteit Persoonsgegevens (the Dutch Data Protection Authority)
Postbus 93374
2509 AJ Den Haag
www.autoriteitpersoonsgegevens.nl

10. Minors
Our website is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16. If we discover that we have inadvertently collected personal data from a child without the consent of a parent or guardian, we will delete this data as soon as possible. If you believe we may have collected data from a child, please contact us at info@drinkadptgn.com.

11. Changes to this privacy policy
We may update this privacy policy. The most current version is always available at drinkadptgn.com/privacy-policy. In the event of significant changes, we will inform registered newsletter subscribers by email.