WaterPenguin: Water Reminder

Effective date: 14 October 2026
Last updated: 14 October 2026

1. Who We Are

About WaterPenguin

WaterPenguin (“WaterPenguin”, “the app”, “we”, “us”, or “our”) is operated by Codexia Technologies, a company registered in Pakistan.

Registered Office:
Office # 17, Fourth Floor, Ashrafi Tower, Commercial Zone 19, Liberty Market, Gulberg III, Lahore, Pakistan.

Contact for Privacy Matters: support@waterpenguin.com

For users in the European Economic Area (EEA) and the United Kingdom (UK), Codexia Technologies acts as the data controller for the personal data described in this Privacy Policy.

2. Our Approach in Plain Language

Here is a summary of our privacy commitments:

• WaterPenguin stores your hydration data on your device by default. Cloud backup is optional and disabled unless you enable it.
• We never sell your personal data.
• We never use your health data for advertising or share it with advertisers or data brokers.
• Health data and location access are optional. The app works without either permission.
• You can delete your data at any time from within the app.

If anything in the detailed sections below appears to contradict these commitments, please contact us so we can investigate and correct the wording.

3. Information We Collect

3.1 Information You Provide

We collect information you provide during setup and while using WaterPenguin.

• First name or nickname: Used to personalise app messages. Optional.
• Gender: Used to calculate your hydration goal. Required only if you choose a calculated goal.
• Age: Used to calculate your hydration goal. Required only if you choose a calculated goal.
• Weight: Used to calculate your hydration goal. Required only if you choose a calculated goal.
• Height: Used to calculate your hydration goal. Required only if you choose a calculated goal.
• Activity level: Used to calculate your hydration goal. Required only if you choose a calculated goal.
• Climate or environment: Used to calculate your hydration goal. Required only if you choose a calculated goal.
• Stated goal: Your selected goal, such as general hydration, fitness, or weight management, helps tailor app wording and guidance. Optional.
• Drink logs: Drink type, amount, and time are used to provide hydration tracking and history.
• Reminder settings: Units, wake-up time, sleep time, and reminder preferences are used to schedule reminders. Optional.

You can skip the calculated hydration goal and set your own daily target manually.

3.2 Health and Fitness Data

If you grant permission, WaterPenguin reads certain information from Apple Health on iOS or Health Connect / Google Fit on Android, depending on the integrations supported by your version of the app.

This information may include:

• Step count.
• Workout data.
• Active energy or calories burned.
• Heart rate, if supported and accessed by the app.

We use this information solely to adjust your daily hydration goal according to your activity level. For example, a day with 12,000 steps may result in a higher hydration target than a rest day.

WaterPenguin also writes your logged water intake to Apple Health or Health Connect, where supported, so your hydration information can appear alongside your other health data.

Our commitments regarding health data:

• Health data is never used for advertising or marketing.
• Health data is never sold, rented, or shared with data brokers.
• Health data is never shared with third parties for their independent purposes.
• Health data is used only to calculate and display your hydration goal and history within the app.
• Health data read from Apple Health is processed on your device and is not transmitted to our servers unless you explicitly enable cloud backup.

Health permissions are entirely optional. If you decline permission, WaterPenguin continues to work normally, but activity-based hydration adjustments will not be available.

You can revoke health permissions at any time through your device settings or the relevant settings within WaterPenguin.

3.3 Location Data

If you grant permission, WaterPenguin uses your device’s approximate location to retrieve local weather conditions, including temperature and humidity, and adjust your daily hydration goal accordingly.

• We request only the minimum location precision necessary to retrieve local weather.
• Your location is used to retrieve weather information and calculate your hydration goal.
• We do not store a history of your locations or build a location profile about you.
• Location data is never used for advertising or sold or shared with data brokers.
• Weather information is retrieved through Open-Meteo API. Your approximate location is transmitted to that provider solely to retrieve weather information for your area.

Location permission is optional. If you decline it, the app continues to work normally, but weather-based hydration adjustments will not be available.

3.4 Information Collected Automatically

Diagnostics and Crash Reports

We use Google Analytics to understand why the app crashes or behaves unexpectedly.

Diagnostic information may include:

• Device model.
• Operating system version.
• App version.
• Language and region settings.
• Technical details relating to a crash or error.

This information does not include your hydration data, health data, or location.

Usage Analytics

We use Google Analytics to understand how people use WaterPenguin, including which screens they visit, which features they use, and where they encounter difficulties.

This information helps us improve the app and prioritise future features.

Analytics events are associated with a pseudonymous identifier rather than your name or email address. We do not send your health data, location data, or body measurements to analytics providers.

You can opt out of analytics and crash reporting through the app’s settings, provided these controls are implemented in the released version.

3.5 Subscription and Payment Information

Subscriptions are purchased and billed through the Apple App Store or Google Play, not directly by WaterPenguin.

We do not receive or store your payment card details, billing address, or other financial information used to process your purchase.

Apple and Google handle payment processing under their respective privacy policies.

We receive only the information necessary to manage your access to paid features, such as:

• Whether your subscription is active.
• Your subscription plan.
• Your subscription renewal date, where provided.

3.6 Cloud Backup

Cloud backup is optional and disabled by default.

If you enable cloud backup, the following information is transmitted to and stored on our servers hosted by hosted by iOS and Android:

• Your hydration logs and history.
• Your hydration goal settings and personalisation inputs.
• Your streaks and milestone records.

If you do not enable cloud backup, this information remains on your device, except for the specific data transfers described in the health platform integration and location data sections of this policy.

3.7 Support Correspondence

If you contact our support team, we collect the information you provide, including your email address and the contents of your message.

We retain this correspondence to respond to your request, provide support, and identify recurring issues.

4. What We Do Not Do

WaterPenguin is committed to protecting your privacy.

• We do not sell your personal data.
• We do not share your personal data for cross-context behavioural advertising as defined under California law.
• We do not use health or location data for advertising.
• We do not display third-party advertising within WaterPenguin.
• We do not use your personal data to train machine learning models.
• We do not require an account to use the app.

5. Legal Bases for Processing

For users in the EEA and UK, we process personal data under the following legal bases, as applicable.

5.1 Contractual Necessity

We process information necessary to provide the app’s core features, including hydration tracking, reminders, and history, under Article 6(1)(b) of the GDPR.

We also rely on this legal basis where applicable to manage subscriptions and respond to support requests relating to the services you use.

5.2 Consent

We rely on your consent where required by law, including:

• Explicit consent under Article 9(2)(a) of the GDPR for processing health and fitness data.
• Consent under Article 6(1)(a) of the GDPR for processing location data for weather-based hydration goals.
• Consent for analytics where required by applicable law.

You can withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before your consent was withdrawn.

5.3 Legitimate Interests

We may process limited diagnostic information under Article 6(1)(f) of the GDPR to maintain app stability, troubleshoot errors, and protect the security of our services.

Where we rely on legitimate interests, we consider your rights and interests and use appropriate safeguards.

5.4 Legal Obligations

We may process or retain information when necessary to comply with applicable legal obligations under Article 6(1)(c) of the GDPR.

5.5 Special Category Health Data

Health data is special category personal data under Article 9 of the GDPR.

We process this information only with your explicit, separately given consent and for the purposes described in this policy.

You may withdraw that consent at any time through the app’s settings or your device’s health permissions, without affecting the lawfulness of processing carried out before withdrawal.

6. Who We Share Data With

We share personal data only with the recipients necessary to provide, maintain, and support WaterPenguin.

6.1 Service Providers

Depending on the features you use and the integrations implemented in the app, we may share limited information with:

• Apple and Google: Subscription status and related information necessary for payment processing and subscription management.
• Crash reporting provider: Device and crash diagnostics used to identify and resolve technical problems.
• Analytics provider: Pseudonymous usage events used to understand feature usage and improve the app.
• Weather provider: Approximate location at the time of a weather request, used to retrieve local weather information.
• Cloud hosting provider: Backed-up hydration data, only if you enable cloud backup.

Our service providers are permitted to process information only as necessary for their relevant services and subject to applicable contractual and legal requirements.

6.2 Legal Requirements

We may disclose personal data when required by law, in response to a valid court order or lawful request from a competent authority, or when necessary to establish, exercise, or defend legal claims.

Where legally permitted, we will notify you if we receive such a request.

6.3 Business Transfers

If Codexia Technologies is involved in a merger, acquisition, restructuring, or sale of assets, personal data may be transferred as part of that transaction.

Where appropriate and legally permitted, we will notify you before your data becomes subject to a materially different privacy policy and provide an opportunity to delete your data.

7. International Data Transfers

Codexia Technologies is based in Pakistan, and our team also operates from South Africa. Our service providers may process personal data in other countries, including the United States and countries within the European Union.

Where personal data is transferred outside the EEA or UK, we implement appropriate safeguards where required by applicable data protection law.

These safeguards may include:

• Standard Contractual Clauses approved by the European Commission.
• The UK International Data Transfer Addendum or other applicable UK transfer mechanisms.
• Supplementary technical and organisational measures where necessary.

You may request further information about the safeguards applicable to a particular transfer by contacting us at support@waterpenguin.com.

8. How Long We Keep Data

We retain personal data only for as long as necessary for the purposes described in this policy, subject to applicable legal requirements.

8.1 Retention Periods

• Data stored on your device: Retained until you delete it or uninstall the app.
• Cloud backup data: Retained until you delete your account or disable cloud backup, with deletion from our servers completed within 30 days, subject to applicable technical and legal requirements.
• Crash and diagnostic data: Retained for up to 12 months.
• Analytics data: Retained for up to 12 months.
• Support correspondence: Retained for up to 24 months after the issue is resolved.
• Legal, tax, and accounting records: Retained for the period required by applicable law.

8.2 Deleting Your Data

Uninstalling WaterPenguin removes locally stored app data from your device.

If you have enabled cloud backup, uninstalling the app alone may not delete the server-side copy.

To delete your cloud data, use Settings → Delete Account within the app before uninstalling it.

9. Your Privacy Rights

9.1 Rights Available to Everyone

Regardless of where you live, you can:

• Delete your data: Use Settings → Delete Account to remove your hydration history, streaks, achievements, and personal data. This action cannot be undone.
• Revoke health access: Change permissions in the app’s settings or your device’s health settings.
• Revoke location access: Change location permissions in your device settings.
• Disable analytics and crash reporting: Use the relevant controls in the app’s settings, where available.
• Cancel your subscription: Manage cancellation through your Apple or Google account.

9.2 Rights of EEA and UK Users

Under the GDPR and UK GDPR, you may have the right to:

• Access your personal data.
• Correct inaccurate or incomplete personal data.
• Request erasure of your personal data.
• Restrict the processing of your personal data.
• Object to processing based on legitimate interests.
• Receive certain personal data in a portable format.
• Withdraw consent at any time where processing is based on consent.
• Lodge a complaint with your local data protection authority.

We welcome the opportunity to address your concerns, but you are not required to contact us before lodging a complaint with the relevant authority.

9.3 Rights of California Residents

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), California residents may have the right to:

• Know what personal information we collect and how we use it.
• Request deletion of personal information.
• Request correction of inaccurate personal information.
• Opt out of the sale or sharing of personal information.
• Limit certain uses and disclosures of sensitive personal information.
• Receive equal treatment when exercising their privacy rights.

We do not sell personal information or share it for cross-context behavioural advertising.

Health and precise location data may qualify as sensitive personal information under California law. We use these data only for the service-related purposes described in this policy, subject to applicable legal requirements. You can revoke health and location permissions at any time.

9.4 Rights in Other Jurisdictions

Users in Brazil, Canada, Australia, South Africa, and other jurisdictions may have additional rights under applicable privacy laws, including Brazil’s LGPD, Canada’s PIPEDA where applicable, Australia’s Privacy Act, and South Africa’s POPIA.

We will handle valid privacy requests in accordance with the laws applicable to the request.

9.5 How to Exercise Your Rights

You can exercise many privacy rights directly within WaterPenguin.

For other requests, contact us at support@waterpenguin.com.

We aim to respond within 30 days, subject to applicable legal deadlines and any permitted extensions. We do not charge a fee for ordinary privacy requests unless permitted by law, and we do not require you to create an account solely to submit a request.

10. Children’s Privacy

WaterPenguin is not intended for children under 13 years of age.

In the EEA and UK, WaterPenguin is not intended for anyone under 16 years of age.

We do not knowingly collect personal data from children below these applicable ages. If you believe a child has provided personal data to us, contact support@waterpenguin.com so we can investigate and take appropriate steps to delete the information where required.

11. Data Security

We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, and disclosure.

Our security measures include:

• Local-first storage: Most hydration data remains on your device by default.
• Encryption in transit: TLS for network communications where applicable.
• Encryption at rest: Encryption for personal data stored on our servers.
• Access controls: Restrictions limiting staff access to production systems.
• Security maintenance: Regular reviews of dependencies and security updates.

No system can be guaranteed to be completely secure. We therefore cannot promise absolute security.

If a personal data breach occurs, we will notify the relevant supervisory authority and affected individuals when required by applicable law, within the applicable deadlines. Where the GDPR requires notification to a supervisory authority, we will generally do so within 72 hours of becoming aware of a reportable breach.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services, technology, legal obligations, or privacy practices.

If we make a material change that affects how we handle your personal data, we will notify you within the app before the change takes effect, where appropriate and legally required.

The “Last updated” date at the top of this policy will reflect the current version.

Previous versions of this Privacy Policy are available upon request.

13. Contact Us

Privacy Enquiries

For questions about this Privacy Policy, to exercise your privacy rights, or to request information about our data practices, contact us at:

Email: support@waterpenguin.com

General Support

For general questions or technical support relating to WaterPenguin, contact:

Email: support@waterpenguin.com

Postal Address

Codexia Technologies
Office # 17, Fourth Floor, Ashrafi Tower
Commercial Zone 19, Liberty Market
Gulberg III, Lahore, Pakistan

We aim to respond to privacy enquiries within 30 days, and we endeavour to resolve most enquiries within a few business days.