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Privacy Policy

June 1, 2026

At Siberian Wellness, we believe that transparency in the processing of your personal data is not only a legal requirement but also an integral part of the trust we build with you. This Privacy Policy explains what personal data we collect, for what purposes, how we use it, and what rights you have in relation to such data.

When the terms "Siberian Wellness", "we," or "us" are used in this document, they refer to AQUAVIVA ITALIA S.R.L. and its affiliates. We process personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, GDPR) and applicable national data protection legislation.

We recommend that you read this Policy in full. If you have any questions or would like further information on any section, please contact us using the details provided in Section 1 below.

1. Who We Are

AQUAVIVA ITALIA S.R.L. is the data controller with respect to your personal data. This means that we determine how and for what purposes your personal data is processed, and we are responsible for ensuring that it is processed in accordance with applicable law.

You can contact us at the following details:

AQUAVIVA ITALIA S.R.L.

Via Ausa, 117, 47853 Coriano (RN), Italy

info_it@siberianhealth.com

2. To Whom This Policy Applies

This Policy applies to everyone who interacts with us: Those who purchase our products, participate in our network marketing program, visit our website or mobile application, or otherwise use our services or mobile applications.

Depending on the nature of such interaction, certain sections of this Policy may be particularly relevant to you.

3. Sources of Your Data

We collect personal data from three main sources: Directly from you, automatically through your use of our services, and from third parties. In each case, we collect only the data necessary for the purposes described in this Policy.

• Data you provide directly. Most of the personal data we process is provided by you. This occurs when you register an account, place an order, join our network marketing program, contact customer support, subscribe to our marketing communications, post a review, or fill out a questionnaire. Depending on the context, this may include your name, contact details, payment information, delivery address, and any preferences or materials you choose to provide.
• Data we collect automatically. When you use our websites or mobile applications, we automatically collect certain technical and usage data. This includes information about your device and browser, your IP address, session identifiers, and data about your interaction with our platform: Pages visited, links clicked, and in-app activity. We collect this data using cookies and similar technologies. Further information can be found in our Cookie Policy.

In connection with our network marketing program, we also collect participation data. This includes information about your organization, activity and engagement, and data necessary for calculating commission rewards.

• Data we receive from third parties. We may receive personal data from third parties to the extent necessary for the provision of our services. For example, payment providers provide us with transaction confirmations and status information, delivery partners provide shipping and order delivery information, and advertising platforms provide campaign performance and attribution data.

In some cases, we may also receive data from social networks (e.g., publicly available profile information) or from influencer agencies in the context of marketing collaborations.

4. What Personal Data We Process and for What Purposes

This section describes the situations in which we process your personal data, the types of data involved, and the legal basis for such processing.

4.1. When Creating and Managing an Account

• Purpose of processing: Account and profile management.

To provide access to our platform and enable you to use our services, we process the data you provide when creating and managing your account.

This may include your Registration Number (user ID), registration date, account status (e.g., Privileged Client or Consultant), full name, gender, date of birth, email address, phone number, address, photo/avatar (if provided), language and country settings, store address, privacy settings, linked social media accounts, and login credentials. For Consultants, we may additionally process identity document data (e.g., passport or other identification) if required for identity verification or compliance with applicable obligations.

Legal basis: Performance of a contract.

4.2. When Making a Purchase

• Purpose of processing: Order processing and fulfilment.

When placing an order, we process the data necessary to complete and record the transaction.

This includes your name, contact details, billing address and delivery address, order details, payment status, transaction identifiers, and IP address. We also retain certain data to comply with accounting and legal obligations.

Legal basis: Performance of a contract; legal obligation with respect to accounting and tax law requirements.

• Purpose of processing: Arranging delivery.

To arrange and monitor the delivery of your order, we process your full name, phone number, email address (for tracking notifications), order number and details, tracking number, payment status, delivery address, and delivery status. Some of your data may be shared with delivery partners to the extent necessary for the performance of their functions.

Legal basis: Performance of a contract; legitimate interest in ensuring efficient delivery operations.

• Purpose of processing: Sending service and security notifications.

We send you service notifications, including updates on order status, payments, delivery, account activity, and security-related events.

For this purpose, we process your user ID, contact details, order and delivery information, and a limited amount of technical data (in particular, device ID and time zone).

Legal basis: Performance of a contract; legitimate interest in ensuring proper information and service provision.

4.3. When Contacting Customer Support

• Purpose of processing: Handling customer support inquiries.

When you contact our customer support, we process the data necessary to respond to your request and provide assistance.

This may include your name, user ID, contact details, account data, order history and order number, communication data (including messages, support tickets, and chat history), and any information or attachments you provide. Where necessary, we may also process technical data (e.g., device information and IP address) and delivery-related data.

Legal basis: Performance of a contract; legitimate interest in ensuring effective customer support and resolving inquiries.

4.4. When Participating in the Network Marketing Program

• Purpose of processing: Managing participation and status.

To manage your participation in the network marketing program, as well as to assign or change your status as a Privileged Client or Consultant, we process your account data, status history, participation criteria, registration and purchase history, referral and recruitment activity, and information about the person who referred you.

Legal basis: Performance of a contract; legitimate interest in managing the program structure and participant roles.

• Purpose of processing: Managing loyalty and referral programs.

To manage loyalty and referral programs for Privileged Clients, we process account data, purchase history, order amounts, rewards (in particular, points, cashback, bonuses, and certificates), and referral data (including referral links, status, and outcomes).

If you joined via a referral link, we also process limited referral program data (e.g., the identifier of the person who referred you and entitlement to rewards).

Legal basis: Performance of a contract; legitimate interest in encouraging engagement and retention.

• Purpose of processing: Maintaining network structure and mentoring relationships.

To maintain the network structure and relationships between participants, we process account data, referral and mentoring connections, team structure (including upline and downline connections), hierarchy levels, status and qualification data, and activity data.

Legal basis: Performance of a contract; legitimate interest in maintaining and organizing the network.

• Purpose of processing: Performance evaluation, commission calculation, and reward allocation.

To evaluate performance, determine eligibility, and calculate commissions, cashback, and other incentives, we process account data, purchase history, order amounts, personal and group performance metrics, team sales volume, rank and eligibility data, accrued commissions and payouts, and progress within incentive programs.

For Consultants, we additionally process business and payment data, including legal status, tax identification number, bank details, payment information, invoices, and transaction records. We also process bonus account and internal wallet data, including balances, accrued amounts, and transaction history within the program.

Legal basis: Performance of a contract; legal obligation with respect to accounting, tax, and financial reporting requirements; legitimate interest in ensuring the accurate functioning of the program.

• Purpose of processing: Managing program communications.

We send messages concerning your participation in the program, including updates on rules, status, eligibility, rewards, as well as restrictions or termination of participation.

For this purpose, we process your name, user ID, contact details, participation data (including participation in loyalty, incentive, qualification, or special programs), status and eligibility information, and communication data.

Legal basis: Performance of a contract; legitimate interest in ensuring effective and timely communication within the program.

• Purpose of processing: Conducting team training and leadership development.

To conduct the aforementioned activities, we process your account data, profile photo, rank advancement and engagement metrics, participation in training and events, use of educational platforms, and relevant communication data. We may also process subscription data, for example, information about subscriptions to corporate news channels, blogs, or messenger channels that you have subscribed to as part of the program.

Legal basis: Performance of a contract; legitimate interest in facilitating participant development and organizing training activities.

• Purpose of processing: Fraud prevention and enforcement of program rules.

To detect, prevent, and investigate fraudulent or abusive activities, and to ensure compliance with program rules and contractual terms, we process account data, technical data (e.g., IP address and device information), purchase history, activity patterns, behavioral data (e.g., action sequences and interaction patterns), network structure and referral data, communication data, and enforcement documents, including notes, investigation findings, and sanctions applied. Where necessary during an investigation, we may also process social media account or group data.

Legal basis: Legitimate interest in preventing fraud and ensuring security; performance of a contract with respect to compliance with contractual terms.

• Purpose of processing: Administering incentive and reward programs.

We offer Consultants special incentive programs that may provide additional benefits, including car or housing rewards.

To administer these programs, verify eligibility, process your application, and provide the relevant benefits, we process account data, performance data (e.g., Personal Volume, Group Revenue, and Organization Volume), network structure data (e.g., downline activity and team sales volume), status and qualification data (e.g., user status, rank, and eligibility), and incentive program data (e.g., participation periods and conditions, progress, balances, achievements, and entitlement to additional rewards).

We also process enhanced analytics and derived data, in particular growth metrics and performance trends, for eligibility assessment.

If the program provides specific benefits, we additionally process application data, supporting documents (e.g., ownership documents or contracts), payment and contractual documents, and relevant communications.

Legal basis: Performance of a contract with respect to program participation and provision of related benefits; legal obligation where processing is required for accounting, taxation, or regulatory compliance; legitimate interest in administering, verifying, and protecting the integrity of special incentive programs.

• Purpose of processing: Managing the joint family registration mechanism.

If a Consultant applies for a joint Family Registration Number with their spouse, we process the personal data of both individuals to verify eligibility and complete the registration.

This may include names, identity document data, marriage certificate, and written confirmations provided by both parties.

Legal basis: Performance of a contract with respect to participation in the network marketing program and administration of the joint family registration mechanism; legitimate interest in verifying eligibility and properly administering the network marketing program structure.

4.5. When Visiting Our Website

• Purpose of processing: Website usage analysis.

We analyze how you use our website to assess its performance, understand user behavior, improve functionality, detect errors, and assist in fraud prevention.

For this purpose, we process technical and usage data, including IP address, browser and device information, operating system, session and device identifiers, and interaction data (e.g., page views, clicks, scrolling, session duration, search queries, navigation paths, and corresponding timestamps).

This processing is partially carried out using cookies and similar tracking technologies. Further information about the cookies we use can be found in our Cookie Policy.

Legal basis: Consent where processing involves the use of cookies or similar tracking technologies. With respect to server-side processing that is not cookie-dependent, we may rely on legitimate interest.

4.6. When Using Our Mobile Application

• Purpose of processing: Providing and maintaining application functionality.

We process your account data, technical and device data (e.g., device ID, device model, operating system, application version, IP address), usage data (e.g., session data, app launches, error logs, and crash reports), and security-related data (e.g., authentication tokens and session identifiers) for the purposes of providing, maintaining, and securing the application.

Legal basis: Performance of a contract; legitimate interest in ensuring the security and stability of the application.

4.7. When Carrying Out Marketing Communications or Engaging with You for Marketing Purposes

• Purpose of processing: Sending direct marketing communications.

If you have subscribed to our newsletters, we process your name, email address, communication preferences, subscription channels, email interaction data (e.g., opens and link clicks), your CRM identifier, consent records, and, where relevant, limited purchase history to personalize communications.

Legal basis: Consent. You have the right to withdraw your consent at any time by using the unsubscribe link in any marketing email or by contacting us directly.

• Purpose of processing: Displaying digital advertising on external platforms.

We promote our products and services through advertising on external platforms and using technologies deployed on our website.

For non-personalized advertising and basic campaign performance measurement, we process a limited amount of technical and attribution data (e.g., referral source, URL, UTM parameters, timestamps, and aggregated campaign data).

With your consent, we also process identifiers (e.g., cookies and device IDs), IP addresses, browser and device data, browsing and purchase-related activity, inferred interests, and consent records. We may also process fraud indicators to identify invalid or abusive traffic.

We activate such technologies only after obtaining your consent. Further information about the cookies we use can be found in our Cookie Policy.

Legal basis: Legitimate interest with respect to non-personalized advertising and basic campaign performance measurement; consent with respect to personalized advertising and marketing cookies.

• Purpose of processing: Managing social media interactions.

When you interact with us on social media, we process your social media profile data, messages, comments, and inquiries, as well as any additional information you choose to provide, such as the content of your messages or attachments.

Legal basis: Legitimate interest in managing our social media presence; performance of a contract where the interaction relates to existing orders or services.

• Purpose of processing: Collecting and publishing reviews, recommendations, and related materials.

If you provide us with a review, recommendation, or other material for publication, we process your name, the material itself, and any photos or videos you choose to provide.

Legal basis: Consent, where you provide material for publication or agree to its use, including for marketing purposes, and where such consent is required for the use of images; performance of a contract, where publication is part of an agreed collaboration; legitimate interest for limited use of non-image content or publicly available content in cases permitted by law.

• Purpose of processing: Conducting surveys and collecting feedback.

When you participate in a survey or provide feedback, we process your contact details if the survey is not anonymous, as well as your responses, including ratings, satisfaction metrics, and opinions. If surveys are sent by email, we do so in connection with a product or service you have previously purchased or used, and each invitation includes an option to unsubscribe.

Legal basis: Legitimate interest in evaluating and improving our products, services, and customer experience.

• Purpose of processing: Organizing events.

When you register for or attend events, we process your contact details, registration data, participation and attendance information, engagement data, and any feedback you provide.

Legal basis: Performance of a contract; legitimate interest in organizing and improving events.

• Purpose of processing: Managing influencer and ambassador collaborations.

For influencers and ambassadors, we process your identification data, contact details, social media profiles, agreement terms, and campaign performance data (e.g., engagement metrics).

For users interacting with such campaigns, we process interaction data (in particular, clicks on tracking links, use of promo codes, and related purchasing activity), as well as a limited set of technical identifiers.

Legal basis: Performance of a contract; legitimate interest in measuring and optimizing campaign performance.

4.8. When Submitting a Complaint or Involving Us in a Dispute

• Purpose of processing: Handling claims and dispute resolution.

If you submit a complaint or a dispute arises, we process the personal data necessary to assess the situation, respond, and manage its resolution, including for the purposes of establishing, exercising, or defending legal claims.

The scope of data processed depends on the specific case and may include account data, order and transaction history, communication data, your status and activity in our network marketing program, and any other relevant information. If the matter relates to a return, we may also process return documentation, for example, written return statements and relevant postal or shipping documents.

Legal basis: Performance of a contract, where applicable; legitimate interest in establishing, exercising, or defending legal claims.

5. To Whom We Disclose Your Data

We do not sell your personal data. We only disclose it to the extent necessary for providing our services, conducting our business, or complying with legal obligations. We ensure that data sharing is limited to the minimum necessary and is carried out in accordance with applicable data protection law.

Depending on how you use our services, we may disclose your data to the following categories of recipients:

• Platform support service providers. We use cloud hosting and IT infrastructure services to operate and maintain our platform and systems. These providers process data to the extent necessary for the reliable and secure operation of our systems.
• Payment providers. When you make a purchase, we share a limited set of data necessary for payment processing and verification with our payment service providers.
• Delivery and logistics service providers. To deliver your order, we share relevant order and contact data with our delivery and logistics partners, including courier services. These providers also provide us with shipment tracking and delivery status information.
• Communication service providers. We use third-party providers to send you service communications, including by email, SMS, or applications such as WhatsApp or Telegram. These providers process your contact details and message content solely for the purpose of delivering such communications.
• Customer support tools. We use support platforms (in particular, ticketing systems and CRM tools) to manage and respond to your inquiries. These providers process the information you provide when contacting our customer support.
• Marketing, advertising, and analytics service providers. We collaborate with various providers to conduct marketing campaigns and analyze platform usage. This includes CRM systems, analytics tools, social media management tools, advertising platforms, marketing agencies, and ad fraud prevention partners. For personalized advertising, we share data with these providers only with your consent.
• Survey and research tools. If you participate in surveys or provide feedback, your responses may be processed through our survey platform providers.
• Event partners. When registering for or attending events, we may share your data with event management platform providers for registration and participation processing. If an event is co-organized with external partners, such partners may also receive limited participant data (in particular, name, contact details, registration information, and related survey data) to the extent necessary to support the event.
• Influencer agencies and platforms. In the context of influencer marketing, we may share relevant data with agencies, platforms, and analytics providers that manage campaigns and measure their performance.
• App stores. Our mobile application is distributed through app stores, which process certain technical and usage data in accordance with their own privacy policies.
• Participants in our network marketing program. Within the platform, individual participants may have access to limited data about other participants where necessary for the functioning of the network. For example, Consultants may access certain performance and activity data of their team members for effective team management.

You can adjust your privacy settings to limit data visibility where possible. However, a certain level of data sharing is necessary for the functioning of the network marketing program.

• Regulatory and judicial authorities. We may disclose personal data to public authorities (in particular, regulators, tax authorities, law enforcement agencies, or courts) where required or necessary to protect our rights or the security of others.
• Successors in business restructuring transactions. In the event of a merger, acquisition, restructuring, or sale of all or part of our business, personal data may be transferred as part of the relevant transaction. In such cases, we will take reasonable steps to ensure that appropriate confidentiality obligations are in place and that your data is processed by the receiving party in accordance with this Policy.

6. International Data Transfers

We operate on a global level, and as a result, your personal data may be transferred to and stored in countries outside the European Economic Area. Where such transfers take place, we apply appropriate safeguards to ensure that your data is protected in accordance with applicable privacy legislation.

In some countries, data protection standards may differ from those in your country of residence. In such cases, we take all necessary measures to ensure the secure processing of your personal data in accordance with this Privacy Policy.

7. Data Retention Periods

We retain personal data no longer than necessary for the purposes described in this Policy. Retention periods vary depending on the type of data and the purpose of processing, taking into account our legitimate interests and applicable legal or regulatory requirements. For example:

• Account data is retained for as long as you remain our user or for the duration of our contractual relationship with you;
• Financial and transaction data is retained for the period required by applicable accounting and tax legislation;
• In the event of a dispute, relevant data may be retained until its full resolution;
• In the event of detected or reasonably suspected fraud, abuse, or other violations, relevant data may be retained for as long as necessary for investigation and prevention of recurrence.

Once the purposes of data processing have been achieved and there is no legal, regulatory, contractual, or legitimate basis for further retention, personal data is securely deleted or anonymized.

Please note that in certain circumstances, we may retain individual data even after receiving a deletion request. This is possible where we have a legal basis for continued processing that is not based on consent, for example, to comply with legal obligations. We may also retain irreversibly anonymized data, which in such form is no longer personal data.

8. Protection of Your Data

We take the security of your personal data seriously and implement appropriate technical and organizational measures to protect it from unauthorized access, misuse, loss, or alteration.

These measures are designed taking into account the nature of the processing and the associated risks, and are regularly reviewed and updated as necessary.

9. Automated Decision-Making

We do not make decisions based solely on automated processing that produce legal or similarly significant effects on you.

Where automated tools are used to detect potential fraud or abuse, any decision that could have significant consequences, such as account restriction, is made by a member of our team.

Please note that some of our advertising partners independently carry out automated processing of the data we share with them, for example, to determine advertising relevant to you or to detect and prevent fraudulent activity. In such cases, they act as independent data controllers and are independently responsible for compliance with applicable data protection legislation.

10. Data of Minors

Our services are not intended for individuals under the age of 16. We do not intentionally collect personal data of children. If you believe that we have inadvertently collected data relating to a child, please contact us at info_it@siberianhealth.com so that we may promptly take appropriate measures. To process your request, we may ask you to confirm that the child is under 16 and that you exercise parental responsibility over the child.

11. Your Rights

Depending on applicable data protection law, you have the following rights with respect to our processing of your data:

• Right to be informed. You have the right to receive information about how we collect and use your personal data.
• Right of access. You have the right to request information about the data we hold relating to you and to obtain a copy of it.
• Right to rectification. You have the right to request the correction of your personal data if it is inaccurate, incomplete, outdated, or no longer necessary for the stated purpose.
• Right to erasure. You have the right to request the deletion of your personal data, unless we are required to continue processing it by law. Please note that if you submit a request to delete your account, this will result in the irrevocable and irreversible loss of your account data, purchase history, accumulated bonuses, bonus balances, and participation records in our network marketing program. This action cannot be undone.
• Right to data portability. You have the right to receive your data in a structured, commonly used, and machine-readable format, or to request its direct transfer to a third party, where technically feasible and reasonable.
• Right to restrict processing. You have the right to restrict, in whole or in part, the use of your data in certain circumstances provided by applicable law, unless we are required to continue processing it by law.
• Right to withdraw consent. Where data is processed on the basis of your freely given consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing carried out prior to the withdrawal.
• Right to object. You have the right to object at any time to the processing of your personal data. We may continue processing your data if we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or if processing is necessary for the establishment, exercise, or defense of legal claims.
• Right to lodge a complaint. If you believe that our processing of your personal data does not comply with applicable data protection law, you have the right to lodge a complaint with the supervisory authority in your country of residence, place of work, or where the alleged infringement occurred.

12. How to Exercise Your Rights

To exercise any of your rights, please contact us at info_it@siberianhealth.com. To ensure effective processing of your request and to protect your data from unauthorized access, we may ask you to verify your identity before taking any action.

We will respond to your request within one month of its receipt. This period may be extended by up to two further months where necessary, taking into account the complexity or volume of requests. In such cases, we will notify you of the extension in advance.

Some rights may also be exercised directly through your account settings. For example, you can update your profile data, manage your marketing preference settings, or submit an account deletion request within the platform. Where such an option is available, we will indicate it in the relevant section and, for security reasons, will only accept such requests through account settings.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing activities, business practices, or applicable law. The updated version will be posted on our website with a revised date. In the event of material changes, we will notify you by email or through a prominent notice on our platform before such changes take effect.