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Our privacy policy is designed to build a relationship of trust between you and our services in order to provide you with a positive experience in a completely transparent manner.

Thanks to this policy, we will be able to take into account your requirements and be in conformity with your expectations.

In order to respect your trust, ADHERO CREATIVE OÜ, we guarantee in a primordial way the respect of your personal data, as well as the confidentiality of our clients (hereinafter " Your data ").

For a perfect transparency towards you, in order to guarantee a secure use of our website in all its available versions and linked applications (hereinafter the " Freshup Profesionnal Site "), we make available the way in which we treat your data, so that our services are always in agreement with the respect of your rights. In this way, we ensure the security, confidentiality and non-tampering of your privacy and data across all our platforms.

Our policy and we guarantee that all necessary precautions are taken to protect your data against disclosure, loss or alteration. That is why we provide you with all the elements that allow you to easily understand our way of handling your data. This data will only be kept for the time necessary for the management and processing determined. You will of course be able to access and modify your data at any time, as it will be available in your personal areas of the Freshup Professional website.

For these purposes, we strive to take all necessary steps to comply with the applicable law on data protection.

Thus, the undersigned ADHERO CREATIVE OÜ commits itself by this policy of protection of your personal data to respect the essential principles of the general European regulation and of the French law in the matter of protection of personal data, by putting at your disposal the information concerning the existence and the modalities of the treatment of the data here applied (paragraph 3), the rights that you have concerning your data, as well as by applying these rights ourselves (paragraph 6 and 10). Any information regarding possible transfers to a third country or recipients is also made available, as well as the time of storage of the data collected (paragraph 5) and security measures (paragraph 9).



When we mention "you" in this Policy of protection of personal data, it is simply because it is directly linked to you and concerns you as a client of ADHERO CREATIVE OÜ, if you have placed an order on the Freshup Professional site, a client of ADHERO CREATIVE OÜ if you have created a client account but have not ordered products or services, or if you have navigated as a visitor on the Freshup Professional site without having created a client account or having placed an order.


  1. WHO WE ARE?

ADHERO CREATIVE OÜ is a limited liability company with a capital of 2500 euros, registered with the REGISTRATION DEPARTMENT OF TARTU COUNTY COURT under the number 14750839, represented by Mr Alexis Van Damme, in the capacity of President and General Manager and whose head office is located at Harju maakond, Tallinn, Kristiine linnaosa, Vana-liivamäe 3-31, 10132, Estonia.

ADHERO CREATIVE OÜ publishes the Freshup Professional Site and implements, as such, various treatments of your Data in the capacity of data controller.



3.1 When do we collect your personal data?

Your personal data may be collected if you visit the Freshup Professional website using cookies, if you create a customer account on the Freshup Professional website, if you place an order for one of our products or services or if you agree to be a member of our newsletters (SMS, e-mails).

We use your personal information to make your visit to the Freshup Professional website more enjoyable and to provide you with a more personalized experience. This allows us to better process your orders, make payment in installments available, prevent fraud, provide refunds as necessary, and manage your customer reviews.


3.2.  Your navigation on the Freshup Professional Website

In order to enable you to browse the Freshup Professional website, we process your data with your consent as the legal basis for this.


3.3. Processing your orders

In order to process your orders, we use your data.

The use we make of it serves to manage the mediation, the customer relationship (and that through social networks), our after-sales service and distance selling, our actions relating to the management of marketing and commercial prospection for the Freshup Professional website, as well as for the management, deliveries and transport of orders.

The execution of the contract between the two parties (you and us) is the legal basis for the treatment of this data.

The legal obligation of ADHERO CREATIVE OÜ is the legal basis of the treatment, as far as the management of the recall of the products is concerned. Your consent or our legitimate interest are, according to the cases, the legal base of the treatment for the marketing actions and of commercial prospection. Your consent is the legal basis for the implementation of the "flash" payment.


3.4. Payment in installments

For the orders concerned by the payment in several times and for certain customers, your data are processed in order to be able to offer you this type of payment. The application of the contract between the two parties is the legal basis for the data processing. However, your consent remains the basis for the processing of your bank data.


3.4.1 SplitIt

In order to offer you SplitIt's payment options, we may need to transfer to SplitIt your personal data including your contact information and order details, so that SplitIt can assess whether you qualify for them and tailor them to your needs. Your transferred personal data will be treated in accordance with SplitIt's privacy policy.


3.5. Customer Reviews

To be able to share your reviews with our customers and visitors as well as allow you to leave your review on the Freshup Professional website we use your data on the legal basis of your consent or legitimate interest.


3.6. Collection of payments and fight against fraud

In order to enable the collection of payments and the fight against fraud, we use your data.

This also enables us to ensure the security of payments.

The application of this contract between the two parties as well as the legitimate interest of ADHERO CREATIVE OÜ, in its capacity as data controller, are the legal bases of this treatment.


3.7. Management operations of the advertising department of ADHERO CREATIVE OÜ

The operations of advertising management of ADHERO CREATIVE OÜ are managed thanks to the use of your data.

This will allow us to increase our data of clients and prospects, to manage the maintenance and technical activities of prospects, the commercial statistics and the studies of advertising campaigns, the updating of the files of prospection of the organization in charge of the management of the oppositions to the canvassing by telephone, the solicitations, the installation of our contests and lotteries or any other operation with promotional end except games of money and chance on line

The legal bases of the above mentioned mentions are the consent of the user or the legitimate interest of ADHERO CREATIVE OÜ.



Your data is transmitted to several internal services of Freshup Professional

They are not sent to third parties, except in the situations specified below:

In order to process your orders, your personal data may be transmitted to several service providers whose specializations are banking transactions, customer relations, after-sales service, delivery, IT development, site management or the provision of guarantees or insurance.

For the implementation of the payment in x times, your data can be shared with service providers such as payment and transaction centers (banks...), or call centers for the management of business processes or customer experience, or, for customer reviews, to a manager of collection and processing of customer reviews.

Freshup Professional's advertising network is managed, thanks to your data, by clients of the network and advertisers.


The data collected by Freshup Professional is kept only for the time and assistance necessary to set up and carry out the operations mentioned in paragraph 3 of our personal data policy.

We keep for a certain time some data collected by Freshup Professional:

In current archives for the prospects, during 3 years from the last contact of the client (they are therefore consultable by the services of ADHERO CREATIVE OÜ). We do not carry out intermediate archiving of these data (as for the data representing an administrative interest for certain services, as for the litigation, the conservation periods are fixed by the applicable rules of prescription).

With regard to our orders, your data will be archived in the current archives for 5 years from the end of the use of the customer's orders, and in the intermediate archives for 5 years from the end of the conservation in the current archives. The same applies to customers.

Bank data is stored in the current archives for the entire period of validity of the bank card (plus one day). There is no intermediate storage of bank data.

Cookies and their use and time limit are detailed in paragraph 7 of our policy.



6.1. You have the right to request access, modification and rectification of your Data.


6.2. You have the right to request the limitation of the processing of your Data.

Important note: to do so, you must challenge the accuracy of your personal data for the time necessary for us to verify its accuracy. Or, if you believe that our use of your personal data is unlawful and you request a limitation of its use and not its deletion. We no longer need to use your data for the purposes mentioned in paragraph 3, but your data is still useful for the establishment, exercise or defense of your legal rights, in the event that you decide to exercise your right to object during the time required for verification to determine whether the legitimate reasons we are pursuing prevail over yours.


6.3. You have the right to request the deletion of your Data.

If you demand the deletion of your personal data, ADHERO CREATIVE OÜ will still have the possibility of conserving them in an intermediate archive format during the time necessary to satisfy its legal, accounting and fiscal obligations.


6.4. You have the right to demand the exercise of your right of opposition to the treatments exploited for commercial prospecting purposes.

In case of e-mail prospecting, you have the right to ask for the modification or the unsubscription of the newsletters by clicking on the hypertext link "unsubscribe" available in all the newsletters, or by navigating directly to the contact page of the Freshup Professional website.

In case of SMS canvassing, it is possible to unsubscribe by sending a text message with the word "STOP", or by navigating to the contact page of the Freshup Professional website.


6.5. You have the right to transmit post-mortem prerogatives concerning the conservation, deletion and communication of your personal data.

In case of absence of this type of prerogative, your successors and heirs have the possibility of communicating with ADHERO CREATIVE OÜ in order to have access to the uses of these data and to allow an "organization and settlement of the succession of the deceased" and/or to close the account on the site and/or to ask for the non-continuation of the treatment of the personal data.

You can also make the request of non communication of your data to a third party in case of death.


6.6. You are entitled to claim your right to portability.


6.7. You have the right to withdraw your consent to the performance of processing operations based on this legal basis.

Important clarification: If you decide to withdraw your consent, this will not affect the lawfulness of the uses made before your withdrawal of consent.

6.8. You have the right, when you wish, to bring a complaint before the competent control authority.

In order to exercise your rights, please send your complaint (accompanied by your e-mail, name, first name, copy of your identity card and postal address) to the data protection delegation of ADHERO CREATIVE OÜ by e-mail to and/or by post to ADHERO CREATIVE OÜ, Harju maakond, Tallinn, Kristiine linnaosa, Vana-liivamäe 3-31, 10132, Estonia

Within a maximum of one (1) month after the date of reception of the complaint, we will send you a response.



7.1. What is a cookie?

When you navigate on an internet site such as the site of ADHERO CREATIVE OÜ, this one can then, according to your choice, insert on your receiver (computer, telephone or tablet), through your navigator, a text file.

This text file is called COOKIE. This cookie then allows the website like Freshup Professional, during the prescribed time of validity or recording of the cookie, to identify your receiver used when you make another visit.

Only the issuer of a cookie is likely to read or modify the information contained in this cookie.


7.2. What are cookies used for on

We can classify different types of cookies by categories. Some of them are emitted directly by ADHERO CREATIVE OÜ and its service providers, but some sometimes come from third party companies.


7.2.1. Cookies issued by Freshup Professional and its service providers

There are several categories of cookies that can be found on your transmitter when you navigate on our website: Essential" cookies

In order to have access to our site, the "essential" cookies are necessary, they are used for example to be able to make the order.

If they were not present, you could encounter problems browsing the site and be unable to place an order.

Essential" cookies also allow Freshup Professional to track its activity.

They can be inserted on your transmitter by Freshup Professional or by its providers. Analytical and Personalization" cookies

Analytical and personalization" cookies are not mandatory, they will allow us to facilitate your research, optimize your experience with us, we will be able to better target your expectations and adapt our offers and maximize the organization of our site. Advertising" cookies

Advertising cookies are displayed in the spaces reserved for advertising on our site. The interest for you is that your browsing time is better and optimized thanks to the presentation of offers and advertisements relevant to you.

To do this, "advertising" cookies will target your expectations in real time and offer you advertising content adapted to your desires and interests at the time, through your recent browsing history on other sites.

This allows us to avoid presenting you with advertising content that is of no interest to you. At the same time, ADHERO CREATIVE OÜ prefers to see its offers and advertisements proposed to users who will be interested by them.

The proposed advertising contents can contain cookies emitted by Freshup Professional or by its service providers, or by third parties by means of the association of a cookie with the advertising content of an advertiser.


7.2.2. Cookies issued by third party companies

Third parties using cookies on our site use their own privacy policies. These cookies are not necessary for the use of our site.


7.2.3. Cookies issued by third party applications integrated into our site

While you are browsing our site, we may include third-party computer applications on our site to give you the ability to share content and/or your opinion from our site with others, for example when you click on the "share" or "like" buttons from social networks.

These social networks can then through these buttons identify you even if you did not use them while browsing the site. It is possible for them to do this if when you last browsed the site you were simultaneously logged in or active on your social network transmitter. We have no control over the uses they make of the data they have.

In order to learn more about the use of your data and advertising content, you can go to your social networks and consult their privacy policies. You should then be able to use these policies to manage your settings according to your preferences on the user accounts of each of the social networks on which you are registered.


Privacy policy of the above mentioned social networks, click on the social network of your choice:



Google + :


Concerning our advertising network, we remind you, as mentioned before, that all our advertising spaces may contain cookies from third parties (advertiser at the origin of the advertisement presented, third party service providers of the advertiser...).

They can thus with these cookies and during the prescribed time of validity of those, propose advertisements in the places placed at the disposal for the advertisements of the thirds, to count the number of contents which they propose in our spaces, to know the audience of these advertisements and the number of clicks; thanks to that they will be able to claim the sums which are due to them and to establish their statistics. They can also know that your sender is the one who previously visited another site containing one of their ads, and therefore target you and personalize their content if necessary.


7.3. The options offered by your browser software (Internet Explorer, Firefox, Google Chrome, etc.).

Your browser contains many options that you can set according to your preferences. You can then choose to accept or reject cookies on your browser.

However, if you choose to accept the recording of these cookies on your transmitter, then, at the time of your visits on sites or contents with cookies present, those will be automatically recorded on your transmitter.

Depending on your preferences, you can choose to activate a reminder asking you whether you accept or reject cookies before they are stored, or you can refuse to accept or reject each time a cookie is stored on your browser.

However, it is important to note that the choices you make when setting these parameters may modify or alter your navigation on the Internet or on certain sites or services that require the use of these cookies (such as ordering on our site, for example).

In the event that you prefer to refuse these cookies on your transmitter or delete those already saved, we decline all responsibility for the consequences of the alteration of the functioning of our services, which would result from the inability of our services to save or have access to the cookies used for their functioning.


7.3.1. How to choose your options according to your browser?

You have different options and choices available to you depending on your browser. In order to have more, you can consult the help menu of it.

Internet Explorer™ :

Safari™ :

Chrome™ :

Firefox™ :

Opera™ :



Most of the time, your data is held within the European Union.

However, where our service providers are located in countries outside the European Union, we share some of your data with third countries, such as third countries where the European Commission has not conducted a compliance assessment.

In this case, we take steps to ensure that such data sharing is done in compliance with the relevant regulations and that protection of your privacy and fundamental rights is guaranteed (e.g. by using the European Commission's contractual clauses).

The Data Protection Officer can, upon request, provide you with more information about the data transfer.



With the technical and organizational measures we take, we can guarantee a level of security that is in line with the risks to the rights and freedoms of natural persons with regard to the points mentioned in point 2. For this purpose, we take into account the origin, the scope, the context, the costs and the state of knowledge, the purposes of the processing, but also the identified risks.

In addition, we are up to date with the PCI DSS payment card industry security standard, which reflects our commitment to security.



Through the automated processing we use (e.g. profiling), you are subject to legal effects that affect you.

This is necessary for the conclusion or performance of the contract between you and us.

This is how we can offer and carry out automated customer identification and "3 x payment". The basis for this is the analysis of different variables concerning the type of products, services ordered, or customer profile.

If the risk is evaluated with these statistics as being too high (fraud/unpaid), then this payment method will not be offered.

However, if you wish, you can obtain a human intervention even though the decisions are automated, so you can give your opinion and/or oppose the automatic decision.



Our personal data policy will be updated whenever necessary in order to be always in accordance with the regulations applicable to the protection of your data (at least every three (3) years).


All rights reserved - July 11, 2022