1. Introduction

The right to privacy and, specifically, the right to personal data protection is one of the values of FLUIDRA S.A. (hereinafter, FSA), a company that belongs to the Fluidra Group, which is set out in our Code of Ethics.

The aim of this policy is to explain how FSA shall process any personal data it collects from the various forms that may be posted on the FSA website. Your personal data shall be processed in the strictest confidence and solely for the purposes to which you have consented, as explained below in this General Privacy Policy and in each of the Privacy Policies on each of the forms.

  1. Commitment to privacy

FSA is fully committed to compliance with the EU’s General Data Protection Regulation and the laws on personal data protection that may be in force at any given time, as this is a top priority for FSA.

Therefore, FSA has taken the decision to implement the following principles, whereby privacy forms the basis of all data processing.

  • Transparency in data processing is one of our priorities, so whenever we collect personal data about you we shall duly inform you of the purpose for which they shall be processed in the relevant privacy policy.
  • We shall only process the data that are strictly necessary for the purposes about which you shall have been informed.
  • We shall never oblige you to provide personal data, unless absolutely necessary to render you a service that you may have requested.
  • Whenever possible, we shall make the most straightforward means available to you for you to control your personal data.
  • We do not share data with any third parties, except with those suppliers that render us services, and those about which we have informed you beforehand and to which you have given your consent.

 Purposes of data processing 

FSA collects your personal data for handling your requests and providing you with the products and services that you may find useful. Specifically, we process your personal data for the following purposes:

  1. To reply to your queries, questions and requests made through customer service, contact or press channels posted on each website and to contact you in order to deal with them, as well as to provide you with information should you be a distributor.
  2. To improve our websites, services and products, as well as to provide a better service and content.
  3. To enable you to download files together with additional subsequent information that we may send to you that is adapted to your interests at all times.
  4. Manage the sending of the informative FSA newsletter adapted to your interests.
  1. Send you personalized commercial communications regarding FSA products and services that may be of your interest.

On some occasions, it may be necessary to process your personal data to comply with legal obligations, or in relation to a contractual relationship we may have with you.

In all other cases, whenever required, we shall ask you for your consent for processing your personal data.

  1. Marketing messages

Within the framework of its promotional activities, FSA may provide you with the means for registering or signing up for the company’s newsletters and general or commercial information about it. The sending of such messages shall be subject to you having given your consent to do so at all times.

In the event that you have given your consent, FSA shall send you customized information about its products, business and services in accordance with your tastes and preferences.

You may withdraw your consent at any time whenever you receive marketing messages through the link or button enabled for this purpose in all messages, or by expressing your desire to withdraw your consent through the following channels:

  1. An email to dataprivacy@fluidra.com.
  2. A letter addressed to Avda. Francesc Macià, 60, planta 20, 08208, Sabadell (Barcelona).
  1. Automatized decisions and profiling

FSA can create a profile through the analysis of your web behavior, showing you products that may be of your interest on the basis of the preferences you have shown through your browsing, or information obtained by means of cookies.

Such personalization will be made in a partially automatized means, in the sense that FSA shall determine the personalization parameters although it is the technological platform which generates the user profile.

  1. International data transfers

FSA , as an international company, has international service providers that may render their services from outside the EU. As a result, it is possible that your data may be transferred outside of the European Union or the European Economic Area.

In any event, FSA shall ensure that such data processing is protected by the appropriate safeguards, which may include Standard Clauses approved by the EU that are taken from agreements approved by the EU regulator and that provide sufficient safeguards to ensure that data processing complies with the requirements of the EU’s General Data Protection Regulation, as well as third-party certifications, amongst others.

  1. Duration of processing and term of storage

FSA is committed to only processing your personal data when we actually need to do so in order to provide you with quality service. Therefore, we make every reasonable endeavor to keep the term of processing and storage of personal data as short as possible.

To this regard, we shall inform you of the term of processing and/or storage of personal data on each form from which data are collected.

In any event, even if you request that we delete your data, we may store and keep them, subject to their being blocked as required by law, for the term required for us to fulfill our legal obligations and for their disclosure to the competent Authorities on the various matters to which they are subject.

  1. Exercise of rights and complaints to the Spanish Data Protection Agency (AEPD) 

As a result of FSA processing your personal data, current laws grant you a number of rights. Below is a brief explanation of each right to assist you should you wish to exercise them:

  1. Right to access. You are entitled to find out which of your personal data are processed and the purposes for which we process them.
  2. Right to rectification. Your data belong to you and, as such, you may request that they be rectified at any time if our records are inaccurate.
  3. Right to erasure. You may at any time request that your personal data be erased from our records. However, as set out in the above section on data storage, it should be remembered that in certain circumstances compliance with the laws in force may prevent this right from actually being exercised.
  4. Right to oppose processing. You may object to your personal data being processed for any of the stated purposes pursuant to the privacy policies that may apply in each case.
  5. Right to restrict processing. You may request restrictions on processing in the following cases:
    1. If you consider that the data we hold about you is incorrect or inaccurate;
    2. If, in the event that you believe we are not legitimately processing your data, you prefer that we restrict their processing rather than erasing them;
    3. If the data we have on record are no longer required for the purposes we collected them for, but you need us to store them to file a lawful claim;
    4. If, having exercised your right to object to the processing of your data for a specific purpose, you are awaiting a reply from us to this regard.
  6. Right to data portability.Provided that it is technically possible to do so and reasonable, you shall be entitled to request that the personal data that you have directly submitted to us be disclosed to another data controller. If this is possible, we shall directly disclose your data to said other data controller, but if it were not possible, we shall provide them to you in a standard format.

Whenever we process your data based on your consent, you may withdraw it at any time, whereby the only consequences for you, depending on the right exercised, shall be not to be able to render certain services to you.

You may exercise your rights by addressing FSA through either of the following means, accompanied by a copy of a valid ID document:

(i). An email to dataprivacy@fluidra.com.

(ii). A letter to Avda. Francesc Macià, 60, planta 20, 08208, Sabadell (Barcelona).

In addition, should you wish to do so you may contact our Data Protection Officer at dataprivacy@fluidra.com.

In the event that you did not wish to exercise a specific right but needed to make an inquiry or suggestion related the processing of your personal data, you may also write to the addresses provided for exercising your rights.

In any event, you are reminded that you may file a claim with the Competent Authority on personal data protection should you consider that we have not processed your data lawfully or that we have ignored your requests or rights. In Spain, the Competent Authority is the Spanish Data Protection Agency.

  1. Confidentiality and security in data processing

Your personal data are very important to us and we undertake to process them in the strictest confidence and with utmost discretion, as well as to implement all security measures that we consider are required and reasonable.

To this regard, FSA hereby states and warrants that it has put all the technical means available to it to avoid the loss, misuse, alteration, unauthorized access and theft of the data provided by the users.

  1. Social media

Social media are part of the everyday lives of many Internet users, so FSA has created a number of profiles on social media platforms.

All users may join the pages or groups set up by FSA on the various social media platforms.

However, you are reminded that, unless we directly ask you for your data (for example, through marketing campaigns, competitions, promotions or in any other valid way), your personal data belong to the corresponding social media platform. Therefore, we recommend that you read the terms and conditions of use and privacy policies carefully and be sure to set your preferences insofar as the processing of your data is concerned.