Privacy policy

1. Introduction

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

The purpose of this policy is to explain how Fluidra will process any personal data that may be collected through the various forms that can be found on the website www.fluidra.com. Your personal data will be treated confidentially and only for the purposes for which you have been informed, as explained below in this Privacy Policy.

2. Commitment with privacy

Fluidra 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 Fluidra’s Group.

Therefore, Fluidra 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 shall we 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.
Your data shall not be assigned, sold, leased or in any other way whatsoever made available to third parties, except in the case of Fluidra’s service providers that render certain services, but under no circumstances shall they process them for their own ends. Some of these service providers may be based outside of the European Union, as stated in the section “International Transfers”.

Purposes, bases of legitimacy and storage periods of the data processing.

Fluidra collects your personal data for handling your requests and providing you with products and services that you may find useful.

Depending on your interaction on the site, your personal data will be processed for the following purposes and in accordance with the following legal grounds:

Contact form: "Investor Relations", "Press", "Human Resources" or "Other".
Depending on the area of interest selected by you ("Investor Relations", "Press", "Human Resources" or "other"), we inform you that your data will be processed by FLUIDRA S.A., for the following purposes: (i) To redirect the message to the corresponding department depending on the area of interest selected (Investor Relations, Press, Human Resources, or any other department of Fluidra, S.A. that can respond to the query raised) and; (ii) To respond to any doubts or queries you may raise, based on the area of interest selected.	The legal grounds is Fluidra's legitimate interest in responding to your questions or requests made through the "Investor Relations", "Press", "Human Resources" or "Other" options. The benefit for Fluidra is to know precisely the needs of the interested parties and thus improve the quality of the services provided. The benefit for stakeholders is to be able to receive clear and concise information regarding their queries or requests. Please note that in order to assess the legitimate interest, a legitimate interest weighting has been carried out in which we have analysed our own benefits as a data controller as well as the benefits of third parties, and concluded that our legitimate interest in the processing outweighs the interests, rights and freedoms of users. You can request more information about the weighting of legitimate interest by contacting our Data Protection Officer (DPO) at the address indicated in the final section of this section. We would also like to take this opportunity to remind you that you have the right to object to processing based on legitimate interest.	Any data you provide to us when you have selected the "Investor Relations", "Press", "Human Resources" or "Other" options will be processed for as long as it is necessary to deal with your request or enquiry.

Contact form: "Investor Relations", "Press", "Human Resources" or "Other".

Purpose

Legal ground

Storage period

Depending on the area of interest selected by you ("Investor Relations", "Press", "Human Resources" or "other"), we inform you that your data will be processed by FLUIDRA S.A., for the following purposes:

(i) To redirect the message to the corresponding department depending on the area of interest selected (Investor Relations, Press, Human Resources, or any other department of Fluidra, S.A. that can respond to the query raised) and;

(ii) To respond to any doubts or queries you may raise, based on the area of interest selected.

The legal grounds is Fluidra's legitimate interest in responding to your questions or requests made through the "Investor Relations", "Press", "Human Resources" or "Other" options.

The benefit for Fluidra is to know precisely the needs of the interested parties and thus improve the quality of the services provided. The benefit for stakeholders is to be able to receive clear and concise information regarding their queries or requests.

Please note that in order to assess the legitimate interest, a legitimate interest weighting has been carried out in which we have analysed our own benefits as a data controller as well as the benefits of third parties, and concluded that our legitimate interest in the processing outweighs the interests, rights and freedoms of users. You can request more information about the weighting of legitimate interest by contacting our Data Protection Officer (DPO) at the address indicated in the final section of this section. We would also like to take this opportunity to remind you that you have the right to object to processing based on legitimate interest.

Any data you provide to us when you have selected the "Investor Relations", "Press", "Human Resources" or "Other" options will be processed for as long as it is necessary to deal with your request or enquiry.

Newsletter form for investors, analysts and/or shareholders
To provide you with communications in relation to stock market or financial news and information of interest to investors, analysts and/or shareholders.	The legal grounds is the provision of your consent by means of the additional box provided for this purpose on the form. In addition, we inform you that you may revoke your consent at any time, and at each communication.	All the data you provide will be processed until you unsubscribe from the newsletter, or until Fluidra considers that you are no longer interested in receiving communications from the newsletter.

Newsletter form for investors, analysts and/or shareholders

Purpose

Legal ground

Storage period

To provide you with communications in relation to stock market or financial news and information of interest to investors, analysts and/or shareholders.

The legal grounds is the provision of your consent by means of the additional box provided for this purpose on the form.

In addition, we inform you that you may revoke your consent at any time, and at each communication.

All the data you provide will be processed until you unsubscribe from the newsletter, or until Fluidra considers that you are no longer interested in receiving communications from the newsletter.

Contact form: fluidra.com/projects
Purpose	Legal ground	Storage period
Depending on the country, sectors of interest and needs selected in the form, we inform you that your data will be processed by FLUIDRA S.A., for the following purposes: Redirect the message to the corresponding department or company of the Fluidra Group according to the preferences you have selected so that it can respond to the query raised; and To respond to any doubts or queries you may have, based on the interests shown.	The legal basis is Fluidra's legitimate interest in responding to your questions or requests made through the contact form at fluidra.com/projects. The benefit for Fluidra is to know precisely the needs of the interested parties and thus improve the quality of the services provided. The benefit for stakeholders is to receive clear and concise information regarding their queries or requests. Please note that in order to assess the legitimate interest, a weighting of the legitimate interest has been carried out in which we have analysed our own benefits as a data controller, as well as the benefits of third parties, and concluded that our legitimate interest in the processing prevails over the interests, rights and freedoms of users. You can request more information about the weighting of legitimate interest by contacting our Data Protection Officer (DPO) at the address indicated in the final paragraph of this section. We also take this opportunity to remind you that you have the right to object to processing based on legitimate interest.	All the information you provide us when filling in the contact form of fluidra.com/projects will be treated as long as it is necessary to solve your request or query.
To manage the sending of the Fluidra Commercial Pool & Wellness Division newsletter tailored to your interests.	The legal basis is the provision of your consent by means of the specific additional box provided for this purpose on the form.	All data you provide will be processed until you unsubscribe from the newsletter, or until Fluidra can consider that you are no longer interested in receiving communications from the newsletter.
To send you personalized commercial communications about Fluidra Commercial Pool & Wellness Division products and services that may be of interest to you.	The basis of legitimacy is the provision of your consent through the specific additional box provided for this purpose on the form.	All data you provide will be processed until you unsubscribe from the newsletter, or until Fluidra can consider that you are no longer interested in receiving communications from the newsletter.

Careers - Employment page
Purpose	Legal ground	Storage period
For further information on the processing of your data on this matter, please refer to the Privacy Policy of our employment portal at https://fluidra.csod.com/ux/ats/careersite/1/home?c=fluidra.

Use of Cookies
To improve our web sites, services, products, and provide better service and content.	The legal grounds of strictly necessary cookies is Fluidra's legitimate interest in being able to offer you a better browsing experience on our website. The benefit for Fluidra is to provide a good quality website. The benefit to stakeholders is to be able to receive a quality experience by browsing the website. Please note that in order to assess the legitimate interest, a weighting of the legitimate interest has been carried out in which we have analyzed our own benefits as data controller, as well as the benefits of third parties, and in which we conclude that our legitimate interest on the processing prevails over the interests, rights and freedoms of the users. You can request more information about the weighting of legitimate interest by contacting our Data Protection Officer (DPO) at the address indicated at the end of this section. We would also like to take this opportunity to remind you that you have the right to object to processing based on legitimate interest. Likewise, the basis of legitimacy of advertising cookies is the provision of your consent. For more information, please see our Cookie Policy.	For more information, please see our Cookie Policy.

Use of Cookies

Purpose

Legal ground

Storage period

To improve our web sites, services, products, and provide better service and content.

The legal grounds of strictly necessary cookies is Fluidra's legitimate interest in being able to offer you a better browsing experience on our website. The benefit for Fluidra is to provide a good quality website. The benefit to stakeholders is to be able to receive a quality experience by browsing the website. Please note that in order to assess the legitimate interest, a weighting of the legitimate interest has been carried out in which we have analyzed our own benefits as data controller, as well as the benefits of third parties, and in which we conclude that our legitimate interest on the processing prevails over the interests, rights and freedoms of the users. You can request more information about the weighting of legitimate interest by contacting our Data Protection Officer (DPO) at the address indicated at the end of this section. We would also like to take this opportunity to remind you that you have the right to object to processing based on legitimate interest.

Likewise, the basis of legitimacy of advertising cookies is the provision of your consent. For more information, please see our Cookie Policy.

For more information, please see our Cookie Policy.

Without prejudice to informing you of this in the privacy policies of the data collection forms, it may sometimes be necessary to process your personal data in order to comply with legal obligations, in the public interest, on the basis of Fluidra's legitimate interest, or in connection with any contractual relationship we may have with you.

In all other cases, where appropriate, we will ask for your consent to process your personal data.

3. Data communications

Your data will not be transferred, sold, rented or made available in any other way to any third party, except to those service providers of Fluidra, who perform certain activities for Fluidra, but who in no case will process the data for their own purposes. Likewise, your data may be shared with other entities of the Fluidra Group, although the data will be processed for the same purposes indicated, without prejudice to the additional information that each company may provide you with.

Some of these third parties may be located outside the European Union, as indicated in the "International Transfers" section.

4. Sending of commercial communications

Fluidra, as part of its promotional activity, may provide you with resources for registration or subscription to company news or commercial information. These resources will always be subject to your consent to send them.

If you have given your consent, Fluidra will send you information about its products, activities and services personalised for you according to your tastes and preferences.

You may revoke your consent to receive commercial communications at any time, by means of the link or button provided for this purpose in each of the communications, or by communicating your wish to revoke your consent by sending an e-mail to dataprivacy@fluidra.com

5. Duration of processing and storage period

At Fluidra we are committed to processing personal data for as long as it is really useful to us and as long as we can offer you a quality service through its use. Therefore, we will make all appropriate and reasonable efforts to minimise the period of processing and storage of personal data.

In this regard, on each data collection form we will inform you of the expected period of processing and/or retention of your personal data.

In any case, and even if you ask us to delete your data, we may keep them and maintain them, under the appropriate blocking, for the period necessary to comply with our legal obligations and to make them available to the Authorities with competence in the different applicable matters.

6. International data transfers

Fluidra, as an entity of international projection, has international suppliers that can provide their services from outside the EU, so it is possible that your data are processed outside the European Union or the European Economic Area.

In any case, Fluidra will ensure that such data processing is always protected with the appropriate guarantees, which may include Standard Clauses approved by the EU, these being contracts approved by the European regulator, and which provide sufficient guarantees to ensure that the processing complies with the requirements established by the European Data Protection Regulation, as well as certifications from third parties, among others.

7. Exercise of rights and complaints to Agencia Española de Protección de Datos

As a result of Fluidra 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:

Right of access: You are entitled to find out which of your personal data are processed and the purposes for which we process them.
Right of rectification: Your data shall always belong to you and, as such, you may at any time request that they be rectified if the records we hold of you were wrong.
Right of 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.
Right to object: You may object to your personal data from being processed in relation to any of the purposes for which we process them, pursuant to the privacy policies that may apply in each case.
Right to restriction of processing: You may request restriction of processing in the following cases:
1. If you consider that the data we hold about you are 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.
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 such 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 Fluidra through an email to dataprivacy@fluidra.com

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

If you have any doubt or complaint about how we process your personal data, or any other matter related to the matter, you can contact our DPO, by e-mail to dataprivacy@fluidra.com, with the reference or to the attention of the "Data Protection Officer". In case of not obtaining an answer within a reasonable period of time, you will be able to lodge a complaint with to the Agencia Española de Protección de Datos.

8. 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 discretion, as well as to implement all security measures that we consider are required and reasonable.

To this regard, Fluidra 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.

9. Social Media

Social Media are part of the daily life of many Internet users, and for them we have created different profiles in them.

All users have the opportunity to join the pages or groups that Fluidra has in different social networks.

However, you must take into account that, unless we ask you for your data directly (for example, through marketing actions, contests, promotions, or any other valid way), your data will belong to the corresponding Social Network, so we recommend you to read carefully its conditions of use and privacy policies, as well as to make sure you configure your preferences regarding data processing.