General Privacy Policy
Introduction
The right to privacy and, specifically, the right to personal data protection, is one of the Fluidra Group values set forth in our Code of Ethics.
The aim of this policy is to explain how we will process your personal data in connection to the Fluidra Pro ecosystem. Your data will be processed confidentially and only for the purposes you were informed of and, where applicable, consented to, as explained below.
Data controller
Your data will be processed separately by FLUIDRA GLOBAL DISTRIBUTION, S.L.U., located at Avda. Alcalde Barnils, 69, 08174 Sant Cugat del Vallès (Barcelona), with tax ID number NIF B63216121, and by the Fluidra Group company/companies with which you have a contractual relationship (hereinafter, jointly “Fluidra”).
Privacy commitment
Fluidra is fully committed to complying with the EU General Data Protection Regulation and other data protection regulations in force at all times, as this is a priority objective for the company.
To that end, Fluidra has decided to implement the following principles, with privacy being the basis on which all processing is carried out:
- Data processing transparency is one of our priorities, so whenever we collect personal data about you, we will duly inform you of the purposes of the processing in the corresponding privacy policy.
- We will always process the data strictly necessary to carry out processing to which you have given your consent.
- We will never force you to supply personal data unless the data are really necessary to provide the service you have requested.
- Whenever possible, we will give you simple tools to help control your data.
- We will not share data with third parties, except for service providers and parties we have previously informed you of and to which you have given your consent.
Processing purposes, legitimate basis and storage periods
If you have access to Fluidra Pro eSales, we may process your data in accordance with the following:
| Purpose | Legitimate basis | Storage period |
|---|---|---|
| To answer your inquiries, questions, or requests lodged over the website or via administration@fluidrabalkans.com (Fluidra Balkans) and reach out to you to solve them. | The legitimate basis is Fluidra’s legitimate interest in answering your questions or requests. The benefit of this for us is having accurate knowledge about what you need in order to improve the quality of our services. The benefit for you is being able to receive clear and concise information regarding your inquiries and requests. Please bear in mind that the legitimate interest was subject to a weighting by analyzing our benefits as data controller and third-party benefits in order to assess legitimate interest, and it was concluded that our legitimate interest in processing prevails over your interests, rights and freedoms as a user. Find out more about the weighting of our legitimate interest by contacting our Data Protection Officer at the address at the bottom of this section. We also take this opportunity to remind you of your right to object to processing based on legitimate interest. | Your data will be processed for as long as required to resolve your request or inquiry. |
| To allow you to buy products offered over Fluidra eSales, including fraud prevention during procurement. | The legitimate basis is the contractual relationship between the Parties. In relation to fraud prevention, the legitimate basis is Fluidra’s legitimate interest in fighting fraud. The benefit of this for us is to detect and prevent the commission of offenses in relation to the purchase of products and services that entail potential financial or reputational loss. The benefit for you is increased security in the financial services you use by allowing you to partner with us in combatting fraud against the state financial system. Please bear in mind that the legitimate interest was subject to a weighting by analyzing our benefits as data controller and third-party benefits in order to assess legitimate interest, and it was concluded that our legitimate interest in processing prevails over your interests, rights and freedoms as a user. Find out more about the weighting of our legitimate interest by contacting our Data Protection Officer at the address at the bottom of this section. We also take this opportunity to remind you of your right to object to processing based on legitimate interest. | |
| To let you manage your customer portfolio by sending a delivery note to your customers. In this case, Fluidra will act as the data processor of the customers you enter in the platform by enforcing the following data processing agreement: Fluidra Balkans | The legitimate basis is the contractual relationship between the Parties. | Your data will be processed for as long as needed to manage your account and its features until you ask for your account to be deleted or until the contractual relationship between us ends. |
| To let you access the ‘outlet’ section of the website, where enabled. | The legitimate basis is the contractual relationship between the Parties. | Your data will be processed as needed to enable you to access the ‘outlet’ section. |
| To provide information on products in our catalog. | The legitimate basis of the processing is the contractual relationship between the Parties. | Your data will be processed when necessary to provide you information on products from our catalog. |
| To seek your opinion in relation to the products and services we offer. | The legitimate basis is Fluidra’s legitimate interest in obtaining opinions on services rendered. The benefit of this for us is knowing what you think about the quality of our services in order to introduce improvements to them. The benefit for you is enjoying improved products and services going forward thanks to the improvements we make on the basis of these opinions. Please bear in mind that the legitimate interest was subject to a weighting by analyzing our benefits as data controller and third-party benefits in order to assess legitimate interest, and it was concluded that our legitimate interest in processing prevails over your interests, rights and freedoms as a user. Find out more about the weighting of our legitimate interest by contacting our Data Protection Officer at the address at the bottom of this section. We also take this opportunity to remind you of your right to object to processing based on legitimate interest. | Your data will be processed for as long as needed to manage your opinions on our products and services. |
If you have access to the Fluidra Media Center, we may process your data in accordance with the following:
| Purpose | Legitimate basis | Storage period |
|---|---|---|
| to allow you to download our product and service catalog and send to you via email. | The legitimate basis is the contractual relationship between the Parties. | Your data will be processed when necessary to provide you information on products from our catalog. |
If you have an account [enter a profile name that DOES make it possible to manage other users from your company], we will be able to process your data in accordance with the following:
| Purpose | Legitimate basis | Storage period |
|---|---|---|
| To give you access to a user account for the Fluidra Pro ecosystem. | The legitimate basis of the processing is the contractual relationship between the Parties. | Your data will be processed for as long as needed to manage your account and its features until you ask for your account to be deleted or until the contractual relationship between us ends. |
| To let you manage and assign accesses to the different Fluidra Pro ecosystem sections in relation to the people in your company who need access to them. | The legitimate basis of the processing is the contractual relationship between the Parties. | Your data will be processed for as long as needed to manage your account and its features until you ask for your account to be deleted or until the contractual relationship between us ends. |
| To send you messages on the status of your Fluidra Pro account. | The legitimate basis of the processing is the contractual relationship between the Parties. | Your data will be processed for as long as needed to manage your account and its features until you ask for your account to be deleted or until the contractual relationship between us ends. |
If you have an account [enter a profile name that does NOT make it possible to manage other users from your company], we will be able to process your data in accordance with the following:
| Purpose | Legitimate basis | Storage period |
|---|---|---|
| To give you access to a user account for the Fluidra Pro ecosystem that your company has assigned to you. | The legitimate basis of the processing is the contractual relationship between the Parties. | Your data will be processed for as long as needed to manage your account and its features until you ask for your account to be deleted or until the contractual relationship between us ends. |
| To send you messages on the status of your Fluidra Pro account. | The legitimate basis of the processing is the contractual relationship between the Parties. | Your data will be processed for as long as needed to manage your account and its features until you ask for your account to be deleted or until the contractual relationship between us ends. |
In relation to the use of cookies in the Fluidra Pro ecosystem, we will be able to process your data in accordance with the following:
| Purpose | Legitimate basis | Storage period |
|---|---|---|
| To improve our web pages, services and products, and provide a better service and content. | The legitimate basis of the strictly necessary cookies is our legitimate interest in offering you an enhanced browsing experience across our site. The benefit of this for us is to offer a good quality website. The benefit for you is enjoying a quality browsing experience across our site. Please bear in mind that the legitimate interest was subject to a weighting by analyzing our benefits as data controller and third-party benefits in order to assess legitimate interest, and it was concluded that our legitimate interest in processing prevails over your interests, rights and freedoms as a user. Find out more about the weighting of our legitimate interest by contacting our Data Protection Officer at the address at the bottom of this section. We also take this opportunity to remind you of your right to object to processing based on legitimate interest. The legitimate basis of the analytical and advertising cookies is the provision of your consent. See our Cookie Policy for more. | See our Cookie Policy for more on cookie storage. |
It may sometimes be necessary to process your data to meet legal obligations or in relation to any contractual relationship we may have with you.
In other cases, and where appropriate, we will seek your consent to process your data.
Sending marketing messages.
As part of our promotional activity, Fluidra may provide you with resources to sign up to our newsletter or commercial information such as promotions that could be of interest to you. These resources will always be sent subject to your consent.
If you have authorized us to do so, Fluidra will send you information on customized products, activities and services in keeping with your tastes and preferences.
You may withdraw your consent to receive marketing messages at any time using the link or button to that effect in each of the messages or by expressing your wish to withdraw it by emailing us at dataprivacy@fluidra.com.
Data disclosures
If necessary, Fluidra will provide your contact details to the transport agency charged with managing a shipment agreed on with you. However, no other data disclosures to third parties are planned in general, except if there is a legal obligation to do so by us.
To manage secure payments on our site, you must provide your data directly to Adyen B.V. with secure encryption and in accordance with strict banking regulations, in keeping with its privacy policy (https://www.adyen.com). Fluidra will not process your payment gateway details.
Fluidra may also give access to your data to data processors which will never process them for their own purposes. Some of these vendors may be outside the European Union, as indicated in the ‘International data transfers’ section.
International data transfers
As an organization with an international reach, Fluidra has international vendors who may provide their services from outside the EU, so your data could be processed outside the European Union or the European Economic Area.
In such cases, Fluidra will ensure the data processing is always protected with the appropriate safeguards, which may include standard clauses approved by the EU in the form of contracts approved by the European regulator and providing sufficient safeguards to ensure that the processing complies with the requirements established by the EU’s GDPR, as well as third-party certificates, among others.
Data processing and storage periods
Fluidra is committed to processing personal data that are truly useful for us and which can offer you a quality service by exploiting them. To that end, we will make every appropriate and reasonable effort to minimize data processing and storage periods.
In that regard, section 4 of this policy informs you of the planned processing and/or storage periods for your data.
In any event, even if you ask us to delete your data, we may keep them on record duly locked, for the term required to comply with our legal obligations and make them available to the competent authorities with powers on any matters to which your data may be subject.
Exercise of rights and claims before the Spanish Data Protection Agency
As a consequence of processing your data, the laws in force grant you a number of rights. Below is a summarized explanation of each right to make it easier for you to exercise them:
- Right of access: You have the right to know the personal data we process on you and what we process the data for.
- Right to rectification: Your data will always be yours and as such you may seek their rectification at any time if you become aware that the data in our records contain errors.
- Right to erasure: You may ask for your data to be erased from our files at any time. However, as indicated in the data storage section above, in certain circumstances compliance with the laws in force may impede the effective exercise of this right.
- Right to object: You may object to the processing of your data in relation to any of the purposes we process the data for, in accordance with the privacy policies applicable in each case.
- Right to restriction of processing: You may seek restriction of processing in the following cases:
- If you consider that the data we have on you are not correct or accurate;
- If you consider we that are not processing your data legitimately but prefer that we restrict their processing rather than delete them;
- If the data we have are no longer required for the purpose for which we collected them but you need us to keep them to lodge legal claims;
- If, having exercised your right to object to processing, you are waiting to hear back from us.
- Right to data portability: Whenever technically possible and reasonable, you are entitled to ask that the data you directly provided to us be disclosed to another data controller. If we are able to do so, we will directly provide your data directly to the other data controller, but if we are unable to do so we will provide the data to you in a standard format.
Whenever we process your data on the basis of your consent, you may withdraw it at any time without any consequences for you beyond us being unable to provide certain services, depending on the right exercised.
You may exercise your rights by emailing Fluidra at dataprivacy@fluidra.com.
If you consider it necessary, you can also email our DPO at dataprivacy@fluidra.com.
For any question or claim regarding the way we process your data or for any other related matter, please contact our DPO by emailing dataprivacy@fluidra.com with the subject line or FAO “Data Protection Officer”. If you do not obtain an answer within a reasonable period of time, you may file a claim with the Spanish Data Protection Agency.
Confidentiality and security in data processing
Your data are very important to us and we undertake to process them with the utmost confidentiality and discretion, and to implement all the security measures we consider appropriate and reasonable.
Fluidra hereby states and warrants that we have established all the technical measures available to us to prevent the loss, misuse, alteration, unauthorized access or theft of the data you provide.
Social Media
Social media are part of the everyday life of many internet users and we have created different profiles on the platforms for them.
All users have the opportunity to join the pages or groups that Fluidra has on different social media.
However, please bear in mind that, unless we ask for your data directly (e.g., through marketing campaigns, competitions, promotions or any other valid form) your data will belong to the social network in question and, therefore, we recommend you read their terms of use and privacy policies carefully and set your data processing preferences.
Profiling and automated decisions
Fluidra may create a professional profile by analysing your behaviour on the Website, such as showing you products that may be of interest to you or reminding you that you have products added to your shopping cart without having completed the purchase, on the basis of the preferences you have shown through your browsing, or information obtained through cookies, with the ultimate aim of personalising your experience on our Website.
This personalisation is partially automated, insofar as Fluidra determines the personalisation parameters, although it is the technological platform that generates the user profile.
Furthermore, Fluidra informs you that this generated profile has no legal effect and does not significantly affect you in the same way.
Remember that you can personalise your cookie preferences using the cookie configurator. For more information, please consult the Cookie Policy.
