PRIVACY POLICY FOR USERS OF THE “Fluidra Pool” APPLICATION

Privacy policy

In accordance with the current regulations on the protection of personal data, we inform you that your personal data will be processed by FLUIDRA GLOBAL DISTRIBUTION, S.L. (“FLUIDRA”) located at Avenue Alcalde Barnils, 69, 08174 Sant Cugat del Vallès (Barcelona), and C.I.F. No. B63216121.

Your personal data will be processed for the following purposes and in accordance with the bases of legitimacy indicated below:

· Purpose: Registration and creation of a User account in order to give users access to the Application.

· Legal grounds: The legal ground is the contractual relationship between the parties.

· Purpose: Tracking the status of the users’ pool in order to help them treat their water.

· Legal grounds: The legal ground is the contractual relationship between the parties.

· Purpose: Keep the user informed of new versions, improvements, and news of the Application.

· Legal grounds: The legal ground is the contractual relationship between the parties.

· Purpose: Processing of your location data to locate your pool in order to offer personalized service and management of your pool including to determine the applicable terms and conditions and language settings in the Application.

· Legal grounds: If you choose to enter the location of your pool in the Application without activating geolocation, the legal ground for this processing of the location data is that it is necessary to enter into a contract with and perform services for you as the user cf. Article 6 (1) (b) of the General Data Protection Regulation (GDPR).
If you choose to provide us with the location of your pool by activating geolocation through the Google Maps system, we rely on your consent as a legal basis for data processing, whereas consent is expressed through the completion of this parameter in the Application cf. Article 6 (1) (a) of the General Data Protection Regulation (GDPR). Bear in mind that if you use Google Maps automatic geolocation to locate your pool, FLUIDRA will only know your location at the exact moment you are indicating where your pool is. In no case will your device's position be geolocated for a period of time beyond that necessary to know where your pool is located. Additionally, we inform you that you can revoke your consent to locating your pool through Google Maps automatic geolocation at any time using the settings or notification settings of the mobile device or tablet. If you do so we will retain the location of your pool (not your location as user) in order to continue providing the services.

· Purpose: Management and response to user queries or opinions through the Application's messaging mailbox.

· Legal grounds: The legal ground is FLUIDRA's legitimate interest in responding to the user’s questions or requests.

The benefit that this generates for FLUDRA is precisely knowing the needs of the interested parties and thus improving the quality of the services provided. The benefit for the interested parties is to be able to receive clear and concise information regarding their queries or requests. Bear in mind that to assess the legitimate interest, a weighting of the legitimate interest has been carried out in which the benefits of the data controller have been analyzed, as well as the benefits of third parties, and in which it is 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 section of this section. We also take this opportunity to remind you that you have the right to object to processing based on legitimate interest.

· Purpose: Share information about the user’s pool with those users of the Application to whom you have given access. Likewise, also to give you access to the pool information of other users who have decided to share it with you.

· Legal grounds: The legal ground is the provision of your consent through the “Pool settings” section of the Application. Additionally, we inform you that you can revoke your consent at any time through the “Pool setting” section of the Application.

· Purpose: Sending information about products and services marketed and offered by the Fluidra Group, in relation to the Jandy, Astralpool, Polaris, Cepex, Zodiac and Gre brands, based on the state of your pool.

· Legal grounds: The legal ground is the provision of your consent through the additional box provided for this purpose in the form, or through the specific form once you access the Application.

Keep in mind that these communications can be sent through push notifications, pop-up messages, or via email, provided you have given your consent. Additionally, we inform you that you may revoke your consent at any time in the relevant section of the Application, through the channel indicated later in this privacy policy, as well as through each communication you receive.

The data requested at the time of registration and creation of a User account, marked with an asterisk, are essential to carry out the processing.

The Application offers the option of receiving information through “push” notifications (this is the name given to a type of communication in which data is transmitted even though the Application remains in the background). Similarly, the Application also allows the user to receive information through “pop up” messages. The user can deactivate these services at any time using the settings or notification settings of the mobile device or tablet.

Your data will not be transferred, sold, rented or made available in any other way to any third party. In certain cases, access will be given to those service providers of the company, who carry out certain activities for FLUIDRA, but in no case will they process the data for their own purposes. Bear in mind that if you access third-party websites or platforms through links that FLUIDRA has sent you in any of its communications, this does not imply a communication of your personal data from FLUIDRA to said third-party websites or platforms. FLUIDRA, as an entity with international projection, has international providers that can provide their services from outside the European Economic Area, so it is possible that your data will be processed outside said area. In any case, FLUIDRA will ensure that said data processing is always protected with the appropriate guarantees indicated in the applicable regulations, which may include, by way of illustration and not exhaustive: Standard Clauses approved by the European Union or Third-party Certifications.

All the data you provide us will be processed during the period in which your account remains active, that is, until you request to cancel your account, or until FLUIDRA may consider that you are no longer interested in maintaining the account. same after a period of inactivity of 2 years on his part.

Also, if you have provided your data for the treatment related to the sending of information on products and services marketed and offered by the Fluidra Group, in relation to the Jandy, Astralpool, Polaris, Cepex, Zodiac and Gre brands, based on the state of your pool, Your data will be processed as long as you do not unsubscribe from the processing or until FLUIDRA considers that, by any means available according to the technology available at any given time, you are no longer interested in the products offered. In any case, you can unsubscribe from this type of communication at any time, as indicated in the following paragraphs.

At the end of the period indicated in this section, FLUIDRA will keep your data duly anonymized for statistical or market study purposes, whenever possible, or duly blocked to comply with any legal obligation of the company.

Additionally, some of the communications you receive from FLUIDRA may contain links to third-party websites or platforms, such as Amazon. Below, we provide you with Amazon's privacy policy:https://www.amazon.es/gp/help/customer/display.html?nodeId=GX7NJQ4ZB8MHFRNJ. Similarly, if you decide to use geolocation to geographically locate your pool, please note that Google Maps technology will be used, in accordance with the following privacy information: https://policies.google.com/privacy ?hl=es. In this sense, FLUIDRA informs you that, if you access said channels offered by third parties, your data, other than location data, will be exclusively processed by the third party, in accordance with the provisions of the privacy policies of said third-party websites or platforms. Consequently, we recommend that you carefully read the conditions of use and privacy policies of third parties, as well as make sure to configure your preferences regarding data processing. If you do not agree with said privacy policies, do not provide your data. FLUIDRA cannot control their use on third-party platforms.

Likewise, you may exercise your rights of access, rectification, deletion, opposition, limitation or portability by email to the address dataprivacy@fluidra.com, with the reference “Personal Data”.

If you have any questions or complaints about how we treat your personal data, or any other matter related to the matter, you can contact our Data Protection Delegate, by email at the address dataprivacy@fluidra.com, with the reference “Data Protection Officer”. If you do not receive a response within a reasonable period, you may file a claim with the competent Data Protection Authority.