PRIVACY POLICY – FLUIDRA ACADEMY

Introduction

The right to privacy, and specifically the right to the protection of personal data, is one of the values of the Fluidra Group and is reflected in our Code of Ethics.

The purpose of this Privacy Policy is to explain how we process personal data in relation to Fluidra Academy. Your personal data will be processed confidentially and only for the purposes described below and, where applicable, for the purposes to which you have consented.

Data Controller

Your personal data will be processed separately by FLUIDRA GLOBAL DISTRIBUTION, S.L.U., with registered office at Avda. Alcalde Barnils, 69, 08174 Sant Cugat del Vallès, Barcelona, Spain, Tax ID B63216121, and by the Fluidra Group company or companies with which you have a contractual or commercial relationship (hereinafter jointly referred to as “Fluidra”).

Privacy Commitment

Fluidra is fully committed to complying with the General Data Protection Regulation of the European Union and with the personal data protection regulations applicable at any time.

For this purpose, Fluidra undertakes to apply the following principles:

• Transparency in the processing of personal data.
• Processing only the data strictly necessary for the relevant purpose.
• Not requiring personal data unless it is necessary to provide the requested service.
• Providing, where possible, simple means to control your personal data.
• Not sharing personal data with third parties except with service providers, legal recipients, or where you have been previously informed and, where necessary, have given your consent.

Purposes of Processing, Legal Bases and Retention Periods

Fluidra may process your personal data for the following purposes in relation to Fluidra Academy:

Management of users in Fluidra Academy

Fluidra may process your personal data to create, validate, manage and maintain your user account on Fluidra Academy.

This may include identification data, professional contact details, company information, customer code, division, role, access permissions and authentication-related information.

The legal basis for this processing is the performance of the service requested by the user, the contractual or commercial relationship with Fluidra, and Fluidra’s legitimate interest in managing access to its training platform.

The data will be retained for as long as the user account remains active and, thereafter, for the period necessary to comply with legal obligations or handle possible liabilities.

Management of training activities

Fluidra may process your personal data to manage enrolments, participation in training activities, access to courses, webinars, learning paths, educational resources and other training services.

This may include course registrations, attendance, learning progress, completion records, assessment results and certifications obtained.

The legal basis for this processing is the provision of the training service, the contractual or commercial relationship with Fluidra, and Fluidra’s legitimate interest in providing and improving its training activities.

The data will be retained for as long as necessary to manage the training activity and maintain the corresponding learning records, unless a longer period is required by law or for the management of liabilities.

Management of paid training courses

Where a paid training course is requested, Fluidra may process personal data necessary to manage the enrolment request, the training contract, acceptance or refusal of the enrolment, automatic registration of participants, order creation, invoicing and payment management according to the usual commercial conditions applicable between Fluidra and the customer.

This may include data relating to the customer, the contracting company, the registered participants and billing information.

The legal basis for this processing is the performance of the contract or pre-contractual measures, the commercial relationship with Fluidra and compliance with legal obligations.

The data will be retained for the duration of the contractual relationship and thereafter for the legally required retention periods.

Use of cookies in Fluidra Academy

Fluidra Academy uses cookies. For more information about the use of cookies, please consult the Cookie Policy.

Sending of commercial communications

As part of its promotional activities, Fluidra may provide resources for registration or subscription to news, updates or commercial information about Fluidra products, activities and services.

If you have given your consent, Fluidra may send you personalized information about its products, activities and services based on your interests and preferences.

You may withdraw your consent to receive commercial communications at any time through the link or button included in each communication, or by sending an email to dataprivacy@fluidra.com.

Data Communications

As a general rule, Fluidra will not disclose your personal data to third parties unless legally required to do so, necessary for the provision of the service, or where you have been previously informed.

Fluidra may give access to your personal data to service providers acting as data processors, who may not process the data for their own purposes.

These providers may include technology providers, hosting providers, authentication providers, learning management platform providers, support providers, communication tools and other suppliers necessary for the operation of Fluidra Academy.

Some of these providers may be located outside the European Union, as described in the section on international data transfers.

International Data Transfers

As an international group, Fluidra may use international providers that provide services from countries outside the European Union or the European Economic Area.

In all cases, Fluidra ensures that such processing is protected by appropriate safeguards, which may include Standard Contractual Clauses approved by the European Union, contractual safeguards, third-party certifications or other legally recognized mechanisms.

Processing and Retention Period

Fluidra undertakes to process personal data only for as long as it is useful and necessary to provide the relevant service.

In any case, even if you request the deletion of your data, Fluidra may retain and block the data for the period necessary to comply with legal obligations, respond to possible liabilities and make them available to the competent authorities where applicable.

Exercise of Rights and Complaints

Under applicable data protection legislation, you may exercise the following rights:

• Right of access;
• Right of rectification;
• Right of erasure;
• Right to object;
• Right to restriction of processing;
• Right to data portability;
• Right to withdraw consent at any time, where processing is based on consent.

To exercise your rights, you may contact Fluidra by email at dataprivacy@fluidra.com.

You may also contact Fluidra’s Data Protection Officer at dataprivacy@fluidra.com.

If you do not receive a response within a reasonable period, or if you consider it necessary, you may lodge a complaint with the Spanish Data Protection Agency.

Confidentiality and Security

Fluidra treats personal data with strict confidentiality and undertakes to implement the technical and organizational security measures it considers appropriate and reasonable to prevent loss, misuse, alteration, unauthorized access or theft of personal data.

Social Networks

Fluidra may maintain profiles on social networks.

Users may join Fluidra’s pages or groups on such social networks. However, unless Fluidra directly requests personal data through a specific action, the data will be processed by the relevant social network according to its own terms and privacy policy.

We recommend that users carefully read the terms of use and privacy policies of the relevant social networks and configure their privacy preferences accordingly.

Profiling and Automated Decisions

Fluidra may create a professional profile based on your interaction with Fluidra Academy, such as your training interests, course enrolments, learning progress, completed courses, certifications and interaction with training content.

This profiling may be used to personalize your learning experience, recommend relevant training content and improve the services offered through Fluidra Academy.

This personalization may be partially automated, as Fluidra determines the personalization criteria while the technological platform may generate the user profile.

Fluidra informs you that this profiling does not have legal effects and does not significantly affect you in a similar way.

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