1. Introduction

The right to privacy, and specifically the right to personal data protection is one of the values of Swim & Fun which is included in our Code of Ethics.

The objective of this policy is to explain how Swim & Fun will process the personal data that may be collected through the different forms that may be found on this website. Your personal data will be processed confidentially and only for those purposes that you have consented to, as explained below in this General Privacy Policy and in each of the Privacy Policies of the different forms.

 

2. Commitment to privacy

Swim & Fun 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, Swim & Fun 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 Swim & Fun 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 conservation periods of the data processing.

Swim & Fun 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 any given web page, we shall process your data for, but not limited to, the following purposes:

Purpose

Legal Grounds

Storage period
To respond to your inquiries, questions and requests made through the channels or means provided or available through the website. There are two channels in order to answer consumers queries; firstly through the chat and secondly through the option: New request.

The basis of legitimacy is the legitimate interest of Swim & Fun in responding to your queries.

The benefit for Swim & Fun is to be able to establish a potential pre-contractual relationship with the interested party, thus being able to precisely know their needs.

The benefit for the interested parties is to be able to receive clear and concise information regarding their queries or requests.

For more information on legitimate interest, please refer to section 4 of this privacy policy.		 All data you provide will be processed for the time necessary to fulfill your request or inquiry. It depends on the nature of the information and the reason for its retention.

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

The basis for legitimizing strictly necessary cookies is Swim & Fun legitimate interest in being able to offer you a better browsing experience on our website. The benefit to Swim & Fun is to provide a good quality website. The benefit to stakeholders is to be able to receive a quality experience by browsing the website.

The basis of legitimacy for the rest of cookies is the consent you have given by accepting cookies.

 For more information, please refer to our cookie policy.

To give access to the user’s account.

The basis of legitimacy is the contractual relationship between the company and the costumer.

All data you provide will be processed for the time necessary to fulfill your request or inquiry. It depends on the nature of the information and the reason for its retention.
On some occasions it may be necessary for us to process your personal data in order to comply with legal obligations, or in connection with any 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.

 

3. International Data Transfers

Swim & Fun, 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, Swim & Fun 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.

 

4. Processing activities based on the legitimate interest

In accordance with what is indicated in the second section of this Privacy Policy, Swim & Fun may carry out processing based on legitimate interest. 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 a 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 users.

You may at any time request further information about the weighting of legitimate interest by contacting our Data Protection Officer (DPO) at the address indicated in section 6 of this Privacy Policy. We would also like to take this opportunity to remind you that you have the right to object to processing based on legitimate interest.

 

5. Duration of processing and term of storage

Swim & Fun is bound by the undertaking to only process your personal data while they are actually useful to us and we are able to provide you with a quality Service by using them. Therefore, we make every reasonable endeavour 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.

 

6. Exercise of rights and complaints to the Data Protection Agency

As a result of Swim & Fun 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 of access. You are entitled to find out which of your personal data are processed and the purposes for which we process them.
  2. 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 them were wrong.
  3. 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.
  4. 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.
  5. Right to restriction of processing. You may request restriction of processing in the following cases:

a. If you consider that the data we hold about you are incorrect or inaccurate.

b. 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.

c. 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.

d. 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 Swim & Fun 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 corresponding Data Protection Authority.

 

7. 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, Swim & Fun 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 or Customers.

 

8. Social Media

Social Networks 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.