General privacy policy
1. Introduction
The right to privacy and, specifically, the right to personal data protection is one of the values of MANUFACTURAS GRE S.A (hereinafter, GRE), and FLUIDRA, S.A., matrix company of the Fluidra Group (the companies forming part of the Fluidra Group can be viewed at www.fluidra.com
The aim of this policy is to explain how GRE shall process any personal data it collects from the various forms that may be posted on the pages of GRE’s Website: grepool.com. Your personal data shall be processed in the strictest confidence and solely for the purposes to which you have consented, as explained below in this General Privacy Policy and in each of the Privacy Policies on each of the forms.
2. Commitment to privacy
GRE 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 GRE and Fluidra Group.
Therefore, GRE and Fluidra Group 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 we shall 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 will not be transferred, sold, rented or made available to any form of third parties, except to other companies of the Fluidra Group that provide services to GRE and to those third party providers of services to Gre or the Fluidra Group, who perform certain activities for Gre, but who under no circumstance will handle the data for their own aims. Some of these providers may be outside of the European Union, as indicated in the section “International Transfers
Purposes of data processing
GRE collects your personal data for handling your requests and providing you with the products and services that you may find useful. Depending on your interaction on the website we treat your personal data, for example, for the following aims:
a) To reply to your queries, questions and requests made through customer service or contact or press channels posted on each website and to contact you in order to deal with them.
b) In order to improve our websites, service and products, as well as to provide a better service and content.
On some occasions, it may be necessary to process your personal data to comply with legal obligations, or in relation to a 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. Sending marketing messages
Within the framework of its marketing activities, GRE may provide you with the means for registering or signing up for the company's newsletters and general or commercial information about it. The sending of such messages shall be subject to you having given your consent to do so at all times
In the event that you have given your consent, GRE shall send you customized information about its products, business and services in accordance with your tastes and preferences.
You may withdraw your consent at any time whenever you receive marketing messages through the link or button enabled for this purpose in all messages, or by expressing your desire to withdraw your consent through the following channels:
(i). An email to dataprivacy@fluidra.com.
(ii). A letter addressed to Avda. Francesc Macià, 60, planta 20, 08208, Sabadell (Barcelona).
4. Automated decisions and the creation of profiles
For some services, we may process your personal data using automated means. This means that certain decisions are automatically taken without human intervention. For example, in the event that you have selected products, messages to inform you that the product is still available.
Your data may likewise be processed to create a profile for the purpose of predicting your behavior on the Website by displaying the main page of products that may be of interest to you, based on the preferences you have shown from your browsing habits or on information obtained from cookies. You may contact us by email at dataprivacy@fluidra.com.
5. Duration of processing and term of storage
At GRE we are 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 endeavor 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 fulfil our legal obligations and for their disclosure to the Authorities with powers on the various matters to which they are subject.
6. International Transfers
Gre, as a company with international projection, has international suppliers that can provide its services from outside of the EU, therefore your data may be handled outside of the European Union or the European Economic Area.
In any case, Gre will assure that the mentioned treatment of data is always protected with the opportune guarantees, that may include:
- Standard Clauses approved by the EU: These are contracts approved by European regulator, and provide sufficient guarantees that the treatment complies with the requirements established by the European Regulation for Data Protection.
- Certifications of third parties: For example, the Privacy Shield, framework agreement between the EU and the United States that establishes a standardised framework for the treatment of data according to the European Data Protection Regulation.
7. Exercise of rights and complaints to the Spanish Data Protection Agency (AEPD)
As a result of GRE 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 GRE through either of the following means, accompanied by a copy of a valid ID document:
(i). An email to dataprivacy@fluidra.com.
(ii). A letter to Avda. Francesc Macià, 60, planta 20, 08208, Sabadell (Barcelona).
In addition, should you wish to do so you may contact our Data Protection Officer at dataprivacy@fluidra.com.
In the event that you did not wish to exercise a specific right but needed to make an inquiry or suggestion related the processing of your personal data, you may also write to the addresses provided for exercising your rights.
In any event, you are reminded that you may file a claim with the Competent Authority on personal data protection should you consider that we have not processed your data lawfully or that we have ignored your requests or rights. In Spain, the Competent Authority is the Spanish Data Protection Agency.
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, GRE 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 form part of the everyday lives of many Internet users, so we have created a number of GRE profiles on them.
All users may join the pages or groups that GRE has on various social media.
However, you are reminded that, unless we directly ask you for your data (for example, through marketing campaigns, competitions, promotions or in any other valid way), your personal data shall belong to the corresponding social medium, as a result of which we recommend that you read its terms and conditions of use and privacy policies carefully, as well as ensuring that you set your preferences insofar as the processing of your data is concerned.