Introduction

Fluidra Group Australia Pty Ltd (ACN 002 641 965) (Astral Pool) respects and upholds your rights under the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act). This Privacy Policy for Astral Pool lets you know what personal information of yours we hold, what we do with it, who we will disclose it to and how you can access the personal information we hold about you. You can also find out here how to change inaccurate personal information and how to opt out of receiving communications from us.

How does Astral Pool collect and hold your personal information?

Where possible, Astral Pool will generally collect your personal information directly from you. Astral Pool may also collect your personal information from dealers and resellers of our products and services in various circumstances including where they place a product service call on your behalf. We may also collect personal information from our website(s), Facebook or other social media platforms that we operate or establish.

What personal information about you does Astral Pool collect and hold?

The types of personal information that Astral Pool collects from you will be directly related to the specific purpose for which it has been collected. How much personal information that you choose to disclose to us is completely up to you. The only way we know something about you personally is if you provide it to us. However, failure to provide certain information may result in Astral Pool being unable to provide you with the relevant product or service.

The information Astral Pool collects will include:

If you request products or services from us directly (eg via our online store) we may collect information from you such as your name, email address, phone number(s), address and credit card details.

If you make an enquiry, provide feedback or make a complaint to us, we may collect information from you such as your name, email address, phone number(s) and address.

If you make an application for employment with Astral Pool, we may collect any information that is relevant to such employment including:

your name and contact details (ie residential address, phone number(s) and/or email address)

any other information relevant to the recruitment process (including any information contained in the application form and your resume).

What does Astral Pool do with your personal information?

We will only use and disclose your personal information for the purposes which you provide it or a related secondary purpose which you would reasonably expect. This includes, for example:

providing the products and/or services you have requested from Astral Pool including for example:

delivering products or services to you;

managing warranty claims; or

responding to any enquiries, feedback or complaints made by you;

assessing and administering any applications for employment with Astral Pool; and

determining whether to give dealers or resellers of Astral Pool products commercial credit.

Who will Astral Pool disclose your personal information to?

Astral Pool may disclose your personal information to:

other companies or people that we have your consent to share the information with;

other members of Astral Pool’s related group companies;

all staff involved in processing or managing your account and other third parties who may be required to assist us with processing or managing your account; and

contractors and third party service providers, on a confidential basis, that we use in the ordinary course of our business to assist with the delivery of the product or service you have requested.

We may disclose your personal information to recipients outside of Australia. Specifically, Astral Pool may disclose your personal information to its parent company Fluidra SA in Barcelona, Spain. Astral Pool will take reasonable steps to ensure that your personal information is handled by any overseas recipients in accordance with the Privacy Act and our instructions for the purposes described above. By providing Astral Pool with your personal information, you consent to this disclosure of your personal information.

Openness

You may request access to personal information (including your credit information) we hold about you by contacting the Privacy Officer at the address below. Where we hold information that you are entitled to access, we will endeavour to provide you with a suitable range of choices as to how access is provided (eg, emailing or mailing it to you). A fee may be charged to cover the cost of retrieval.

If at any time you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request amendment of it and we will either amend the information or make a record of your comment, as we think appropriate.

Marketing

Where we have obtained your consent to do so, or in circumstances where you would reasonably expect that your personal information would be used or disclosed for this purpose, we may contact you from time to time with marketing material about our other products or services. You may opt out of receiving this material at any time by contacting us on 03 9554 2200 or 1300 727 116 or by email to privacyofficer@astralpool.com.au. Your consent to receiving this information will remain current until you advise us otherwise.

Questions and complaints

If you have any questions about this Privacy Policy or believe that we have at any time failed to keep one of our commitments to you to handle your personal information in the manner required by the Privacy Act, then we ask that you contact us immediately using the following contact details:

Privacy Officer

Astral Pool

111 Indian Drive

Keysborough

Victoria 3174

privacyofficer@astralpool.com.au

We will respond and advise whether we agree with your complaint or not. If we do not agree, we will provide reasons. If we do agree, we will advise what (if any) action we consider appropriate to take in response. If you are still not satisfied after having contacted us and given us a reasonable time to respond, then we suggest that you contact the Office of the Australian Information Commissioner by:

Phone: 1300 363 992 (local call cost, but calls from mobile and pay phones may incur higher charges). If calling from overseas (including Norfolk Island): +61 2 9284 9749

TTY: 1800 620 241 (this number is dedicated to the hearing impaired only, no voice calls)

TIS: Translating and Interpreting Service: 131 450 (If you don’t speak English or English is your second language and you need assistance and ask for the Office of the Australian Information Commissioner)

Post: GPO Box 2999 Canberra ACT 2601

Fax: +61 2 9284 9666

Email: enquiries@oaic.gov.au

Astral Pool website

When visiting Astral Pool’s website(s), the site server makes a record of the visit and logs the following information for statistical and administrative purposes:

the user’s server address – to consider the users who use the site regularly and tailor the site to their interests and requirements;

the date and time of the visit to the site – this is important for identifying the website’s busy times and ensuring maintenance on the site is conducted outside these periods;

pages accessed and documents downloaded – this indicates to Astral Pool which pages or documents are most important to users and also helps identify important information that may be difficult to find;

duration of the visit – this indicates to us how interesting and informative the Astral Pool site is to users;

the type of browser used – this is important for browser specific coding; and

in order to optimise the Astral Pool website(s) and better understand its usage, we collect the visiting domain name or IP address, Computer Operating System, Browser Type and Screen Resolution.

The information set out above is collected by automated means including via cookies. A cookie is a piece of information that an internet website sends to your browser when you access information at that site. You can change the privacy settings of your browser, in particular, you can refuse all cookies or opt to be notified each time a cookie is sent to your computer. By blocking or deleting cookies used on our website(s), you may not be able to take full advantage of services offered via our website(s).

Retention and destruction of personal information

Astral Pool will destroy or de-identify your personal information as soon as practicable once it is longer needed for the purpose for which it was collected. However, we may be required by law to retain your personal information after your relationship with us has expired. In this case your personal information will continue to be protected in accordance with this policy. If we destroy personal information we will do so by taking reasonable steps and using up-to-date techniques and processes.

Security of information

Astral Pool will take reasonable steps to protect your personally identifiable information as you transmit your information from your computer to our website(s) and to protect such information from loss, misuse, and unauthorised access, use, modification, disclosure, alteration, or destruction.

However, you should keep in mind that the transmission of information over the internet is not completely secure or error-free. In particular, email sent to or from this website may not be secure, and you should therefore take special care in deciding what information you send to us via email.

Miscellaneous

In this policy personal information has the same meaning as under the Privacy Act.

This policy is effective from 1st July, 2014. We may change this policy from time to time. Although we intend to observe this Privacy Policy at all times, it is not legally binding on Astral Pool in any way. From time to time we may regard it as necessary or desirable to act outside the policy. Astral Pool may do so, subject only to any other applicable contractual rights you have and any statutory rights you have under the Privacy Act or other applicable legislation.

Credit Reporting Policy

Credit applications by businesses for our services

Astral Pool provides commercial credit for the purposes of the Privacy Act to businesses who apply for credit in relation to our goods and services. We do not provide any consumer credit.

References to you and your in this credit reporting policy are references to individuals in relation to whom we hold credit information or credit eligibility information for the purposes of the Privacy Act in connection with such credit. This policy provides details about our management of such information.

How we collect and hold credit information and credit eligibility information about you

Credit information relates mainly to your credit-related dealings with us and comprises various types of information collected by credit reporting bodies (CRBs) that report on consumer credit worthiness. We may collect or generate various categories of credit information about you.

We may also collect credit eligibility information about you, which is mostly information provided by CRBs relating to your dealings with other credit providers (for example, financial institutions that provide you with loans or other businesses that provide you with credit in connection with their products or services).

Credit information and credit eligibility information may include:

identification information: such as your name, address, date of birth or employer;

consumer credit liability information: being information about consumer credit accounts you hold with other credit providers;

details about information requests made to CRBs: such as the fact that we or another credit provider have requested credit reporting information about you from a CRB to assess a credit application and various details about the credit you have applied for;

default information: being information about overdue payments owed by you in connection with consumer credit which have been disclosed to a CRB by other credit providers;

payment information: being information that an overdue payment has been repaid;

information about consumer credit-related serious credit infringements;

new arrangement information: being information about certain credit-related arrangements you may have entered with another credit provider in connection with a consumer credit default or serious credit infringement;

court proceedings information: being information about certain credit-related judgments;

personal insolvency information: being information recorded in the National Personal Insolvency Index about bankruptcy or various other insolvency-related matters; or

publicly available information about activities relating to credit worthiness.

Credit eligibility also includes credit worthiness information that we may derive from data we receive from a CRB, such as a credit risk score.

We may collect credit information about you in any of the circumstances described above under the heading ‘How we collect and hold credit information and credit eligibility information about you’ above. We collect credit eligibility information from CRBs but may collect it from other third parties where permitted by the Privacy Act (such as from other credit providers with your consent).

We store and safeguard your credit information and credit eligibility information in the manner described in the Privacy Policy above.

How we use and when we disclose your credit information and credit eligibility information

We may disclose your credit information to CRBs. Those CRBs may then include that information in credit reporting information that they provide to other credit providers to assist them to assess your credit worthiness. For example, we may disclose to a CRB the type of commercial credit, and the amount of credit, sought in your application for credit with us. We may also use and disclose your credit information for other purposes and in other circumstances as described in the Privacy Policy above when permitted to do so by the Privacy Act.

Our use and disclosure of credit eligibility information is regulated by provisions of Part IIIA of the Privacy Act and the Credit Reporting Privacy Code. We will only use or disclose such information for purposes permitted by these provisions, such as:

to process an application for credit with us in relation to our goods and services;

to manage the commercial credit we provide and collect overdue payments; or

where a disclosure is required or authorised under an Australian law or a court/tribunal order.

Correction of and access to credit information and credit eligibility information

To request correction of, or access to, your credit eligibility information please see the heading ‘Openness’ above.

Complaints regarding our compliance with credit reporting requirements

If at any time you would like to make a complaint about whether we have complied with Part IIIA of the Privacy Act or with the Credit Reporting Privacy Code please contact our Privacy Officer at privacyofficer@astralpool.com.au so that we may resolve your concerns.

If you make such a complaint, we will write to you as soon as possible acknowledging that we have received your complaint and setting out how we will deal with it. We will endeavour to investigate and resolve your complaint within a reasonable period of time. We may need to consult with a CRB or another credit provider to do so. If we need more than 30 days to resolve your complaint, we will advise you of the reasons for the delay and ask for your consent to extend this day period.