Fluidra is a global manufacturer of residential pool equipment and connected pool solutions. The Fluidra family of brands includes Jandy, Polaris, Zodiac, iAquaLink, Cover-Pools, Nature2, Caretaker, Baracuda, SAVI, and Grand Effects. This Privacy Policy describes the practices of Zodiac Pool Systems LLC, a Fluidra company, in North America and its affiliated entities (collectively, “Fluidra,” “we,” “us,” or “our”) in connection with information that we collect through https://www.fluidrausa.com and the other websites operated by us from which you are accessing this Privacy Policy (the “Websites”), through the software application made available by us for use on or through computers and mobile devices (the “App”), through our social media pages that we control from which you are accessing this Privacy Policy (“Social Media Pages”), through HTML-formatted email messages that we send to you that link to this Privacy Policy, through our pool automation systems and other connected products and services (the “Connected Products”), and through our offline communications with you in connection with your interest in or use of our products and services (collectively, including the Websites, the App, our Social Media Pages, email messages, Connected Products and offline communications, the “Services”).

If you are a California resident, please see our California Privacy Notice, for additional details on how we handle your personal information and how to exercise your rights under the California Consumer Privacy Act.

Personal Information

"Personal Information" is information that identifies you as an individual or relates to an identifiable individual, including:

Name;

Postal address (including billing and shipping addresses);

Telephone number;

Internal account ID, username, and password;

Email address; and

Credit and debit card numbers.

We may need to collect and process these types of Personal Information in order to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide you with the requested Services.

Collection of Personal Information

We and our service providers may collect Personal Information in a variety of ways, including:

Through the Services: We may collect Personal Information through the Services. For example, we may collect Personal Information when you request information or sign up for a newsletter through our Websites, when you use our Social Media Pages, or when you register or create an account in connection with our App or Connected Products, or when you contact us for customer or technical support.

Offline: We may collect Personal Information from you offline, such as when you visit us at trade shows or contact customer service.

From Other Sources: We may receive your Personal Information from other sources, such as public databases, joint marketing collaborators, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties.

We may use a third-party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information may be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy.

If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers may use Personal Information for our legitimate business interests, including the following:

To respond to your inquiries and fulfill your requests, complete your transactions and provide you with related customer service.

To provide to you technical support and training information relating to our Services.

To send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communications that we believe may be of interest.

To personalize your experience on the Services by presenting products and offers tailored to you, and to facilitate social sharing functionality.

To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules containing information about how we use and disclose your Personal Information.

For our business purposes, such as data analysis, user research, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, validating and managing the warranty process, and operating and expanding our business activities.

Disclosure of Personal Information

Your Personal Information may be disclosed:

To our affiliates for the purposes described in this Privacy Policy.

To our third-party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.

To third parties, to permit them to send you marketing communications, consistent with your choices.

To third-party sponsors of sweepstakes, contests and similar promotions.

By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

Other Uses and Disclosures

We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

In addition, we may use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Other Information

"Other Information" is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:

Browser and device information;

App usage data;

Information collected through cookies, pixel tags and other technologies;

Demographic information and other information provided by you that does not reveal your specific identity; and

Information that has been aggregated in a manner that it no longer reveals your specific identity.

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including:

Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.

Through your use of the App: When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.

Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.

Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.

Analytics: We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Using Adobe Flash technology (including Flash Local Shared Objects ("Flash LSOs")) and other similar technologies: We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as"information", how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.

IP Address: Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.

Through Connected Products: We may collect information pertaining to the configuration and use of a Connected Product, such as how a Connected Product is configured for a particular location and or use (e.g., pump schedules and temperature set-points), as well as operational data such as information describing the operational state and performance of a Connected Product at a particular moment in time, such as pump speed or power consumption of a Connected Product.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, LinkedIn, Twitter, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the App or our Social Media Pages.

Third Party Advertising

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services, based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contacting Us" section below.

Choices and Access

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by clicking the opt-out mechanism provided in each of these emails.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

How you can access, change or suppress your Personal Information

If you would like to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us in accordance with the "Contacting Us" section below.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). There may also be residual information that will remain within our databases and other records, which will not be removed.

Retention Period

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);

Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or

Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Use of Services by Minors

The Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13.

Jurisdiction and Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

If you are located in the EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures , such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contacting Us” section below.

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

Updates to This Privacy Policy

We may change this Privacy Policy. The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Contacting Us

Zodiac Pool Systems LLC is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at contact.privacy@fluidra.com or:

Zodiac Pool Systems LLC

Attn: IT Department

2882 Whiptail Loop # 100

Carlsbad, California 92010

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA

If you are located in the EEA, you also may:

contact us at the following address with any questions about this Privacy Policy:

Fluidra

Avda. Francesc Macià, 60, planta 20, 08208, Sabadell (Barcelona) Spain

contact us as the following e-mail address: dataprivacy@fluidra.com

lodge a complaint with a supervisory authority competent for your country or region.