GLOBAL RECRUITING PRIVACY POLICY

 

Thank you for your interest in Fluidra. In connection with the processing of your job application and curriculum vitae (CV), we would like to inform you of the following:

1. DATA CONTROLLERS (Joint Controllership)

Your personal data related to your application will be processed jointly by Fluidra S.A. (HQ) and the Fluidra entity/entities indicated in the job posting for the country where you apply (together, the “Joint Controllers”). The joint controllership allocates responsibilities for transparency duties, rights handling, and security. A summary of roles and a list of entities is available here

Fluidra S.A.'s address is Av. Alcalde Barnils, 63, 08174 Sant Cugat del Vallès (Barcelona), Spain, and its tax identification number is A17728593.

If you are applying to a position in the United States, your personal data will be collected and processed by Fluidra North America LLC or the relevant Fluidra North America entity listed in the job posting. Fluidra North America’s address is 2077 Convention Center Concourse, Atlanta GA 30337.

 

2. PURPOSES

Your data will be processed primarily to manage your application for the relevant vacancy and to contact you for any related matters, through appropriate channels, including email, telephone, SMS, or other electronic communications.

We may also use your data for the following purposes:

- Verifying your academic or employment background in line with current regulations;

- Inviting you to interviews, assessments, or language/ skills tests;

- Contacting references you have provided;

- Reviewing your video application, if applicable;

- Conducting other assessments relevant to the role.

Where required, we will ask for your prior consent before carrying out specific processing activities. If you opt in, we may send you job alerts or keep you in our talent pool. You can unsubscribe at any time.  

In most jurisdictions, the legal basis for processing is the pre-contractual relationship between you and the Company. In the United States, processing is based on applicable U.S. employment and privacy laws, and may also rely on our legitimate business interests in managing recruitment operations. Similar legal grounds may apply in other countries where Fluidra operates, such as in Europe, Australia, and Brazil. For applications to a Brazilian company, your personal data will be processed in accordance with the legal bases set out in Article 7 of the LGPD, in particular for pre-contractual procedures related to a potential employment relationship.

If you do not provide us with the requested data, we may not be able to consider or process your job application.

If you are not selected, we may ask you for consent to retain your data for future recruitment opportunities.

We do not take recruitment decisions based solely on automated processing that produce legal or similarly significant effects on you.

3. DATA SHARING

Your data will not be transferred, sold, rented or made available in any way to third parties, except to service providers acting on behalf of the Company who process the data only under our documented instructions, are bound by confidentiality and appropriate security obligations, and never for their own purposes.

Your data may also be shared with other entities within the Fluidra Group, including those acting as joint controllers, but only for the same purposes described above, and always subject to any additional privacy provided by each company.

4. INTERNATIONAL TRANSFERS

Due to Fluidra’s international presence, international transfers may take place depending on the location of the company to which you are applying to. In general, the Company may rely on third-party service providers that process data outside the country or region where the application is submitted, and may also share data with other Fluidra entities acting as joint controllers.

For applications to a European company, your data may be processed outside the European Union or the European Economic Area. In such cases, Fluidra will ensure appropriate safeguards are in place, such as the use of EU Standard Contractual Clauses or relying on certified third parties.

For applications to a U.S. company, Fluidra North America, and its US subsidiaries, adheres to applicable U.S. state and federal privacy laws. Personal data may be shared with authorized Fluidra affiliates or service providers strictly for recruitment purposes and subject to contractual confidentiality and security obligations.

For applications to an Australian company, personal data may be shared with recipients in overseas countries, including those where Fluidra group companies are located (such as Spain, the United States, and Brazil), and where SAP subprocessors operate, subject to appropriate safeguards under applicable law. For further information about countries where SAP subprocessors are located, please see the following link: SAP

For applications to a Brazilian company, any international transfers of your personal data will take place in accordance with Article 33 of the LGPD and applicable regulations issued by the Brazilian Data Protection Authority (ANPD), using appropriate transfer mechanisms such as standard contractual clauses approved by the ANPD, specific contractual safeguards, binding corporate rules or other lawful mechanisms recognised under Brazilian law.

For applications to companies in other countries, Fluidra will apply equivalent safeguards, in line with the applicable local regulations, to ensure your personal data is protected when processed internationally.

5. RETENTION PERIOD

We will retain your personal data for as long as necessary to manage the recruitment process. If you are hired, your information will become part of your employee file and will be subject to the applicable employee privacy notice, as well as the retention requirements set forth by local law and the records retention policy of the employing Fluidra entity.

If you are not selected, we may retain your data for future hiring needs, depending on your jurisdiction:

  • United States: In accordance with U.S. law and Fluidra North America’s Records Retention Policy, we retain applicant data for up to four (4) years from the date of submission or the decision not to hire.
  • European Union and other regions: Candidate data will be stored for a maximum of two (2) years from your last interaction with the recruitment system, unless local laws require a shorter or longer period.
  • Australia: We will retain your data for up to two (2) years from your last interaction, unless it is required to be retained longer under Australian law.
  • Brazil: Applicant data may be retained for up to two (2) years from your last interaction with the recruitment system, unless a longer period is required under applicable labour, administrative, or regulatory obligations. or until the purpose of processing has been fulfilled, subject to applicable legal retention obligations.

You may request deletion of your data at any time (subject to legal requirements), or your data may be automatically deleted after the applicable retention period.

In cases where we wish to retain your data for a longer period than indicated above, we will request your prior consent where required.

6. EXERCISE OF YOUR RIGHTS

If you are applying to a company located in the European Economic Area (EEA) you may object to the processing of your data at any time, although this may affect your participation in the recruitment process if this processing is necessary. If that is the case, we will inform you accordingly.

You may also exercise your rights of access, rectification, erasure, objection, restriction, or data portability by contacting us at dataprivacy@fluidra.com. For any questions about the processing of your personal data, or any other privacy related matters, you can contact our Data Protection Officer at dataprivacy@fluidra.com. If you do not receive a response within a reasonable time, you may file a complaint with the Spanish Data Protection Authority.

i) If you are applying to a company located in the United States:

  • You may have rights under applicable state privacy laws, including:
  • The right to know what personal data we collect and how we use it;
  • The right to access, correct, or delete your data (subject to exceptions);
  • The right to limit use of sensitive personal data (where applicable); and
  • The right not to be discriminated against for exercising your rights.

To exercise any of these rights, or for questions about your personal data, please contact contact.privacy@fluidra.com or visit https://www.fluidrausa.com/en/legal.

ii) If you are applying to a company located in Australia:

You may have rights under applicable privacy laws including:

  • the right to access and seek correction of your personal information; and
  • the right to file a complaint with us about a breach of your rights under applicable privacy laws.

If you have any questions about the processing of your personal information, would like to make a  complaint about how we handle your personal data, or would like to access or correct the personal data we hold about you, please contact us at apacprivacy@fluidra.com. If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you have the option to reach out to the Office of the Australian Information Commissioner. Further information is contained in our Privacy Policy available at https://www.fluidra.com.au/privacy-policy/

iii) if you are applying to a company located in Brazil:

You may have rights under applicable privacy laws, including, among others, the right to confirm whether we process your personal data, to access or correct your data, to request anonymization, blocking or deletion, to revoke your consent when applicable, and to obtain information about the entities with which your data is shared.

To exercise these rights or if you have any questions, please contact us at dataprivacy@fluidra.com. If you do not receive a response within a reasonable time, you may contact the Brazilian Data Protection Authority (ANPD).

For further information about how Fluidra processes your personal data, you may also consult our general Privacy Policy available at https://www.fluidra.com/privacy-policy/. A Portuguese version of this notice is available upon request for Brazilian candidates. For candidates whose local language is not English, a version in the appropriate local language can also be made available upon request.