Updated March 2024
Waterair, having its registered office at Zone Artisanale, 68580 Seppois-Le-Bas (hereinafter referred to as “the Company” or “we” or “us”) is aware of the importance of protecting privacy and individual freedoms. Therefore, we undertake to protect these pursuant to applicable law and in particular EU Regulation No. 2016/679 of 27 April 2016 (hereinafter referred to as “the Regulation”) and the French Data Protection Act no. 78-17 of 6 January 1978, as amended.
In the course of our relationship, we need to collect information that identifies you. These data are personal data. The purpose of this privacy policy (hereinafter referred to as the “Policy”) is to inform you in particular of the principles governing the way in which we process your personal data in our capacity as data controller within the meaning of the Regulation.
Personal data processed and the purposes of the processing
Concerning internet users and job applicants
Concerning B2C customers or prospects
Concerning B2B partners and customers, subsidiaries, distributors and sub-contractors
Concerning service providers and suppliers
1.Personal data processed and the purposes of the processing
1.1.Concerning internet users and job applicants
When you browse on our websites, the Company needs to process the following data categories:
- Identification data: surname, first name, full postal address, telephone number, email address, signature;
- Data relating to your professional life: CV, covering letter, personality tests, salary range, professional references, copies of diplomas/certificates, pay slips, disabled worker status, driving licence;
- Data on the sites you connect to: sites visited, date and time of browsing, IP address, device and browser used, social network pseudonym, comments, data from cookies, website connection data, browsing statistics, statistics relating to the pool configurator;
- Others: Data from the contact form (reason for your request and description).
The personal data collected are used solely for the purposes set out below on the legal basis associated with them:
| Purposes of processing | Legal basis |
| To manage sites and information inquiries (“catalogue”, “contact”, “quotation”, “implementation study” forms or on social networks) | The legitimate interest of the Company to respond to requests and inquiries and to grow the business To perform pre-contractual measures |
| To manage hiring campaigns and job applications | The consent given by the data subject to create a CV library To perform pre-contractual measures, i.e. sign a possible employment contract |
| To send out newsletters | The legitimate interest of the Company to communicate on its business activities |
| To analyse site traffic | The legitimate interest of the Company to manage the traffic on its website |
| To manage website maintenance and security | The legitimate interest of the Company to ensure its websites are secure and run appropriately |
| To improve users’ browsing experience | The legitimate interest of the Company to resolve technical issues on its websites |
| To manage social networks, audience campaigns (including profiling), sponsored campaigns | The legitimate interest of the Company to manage its communications and predict Internet users’ preferences in order to promote its products Consent given by internet users |
| To manage our e-reputation | The legitimate interest of the Company to manage its image and communicate on the Internet |
| Manage requests from data subjects or legal authorities | Legal obligation |
| Manage sponsorship offers | The legitimate interest of the Company to promote its products |
| Manage competitions | Implement competition rules |
The data collected may be transferred to other companies in the Group (such as our subsidiaries or partners) and used for other purposes depending on the purpose of our exchanges, such as processing a request for a quotation, for example.
1.2.Concerning B2C customers or prospects
As a B2C customer or prospect, the Company may process the following categories of data, depending on the purposes for which they are collected:
- Identification data: title, surname, first name, full postal address, site address, telephone numbers, email address, age group, date and place of birth, identity document;
- Data relating to personal life: household members, number of dependent children, proof of address;
- Data relating to your professional life: social and professional category, job title, most recent pay slips;
- Economic and financial data: quotation, finance application including or excluding insurance, simulation of monthly repayments, interest rate, monthly repayment amounts, details on acceptance/refusal of the financing application, bank details, income, income bracket, latest balance sheet, tax statement, invoices, means of payment, customer credit slip, amount of the deposit;
- Others: prospect number, date and time of phone or face-to-face meetings, information on the pool project, order form, customer number, date and time of delivery of the pool, date the store account is created, store customer number, information on the products ordered, order date, order status, number of products and total number per order, delivery method chosen (carrier or collection from a relay point), total amount spent in the store, discussions concerning orders and intervention requests, information relating to the accessories owned, data from the analyser in relation to the pool, photos; data from pool configurators, results of implementation studies, data from the contact form (reason for the request and description), customer reviews (ratings, comments), amount of trade discounts, gifts.
The personal data collected are used solely for the purposes set out below on the legal basis associated with them:
| Purposes of processing | Legal basis |
| To manage sales prospecting campaigns (including sponsorship, competitions, catalogues, implementation requests, invitations to open days, telephone appointments, contact forms), including on social networks | Consent of the individual / The legitimate interest of the Company to promote its business and manage its communications To implement competition rules The legitimate interest of the Company to predict Internet users’ preferences in order to promote its products including through targeted advertising |
| To manage prospects | Consent given by the person |
| To produce performance statistics (including marketing and sales) | The legitimate interest of the Company to grow its business |
| To manage commercial communications sent to customers | The legitimate interest of the Company to promote its products |
| To manage reception and incoming calls | The Company’s legitimate interest in managing incoming calls and securing its premises |
| To manage mail | The legitimate interest of the Company to manage its mail and promote its products |
| To manage quotes | To perform pre-contractual measures |
| To manage orders | To perform a contract |
| To manage billing | To perform a contract |
| To manage the after-sales service and sales guarantees To manage the customer space and store access | To perform a contract |
| To manage customer reviews | Consent given by the person |
| To manage complaints, disputes and litigation | The legitimate interest of the Company to defend its interests before the courts |
| To manage elements accompanying financing applications To follow up financing applications and compile statistics | The legitimate interest of financial institutions to establish the client’s financing application to be forwarded |
| To manage satisfaction surveys | Consent given by the person |
| To manage requests to change the name of the pool owner | The legitimate interest of the Company to ensure continuity of service and monitor the guarantee |
1.3.Concerning B2B partners and customers, subsidiaries, distributors and sub-contractors
As partners, B2B customers and subsidiaries in the Company’s group, we may need to process the following categories of data, depending on the purposes for which they are used:
- Identification data: title, surname, first name, postal address, telephone number, email address, country;
- Data relating to your professional life: company name, CV, covering letter, salary range, driving licence;
- Others: partnership request application file.
| Purposes of processing | Legal basis |
| To manage B2B orders (equipment sales, billing, accounting, after-sales service) | The Company’s legitimate interest in managing its orders |
| To manage and select partners, distributors and subsidiaries of the Company and partners (including foreign partners) | The legitimate interest of the Company to develop and manage its activities, including activities abroad |
| To manage business relationships for international B2C customers | To perform a contract |
1.4.Concerning service providers and suppliers
As a contact for service providers and suppliers, the Company may need to process the following categories of data, depending on the purposes for which they are used:
- Identification data: surname, first name, telephone number, email address, signature, nationality;
- Data relating to personal life: garment size, shoe size;
- Data relating to your professional life: company name, position, hire date, type of work permit, permit number, professional civil liability certificate.
| Purposes of processing | Legal basis |
| To manage service providers (hire, train, monitor sub-contractors) | The legitimate interest of the Company to work with service providers |
| To manage procurement (including quality issues) | The legitimate interest of the Company to source goods and services |
| To manage service provider interventions for B2C customers | The legitimate interest of the Company to ensure products are delivered and complaints processed |
| To manage suppliers (select and monitor suppliers, manage supplier documentation and accounting) | The legitimate interest of the Company to manage and monitor its suppliers |
2.Storage periods
The personal data we collect are processed for no longer than is necessary for the purposes for which they are to be used, taking into account the applicable limitation periods and the principle of proportionality, in particular:
| Data subject | Storage period |
| Customers | Duration strictly necessary to manage the business relationship and until our guarantees expire |
| Prospects / Customers (as part of commercial prospecting) | 3 years from the date of collection or the date of your last contact or until you object or withdraw your consent |
| Job applicants | Until you withdraw your consent and for 2 years at most |
| Internet users / visitors | 13 months at most, except in cases where specific legal or regulatory provisions require a different storage period Up to 25 months for data generated by cookies |
| Suppliers, partners, sub-contractors | 5 years from the end of the business relationship |
For more information about the storage periods we apply, please contact us at the address below.
3.Data recipients
Your personal data will only be communicated to authorised recipients for the sole purposes being pursued, i.e.:
- To Waterair’s internal departments;
- To our subsidiaries, distributors, partners and sub-contractors;
- To our IT, marketing and communication service providers;
- To the vendors of our software and other IT solutions;
- To any hiring agencies or service providers we may call on;
- To our consultancy firms;
- To our banking and insurance organisations;
- To our project funding partners;
- To regulated professions (such as legal consultants, lawyers, bailiffs, chartered accountants, auditors);
- To social networks and advertising management platforms (Facebook, Instagram, Google, Pinterest, LinkedIn, hiring website platforms);
- To our Data Protection Officer;
- To administrative or judicial authorities at their request.
We only send them the personal data they need to carry out their services and we require them not to use these data for any other purpose.
Your data may be transferred to a country outside the European Union. In such cases, we systematically take all measures to ensure that data recipients comply with an adequate level of protection equivalent to national and European regulations, in particular by signing standard contractual clauses issued by the European Commission.
4.Security measures
We are committed to preserving the confidentiality, integrity, availability and security of your personal data. In accordance with Article 32 of the Regulation, we endeavour to implement appropriate technical, logical and organisational measures to ensure a level of security appropriate to the risks incurred in processing your personal data. We also take steps to prevent, as far as possible, any loss, accidental destruction, alteration or unauthorised access to your personal data.
5.Exercising your rights
In accordance with applicable law, you have the right to:
- Access and rectify your personal data (right of access and rectification);
- Object to the processing of your personal data on legitimate grounds (right to object);
- Within the limits laid down by law, the right to request that the processing of your personal data be restricted or that the data be deleted (right to restrict processing and right to delete personal data);
- Request the portability of your personal data (right to portability);
- Withdraw your consent.
To exercise your rights, please contact us by email at: rgpd@waterair.com or by post at the following address:
Société EDOS SAS
A l’attention de Piscines Waterair
5 rue de Lisbonne
Le Belem
67300 Schiltigheim
France
You also have the right to lodge a complaint with a supervisory authority regarding the manner in which we process your personal data.
6.Data Protection Officer
We have appointed EDOS, having its registered office at 9 rue Schimper in Strasbourg, as our Data Protection Officer (DPO).
You can contact our DPO at the following address if you have any questions about this policy or if you have any queries about how your data are processed: rgpd@waterair.com.
7.Document updates
The Company may amend this Policy as needed. We will ensure that you are informed of these changes by means of a special notice on our site.