PRIVACY POLICY

In this document, “We”, “Us” and “Our” refers to

HIDRO-WATER SLU Cif B-96547435  Ctra. Chirivella – Aldaia, 48. CP46960 Aldaia (Valencia)

This notice sets out the basis on which we will process the personal data that we collect from you or that you provide to us. Please read the following carefully to understand our views and practices in relation to your personal data and how we will process it. It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal details (e.g. name or address) change during your relationship with us so that we can update our records.

This privacy notice explains:

• Who we are;
• Your rights;
• What personal information we collect;
• How we use your personal information;
• Who we share your information with and why;
• How we protect your information;
• How long we keep your information
• How to contact us.

 

Who we are

For the purposes of data protection laws, We are the Data Controller and a proud member of the Culligan International Group (“Culligan”). Culligan is the world leader in providing cleaner, smoother water through innovative, sustainable solutions and unrivalled service across all sectors.

With more than 15,000 team members and 1,000 distributors in 90 countries, Culligan’s more than 35 brands serve more than 170 million customers each year and share a mission to bring better quality water to consumers wherever they need it – at home, at work or on the go.

This Privacy Notice covers all entities of the Culligan Group. However, these companies may also host their own Privacy Notice which could augment this document. If you reside in the EU (or a country that has adopted a local law to implement or adopt the GDPR) (“EU Residents”), it will include the European General Data Protection Regulation (“GDPR”) or the applicable local law implementing or adopting the GDPR.

We have also entered into a business-to-business agreement containing the Standard Contractual Clauses approved by the European Commission to ensure that all transfers of Personal Data to any Culligan entity are protected to the same level as required by European data protection law.

 

Your Rights

You have the right to ask us:

• whether we are processing your personal data and for what purposes (right to be informed): this is done through “fair processing information”, such as this Privacy Notice;
• to obtain a copy of the personal information we hold about you (right of access);
• update or correct your personal data (right to rectification);
• delete your data (right to erasure); and
• restrict the processing of your personal data where applicable (right to restrict processing).

In certain circumstances, you also have the right to:

• object to the processing of your personal data (right to object);
• object to automated decision-making and profiling (right not to be subject to automated decision-making, including profiling); and
• request that information about you be provided to a third party in a commonly used machine-readable format (right to data portability).

 

Exercising Your Rights

For information about your individual rights, including how to correct, restrict, delete, or modify your personal information, or if you would like to request a copy of the personal information we hold about you, please contact us here.

 

Rates

You will not have to pay any fees to access your personal information (or to exercise any of the other rights). In some cases, we may charge a reasonable fee if your access request is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to accommodate the request in such circumstances.

 

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who is not entitled to receive it. If you are not satisfied with our response or for more information about your data protection rights, you can visit the website of your local Data Protection Authority.

• In the UK, check the Information Commissioner’s Office (ICO) website.
• In the EU, you can find your local DPA here.
• In Switzerland, contact the Federal Data Protection and Information Commissioner (FDPIC).

 

What Personal Information We Collect

“Personal data” means any information about a natural person from which he or she can be identified, directly or indirectly. We will collect the personal data relating to you that you provide to us when you apply for a job. This information includes personal data, such as your full name, email address and phone number, job title, department, preferences, and our communications with you.

 

Information you provide

We will collect the personal data you provide to us:

• fill out a contact form on our website;
• contact us about products and/or services;
• subscribe to any of our services;
• Sign up for a free trial;
• log in to our portal and/or any of our applications;
• respond to a survey;
• request to download guides or other resources from our website;
• attend product events;
• interact with us through our social networks;
• opted in (consented) to receive marketing communications from us; or
• apply for a job.

This information includes personal data, such as your full name, email address and phone number, job title, department, preferences, and our communications with you.

 

Information We Collect About You

The type of personal information we collect will depend on the purpose for which it is collected and may include:

• Information about you to help identify you and manage your relationship with Culligan (e.g., name, address, email address(es), zip code, telephone number(s), job title, gender);
• Information about your account with us (e.g., account number, ID or customer number, previous engagements with us, personal preferences, order history, etc.);
• Copies of documentation (e.g., statements, letters, invoices, correspondence);
• Economic and financial information (e.g., payment card numbers, bank details, payment history; we also collect a certain amount of data on behalf of financial institutions relating to the purchase of loan-financed devices (e.g., payslips, proof of address, etc.));
• Audio-visual information when we record interactions with you or when you visit one of our facilities (e.g., call recordings or CCTV);
• Marketing/communications data (e.g., information related to marketing and external communications, such as marketing campaigns, opt-in information, and preferences); where we have used consent as a legal basis for contacting you, consent may be withdrawn at any time;
• Lifestyle information (e.g. volume of water consumption, mineral/vitamin supplements, information needed to choose the right equipment for your home, such as the number of people living in the dwelling in question, your tap water consumption, your electricity consumption);
• Information about your visit to the website, Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform; including the entire Uniform Resource Locator (URL) clickstream towards,  through and from our website (including date and time); products you have viewed or searched for; page response times, download errors, length of visits to certain pages, information about page interaction (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page and any phone numbers used to call our customer service number;
• Information on employment and training (e.g. employer details, relevant professional qualifications, etc.).

 

We may also collect information about you from other sources such as:

• other companies of the Culligan Group;
• external third parties (e.g. credit reference agencies to verify your identity and check your financial solvency, event coordinators in case we attend a stand); and
• of cookies. (Cookies are small text files that are placed on your computer by the websites you visit. They are widely used to make websites work or work more efficiently, as well as to provide information to website owners.)

 

How We Use Your Personal Information

We will only use your personal data where we are permitted to do so by law and for the purposes set out in this Notice. These are:

• When you give consent
• Where it is necessary for the performance of a contract we have entered into or are entering into with you.
• When necessary to comply with a legal or regulatory obligation
• For our legitimate interests or those of a third party, provided that your interests and your fundamental rights and freedoms do not override those interests.

We may use your personal data in the provision and administration of the services you have requested and/or to respond to your inquiries. If you do not provide us with certain information, we may not be able to process your order.

We may also use your personal data to comply with our legal obligations, process complaints and enforce our terms and conditions.

We may use your personal data for our legitimate business interests, including security purposes, improvements to our website, improvements to our solutions and services, and general marketing purposes, as well as internal monitoring and reporting. However, we will not do so when our interests are outweighed by your interests, rights and freedoms.

 

We process your information for the following purposes

The following describes the ways in which we intend to use your personal data.

Perform our contract with you and support and maintain that relationship. This includes the following:

• to register you as a potential or new customer;
• process and deliver your order, including handling payments, fees and charges, and collect and recover any amounts owed to us;
• record specific needs or accommodations that you have or may require from time to time, such as text-to-speech, large print, or medical reasons that allow us to better help you understand our products and services;
• as part of our recruitment activities.

Comply with legal and regulatory requirements. These requirements include:

• confirm your identity for regulatory purposes;
• detect and prevent fraud;
• to comply with our data protection obligations.

For specific business purposes that allow us to provide you with appropriate products and services and a safe experience. Our business purposes include the following:

• manage our relationship with you, including notifying you of changes to our terms or Privacy Notice and/or asking you to leave a review or respond to a survey;
• send you newsletters, keep you up to date on new products or services or recommend other goods or services that may be of interest to you, inform you about special offers and invite you to our events;
• administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting);
• provide you with relevant website content and advertisements and measure or understand the effectiveness of such advertising;
• Use data analytics to improve and develop our website, products/services, marketing, customer relationships, and experiences.
• monitor or record communications (such as phone calls and video calls) with you to resolve any queries or issues and also for training and quality purposes and;

We may use AI technologies and Internet of Things (IoT) data, including machine learning, to perform some activities. In such a case, the result is subject to human supervision and review, and we will not include your personal data in any data analysis with a third-party model without informing you. Where we use publicly available models for general business purposes, we will give you the option to be anonymised or omitted from the data provided. We will always strive to use AI technologies in line with legislation, regulatory guidelines, and government policy.

 

Change of objective

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. We may also process your personal data as part of an acquisition or sale. If this occurs, you will be notified of any changes in the processing or in the controller that occur as a result of this activity.

You have the right to object to us processing your personal data for some of the business purposes listed above but, if you do so, this may affect our ability to provide some or all of our services to you. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where required or permitted by law.

 

How We Protect Your Information

We are committed to ensuring the confidentiality of the personal information we hold, and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.

When we engage third parties, we impose appropriate security, privacy, and confidentiality obligations on them to ensure that personal information is kept secure and unauthorized or accidental access, processing, copying, modification, deletion, loss, or use is prevented.

If we work with third parties in countries outside the UK or the European Union, we ensure that they are countries that have been confirmed by the UK Government and the European Commission to have an adequate level of protection for personal information, or that the organisation receiving the personal data has provided appropriate safeguards and agrees to treat your information with the same level of protection as we do.

We also use the UK International Data Transfer Agreements and EU Standard Contractual Clauses for transfers outside the UK or the European Economic Area.

In limited circumstances, data may be accessed by employees outside of our usual operating locations.  In these circumstances, we ensure that adequate information security measures are in place to safeguard your information.

 

Who We Share Your Information With and Why

We will not sell your personal data and generally will not pass it on to third parties, although there are some exceptions. We may share your personal data in the following ways (as appropriate):

• Culligan Group Companies
  • for administrative, analytical and statistical purposes;
  • to test the information systems operated by our companies;
  • to build a consolidated view of our relationship with you in order to improve the services we can offer you;
  • to send you marketing communications that you have opted (consented to) receive, or that we think may be of interest to you based on the services you receive from us or other companies in our group;
  • to provide service messages that are relevant to our relationship with you;
  • for the processing of complaints and the enforcement of data subjects’ rights (such as the right of access).
• Culligan’s appointed companies (these third parties may be based in countries outside the UK or EU)
  • with third parties or service providers who provide additional data about you in order to improve our ability to design and develop new products and services that can be marketed and sold and that meet the needs of our identified consumer groups and are targeted accordingly;
  • with debt collection agencies for their location and recovery;
  • with payment service providers to enable payments to be completed;
  • with our accountants to prepare tax returns and in support of regulatory reporting;
  • with our legal or regulatory advisors or appointed auditors;
  • with technology and information security providers;
  • with third parties or service providers to conduct market research on our behalf, to help us improve and develop the products and services we offer to you and our other customers;
  • with a prospective buyer (or their advisors), for due diligence purposes, if we are considering the sale of all or part of our business. For example, in the event of a merger, acquisition, divestiture, change of control, or liquidation of Culligan or part of its business (or in anticipation of such an event), we may share your personal data as part of that transaction where necessary to perform our obligations in this Notice.
• Organizations and Parties Designated by You or Authorized by You
• Authorities
  • For the purposes of crime prevention or detection, and/or the arrest or prosecution of offenders, we may share any personal data we collect with law enforcement, other public or private sector agencies, government or representative bodies, in accordance with relevant law, in order to comply with any legal obligation or as permitted by law. This will include public authorities, insurance companies, financial companies and/or other bodies.

 

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including to comply with any legal, accounting or reporting requirements. Where processing is based on your consent, we will only process your personal data until such time as you withdraw your consent.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm arising from the unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes by other means,  as well as the applicable legal requirements.

We will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this Notice.

 

How to Contact Us

If you have any questions about this notice, or need further information about our privacy practices, or wish to make a complaint about how we have treated your personal data, you can contact our Data Protection Officer who will investigate the matter.

September 16, 2025 (5:32 p.m.)