SWIMMING NATURE PRIVACY POLICY

We respect your privacy and are committed to protecting the security of the personal information you provide to us and the information we collect from you in accordance with the provisions of the General Data Protection Regulation (GDPR).

This privacy policy will give you information on how we collect and process your personal information through your use of this website, including any information you may provide through this website when you book swimming lessons, sign up to our marketing publications or create an account.

It is important that you read this privacy policy so that you are fully aware of how and why we are using your information, your privacy rights and how the law protects you.


Who We Are

We are Swimming Nature UK Limited of 1 College Yard, Winchester Avenue, London, NW6 7UA.

We are registered on the Information Commissioner’s Office Register of Data Controllers under registration number ZA306692, and act as a data controller. This means that we are responsible for deciding how we hold and use personal information about you.

We have appointed a designated Data Protection Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions in relation to this privacy policy, including any requests to exercise your legal rights, please contact our Data Protection Officer using the details set out below.

Contact Details

Email address: privacy@swimmingnature.com

Postal address: Data Protection Officer, Swimming Nature, Studio Three, 5/11 Westbourne Grove, London, W2 4UA


Information We Collect

Personal information means any information about an individual from which that person can be identified.

We do not collect any of the following Special Categories of Personal Data:

  1. details about your race or ethnicity;
  2. religious or philosophical beliefs,
  3. sexual orientation;
  4. political opinions;
  5. genetic and biometric data;

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

Account Information

In order to create an account with us, we collect information such as your name, email address, mobile number, postal address, date of birth, gender, relevant medical conditions. The minimum information required to create an account is your name, email address or mobile number for operational communication, your date of birth to ensure we are selecting the correct programme and finally, any relevant medical conditions. Additionally, you may choose to provide details on your membership with partner clubs.

Payment and Card Information

In order to pay for services with Swimming Nature, your credit card details such as card number, card expiration date, CVV code and billing address are collected. This information is sent securely to our payment processing authority who responds with a token to identify your card. This token is stored by Swimming Nature along with your billing address, expiry date and the last 4 digits of your card number. The token is used for any future transactions without requiring the credit card number or CVV code. Your token is stored against all previous payment transactions for auditing.

Location Information

Your IP address is stored for emails sent to you by us which have been opened. This information is used for statistical purposes to show the rate at which emails are opened, as well as to settle disputes.

Usage Information

Whenever you log into one of our platforms, we store the login date, time and IP address for security measures. Additionally, we store the pages which have been visited during the session. We also store cookies for statistical information of your visit to our website.

Lesson Information

When undertaking programmes with Swimming Nature, our instructors collect information relating to your progress through modules in different levels. Additionally, we store any challenge times conducted and awards given.

In addition to assessment information, your attendance is also collected.


How Your Information Is Collected

We use different methods to collect information from and about you including through:

Direct Interactions

You may give us your personal information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

  1. book swimming lessons;
  2. create an account with us;
  3. request our marketing publications to be sent to you;
  4. give us some feedback or contact us.

Automated Technologies or Interactions

As you interact with our website, we will automatically collect information about your equipment, browsing actions and patterns. We collect this personal information by using cookies.

Third Parties

We work with partners who provide us with analytics and advertising services. These companies may use cookies and similar technologies to collect information about your interactions with our services and other websites and applications.

Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.


How We Use Your Information

We take your privacy very seriously and unless required to do so by law, we will never disclose, share or sell your personal information without your consent.

Where you have consented to us processing your personal information and to us providing you with marketing communications, you are free to withdraw consent at any time, through your account at https://book.swimmingnature.com.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the provisions of the GDPR, where this is required or permitted by law.

We will process personal information that we collect, store and use for the following purposes:

Communicate With You

Your contact information is used to communicate with you about your lessons including changes to times, renewals or other day to day operational tasks. We additionally use your contact information to send marketing information to you, which can be controlled through your account settings at https://book.swimmingnature.com.

Improve Our Programmes

We use assessment information to try and improve the experience for our customers. This may be in a way where we use company progression against a company average to ensure high lesson standards are kept, or statistics such as progression rates through programmes.

Cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse information about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the information is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie does not give us access to your computer or any information about you, other than the information you choose to share with us.

You can choose to accept or decline cookies. If you choose to decline cookies, this may prevent you from taking full advantage of the website.


If you fail to provide personal information

You are not obligated to provide your personal information to us, however, as this information is required for us to provide you with our services, communicate with you, or to comply with our legal obligations, we will not be able to do so without it.


Your Rights

By law you have the right to:

Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the accuracy of the information; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party of your choice, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Lodge a complaint at any time with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance if unsatisfied with how we have handled your information.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact [*] in writing.


How Information is Shared

We will not share or disclose your personal information without your consent, other than for the purposes specified in this Privacy Policy or where the law requires us to do so.

We sometimes need to share your personal information, for the purposes specified in this Privacy Policy, as follows:

Partners

Partners of Swimming Nature such as providers of swimming pools where they can authenticate your lessons. Details for students which are sent to these providers for that particular day are name, age and any membership details.

External Processing

Your information may also be sent to providers for external processing, such as email and text message sending tools. This information is sent securely and removed once processed.

For example, your personal information may be provided to Sporting Technology Limited, through our use of their software FLOW for the following purposes:

  1. to analyse our teaching methodology;
  2. to provide a record of performance levels of those that use our services;
  3. to manage bookings, assessments, instructors and operators; and
  4. to manage our finances.

Where this is necessary, all processors acting on our behalf only process your personal information in accordance with instructions from us and comply fully with this privacy policy, the data protection laws and any other appropriate confidentiality and security measures.

As a result of us disclosing your personal information to any of the parties mentioned above, your personal information may be held by us and additionally by the parties mentioned above.


Access of Data

Exporting Data

By accessing your profile through https://book.swimmingnature.com you will have access to most of the account information for your account. To request a copy of your data, please contact the Data Protection Officer via email or post.

Deleting Data

By contacting the Data Protection Officer via email or post you have the facility to delete your account completely. Note that account deletion can only occur when there are no further future services with Swimming Nature.

Please note that identifying information will be deleted within 24 hours, while assessment information and the date of birth for any students will be retained for statistical purposes. Please also note that once deleted, it may take up to a further 90 days for personal information to be deleted from data backups which are held securely.


Data Retention

We will only retain your personal information for as long as you have active bookings with us in order for us to operate your account and to fulfil the purposes we collected it for, including for the purposes of correctly track student assessment history and satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, the applicable legal requirements, and the relevant limitation periods that apply to taking any legal action.

You can ask us to stop sending you marketing messages at any time. Where you opt out of receiving these marketing messages, this will not apply to personal information collected and processed through your use of this website.


Children

In line with the importance on ensuring information security for the accounts of children, we require a parent or guardian to authorise the use of their information for us to deliver our services. Children under the age of 13 will be unable to create an account themselves and must have a parent or guardian’s authorisation on their account.


Information Security

We work hard to keep your information safe and have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes using Transport Layer Security (“TLS”) to encrypt many of our Services and ensuring that account information is password protected, and sensitive account information if further protected with 128 bit SSL encryption. In addition, we limit access to your personal information to those employees and other third parties who have a business need to know. They will only process your personal information on our instructions and are subject to a duty of confidentiality.


Changes to This Policy

We reserve the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.


Contact Us

If you have questions, suggestions, or concerns about our use of your information or this policy, or, to keep us informed if your personal information changes, please contact us at privacy@swimmingnature.com.

Swimming Nature UK Limited
Studio Three, 5/11 Westbourne Grove
London
W2 4UA
United Kingdom
03445040506