Privacy policy | Got2Swim

Privacy and General Data Protection Policy

Got 2 Swim understands that your personal data is entrusted to us and appreciates the importance of protecting and respecting your privacy. To this end we comply fully with the data protection law in force in the UK, General Data Protection Regulation (GDPR) 2018.

This privacy policy sets out how Got 2 Swim uses and protects any information that you give Got 2 Swim when you use this website.

Got 2 Swim is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

Changes to our Privacy Policy

Got 2 Swim keeps this Privacy Policy under regular review and as a result it may be amended from time to time without notice. As a result we encourage you to review this Privacy Policy regularly.

When we refer to ‘we’, ‘us’ and ‘our’, we mean Got 2 Swim and when we refer to ‘you’ we also refer to the personal data you have provided us regarding your child.

What we collect

Personal data we collect from you may include the following:

information that you give us when you enquire or you engage in swimming lessons for your child or child in your care including name, address, contact details (including email address and phone number)
details of services your child has received from us or which have been received from a third party through our company.
information about complaints and incidents
information you give us when you make a payment to us, such as financial or credit card information

Where you have named someone as your child’s next of kin or carer and provided us with personal data about that individual, it is your responsibility to ensure that that individual is aware of and accepts the terms of this Privacy Policy.

How do we lawfully process your personal data?

Your personal data will be kept confidential and secure and will only be used for the purpose(s) for which it was collected and in accordance with this Privacy Policy, applicable Data Protection Laws.

Set out below are some of the ways in which we process personal data although to do so lawfully we need to have a legal ground for doing so. We normally process personal data if it is:

necessary to provide you with our services – to enable us to carry out our obligations to you arising from any contract entered into between us and you including relating to the provision by us of services to your child and related matter such as billing, accounting and audit and anti-fraud screening
in our or a third party’s legitimate interests to do so – see details below
required or allowed by any applicable law
Internal record keeping.
We may use the information to improve our products and services.
We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.

Generally, we will only ask for your consent to processing if there is no other legal grounds to process. In these circumstances, we will always aim to be clear and transparent about why we need your consent and what we are asking it for. Where we are relying on consent to process personal data you have the right to withdraw your consent at any time by contacting us using the details below and we will stop the processing for which consent was obtained.

To process special category data we rely on additional legal grounds and generally, they are as follows:

With your explicit consent as legal guardian to the swimmer
It is necessary to establish, make or defend legal claims or court action
It is necessary so that we can comply with employment law
It is necessary for a public interest purpose in line with any laws that are applicable. This should assist in protecting the public against dishonesty, malpractice or other seriously improper behaviour for example, investigating complaints, regulatory breaches or investigations
genetic data, biometric data for the purpose of uniquely identifying a natural person, or

About your child – If you are a parent signing up for swimming lessons on behalf of your child, we will need you to complete your details but we will also need some information about your child. We won’t need a separate email address or contact number but we will need to know a bit of health information about the swimmer so we can make sure we are aware of any medical conditions or any extra support they may need. In accordance with the T&Cs if you disclose medical information that gives us cause for concern we may need a letter from your GP or doctor confirming that your child is fit enough to have swimming lessons.

Please note if we require a note from your GP or your child’s GP confirming that the swimmer is fit to swim and suitable for swimming lessons, you will be asked to contact your GP directly and provide us with a copy of their recommendations. We will not contact your GP directly.

Security of your personal data

We protect all personal data we hold about you or your child by ensuring that we have appropriate organisational and technical security measures in place to prevent unauthorised access or unlawful processing of personal data and to prevent personal data being lost, destroyed or damaged.

Any personal data you or your child provide will be held for as long as is necessary having regard to the purpose for which it was collected and in accordance with all applicable UK laws.

The transmission of information via the internet cannot be guaranteed as completely secure.

At your request, we may occasionally transfer personal information to you via email, or you may choose to transfer information to us via email. Email is not a secure method of information transmission; if you choose to send or receive such information via email, you do so understanding the risks associated with doing so.

How long do we retain your personal data?

Unless we explain otherwise to you, we will retain personal data you have provided about yourself and your child on the basis of the following guidelines:

for as long as we have a reasonable business need, such as managing our relationship with you and managing our business
Children: When children turn 18 they have 3 years to bring a legal claim. As such, we keep our swim school records for any child under the age of 18, until their 18^thbirthday and then for a further 3 years.
in line with legal and regulatory requirements or guidance.

Disclosure of your personal data to third parties

In the usual course of our business we may disclose personal data provided by you (which will be limited to the extent reasonably necessary) to certain third party organisations that we use to support the delivery of our services. This may include the following:

business partners, and sub-contractors for the performance of any contract we enter into with you,
organisations providing IT systems support and hosting in relation to the IT systems on which your information is stored,
third party service providers for the purposes of storage of information and confidential destruction, third party marketing companies for the purpose of sending marketing emails, subject to obtaining appropriate consent.

Where a third party data processor is used, we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under the General Data Protection Laws.

Special Category/Health information collected during provision of services

Special category data (including information relating to your child’s health) will only be disclosed to third parties in accordance with this Privacy Policy.

CCTV

Many of our premises are surveyed by CCTV for the purposes of security. Images and videos may be retained for 30 days in accordance with ICO guidelines.

How we use 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 or lets you know when you visit a particular site. 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 data about webpage 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 data 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 in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by emailing us at privacy@got2swim.co.uk

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.

Your Rights under Data Protection Laws

The law gives you certain rights in respect of the personal data that we hold about you as well as information about what we do with it, who we share it with and how long we will hold it for. The website of the Information Commissioner’s Office (http://www.ico.org.uk) has a wealth of useful information in respect of your rights in your personal data. In addition to your right to stop marketing, detailed above, below is a short overview of the most commonly-used rights.

Data Subject Access Request – With some exceptions designed to protect the rights of others you have the right to a copy of the personal data that we hold about you or your child as well as information about what we do with it, who we share it with and how long we will hold it for.
The Right of Erasure (‘Right to be Forgotten’) – the right to have your and your child’s personal information erased where we have no reason to continue processing;
Data Portability – the right to move, copy or transfer personal information you have provided to us;
Right to Rectification – You have the right to have the personal data we hold about you or your child corrected if it is factually inaccurate. If any of your or your child’s personal data has changed, especially medical information, contact information such as: email address, postal address and phone number please get in touch so we can ensure your personal data is kept up to date

If you want to exercise your rights in respect of your personal data, the best way to do so is to contact us by email on bruce@got2swim.co.uk for the attention of the data protection officer at the address below. In order to protect your privacy, we may ask you to prove your identity before we take any steps in response to such a request.
If you are not satisfied with how we handle your request, you can contact the Information Commissioner’s Office on 0303 123 1113 or visit their website (http://www.ico.org.uk).

Changes to our Privacy Policy

We keep our Privacy Policy under regular review and as a result it may be amended from time to time without notice. As a result we encourage you to review this Privacy Policy regularly.