Privacy Policy

Cindy’s Swim School (“We”) are committed to protecting and respecting your privacy.

This policy (together with our Terms & Conditions and Cookie Policy and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please see below what data we use about you and why. Although in the scale of things we are a relatively small business we have big intentions in terms of transparency and value exchange regarding your data and how we use it. By visiting www.cindysswimschool.co.uk you are accepting and consenting to the practices described in this policy. For the purpose of the GDPR, the data controller is Cindy’s Swim School LLP, Albany House, Claremont Lane, Esher, Surrey, KT10 9FQ.

 

1. Definitions

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and GDPR as it forms parts of the United Kingdom domestic law by virtue of Section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR”)
“We/Us/Our” means Cindy’s Swim School. Our website address is: https://cindysswimschool.co.uk.

 

2. Information about us

2.1 Our Site is owned and operated by Cindy’s Swim School LLP of Albany House, Claremont Lane, Esher, Surrey, KT10 9FQ.

 

3. What does this Policy cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

Embedded content from other websites

Articles on this site may include embedded content from YouTube, Instagram and Facebook (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. Facebook and YouTube, for example, will retain your information for as long as you have an account.

Photography

No photography or filming is allowed at Cindy’s Swim School lessons without prior permission from Cindy’s Swim School. This is to protect all pupils and teachers.

From time to time we may take photographs at classes including of your children to celebrate their progress.  We may also from time to time use these in marketing Cindy’s Swim School.  If you do not want your child to be photographed by us that is of course absolutely fine.  To manage this we need you to tell whoever is teaching the pupil on the day to ensure they are excluded from any photographs being taken of them.

We will always let a class know onsite at the beginning of the session that photographs or footage are to be taken. If this is ever an issue on the day, the pupil can of course be excluded. However logistically to enable this we need to make it the responsibility of the parent / guardian to make this known to the teacher before photography or filming commences – to ensure they are not captured.

Some of the swimming pools we use have CCTV installed for the protection of their property. These are managed by the sites themselves and Cindy’s Swim School does not have access to and does not use any of the footage.

 

4. Your rights

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

 

5. What data do we collect?

Depending upon your use of Our Site, you may give us information about you by filling in forms, registering to use our site, subscribing to our service, downloading information, participating in social media functions, taking part in a survey or reporting a problem with our site. We may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies and Our Cookie Policy:

5.1 name;
5.2 contact information such as email addresses and telephone numbers;
5.3 IP address;
5.4 web browser type and version;
5.5 operating system;
5.6 a list of URLs starting with a referring site and your activity on Our Site;
5.7 electronic reviews or correspondence submitted via our website.

 

6. How do we use your data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the UK GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1 Providing and managing your access to Our Site;
6.2.2 Supplying Our services to you (please note that We require your personal data in order to respond to requests for our services and online resources);
6.2.3 Replying to emails from you;
6.2.4 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing us at info@cindysswimschool.co.uk or by unsubscribing at the foot of emails;
6.2.5 Market research;
6.2.6 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our services. We will not, however, send you any spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We retain your personal information as long as it is necessary to provide the service requested by our customers, or for as long as consent is granted, unless otherwise prohibited by law. In addition, if such information is relevant, we retain it for the period required by applicable UK tax law (currently 6 years).

 

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under GDPR as it forms parts of the United Kingdom domestic law by virtue of Section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR”) including:

7.2.1 Ensuring that our partners are UK GDPR compliant.

7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:

7.4.1 Data stored on our website is protected by a firewall and security software.
7.4.2 Back ups of our website are stored securely in a UK GDPR compliant way.
7.4.3 SSL/TLS encryption of all data transmitted via our website.

 

8. Do we share your data?

8.1 Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

Note: If you request a password reset, your IP address will be included in the reset email. All emails sent via the website are encrypted via SSL/TLS.

 

9. What happens if our organisation changes hands?

9.1 We may, from time to time, expand or reduce Our organisation and this may involve the sale and/or the transfer of control of all or part of Our organisation. Any personal data that you have provided will, where it is relevant to any part of Our organisation that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

 

10. How can you control your data?

10.1 When you submit personal data via Our Site, you will be given options to restrict Our use of your data. In particular, We will give you controls on Our use of your data for direct marketing purposes (including the ability to opt-out of cookies or opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).

 

11. Your right to withhold information

11.1 You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
11.2 You may restrict Our use of Cookies. For more information, see section 13 and Our Cookie Policy.

 

12. How can you access your data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held Under the UK GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at info@cindysswimschool.co.uk, or using the contact details below in section 14.

 

13. Our use of cookies

13.1 Our Site places and accesses certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products. In addition, Our Site uses analytics services provided by Google Analytics and SoPro, and content provided by Vimeo and LinkedIn, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. For more details, please refer to Our Cookie Policy.

 

14. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@cindysswimschool.co.uk. You can also write to us:

Cindy’s Swim School LLP, Albany House, Claremont Lane, Esher, Surrey, KT10 9FQ

Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

 

15. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.