This Privacy Notice sets out the basis on which we will process the personally identifying information (‘Personal Data’) that we collect and receive from and about users of our website (www.aweswim.co.uk, www.aweswim.com) (together “the Sites”) and customers who purchase swimming lessons, attend our lessons or subscribe to our newsletters
Our privacy commitments
- We will only collect, keep, use and share Personal Data for legitimate business purposes that we explain here below, or if we’re legally required to do so.
- We will be as clear and open as we can with you on what Personal Data we collect and how it will be processed.
· For as long as we maintain records of your Personal Data, we will keep it up to date and protect it with appropriate safety measures.
We collect the following Personal data from or about you as an Aweswim customer:
· Personal Data Collected Directly from you through the booking process: your name, your children’s name(s), phone number, postal address, email address, gender and ages. Our legal basis for the collection and processing of this data is the provision to you of the services purchased by you.
· Personal Data Collected Automatically from the use by you of the Sites. The data transmitted from your browser includes your IP address, the date and time of the visit the pages accessed, the access status/HTTP status code, your browser, your operating system and interface, as well as the language and version of the browser software. The legal basis for collecting and processing this personal data is to be able to operate the Sites and provide you with access to the pages you wish to access.
We use your Personal Data:
· For the administration of your purchases and our lessons and to contact you about your purchase (for example with details on your lessons or attendance).
· To contact you with marketing messages which you have requested or agreed to receive from us (for example via a branded newsletter);
· To contact you with surveys and feedback requests (for example relating to our swimming lessons you or your child have attended);
· To analyse the purchase history of our customers and the way our customers use the Sites.
Google Analytics, a web analytics service provided by Google, Inc. (“Google”) also places cookies on your computer, to enable Google to provide us with activity reports relating to the Sites. Google uses this data only to provide us with information on how users use the Sites and does not associate your IP address with any other data held by Google. The information generated by Google cookies about your use of the platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. You may refuse these cookies by selecting the appropriate settings on your browser or by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
Aweswim Ltd will not sell your information. We will not share your information with any third party except as stated in this Privacy Notice or as required to operate the Sites or provide our services to you.
We will share your Personal Data with social media sites to enable them to provide marketing messages that you have agreed to receive from them. The social media sites we share your Personal Data with as at the date of this Privacy Notice and their respective privacy statements are:
Hootsuite, https://hootsuite.com/legal/privacyAL MEDIA FOLLOWE
SOCIAL MEDIA FOLLOWERS
We receive the following Personal Data about you if you follow one of our social media accounts: Your account name, gender, general interests, location, age. Our legal basis for processing this data is our legitimate interest in providing social media and marketing content that is of interest to our followers on social media.
We use this Personal Data:
· to provide bespoke social media content (for example by analysing your general interests);
· to create targeted advertising across all our social media channels (for example by analysing responses to posts and existing advertisements);
· to find out more about our digital community (for example by analysing the age ranges of our followers).
Aweswim will not sell your information. We will not share your information with any third party except as stated in this Privacy Notice or as required to operate the Sites and provide our services to you.
We collect the following Personal Data about you if you visit one of our Sites: site referrals, browsing pattern, browser type, location, general interests, gender, age. The data transmitted from your browser includes your IP address, the date and time of the visit the pages accessed, the access status/ HTTP status code, your browser, your operating system and interface, as well as the language and version of the browser software. The legal basis for collecting and processing this personal data is our legitimate interest in operating the Sites, providing you with access to the pages you wish to access, understanding the interests of our potential customers and providing you with relevant information about our services.
We use this Personal Data:
· to provide you with bespoke website content (for example by analysing our site visitors’ age ranges);
· to gain insight into your behaviour and preferences (for example by analysing the website pages you visit);
· to create bespoke marketing messages (for example by analysing the click throughs on our Sites);
· to re-target our website visitors with relevant marketing messages (for example by using cookies hosted on our Sites);
· to collect site statistics.
Aweswim will not sell your information. We will not share your information with any third party except as stated in this Privacy Notice or as required to operate the Sites, provide our services to you or otherwise as required or permitted by law.
We use third party processors to collect, export, process and store Personal Data on our behalf. The processors we use currently are the following:
1. CRM Tool: Mailchimp,. https://kb.mailchimp.com/accounts/management/about-mailchimp-the-eu-swiss-privacy-shield-and-the-gdpr
2. Cloud Storage: Google Drive,https://cloud.google.com/security/compliance/eu-data-protection/
3. Social Media Platform: Facebook, some data centres located in the U.S. Privacy Shield Certified.https://www.facebook.com/privacy/explanation
4. Survey Tool: Survey Monkey, located in the U.S. Privacy Shield Certified.https://www.surveymonkey.com/mp/policy/privacy-policy/
Web Management Tools
5. Google Analytics, located in the U.S. Privacy Shield certified. https://www.google.com/policies/privacy/
6. StatCounter Analytics http://statcounter.com/policy/
International Data Transfers
We use data processors located outside the European Economic Area only after taking such steps as are required to ensure that Personal Data they process on our behalf receives protection equivalent to that provided in the EEA. Our processors are either certified as compliant with the EU-U.S. Privacy Shield Framework where they are located in the USA or have entered into an agreement with us containing the model clauses approved by the European Commission as providing contractual protection equivalent to that provided by the data protection regulations applicable in the EEA. To learn more about the Privacy Shield program, please visit www.privacyshield.gov.
We maintain technical and physical safeguards that are designed to protect the security and integrity of your Personal Data, and to guard it against accidental or unauthorised access, use, alteration or disclosure to unauthorised third parties. These measures include device encryption, firewalls and virus checking procedures.
Where we keep Personal Data files on local devices these devices are protected and accessible only to authorised Aweswim Ltd employees.
We regularly review our security systems to ensure that your Personal Data remains safe and secure.
Duration of Storage
We will maintain records of your Personal Data for as long as you remain:
· a registered subscriber to our mailing list;
· a registered user of any of our Sites;
· or have completed a purchase with Aweswim Ltd in the last 36 months; or for as long as is necessary to provide our services to you.
Duration of Storage
If you have not opened any email communication from Aweswim or interacted in any other way with us for 36 months we will regard you as an inactive subscriber and delete your details from our records except where retention is necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees.
Your Rights in Relation to Personal Data
· You can update your subscription preferences or unsubscribe from our marketing communications at any time by following the link in the footer of the last email you received from us (“Update your subscription preferences” or “Unsubscribe”)
· You have the right to update and correct the personal information on your account. You also have the right to request from us all personal information that we hold that relates to you, to request restriction of the processing of that data and to request that we delete that data. Where allowed by applicable law there may be an administrative charge for supply of copies of data and we may also require you to provide us with appropriate identification before we comply with this request. You also have the right to object to our continued processing of your personal data. You may also have the right to data portability. If you have a complaint about the way in which we use your personal information you have the right to complain to the Information Commissioner www.ico.gov.uk.
You can contact us with questions about the personal information we hold about you using the contact information provided in the Contact Us of this privacy notice.
We will update this Privacy Notice from time to time to reflect changes in our business. All such changes will be posted to the Sites and if we consider it to be appropriate we will notify subscribers of any material changes by e-mail.
Aweswim Limited is the Data Controller in respect of any Personal Data that you submit to us or that we collect from or about you. We are a limited company registered in England and Wales (registered no. 8270885) with registered offices at 6 Red House Close, Newton Longville, Bucks. MK17 0AH
If you would like to know what information we hold about you or if you have any other queries or complaints in relation to this Privacy Notice, or our Sites, our contact details are as follows: