Privacy Policy

H.G Swim Academy Limited (“HG Swim Academy”, “we”, “us”, “our”) provides swimming lessons and related services in the United Kingdom, including a mobile and web app that allows parents and guardians to track their students’ progress. We are the controller of the personal data described in this policy. If you have any questions about this policy or how we use personal data, you can contact us at: H.G Swim Academy Limited, 11 Redcliffe Street, London SW10 9DR, United Kingdom. Email: info@hgswimacademy.co.uk. Telephone: +44 7751 210336.

This privacy policy explains how we collect, use, share and protect personal data when you visit our website (www.hg-swimacademy.co.uk), use our app, contact us or use any of our services. It also explains your rights in relation to your personal data and how you can exercise them.

The information we collect depends on how you interact with us. We may collect your name, email address, telephone number, postal address and other contact details when you make an enquiry, create an account or book lessons. When you use our app or services, we may collect account details such as your login credentials, your role (parent/guardian, student, instructor) and your communication preferences. For students, we may record details such as name, date of birth, age group, swimming ability level, lesson history, progress records, teacher feedback and goals.

To support health and safety, you may choose to provide information about medical conditions, allergies, disabilities or other needs that may affect participation in lessons; this may include “special category” data. We also process booking and payment information such as lesson bookings, packages purchased, payment history and limited payment details; full payment card details are handled by our payment provider and are not stored by us. When you contact us, we keep records of communications such as emails, messages and complaints. When you use our website or app, we may collect technical and usage data such as IP address, device details, browser type, pages viewed and app usage logs, using cookies or similar technologies.

We usually collect information directly from you, for example when you complete a form, create an account, book a lesson, contact us or use the app. In some cases, we receive information from parents or guardians about their children, from our instructors (for example, lesson reports and progress assessments), and from third‑party providers such as booking or payment platforms that confirm payments or bookings.

We only use personal data where the law allows us to, and we always have a specific purpose.

We use your information to provide our services and run the app, including creating and managing your account, handling bookings and schedules, delivering lessons and recording students’ progress. In these cases, we generally rely on the lawful basis that processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.

We use health and safety information to plan and deliver lessons safely, to manage any risks and to respond to incidents or emergencies. For this type of processing we rely on a combination of vital interests, legal obligations and, where relevant, your explicit consent or specific provisions in UK law that permit the use of health data for safeguarding and duty‑of‑care purposes.

We use your contact details and communication records to respond to enquiries, manage your bookings, handle complaints and send important service messages (for example, changes to lessons or updates to this policy). This processing is usually necessary for the performance of a contract or is in our legitimate interests in running our business and communicating effectively with customers.

With your consent, or where permitted under the Privacy and Electronic Communications Regulations, we may use your contact details to send you marketing communications about our classes, courses, events or offers. You can opt out of marketing at any time as explained below.

We also use technical and usage data to operate, maintain and improve our website and app, to understand how they are used and to keep them secure. For essential cookies and similar technologies we rely on our legitimate interests in operating a secure and effective service. For non‑essential cookies such as analytics or marketing cookies, we rely on your consent.

Finally, we may process personal data to comply with our legal and regulatory obligations, for example to maintain appropriate business, tax and safeguarding records, and to respond to lawful requests from public authorities.

Our services are frequently used by or on behalf of children. In most cases we collect children’s personal data from their parent or guardian, who creates or manages the account and provides information needed to deliver lessons safely. Instructors add progress and assessment information as part of the lessons. Children have the same rights as adults over their personal data. Where a child is mature enough to understand these rights, we will consider whether to deal directly with the child or through their parent or guardian, taking into account the child’s age and best interests.

If you give us information about a student’s health or medical conditions, we will only use it to plan and deliver lessons safely, to meet our duty of care, and to record and respond to incidents or emergencies. This may include, for example, conditions such as asthma, epilepsy or allergies. For this information, we may rely on your explicit consent, on the need to protect vital interests, or on other specific legal provisions that allow the processing of health data for safeguarding, health and safety or similar purposes. You can withdraw your consent at any time, but if you do so we may not be able to provide lessons safely or at all.

Our website and app use cookies and similar technologies to make them work properly, remember your preferences, keep you logged in, understand how visitors use our services and improve performance and content. When you first visit our website, and from time to time afterwards, you will be asked to choose whether to accept non‑essential cookies such as analytics or marketing cookies. You can change your preferences at any time using our cookie settings tool (where available) or through your browser or device settings. For more details, you can refer to our separate cookie policy if provided, or contact us using the details above.

We only share personal data when necessary and with appropriate safeguards in place. We may share data with our instructors and staff so they can deliver lessons, access relevant student information and update progress records. We use service providers to host our website and app, provide IT support, email and SMS services, booking and payment platforms, analytics tools and other services that help us run our business. These service providers act on our instructions and are not allowed to use the data for their own purposes.

We may share personal data with professional advisers such as lawyers, accountants and insurers where this is necessary for our legitimate interests and to comply with our legal obligations. We may also disclose information to public authorities, law‑enforcement or safeguarding bodies where we are legally required to do so or where it is necessary to protect a child or another person from harm.

Some of our service providers may be located outside the United Kingdom. Where this is the case, we will ensure that appropriate safeguards are in place, such as using countries covered by an adequacy decision or standard contractual clauses approved for international transfers. We do not sell personal data.

We keep personal data only for as long as needed for the purposes described in this policy, including to meet legal, accounting and safeguarding requirements. The exact retention period depends on the type of information and the reasons for which it was collected. For example, enquiry and contact records are usually kept for a limited period after we last hear from you; customer and student records, including lesson history and progress notes, may be kept for a period after your last lesson or account closure in line with our safeguarding and insurance obligations; and financial records are typically retained for at least six years to comply with tax and accounting rules. After the relevant retention period expires, we will securely delete or anonymise the data.

We may send you marketing communications about our services if you have asked to receive them or if you are an existing customer and we are allowed to do so under applicable law. You can stop receiving marketing messages at any time by clicking the “unsubscribe” link in any marketing email or by contacting us using the details in section 1. Even if you opt out of marketing, we will still send you important service messages, such as booking confirmations and information about lesson changes or cancellations.

You have several rights in respect of your personal data. These include the right to ask for access to the personal data we hold about you, to ask us to correct inaccurate or incomplete data, and in some circumstances to ask us to delete your data or restrict how we use it. You may also have the right to object to our processing where we rely on legitimate interests, and to object at any time to receiving direct marketing. Where we rely on consent, you can withdraw that consent at any time. In certain circumstances you have the right to receive some of your data in a portable format and to ask us to transfer it to another organisation.

If you wish to exercise any of these rights, please contact us using the details in section 1. We may need to verify your identity before we can act on your request. For children’s data, we will consider the child’s age and understanding when deciding whether to deal with the child directly or via their parent or guardian.

If you have any concerns about how we handle your personal data, we encourage you to contact us first so that we can try to resolve the issue. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator. You can find more information on the ICO website at www.ico.org.uk or by calling 0303 123 1113.

We take appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures include access controls, secure systems, staff training and regular review of our security arrangements. No system is completely secure, so you should also take care when providing information online and keep your account login details confidential.

We may update this privacy policy from time to time to reflect changes in our services, our practices or applicable law. When we make significant changes, we will notify you through our website, the app or by email where appropriate. The date of the latest version will always appear at the top of this policy.