This privacy notice sets out how we collect, use and protect the personal data that you provide to us. It also explains what we do with your data. We also set out details about your rights in relation to the personal data we hold about you, and how to contact us if you have any questions or comments.

We are International Swimming Academy Stars Limited ( ISA, we, our, or us), a company registered in England and Wales under company number 10307362 whose registered office is at International Swimming Academy Head Office, Flat B, 29 Stowe Road, W12 8BE, London. We are registered as a data controller with the Information Commissioner’s Office and our registration number is ZA381818.

This privacy notice applies to the personal data we collect about you through our website (www.internationalswimmingacademy.com), by post, by telephone, and when you otherwise communicate with us. This privacy notice may change from time to time and, if it does, the up-to-date version will always be available on our Website. We will also tell you about any important changes to our privacy notice.

We collect personal data about you if you fill in forms on the website or correspond with us by phone, email, or otherwise. This includes information you provide when you register with us, place orders for goods or services, attend classes or photoshoots, voluntarily complete customer surveys, enter competitions, provide feedback and when you report a problem with our Website. 

Personal data we may process about you:

• • Name (s)
  • Telephone number
  • Mobile phone number
  • Personal email address
  • IP address
  • Bank and/or payment card details
  • Gender
  • Details of any medical conditions that may be relevant to your safety, when in receipt of our services

Personal data we may process about your child/children:

• Name (s)
• Gender
• Date of Birth
• Details of any medical conditions that may be relevant to your child’s/ children’s safety, when in receipt of our services in order to safely and efficiently provide you with our services: for example, to ensure your child is old enough and of sufficient weight to safely swim at particular temperatures; to allow our instructor to appropriately communicate with your child, or to ensure the appropriate changing facilities are available to you.
• No automated decision-making or profiling will take place using your personal data.
• If you use our Website, we automatically collect the following information: web usage information (e.g. IP address); your login information including last login and any failed attempts to login, anonymised demographic information (e.g. age bracket or gender); device type, model, and screen dimensions; browser type and version; IP location; local language setting and time zone setting, operating system and platform, and information about your visit, including the full Uniform Resource Locators (URLs); clickstream to, through and from our Website (including date and time(; time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs).
• Where we collect information about you in the ways described above, we do so on the basis that it is in our legitimate interests to collect and process this data. Where possible, this data will be anonymised. We collect and process this data to ensure that our Website is functioning properly and that our customer experience is to the standard that you and we expect.
• The Website may, from time to time, contain links to and from the websites or advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these notices. Please check these notices before you submit any personal data to these websites.
• We also use cookies on our Website. Please see the cookies section for more information.

Information we receive from other sources:

• We are also working closely with third parties, (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them.
• When we receive information from other sources, we rely on having the appropriate provisions in place telling you how they collect data and who they may share it with. We carefully check our sources to ensure that we only receive your information when it is lawful for us to do so.

We use the information held about you in the following ways: 

Information you give to us. We will use this information to: carry out our obligations arising from any contracts entered into between you and us and to provide you with the information products and services that you request from us including, but not limited to, billing you and contacting you about your swim lessons and/or your orders, respond to your enquiries or to process your requests in relation to your information, let you know about important changes or developments to the Website or our services, provide and personalise our services generally, carry out market research campaigns measure or understand the success of our products and services, and where we might improve the services we provide to you, provide you, or permit selected third parties that you have consented to provide you, with information about goods or services we feel may interest you, contact you to let you know about other products and services that we offer and feel may be of interest, as set out in the section on Marketing Communications, ensure that content from our Website is presented in the most effective manner for you and for your computer, making the Website easier for you to use and providing you with access to all parts of the Website.

Information we collect about you. We will use this information to administer our Website, and of internal operations, including troubleshooting, data analysis, testing, research, statistical and surveys purposes, improve our Website to ensure that content is presented in the most effective manner for you and for your computer, allow you to participate in interactive features of our service, when you choose to do so, assist our efforts to keep our Website safe and secure, measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, and make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them. 

Information we receive from other sources. We may combine this information with information you give to us and the information we collect about you. We may use this information and the combined information for the purposes set out above ( depending on the types of information we receive). We must have a legal basis for processing your personal data. We consider that we have a legal basis where you have given us consent to do so for the specific purposes which we have told you about - for example, we will need your consent to process any health information you provide to us, such as information relating to mobility so that we can provide an appropriate service. We will also rely on consent in the context of direct marketing, as explained below, it is necessary for us to do so to enable us to provide you with the services that you have requested from us - for example, contacting you about orders; it is necessary in order to fulfil our legitimate interests ( or those of a third party) and your interests and fundamental rights do not override those interests, or the law otherwise permits or requires it. Where we process your personal data on the basis of our legitimate interests, there are our  (or our third party’s) interest in providing our services to you in an efficient and secure manner.

• We want to ensure that you are informed and aware of the best products, services, competitions, promotions and events that we can offer you. By consenting to receive additional communications (by mail, telephone, text, picture, video message or email ) from us in respect of such information, we will process your personal data in accordance with this privacy notice.

• If you prefer not to receive any marketing communications from us, you can change your preferences and unsubscribe at any time by clicking on the unsubscribe link on any marketing email from us, or by contacting us at info@internationalswimmingacademy.com. If you choose not to receive this information, we will be unable to keep you informed of new services, competitions, events and promotions that may interest you.

• Your personal data will only be seen or used by our employees, volunteers, or assistant who have a legitimate business need to access your personal data for the purposes set out in this privacy policy.

• We take your privacy seriously and have implemented appropriate physical, technical and organisational security measures designed to secure your personal data against accidental loss, destructions or damage and unauthorised access, use, alteration or disclosure.

Except as explained in this privacy policy, we will not share your personal data without your consent unless required to do so by law.

• We may share your personal data with the following third-party service providers who assist us with administering the provision of our services to you: business partners, suppliers and subcontractors for the performance of any contract we enter into with them of you; agents we engage to perform functions or our behalf including fulfilling order deliveries, sending customers communications, analysing data, providing technical support, providing marketing assistance (including carrying out market research), processing payments, and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes, and analytics and search engine providers that assist us in the improvement and optimisation of our Website. If you need more details about how we manage your data with third-party services click on this link.

• We may also pass aggregate information on the usage of our site ( e.g. we might disclose the median ages of visitors to our site, or the numbers of visitors to our site that come from different geographic areas) to third parties, but this will not include information that can be used to identify you personally. 

• We take your privacy seriously and are committed to maintaining the privacy and security of the personal data you provide to us, and the choices you have regarding our collection and use of your personal data.

• We follow strict security procedures as to how our personal data is stored and used, and who sees it, to help stop any unauthorised persons getting hold of it. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

• Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. You should not share this information with anyone.

• We do not transfer your personal data outside of the European Economic Area except in the case of images captured during our internal photoshoot. Those images are processed and made available for viewing by third-parties who are located outside of the EEA, and we have taken measures to ensure that your data is secure while it is in their care. Unfortunately, the transmission of your personal data via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us over the internet and you acknowledge that any transmission is at your own risk.

• We will keep your personal data for no longer than necessary, for the purposes we have set out above. We will retain your information for as long as need in order to provide the relevant services to you or perform any contract we have with you, and for a maximum of five years from the date of our last interaction in order to deal with any queries, provide you a continuous service should you start swim lessons with another child, or to refer back to your child’s swimming history should you leave and re-enrol.

• If you and your child/children attend an internal photoshoot, we will retain the professional photographs of your child/children for a maximum of five years from the date of the photograph unless you purchase the image or consent to our using the images for other purposes. During the five-year retention period, we may request your permission to use the photograph for: local social media or local newsletters; broader promotional or marketing purposes. Should you consent to either of these, personal data will be kept alongside the photograph to enable us to contact you or to enable you to withdraw consent or to have your photographs deleted sooner than the five-year retention period as referred to above, please contact us at info@internationalswimmingacademy.com.

• If you give us permission to use a photograph from our internal photoshoot for promotional or marketing purposes, we will retain a copy of that photograph for the length of the time we own the copyright relating to that image in order that we can properly exercise our rights under copyright law. 

• Photographs taken at an internal photoshoot may be used for training and quality assurance purposes and we may share them within our group for those purposes. If we retain photos for these reasons, they will not be used for any other purposes without your explicit consent.

• Where you have given us permission to use other photos or videos taken in class, such as at promotional events, we will keep those images for the duration of our requirements or your consent, whichever is shorter. Should you withdraw your consent for use of those images, we will endeavour to remove all available copies from our own social media platforms, but due to the nature of social media, we may not be able to withdraw images that have been shared further. Any third parties that we engage will keep your data stored on their systems for as long as is necessary to provide the relevant services to you or us. If we end our relationship with any third-party providers, we will make sure that they securely delete or return your personal data to us.

• In order to ensure our teachers are at the required standard, we may, when assessing a new teacher, take a video of that and children may be captured as well. This video will only be used internally for teacher assessment and will be securely destroyed once that teacher has fully qualified. We may retain personal data about you for statistical purposes (for example, to help us better advertise our services). Where data is retained for statistical purposes it will always be anonymised, meaning that you will not be identifiable from that data. 

There are circumstances in which your rights may not apply. You have the right to request that we:

• Provide you with a copy of the information we hold about you
• Update any of your personal information if it is inaccurate or out of date
• Delete the personal data we hold about you - if we are providing services to you and you ask us to delete personal data we hold about you then we may be unable to continue providing those services to you;
• Restrict the way in which we process your personal data; stop processing your data if you have valid objections to such processing; and transfer your personal data to a third party.

For more information on your rights and how to use them, or if you would like to make any of the requests set out above, please contact us using the details  provided in section 12. We will respond to all such requests within the time period required by law. As explained in the section on Marketing Communications above, even if you consented to the processing of your personal data for marketing purposes (by ticking the relevant box or by requesting information about services), you have the right to ask us to stop processing your personal data for such purposes. You can exercise this right at any time by contacting us at info@internationalswimmingacademy.com.

What’s a cookie?

• Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or another device when you visit a website.
• Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie.
• Cookies are useful because they allow a website to recognise a user's device.
• Cookies in themselves do not identify you, just the computer or device you are using. 

How do we use cookies?

• Cookies do lots of different jobs, like making it easier for you to log on to and use our Website during future visits, letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience.
• They also allow us to monitor traffic on our Website and can also help to ensure that adverts you see online are more relevant to you and your interests.
• Cookies themselves only record which areas of our Website have been visited by your computer or device and for how long.
• Allowing us to create a cookie does not give us access to the rest of your computer.
• All the cookies that we use are persistent cookies. These cookies remain on your device for the period of time specified in the cookie. They are activated each time that you access the Website from the same device. You can see how long a cookie will be left on your device. To find out how you can visit www.allaboutcookies.com which contains further information about how to manage cookies.

ISA: The Website uses some cookies which are specific to us. These allow us to: check that you’ve accepted cookies; automatically log you in on a device you’ve used before; automatically reconnect you to your last Website session and shopping basket; not replay our intro video to you if you’ve already seen it; reload the correct local content for you.  

Google Analytics: Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use our Website. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on website activity for internet operators and providing other services relating to website activity and internet use. 

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

By using our Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You can choose to opt-out of Google Analytics using your browser settings to manage cookies. With most Internet browsers, you can erase or block cookies or ask to receive a warning before a cookie is stored. The “Help” function within your browser should tell you how. Alternatively, you may wish to visit www.youronlinechoices.eu or www.allaboutcookies, org. which contain comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies. You are under no obligation to accept our cookie statement. Please be aware that restricting cookies may have a negative impact on the functionality of the Website.

If you have any questions or concerns about how we handle your personal data, you can contact us using the following email address.

Email: info@internationalswimmingacademy.com

If you are unsatisfied with our response to any data protection issues you raise with us you have the right to make a complaint to the Information Commissioner's Office (ICO).