Introduction

• Sutton Dolphins is committed to protecting and respecting the privacy of all those who use our website and our services.
• In line with the EU General Data Protection Regulation (GDPR) it is important to us that our visitors to our website and customers  understand what personal data we collect or hold from you and how it will be processed

What personal data do we collect?

Information provided by you:

• You provide us with personal details if you subscribe to our newsletter on our website, send us an enquiry via the website, call us about booking classes or joining classes by using our online form.
• These personal details about yourself including your name, email and telephone number. As a swim school we also require details about your child/children that you wish to enroll. We ask for your child’s name, gender, date of birth, doctors, medical conditions, special requirements and level of water confidence.

Information we collect from you:

Cookies

When you first visit our website, we will ask for your permission to use tracking software to monitor your activity on our site. This helps us to better understand how our site is being accessed. This software is provided by Google Analytics which uses cookies to track visitor usage.

Cookies are small, harmless files saved to the user’s computer’s hard drive that track, collect and store information about the user’s interactions and usage of the website.

If you grant permission, the software will save a cookie to your computer’s hard drive to track and monitor your engagement and navigation of the website each time you visit.

Google Analytics uses your IP user address and tells us about the pages you have accessed and how long you stayed on these pages.

If you do not grant permission, we do not receive this information.

If you wish to block the use of cookies on your hard drive, you can select ‘cookie settings’ under the privacy settings in your browser options and add our domain name (www.mida.co.uk) to the list of websites you deny access.

Google Analytics provides information to us in an anonymised format (general summary rather than individualised) and this information is stored on the respective platforms.

Google take your privacy very seriously. For further information, please visit http://www.google.com/privacy.html

Emailers

• Our email marketing campaigns may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such monitored activity may include things like the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity. This information is used to refine our future email campaigns and supply the user with more relevant content based on their activity.
• For further information, you can read Mailchimps privacy policy which can be found at https://mailchimp.com/legal/privacy/

Payment

• At the time you purchase your swimming course we collect your payment type, transaction number (supplied by payment gateway), IP address (your computers ‘address’), the web browser and version and the full user-agent string. This information is taken to help secure the platform you are using.
• We do not store any card details from the user. All payments are forwarded to the payment gateways for the user to process payments these are Barclays EPDQ .

Why do we hold your data?

• We only hold personal data that we need to provide our customers and prospects with relevant information, fulfil contractual obligations, ensure the safety of our swim class participants and to allow us to fulfil our duty to report any safeguarding issues.
• If you have not given us direct consent to hold this information we will holding the information for legal (we hold past members details for 3 years for accounting purposes)& vital interest (health, safety & welfare) reasons or to ensure we can fulfill our contract with you for our services.

How do we use your data?

• The personal details acquired on the website contact form are used to ensure we can adequately respond to your request.
• The details we take on the online class joining form are used to register, pay and to ensure that we have all the details we need to give your child/children a tailored and safe swimming course that will fully meet their needs.
• Your child’s details are also detailed on a register that we print for the swimming instructor. These registers are shredded at the end of every term.
• Other data is used to verify and secure your payment transaction.
• Should it be necessary for us to raise a safeguarding issue that wasn’t appropriate or sufficient to address with the parents, we may use the child’s doctors details to contact them directly.

Data Retention

• If you send an enquiry to our website, your details will be deleted once actioned.
• If you have paid for one of our swimming courses we will retain your details for 7 years. This is for accounting purposes and as we have a high proportion of customers returning with younger children. This removes the logistical issue of being unable to set a new account with an email that has previously been used on our system.

Information Security

We take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of our website users and the personal information that we hold. Our website complies with all UK national laws and requirements for user privacy and uses a Secure Socket Layer (SSL) certificate.

We have checked to the best of our knowledge that our website and hosting company have taken all steps possible to protect our site and data. The personal information you provide us with and we collect is stored on the shared hosting provided by Adventure Graphics Ltd within a secured MySQL database. For further details please visit https://adventuregraphics.co.uk/privacy-policy/.

The sensitive data entered on our website is encrypted as an additional safety precaution. We class our sensitive data as children’s names, medical conditions and special requirements as well as the passwords you use to access your account. A child’s gender is anonymised and stored as such.

To further protect the data and sensitive data we use Norton’s virus protection software.

While we do take all applicable technical and organisational measures to safeguard your data, it is impossible for us to secure the whole internet entirely. As a user, it is your responsibility to acknowledge this and to understand that the personal details you give to us by your own choice across the internet are transferred at your own risk.

Social Media Platforms

Our social media engagement is subject to the customs and privacy policies of each social media platform. Social media may have their own tracking cookies in place.

While we take great care to ensure the security and safety of our follower’s personal information it is up to the individual to use the platforms with due care and caution in regard to their own privacy and personal details.

Sutton Dolphins will never ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as telephone or email.

If we use social sharing buttons which help share web content directly from web pages to the social media platform in question, users do so at their own discretion. By default, some social media platforms shorten lengthy URL’s (web addresses) so that they look like this; http://bit.ly/wkDTpk18. These shortened URL’s can be prone to spam and hacking. Adventure Graphics cannot not take any liability for damages/implications caused by visiting any shortened links.

The right to be forgotten

We will always include a clear and straightforward opt-out method on all of our email communication with you so that you have an easy to follow route if you decide you no longer wish to be contacted by Sutton Dolphins.

Upon this request, your details will be removed from the database.

Sharing your information

We never share your information with any external third parties except for our trained Swimming Instructors who are all DBS and reference checked. The Swimming Instructors are issued with a register for the length of the swimming course and includes the name, age and special requirements/medical conditions of the child.

We use a Data Processing Agreement to ensure that our Swimming Instructors are aware of their obligations as our ‘data processors’ to further ensure the security of your data.

Your Data Protection Rights

Your personal information is kept private and stored securely until a time it is no longer required, is no longer relevant or you ask us to remove your details.

You may request a copy of the personal data we hold for you or ask us to amend your details free of charge. If you would like a copy of this information, please write to the business address at the bottom of this policy.

We will respond to your request within 30 days providing you provide us with proof of identity.

Questions about this Privacy Policy

It is important to us that our visitors and customers fully understand the privacy implications and this policy aims to outline the obligations and requirements of the users, the website and the website owners as openly and transparently as possible. If there is an area, you are unsure about, please do not hesitate to contact us so we can talk you through it.

Updates to this Privacy Policy

We will update this policy in response to legal, technical or business developments. This policy was last updated in May, 2018.

Resources & Further Information

• ICO GDPR
• ICO GDPR Regarding Children
• Data Protection Act 1998
• Twitter Privacy Policy
• Facebook Privacy Policy
• Google Privacy Policy
• Mailchimp Privacy Policy