Privacy Policy

1. Who we are

SwimPal is a trading name of HINK Digital Ltd.

HINK Digital Ltd is the data controller responsible for the personal information described in this Privacy Policy.

Company details

For questions about this Privacy Policy or how we use your personal information, contact us at:

hello@swimpal.com

2. Information we collect

Information you provide through the waiting-list form

When you join the SwimPal waiting list, we collect:

• your name;
• your swim school’s name; and
• your work email address.

Information you provide when contacting us

When you contact us by email or another method, we may collect:

• your name and contact details;
• the name of your swim school or organisation; and
• any information included in your message.

Please avoid sending sensitive personal information unless it is necessary.

Information collected when you use the website

Our website and hosting providers may automatically collect limited technical information, including:

• your IP address;
• browser and device type;
• operating system;
• pages visited;
• approximate location based on your IP address;
• dates and times of visits; and
• information about errors or website performance.

We use this information to operate, secure and improve the website.

3. How we use your information

We may use your personal information to:

• add you to the SwimPal waiting list;
• let you know when SwimPal demonstrations become available;
• tell you when applications open for the Founding Partner Programme;
• contact you about your interest in SwimPal;
• respond to questions or messages;
• understand which swim schools are interested in SwimPal;
• improve our website and launch plans;
• protect the website against misuse, fraud or security threats; and
• meet our legal and regulatory obligations.

We will not sell your personal information.

4. Our lawful bases

Under UK data protection law, we must have a valid reason for using your personal information.

Consent

We rely on your consent to send you waiting-list updates, information about demonstrations and details of the Founding Partner Programme.

You can withdraw your consent at any time by:

• using the unsubscribe link in an email; or
• contacting us at hello@swimpal.com.

Withdrawing consent will not affect any use of your information that took place before consent was withdrawn.

Legitimate interests

We may rely on our legitimate interests where necessary to:

• respond to enquiries;
• administer and improve our website;
• understand interest in SwimPal;
• maintain the security and reliability of our website; and
• keep appropriate business records.

Where we rely on legitimate interests, we consider whether our interests are balanced against your rights and reasonable expectations.

Legal obligations

We may use or retain information where necessary to comply with a legal or regulatory obligation.

The ICO confirms that organisations do not always require consent where another lawful basis applies, but the applicable basis must be identified before processing begins.

5. Marketing communications

When you join the waiting list, we will use your email address to send information relating to:

• SwimPal’s development and launch;
• demonstrations;
• the Founding Partner Programme; and
• other closely related SwimPal news.

You can unsubscribe at any time. Every marketing email will include an appropriate way to opt out.

We may retain limited information about an opt-out request so that we can make sure we do not contact you again against your wishes.

Electronic marketing rules differ depending on whether the recipient is an individual, sole trader, partnership or corporate organisation. Obtaining clear consent through the waiting-list form is the safest consistent approach for this list.

6. Who we share information with

We may share personal information with trusted service providers that help us operate SwimPal and the website, including providers of:

• website hosting;
• databases and data storage;
• email delivery and mailing-list services;
• website analytics;
• security and error monitoring; and
• professional services such as legal, accounting or technical support.

These providers may only use personal information in accordance with our instructions and their contractual and legal obligations.

We may also disclose information:

• where required by law;
• in response to a valid request from a court, regulator or public authority;
• where necessary to establish, exercise or defend legal claims;
• to investigate or prevent fraud, misuse or security threats; or
• as part of a sale, merger, restructuring or transfer of the business.

7. International transfers

Some of our service providers may process information outside the United Kingdom.

Where personal information is transferred internationally, we will take appropriate steps to ensure it remains protected. These steps may include:

• transferring information to a country recognised by the UK as providing adequate protection;
• using approved contractual protections, such as the UK International Data Transfer Agreement or UK Addendum; or
• relying on another lawful transfer mechanism.

Contact us for further information about the safeguards applying to a particular transfer.

8. How long we keep your information

We will keep waiting-list information while SwimPal is being developed and launched and for as long as you remain interested in receiving updates.

We will delete or anonymise waiting-list information when:

• you withdraw your consent or ask us to delete it;
• we decide not to proceed with the SwimPal launch;
• the information is no longer needed for the purpose for which it was collected; or
• keeping it is no longer lawful.

We may keep limited records for longer where necessary to:

• comply with legal obligations;
• resolve disputes;
• establish or defend legal claims;
• prevent fraud or misuse; or
• record that you have unsubscribed.

Personal information should not be kept for longer than it is needed, and organisations should establish appropriate retention periods.

9. How we protect your information

We take reasonable technical and organisational measures to protect personal information against:

• unauthorised access;
• accidental loss;
• misuse;
• alteration; and
• unlawful disclosure.

However, no website, email service or method of electronic storage can be guaranteed to be completely secure.

10. Cookies

We do not currently use cookies or similar technologies on the SwimPal website, other than any technologies that may be strictly necessary for the website to function.

If we introduce analytics, advertising or other non-essential technologies in future, we will update this Privacy Policy and provide appropriate cookie controls where required.

11. Your data protection rights

Depending on the circumstances, you may have the right to:

• ask for a copy of the personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to delete your information;
• ask us to restrict how we use your information;
• object to certain uses of your information;
• withdraw consent at any time;
• ask us to transfer information you provided to another organisation; and
• complain about how your information has been handled.

These rights are not absolute and may not apply in every situation.

To exercise a right, contact us at hello@swimpal.com. We may need to ask for information to confirm your identity before dealing with your request.

The right to object applies particularly to direct marketing, and people may also withdraw consent or request deletion of their information.

12. Complaints

Please contact us first if you have concerns about how we use your personal information:

hello@swimpal.com

You also have the right to complain to the UK Information Commissioner’s Office.

Further information is available from the Information Commissioner’s Office website.

13. Links to other websites

Our website may contain links to websites operated by other organisations.

We are not responsible for the privacy practices or content of external websites. You should read their privacy policies before providing personal information.

14. Children’s information

The current SwimPal website and waiting list are intended for swim school owners, staff and other business representatives.

We do not knowingly collect personal information from children through the waiting-list form. Please do not submit information about swimmers or children through this form.

15. Changes to this Privacy Policy

We may update this Privacy Policy as SwimPal develops, our website changes or our legal obligations change.

The latest version will always be published on this page, together with the date it was last updated.