This policy was last updated May 24 2018.
This section sets out who we are. It provides some useful information about us including our UK company number, registered address and data controller registration number (provided by the UK Information Commissioner’s Office).
This section informs you of exactly what personal data we collect about you and why. This includes information that is provided to us directly by you as well as information that we gather from your visits to our website and information that we receive from other sources.
This section explains how we will collect, store and use personal data that you provide to us. This is to enable us to carry out the activities relevant to the provision of our services to you.
This section explains how we will ensure that you only receive marketing communications that you wish to receive. We will ensure that you have total control over the information that you receive.
This section explains who will have access to your personal data. It also explains the reason for them accessing your personal data.
This section informs you of who we share your personal data with. It also explains the reason for sharing; this is largely so that we can provide our services to you.
This section explains how we keep your personal data safe and where it will be held.
This section explains the length of time that we will retain your personal data. It also explains why we hold your personal data for such time periods.
This section explains that you have rights in relation to your personal data. It also explains what these rights are and how you can go about exercising them.
This section provides you with contact information should you have any questions or concerns about the way we handle your personal data. It also explains how you can contact the UK Information Commissioner’s Office or the Autoriteit Persoonsgegevens should you be unsatisfied with our response to your data protection issues.
We are Water Babies Limited (Water Babies, we, our or us), a company registered in England and Wales under company number 04322357 whose registered office is at The Bubble, 205 High Street, Honiton, Devon, UK, EX14 1LQ.
We are registered as a data controller with the Information Commissioner's Office and our registration number is Z98515333. We are not required to register as a data controller in the Netherlands as of May 25 2018.
This section informs you of what information we collect about you and why.
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 photo shoots, voluntarily complete customer surveys, enter competitions, provide feedback and when you report a problem with our Website. We may also ask you to share your personal data with us if it is necessary for us to provide our services to you – for example, we may ask if you require mobility assistance when planning or scheduling our swimming lessons.
Personal data we may process about you:
- home address and telephone number
- mobile phone number
- personal email address
- IP address
- bank and/or payment card details
- 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:
- 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
Where we collect gender, biometric or medical data about your or your child/children, we do so on the basis that we require this data 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 teachers 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:
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 of advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
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 them 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.
This section explains how we will collect, store and use personal data you provide to us in order to carry out the activities relevant to the provision of our services to you.
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 for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey 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 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, these are our (or our third party’s) interests in providing our services to you in an efficient and secure manner.
This section is to explain how we will ensure that you only receive marketing communications that you wish to receive.
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, by logging into your WaterWorld account or by contacting us at email@example.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.
We take your privacy seriously and have implemented appropriate physical, technical and organisational security measures designed to secure your personal data against accidental loss, destruction or damage and unauthorised access, use, alteration or disclosure.
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 sub-contractors for the performance of any contract we enter into with them or you;
- agents we engage to perform functions on our behalf including fulfilling order deliveries, sending customer 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.
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.
This section explains how we keep your personal data safe and where it will be held.
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 your personal data is stored and used, and who sees it, to help stop any unauthorised person 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.
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.
This section explains the length of time that we will retain your personal data.
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 needed 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-join.
If you and your child/children attend a photo shoot, we will retain the professional photographs of your child/children for a maximum of three years from the date of the photograph unless you purchase the image or consent to our using the images for other purposes.
During the three 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. Should you wish to withdraw consent or have your photographs deleted sooner than the three year retention period as referred to above, please contact us using the details provided in section 12.
If you give us permission to use a photograph for promotional or marketing purposes or you purchase a photograph during the three year retention period as referred to above, we will retain a copy of that photograph for the length of time Water Babies owns the copyright relating to that image in order that we can properly exercise our rights under copyright law. This will also allow you to return to us and purchase further copies of the image should you wish to do so.
Photographs taken at a photo shoot may be used for training and quality assurance purposes and we may share them within our group and franchise businesses for those purposes. If we retain photos for these reasons, they will not be used for any other purpose without your explicit consent.
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.
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.
This section explains that you have a number of rights in relation to your personal 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 this section [insert link to 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 firstname.lastname@example.org or by calling us on +44 (0)1404 548348.
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. 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.org/ which contains further information about how to manage cookies.
We use three different sets of cookies:
- Water Babies: 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 Website for you in your chosen language;
- reload the correct local content for you.
- Feefo: The Website uses Feefo to display our national and local customer satisfaction ratings. We use a cookie provided by Feefo to make sure we display the right ratings for you.
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 any one (or more) of the following:
Data Protection Team
Water Babies Limited
205 High Street
Telephone: +44 (0)1404 548348
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) or the Autoriteit Persoonsgegevens. These are the authorities in the UK and the Netherlands, respectively, which are tasked with the protection of personal data and privacy.