Version: 1.4 

Reviewed: October 2026 

Supersedes: Version 1.3

 

1. Introduction 

Vale Swim Academy Limited ("Vale Swim Academy", "we", "us") is responsible for the personal information described in this notice. We are committed to protecting the privacy of parents, guardians, swimmers and people who enquire about our services. This notice explains what information we collect, why we use it, who we share it with, how long we keep it and your rights under UK data protection law. 

 

Contact: info@valeswimacademy.co.uk. 

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2. What Information We Collect 

We may collect, where relevant: 

• Parent/guardian or account-holder name, email address, telephone number and contact details. 

• Swimmer name, date of birth and other registration details relevant to lessons. 

• Health, medical, disability, special educational needs or support information relevant to safe swimming tuition. 

• Bookings, attendance, lesson progress, payment status, enquiries and communications. 

• Complaints, incidents, behavioural concerns and safeguarding information where necessary. 

• Information relating to website visits and cookies, depending on the technologies used on the website. 

 

3. Medical, SEN and Safeguarding Information 

Health, medical, disability and some support information may be special category personal data. We use it only where necessary for safe and appropriate tuition, health and safety, reasonable adjustments and responding to emergencies. 

The Article 6 lawful basis is usually contract, legitimate interests or legal obligation, depending on the purpose. We also identify an appropriate Article 9 condition for processing special category data, which may include explicit consent or another applicable condition. We do not assume that ordinary contractual necessity alone permits special category processing. 

We may record safeguarding concerns, disclosures, referrals and actions taken where needed to protect children or others. Such information is restricted to people with a genuine need to know and may be shared with safeguarding agencies or authorities where necessary and lawful. The lawful bases and any additional conditions depend on the circumstances. 

 

4. How We Use Your Information 

We use information to manage registrations, bookings and payments; deliver swimming lessons; keep swimmers safe; make reasonable adjustments; record attendance and progress; respond to enquiries, concerns and complaints; and comply with applicable obligations. 

We may contact people on our waiting list about suitable lesson spaces, holiday lessons or other swimming opportunities they have requested or shown an interest in. Promotional communications are handled in accordance with applicable electronic marketing rules, and we provide an appropriate way to opt out where required. 

 

5. Lawful Basis for Processing 

Our lawful basis depends on the particular activity: 

• Contract — Article 6(1)(b): providing requested lessons and bookings, administering accounts and essential service communications. 

• Legitimate interests — Article 6(1)(f): safely and effectively running the academy, handling enquiries, managing waiting lists and relevant availability updates, keeping appropriate records, and managing complaints, provided those interests are not overridden by individuals’ rights. 

• Legal obligation — Article 6(1)(c): meeting applicable tax, accounting, health and safety, safeguarding and other legal obligations. 

• Consent — Article 6(1)(a): optional uses where we request consent, such as certain photographs or videos. Consent can be withdrawn. 

Where special category information is processed, an additional Article 9 condition is required as explained in section 3. 

 

6. Third-Party Services and Sharing 

We use service providers where needed to deliver and administer our services, including: 

• ClassBase — registration, lesson administration and customer records. 

• Resend — service emails, waiting-list updates and relevant lesson availability communications. 

• GoCardless — Direct Debit payment processing. 

• Stripe — online card payments, including Private Hire. 

We share only information reasonably necessary for the relevant service. We may also disclose information to insurers, professional advisers, regulators, emergency services or safeguarding authorities when justified and lawful. Some service providers may process information outside the UK; where restricted international transfers occur, we use an applicable UK adequacy arrangement or other legally recognised safeguard as required. 

 

7. Security and How Long We Keep Information 

We use appropriate access controls, password-protected systems and secure storage. Information is available only to people who need it for authorised purposes. 

We keep personal information only for as long as needed for its purpose, taking account of legal, accounting, insurance, safeguarding and dispute-related requirements. Routine customer and financial records may commonly be kept for up to six years after the relevant relationship or transaction, where appropriate; this is not a universal maximum or a rule for every category. Safeguarding and incident records may require different retention periods and are assessed separately. When no longer needed, information is securely deleted or destroyed. 

 

8. Your Rights 

Depending on the circumstances, you may have the right to be informed; access your information; correct inaccuracies; request erasure; restrict or object to processing; request data portability; withdraw consent where processing relies on consent; and exercise rights relating to certain automated decisions. Some rights are subject to exemptions and legal conditions. 

To make a request or raise a privacy concern, email info@valeswimacademy.co.uk.

You also have the right to complain to the ICO at https://ico.org.uk/. 

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9. Website Cookies and Technical Information 

Our website and its service providers may use cookies or similar technologies needed for the site to work and, if enabled, optional features such as analytics. Some technical information, such as IP address, browser and access logs, may be processed to operate and secure the website. 

Non-essential cookies must be explained and, where required, used only after an appropriate choice or consent. The cookies and controls actually in use should be described in the website’s cookie information or preference controls. We do not claim to use or not use particular analytics or tracking tools without checking the live website configuration. 

 

10. Children and Privacy 

We aim to explain our use of swimmer information clearly to parents and guardians and, where appropriate, in language children can understand. A child’s ability to consent depends on the specific activity and applicable law; there is no general rule that every swimmer aged 13 or older can independently consent to all processing. 

 

11. Changes to This Notice 

We review this notice periodically. Updated versions will be made available on our website and, where appropriate, notified to customers.