Swim Manager is a cloud-based platform that enables swimming clubs to manage their members, including their personal details, meet entries, invoices and results (the “Service”).
A user may be either a Club, which has entered into an agreement with Swim Manager (“Club”), or a Club’s members (“Members”) or the parent of (or person holding parental responsibility for) a Member (“Parent”). Within this policy we collectively refer to Members and Parents as End Users and to the Club, and End Users as “you” or “your”).
End Users who wish to use this service may be asked to provide Swim Manager, either directly or via their Club administrator, with information including Personal Information and Sensitive Information (“data”)
Please read this policy in order to understand our practices regarding your data and how we will treat it.
For the purposes of EU data protection law, the Data Controller is the Club who makes the Swim Manager service available to its End Users and permits those End Users to access and use the Swim Manager Service, and we are the Data Processor.
Information We Collect
The first type of information we collect is non-identifiable and anonymous information (“Non-Personal Information”). We are not aware of the identity of the End User from which we have collected Non-Personal Information. Non-Personal Information is any unconcealed information which is available to us while End Users are using the Service. Non-personal Information which is being gathered consists of technical information which may include, your Internet Protocol (IP) address used to connect to the Internet, your uniform resource locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, time zone setting, the member’s ‘click-stream’ on the website, the period of time you visited the website and methods used to browse away from a page.
Information You Provide To Us
The second type of data is individually identifiable information (“Personal Information”). This information may identify an individual. It may be of a private and/or sensitive nature.
Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by a Club, End User or the Club’s administrator or through your use of the Swim Manager application. This may include your name (first and last), nickname, ASA number, phone number(s), the date you joined or left the Club, address, country, city, postcode, date of birth and gender.
We will never sell your Personal Information to third parties. (for more information see the Section titled: “Sharing Data gathered through Swim Manager with third parties”).
You do not have any legal obligation to provide any information to Swim Manager, however we require certain information in order to provide the Services. If you choose not to provide us with certain information we may not be able to provide you with the Services. Login credentials (email address), dates of birth and ASA numbers are required to have the Swim Manager system work properly. We may keep such Personal Information in a database. This information will be owned and controlled by the Data Controller.
Swim Manager may also collect the email addresses of people who communicate with Swim Manager via email or via messenger services or create accounts and login credentials.
If you register for a trial account on Swim Manager’s general web site, Swim Manager will collect your name, club, phone number and email address you provided. Swim Manager may use this information to offer Swim Manager’s services and support.
Swim Manager may not be aware of the nature of the information collected through the Service. Such information may include Personal Information about an individual’s racial or ethnic origin, physical or mental health or condition or any other data considered as sensitive under applicable law (“Sensitive Information “).
How We Collect Information On Members
There are two main methods we use:
We collect Non-Personal Information through your use of our Service. In other words, when you are using the Service we are aware of it and may gather, collect and record the information relating to such usage, either independently or through the help of third-party services.
We collect Personal Information which you provide us voluntarily. We collect Personal Information required to operate the Service when you or the Club’s administrator registers and opens an account. In addition, we collect your Personal Information, which may be considered as personally identifiable, whether you provide us such information by entering it manually or via a Club. We also collect Personal Information entered voluntarily by a Club administrator.
Why We Collect This Information
We will use this Data only to provide the Services including:
- carrying out our obligations arising from any contracts entered into between you and Swim Manager and/or any contracts entered into between a Club and Swim Manager and to provide you with the information, products and Services that you request from Swim Manager;
- administering your account with Swim Manager;
- verifying and carrying out financial transactions in relation to payments you make in connection with the Service;
- notifying you about changes to our Service;
- contacting you for the purpose of providing you with technical assistance and other related information about the Service;
- replying to your queries, troubleshooting problems, detect and protect against error, fraud or other criminal activity;
We may combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Sharing Data Gathered Through Swim Manager With Third Parties
We may share your data in a limited fashion with selected third parties. Our selected third parties may include:
- business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They may assist us in providing the Services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analysing data, providing IT and other support services or in other tasks, from time to time. These third parties will only use your information to the extent necessary to perform their functions;
- analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy (this will not identify you as an individual) and data processors who process your personal data on our behalf and in accordance with our instructions and applicable data protection law.
Additionally, your Club may grant third party access to your data by enabling the Swim Manager integration for that third party. Swim Manager is not responsible for the privacy practices employed by any third party given access by you or your Club to your data.
We may disclose your personal information to a third party if all or substantially all of Swim Manager’s assets are acquired by a third party.
Modification or Deletion of Personal Information Gathered Through Swim Manager
Data stored within Swim Manager is inherently dynamic and may contain errors and omissions. If for any reason you wish to modify your Personal Information you may do so through Swim Manager by editing the relevant data that needs to be modified. Please note that certain data cannot be edited without the Data Controller’s consent such as data related to your membership of the Club. In order to delete your Personal Information completely please contact the Data Controller.
Swim Manager is a mere processor of data and is not the data owner or Data Controller. As such Swim Manager may not be able to delete your information without the Data Controller’s authorization.
Members may have a legal right under certain applicable laws (for instance if the Member is an E.U. citizen) to receive, rectify, erase, and restrict Personal Information about them that is held by us, to object to processing and, if processing occurs based on consent, to withdraw their consent. Members may also have the right to withdraw consent to processing for statistical and research purposes.
If, for any reason, an End User wishes to modify, delete or retrieve his/her Personal Information, s/he may do so by contacting the applicable Data Controller (e.g. Swim Manager’s Customer, your Club). The Data Controller shall perform the necessary process to identify the End User as an End User who has the right to retrieve the specific information and then make the appropriate change/retrieval.
For any request or question regarding deletion or amendment of End User data, please contact us at email@example.com.
Swim Manager will retain data it processes on behalf of its Clubs only for as long as required to provide the Service to its Clubs and as necessary to comply with its legal obligations, resolve disputes and enforce its agreements. The data in Swim Manager is backed up for system continuity purposes and each backup file may be stored for up to 90 days.
After a request from the Data Controller to delete any data or a deletion of data from the Swim Manager interface, the data will either be permanently deleted or marked as deleted. When an organization account is closed the account and all its data will be permanently deleted after 60 days of closure. Upon deleting a Member, Swim Manager will permanently delete the Member data after 30 days.
Swim Manager collects and retains metadata and statistical information concerning the use of the Service which are not subject to the deletion procedures in this policy and may be retained by Swim Manager for no more than required to conduct its business. Some data may be retained also on our third-party service providers’ servers in accordance with their retention policies. You will not be identifiable from this retained metadata or statistical information.
The Club may retain Personal Information and other Data about an End User which the Data Controller owns and the End User may have no access to. If you have any questions about the right of the Club to retain and process your Personal Information you should raise this directly with the Club.
Cookies & Local Storage
When you access or use the Service, we may use industry-wide technologies such as “cookies” or similar technologies, which stores certain information on your computer (“Local Storage”) and which will allow us to enable automatic activation of certain features, and make your Service experience much more convenient and effortless. The cookies used by the Service are created per session and do not include any information about you, other than your session key (usually removed as your session ends but sometimes can be kept in your device for no more than 6 months) and the ability to login again quickly. Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience with the Service may be limited.
- Strictly necessary cookies. These are cookies that are required for the operation of our Site and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our Service.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us for our legitimate interests of improving the way our Service works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our Site. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).
The effect of disabling cookies depends on which cookies you disable but, in general, the Service may not operate properly if cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on our sites. If you disable all cookies, you will be unable to use our Services.
Security and Storage of Information
We take a great care in implementing, enforcing and maintaining the security of the Service, and our Users’ Personal Information. Swim Manager implements, enforces and maintains security policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of personal data and monitor compliance of such policies on an ongoing basis.
The Personal Information is hosted on servers which provide advanced security features and are compliant with ISO 27001 standard, among other certifications. All Personal Information is stored with logical separation from information of other customers. However, we do not guarantee that unauthorized access will never occur.
Swim Manager shall act in accordance with its policies to promptly notify Clubs in the event that we discover that any personal data processed by Swim Manager on behalf of Club is lost, stolen, or where there has been any unauthorized access to it subject to applicable law and instructions from any agency or authority. Furthermore, Swim Manager undertakes to co-operate with the Club in investigating and remedying any such security breach. If any security breach involves Personal Information, Swim Manager shall promptly take remedial measures, including without limitation, reasonable measures to restore the security of the Personal Information and limit unauthorized or illegal dissemination of the Personal Information or any part thereof.
E.U. citizens have the right to lodge a complaint with a supervisory authority (Data Protection Authority in your jurisdiction) in case of a breach of any E.U. data protection and privacy regulations. If the supervisory authority fails to deal with a complaint or inform you within the time frame set under applicable law, you have the right to an effective judicial remedy.
We do not knowingly collect or solicit information or data directly from children under the age of 16 or knowingly allow children under the age of 16 to directly register for the Swim Manager Service. If you are under 16, do not register or attempt to register for the Swim Manager Service or send any information about yourself to us. If we learn that we have collected or have been sent Personal Information or Personal Data from a child under the age of 16, we reserve the right to delete that Personal Information or Personal Data as soon as reasonably practicable without any liability to Swim Manager from any End User. If you believe that we might have collected or been sent information from a minor under the age of 16, please contact us at: firstname.lastname@example.org as soon as possible.
In order to provide the Service to Clubs we do store data about children under the age of 16 who are Members of the Club. In these cases it is the Club’s responsibility, as Data Controller, to ensure that they have obtained the necessary parental consent for processing this data. Swim Manager does provide mechanisms for Clubs to store data about parents separately from data relating to Members, and we strongly recommend that Clubs use these features to only store data about children that is necessary for their membership of the Club. Parents may use all of the features of the Service to access, modify and delete any data relating to children for whom they are responsible, as outlined in this Policy.
Questions, Contact Information and Complaints