Privacy policy
Born2Swim Privacy Policy
- Introduction
‘Born2Swim’ is the trading name of Swim Perth Pty Ltd. The Born2Swim website is owned and operated by Swim Perth Pty Ltd ABN 32 609 618 966. In this policy, all references to “we” or “us” refer to Swim Perth Pty Ltd.
We value the privacy of our customers so we have voluntarily adopted the Australian Privacy Principles (APPs) and the Notifiable Data Breach Scheme contained in the Privacy Act 1988 (Cth) (Privacy Act). This legislation governs the way in which we collect, use, disclose, store, secure and dispose of your personal information and how we notify you in circumstances where your information is lost or accessed.
This policy outlines how we manage and safeguard the personal information which we receive in connection with our business, and it should be read in conjunction with our membership terms. Access to our website and our services is conditional on your acceptance of this policy and you agree that your use of our website and services implies that you consent to this policy.
- Personal Information
‘Personal information’ is any information or opinion about an identified individual or a reasonably identifiable individual. In general terms, it is any information that can be used to personally identify you.
- What personal information do we collect?
We collect information about you in order to provide you with our services. You may choose whether to provide us with this information, however your choices may affect our ability to offer you all or part of our services. We do not wish to collect personal information which is ‘sensitive’ or ‘solicited’, as defined under the Privacy Act.
Personal information we collect includes:
(a) Enrolment information: when you register with our website or enrol your child for lessons with us, you provide personal information which may include your name, email address, contact information and any other information which you may provide us.
(b) Payment Information: in order to facilitate payments and to receive invoices and reimbursements (where applicable) you may provide us with payment information which may include bank details, credit card details or other billing information.
(c) Communication Information: when you communicate with us via telephone, email, SMS or online we will collect your contact information and any other information you choose to provide to us.
(d) Photographic Information: when we take your photograph or the photograph of others in connection with the provision of our services to you we will collect personal information about you or others which may include your likeness and appearance, biometric information, and information relating to your age, gender, religious beliefs and racial or ethnic origin. Your photographic information may be considered ‘sensitive information’, but we will only collect your photographic information with your consent. If you indicate that you do not wish your photograph to be taken, we will comply with that request.
(e) Cookie Information: we may use cookies and similar tracking devices on our website in where necessary to maintain and improve our services to you. Further information on cookie and data collection is contained in the “Website Usage” paragraph below. You can disable cookies on your browser.
(f) Third-party plugin Information: We may integrate a third-party plugin into our website. The use of third-party plugins may result in data collection by both us and the relevant third party. We do not control the information you share with third parties via these plugins. You should refer to the third party’s privacy statement to understand their data handling practices
- How we collect and store personal information
We collect and store your personal information directly through your use of our website and services via:
(a) our enrolment form;
(b) Ezidebit direct debit form (if applicable to you);
(c) subscribing to our email newsletter; and
(c) any verbal or written communications with us.
It is your choice whether or not to provide the personal information requested by us for the provision of swimming lessons. However, if the information requested is not provided, we may be unable to enrol your child or continue to provide lessons.
We store personal information using:
(a) business software;
(b) cloud-based software storage that we may use from time to time; and
(c) paper files.
Paper files are secured in a locked cabinet, only accessible to the owners and certain authorised staff. Unfortunately, no electronic data transmission can be guaranteed as totally secure. Therefore we cannot warrant the security of any information transmitted to us or from our website. Users of our website do so at their own risk.
If we detect misuse, loss or unauthorised access, modification or disclosure to your personal information, we will comply with all relevant provisions of the Notifiable Data Breach Scheme.
- Retention
We retain your personal information for as long as necessary to provide services to you once you have enrolled with us. When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. If you ask us not to retain your personal information after you cancel your membership, we will delete it.
- Why do we collect, hold, use and disclose personal information?
The primary purpose for collecting Personal Information about you is to perform our business activities. In general, we may collect, hold, use and disclose your personal information for the following purposes:
(a) to provide services to you;
(b) to communicate with you via email and / or phone;
(c) to inform you about our services an, offers which may be of interest to you;
(d) to provide you with news, information or advice about our existing and new services;
(e) to manage and enhance our services; and
(f) as required or permitted by law (including the Privacy Act).
We will only disclose your personal information, with your consent, to the extent required to provide the services as requested or authorised.
Where your personal information is not ‘sensitive information’ we may also use your personal information for secondary purposes closely related to the primary purposes outlined above, in circumstances where you would reasonably expect such use or disclosure.
We will never rent or sell your personal information.
- Who do we disclose your personal information to?
We may disclose your Personal Information to our employees, contractors or external service providers for the operation of our website or our business and providing products and services to you, including web hosting providers, IT systems administrators, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors, such as accountants, solicitors, business advisors and consultants; and anyone else as required by any law, including the Privacy Act.
- Accessing and correcting your personal information
You are entitled to access the personal information we hold about you and you may request that we update or correct any information we hold. If you wish to access your personal information, please contact us at info@born2swim.com.au. We will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your personal information. In order to protect your personal information, we may require you to identify yourself before releasing the requested information.
- Direct marketing
Where we use your personal information to send you marketing and promotional information you will be provided with the opportunity to opt-out of receiving such information in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). Unless you exercise your right to opt-out of such communications, you will be taken to have consented to receive similar information and communications in the future. We do not provide your personal information to other organisations for the purposes of direct marketing.
- How can you contact us?
Please email us at: info@born2swim.com.au or write to us at 2/11 Sphinx Way Bibra Lake WA 6163
You may also contact the Office of the Australian Information Commissioner at www.oaic.gov.au/privacy.
- Links
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third party website.
- Further Information
Further information about individuals' rights under the Privacy Act can be obtained from the Office of the Australian Information Commission Enquiry Line on 1300 363 992.
Copyright. Swim Perth Pty Ltd (Dec 2019)