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Privacy Policy

SWIMMA LTD – PRIVACY POLICY

 

Last Updated: 16 August 2025

 

This Privacy Policy (the “Policy”) is issued by SWIMMA Ltd, a company incorporated and registered in England and Wales under company number 16396373, with its registered office at 142 Dawes Road, London (hereinafter referred to as “SWIMMA”, “we”, “our” or “us”).

 

SWIMMA Ltd is committed to ensuring that the collection, processing, use, disclosure, storage and retention of your personal data, including sensitive health data, is conducted in strict compliance with applicable data protection legislation, including but not limited to the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and any successor or supplementary legislation.

 

1. Data Controller

 

For the purposes of applicable data protection legislation, the data controller responsible for your personal data is:

 

SWIMMA Ltd Registered in England and Wales: Company Number

Registered Office: 142 Dawes Road, London

Email: team@swimma.net

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You have the right to lodge complaints with the supervisory authority:

Information Commissioner’s Office (ICO)

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom Telephone: 0303 123 1113 Website: https://ico.org.uk

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2. Categories of Personal Data Collected

SWIMMA Ltd collects and processes the following categories of information:

2.1 Account and Profile Information: name, date of birth, gender, contact details, account credentials, profile photographs. ​

2.2 Health and Fitness Data: swimming performance metrics (distance, pace, stroke type, stroke rate, calories burned, lap counts), biometric and physiological data (heart rate, VOâ‚‚ max, lactate threshold, recovery time), training logs, location metadata (GPS, pool identifiers), and any other data voluntarily uploaded or synced.

2.3 Device and Technical Data: device identifiers, operating system, browser type, IP addresses, cookies, and telemetry. ​

2.4 Third-Party Integration Data: data imported or exported to or from external services (including but not limited to Strava, Garmin, Whoop, or Runna), subject to your explicit authorisation. ​

2.5 Communications Data: correspondence with our support team, feedback, complaints, or survey responses.

 

3. Purposes of Processing

We process personal data for the following purposes:

  • Provision, maintenance and enhancement of the SWIMMA Service, including personalised swim training plans, feedback, and performance analytics.​

  • Account creation, management, authentication, and subscription billing.Synchronisation with wearable devices and third-party platforms.​

  • Compliance with legal obligations and enforcement of our contractual rights.Internal research, statistical analysis, and improvement of our platform (with health and biometric data anonymised or pseudonymised where possible).​

  • Direct marketing or promotional communications (only with your explicit consent).

 

4. Legal Bases for Processing

Processing activities are conducted on the following lawful bases:

  • Performance of a Contract – data necessary to provide you with the Service.​

  • Legal Obligation – data required to comply with applicable law.​

  • Consent – explicit consent required for processing of health, biometric or location data, and for direct marketing.​

  • Legitimate Interests – improving and securing the Service, preventing misuse, protecting intellectual property, and analysing aggregated trends, provided such interests do not override your rights.

 

5. Health Data and Medical Disclaimer

5.1 SWIMMA Ltd acknowledges that health and biometric data constitute “special category data” under the UK GDPR. Processing of such data shall be strictly subject to your explicit, informed consent.

5.2 Users are solely responsible for ensuring that they are medically fit to undertake any swimming or exercise programmes derived from the Service. SWIMMA Ltd does not provide medical advice, diagnosis, or treatment, and you should consult a qualified healthcare professional prior to commencing or modifying any exercise regime.

5.3 In no circumstances shall SWIMMA Ltd be liable for injury, illness, exacerbation of medical conditions, or death arising from reliance on information provided by the Service.

 

6. Data Retention

Data shall be retained only as long as necessary to fulfil the purposes specified herein, unless a longer retention period is required by law. Health and biometric data shall be permanently deleted or anonymised upon termination of your account, unless retention is required by law or to defend legal claims.

 

7. Data Disclosure and Transfers

7.1 SWIMMA Ltd shall not sell, rent, or commercially exploit your personal or health data to data brokers or advertisers.

7.2 Data may be disclosed to:Service providers (hosting, storage, analytics, payment, communications) bound by contractual confidentiality and data protection obligations.Third-party integrations, strictly pursuant to your explicit authorisation.Regulatory authorities or courts, where legally mandated.

7.3 Where data is transferred outside the UK, SWIMMA Ltd shall ensure adequacy mechanisms (UK adequacy regulations, International Data Transfer Agreements, or Standard Contractual Clauses) are in place.

 

8. Security

We employ industry-standard and state-of-the-art measures, including encryption in transit and at rest, pseudonymisation, strict access controls, penetration testing, intrusion detection, and regular third-party audits to protect personal and health data against loss, theft, alteration, or unauthorised disclosure.

 

9. User Rights

Subject to applicable law, you have the right to:

  • Access your personal data and obtain a copy.Rectify inaccuracies.​

  • Withdraw consent at any time (without affecting lawfulness of prior processing).Request deletion (“right to be forgotten”).​

  • Restrict or object to processing.​

  • Port your data to another provider in a machine-readable format.​

  • Lodge a complaint with the ICO.

 

10. Public Sharing, Aggregation and AI Use

10.1 SWIMMA Ltd shall not publish or disclose your health or activity data in public “heatmaps” or aggregated displays in a manner that could enable re-identification of individuals or reveal sensitive locations. 10.2 By default, privacy settings shall be configured to the most protective levels. 10.3 SWIMMA Ltd prohibits the use of personal or health data in artificial intelligence or machine learning model training, absent explicit, opt-in consent.

 

11. Children’s Data

The Service is not intended for users under the age of 16. We do not knowingly collect or process personal data of individuals under 16 without verifiable parental consent.

 

12. Changes to this Policy

SWIMMA Ltd reserves the right to amend this Policy at any time. Updated versions will be posted within the Service with the “Last Updated” date amended accordingly.

 

13. Contact Information

Questions, requests or complaints regarding this Policy should be addressed to:Data Protection OfficerSWIMMA LtdEmail: team@swimma.netTelephone: +447801287165

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