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Privacy statement
1. Who is responsible
The Swim Academy (a sole proprietorship of R. Nemeth, KvK 71117369, Gustav Mahlerlaan 24, 1082 MC Amsterdam) is responsible for the processing of your personal data described here. Questions about privacy: info@theswimacademy.nl or +31 6 43 45 25 24.
Our partner clubs (Clubsportive in Amsterdam Zuidas and Special Sports in Amstelveen) are themselves responsible for what they do with your data as a member of their club, such as access control at the entrance. Their own privacy statements apply to that.
2. What we use, why, and for how long
| What | Why | Legal basis | How long |
|---|---|---|---|
| Name, email, phone number, your account in the TSA app | Booking, planning your lessons, confirmations and reminders | Agreement | As long as you have an account, and up to 2 years after your last lesson |
| Bookings, memberships, payments, invoices | Payment and our administration | Agreement; legal obligation | 7 years (tax retention obligation) |
| Your level, goals and lesson notes | Giving lessons that fit you and tracking your progress | Agreement | Up to 2 years after your last lesson |
| Health information you choose to share (for example a condition, injury, pregnancy or fear of water) | Your safety and adapting your lessons | Your explicit permission | Until your membership ends, then deleted within 3 months. You can withdraw permission at any time. |
| Freeze requests | Assessing a freeze of your membership | Agreement | We only record the approved dates. We return or delete any supporting document once we've seen it. |
| Name and contact details passed to the partner club | Arranging the club access included in your membership | Agreement | The club keeps them according to its own privacy statement |
| Messages by WhatsApp, email and phone | Answering your questions and helping you | Agreement; legitimate interest | Up to 2 years after the last contact |
| Technique video | Analysing your technique in your lesson | Your permission | 3 months |
| Photos and video at our lessons | Our website, social media and ads. You can tell your coach you don't want to be filmed; we then keep you out of the picture or unrecognisable. | Legitimate interest (promoting our lessons); for publishing you clearly recognisable: your permission | As long as we use the material; until you withdraw your permission |
| Website measurement and ad measurement (see section 4) | Understanding how the website is used and which ads lead to bookings | Your permission via the cookie banner | Google Analytics: 14 months. Other tools: see the cookie table. |
| Outdoor swimming interest form (name, email, phone number if you give it, group preference) | Letting you know when the schedule is out | Your permission | Until the end of that outdoor season, at most 12 months |
| Withdrawal form (name, email, which agreement) | Handling your withdrawal and confirming receipt | Legal obligation | 7 years, with our administration |
| Job applications (CV, letter, messages) | Assessing your application | Steps at your request before an agreement | 4 weeks after the end of the procedure; 1 year if you allow us to keep it |
If you don't give us the details needed for a booking, we can't take your booking. Sharing health information is voluntary, but we need to know about anything that matters for your safety in the water.
3. Who receives your data
We only share data with parties that need it for the purposes above. Companies that work on our behalf (processors) may only use your data on our instructions.
- bsport (France): booking system and the TSA app; payments through its payment provider Stripe.
- Google: Workspace (email and files), and on the website, only with your permission, Google Analytics and Google Ads, loaded through Google Tag Manager.
- Microsoft Clarity: anonymous click and scroll heatmaps of the website, only with your permission.
- Meta / WhatsApp: messages with our team.
- Bluehost (Newfold Digital): hosting of our website, including the fonts, and sending the forms on our website by email.
- Google Fonts: the fonts of our website. When a page loads, your browser connects to Google, which receives your IP address.
- Partner clubs Clubsportive and Special Sports: to arrange your club access (see section 1).
- Our accountant, and authorities if the law requires it.
Some of these companies are based in the United States or may process data there. We only use them when there is a valid basis for such a transfer, such as the EU-US Data Privacy Framework or the European Commission's standard contractual clauses.
4. Website, cookies and ad measurement
When you first visit, the cookie banner asks for your choice. Without your permission, we only use what is needed for the website to work. You can change your choice at any time via "Cookie settings" at the bottom of every page.
| Name | From | Purpose | Duration | Permission |
|---|---|---|---|---|
| tsa-consent | TSA | Remembers your cookie choice | 12 months | Necessary |
| tsa-loc | TSA | Remembers the location you chose during this visit | Until you close the tab | Necessary |
| Booking widget storage | bsport | Makes the calendar and checkout work | Session / set by bsport | Necessary |
| _ga, _ga_* | Google Analytics | Counts visits and how the website is used | Up to 2 years | Statistics |
| _gcl_au and other Google Ads cookies | Google Ads | Measures whether an ad leads to a booking | Up to 90 days | Ad measurement |
| _clck, _clsk | Microsoft Clarity | Anonymous heatmaps of clicks and scrolling | Up to 1 year | Statistics |
Which ads lead to try-outs. To learn which ads and pages lead to paid try-outs, we look at two things side by side: the anonymous website event that someone picked a time slot (only if they gave permission for statistics or ad measurement), and the number of paid try-outs per location and time slot in our booking system. We only compare counts per time slot. We never send names, email addresses or phone numbers to Google or Microsoft. Our basis is our legitimate interest in spending our advertising budget responsibly.
Google Analytics does not store IP addresses. Clarity hides what you type into forms on the website.
5. Automated decisions
We don't make decisions about you based solely on automated processing.
6. Security
We protect your data with appropriate measures: access only for those who need it, two-step verification wherever our suppliers offer it, secure connections (https) and processing agreements with our suppliers. If something goes wrong anyway, we act in line with the law, including reporting to the Dutch Data Protection Authority and informing you where needed.
7. Your rights
You have the right to access, correct and delete your data, to restrict or object to its use, and to receive your data in a usable format. Where we use your data based on permission, you can withdraw that permission at any time; this doesn't affect what we did before.
Send your request to info@theswimacademy.nl. We respond within one month. We may ask you to confirm your identity, but we never ask for a copy of your passport or ID card.
Don't agree with how we handle your data? Let us know first, so we can try to solve it. You also have the right to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) via autoriteitpersoonsgegevens.nl.
8. Changes
We update this statement when our services or the tools we use change. The date at the top shows the current version. We inform you of important changes by email or in the app.