Privacy Policy

Easy2Swim ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA) of South Africa, and where applicable, the General Data Protection Regulation (GDPR) for our European Union users.

This Privacy Policy explains how we collect, use, process, and protect your personal information when you visit our website at www.easy2swim.co.za or use our swimming instruction services.

1. Information Officer Details (POPIA Requirement)

2. Legal Basis for Processing Personal Information

We process your personal information based on the following legal grounds as required by POPIA:

• Consent: You have given explicit consent for processing
• Contract: Processing is necessary for the performance of our services
• Legal Obligation: Processing is required by South African law
• Legitimate Interest: Processing is necessary for our legitimate business interests
• Protection of Your Vital Interests: In cases of medical emergencies during swimming lessons

3. Personal Information We Collect

3.1 Information You Provide Directly

• Full name and surname
• Contact details (email address, phone number, physical address)
• Date of birth (for age-appropriate class placement)
• Medical information relevant to swimming safety
• Emergency contact information
• Payment and billing information
• Swimming ability and assessment records

3.2 Information Collected Automatically

• IP address and device information
• Browser type and version
• Pages visited and time spent on our website
• Referring website addresses
• Cookie data (see our Cookie Policy below)

3.3 Special Personal Information

In accordance with POPIA, we may collect special personal information (health data) only with your explicit consent and only as necessary for:

• Ensuring swimmer safety
• Appropriate class placement
• Emergency medical response

4. How We Use Your Information

We process your personal information for the following purposes:

• To provide swimming instruction services
• To assess swimming abilities and place students in appropriate classes
• To communicate about schedules, changes, and updates
• To process payments and maintain financial records
• To ensure safety and respond to emergencies
• To comply with legal and regulatory requirements
• To improve our services and website functionality
• To send marketing communications (only with your consent)

5. Sharing of Personal Information

We do not sell, rent, or lease your personal information to third parties. We may share your information only in the following circumstances:

• Service Providers: With trusted third parties who assist in operating our business (e.g., payment processors, email services)
• Legal Requirements: When required by law, court order, or government regulations
• Emergency Situations: With medical professionals in case of emergencies
• Business Transfers: In the event of a merger, acquisition, or sale of assets
• With Your Consent: When you have given us explicit permission to share

6. Your Rights Under POPIA

Under the Protection of Personal Information Act, you have the following rights:

To exercise any of these rights, please contact our Information Officer at info@easy2swim.co.za

7. Data Security Measures

We implement appropriate technical and organisational measures to protect your personal information against:

• Unauthorised access or disclosure
• Accidental loss or destruction
• Unlawful processing
• Damage or alteration

Our security measures include:

• Secure Socket Layer (SSL) encryption for data transmission
• Regular security assessments and updates
• Access controls and authentication procedures
• Staff training on data protection
• Secure physical storage of paper records

8. Data Retention

We retain your personal information only for as long as necessary to:

• Provide our services to you
• Comply with legal obligations (including tax and accounting requirements)
• Resolve disputes and enforce agreements
• Maintain safety and incident records as required by insurance

Specific retention periods:

• Customer records: 5 years after last service
• Financial records: 5 years (as per South African tax law)
• Medical/incident records: 3 years (or longer if involving minors)
• Marketing contacts: Until consent is withdrawn

9. Children's Privacy

As a swimming school, we provide services to children. We collect children's personal information only with parental or guardian consent. Parents/guardians have the right to:

• Review their child's personal information
• Request correction or deletion of their child's data
• Withdraw consent for processing
• Object to certain types of processing

10. Cookie Policy

Our website uses cookies to enhance user experience. Cookies are small text files stored on your device that help us:

• Remember your preferences
• Understand how you use our website
• Improve website functionality
• Provide relevant content

You can control cookies through your browser settings. Disabling cookies may affect website functionality.

11. Cross-Border Information Transfers

We primarily process data within South Africa. If we transfer personal information outside South Africa, we ensure appropriate safeguards are in place, including:

• Adequate data protection laws in the receiving country
• Appropriate contractual clauses
• Your explicit consent where required

12. Direct Marketing

In compliance with POPIA Section 69, we will only send you direct marketing communications if:

• You have given consent, or
• You are an existing customer and the marketing relates to similar services

All marketing communications will include an easy opt-out mechanism. You can unsubscribe at any time by:

• Clicking the unsubscribe link in emails
• Replying STOP to SMS messages
• Contacting us at info@easy2swim.co.za

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

• Posting a notice on our website
• Sending an email to registered users
• Updating the "Last Updated" date above

Continued use of our services after changes constitutes acceptance of the updated policy.

14. Complaints and Disputes

If you have concerns about how we handle your personal information:

1. Contact our Information Officer at info@easy2swim.co.za
2. We will investigate and respond within 10 business days
3. If unsatisfied, you may lodge a complaint with the Information Regulator