This page is reviewed regularly. We reserve the right to amend this policy without notice.
This page was updated on 18/09/2020
Who We Are
Swimsmooth Ireland (Swimsmooth.ie) (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations and explains how, why and when we process your personal data.
Swimsmooth.ie is located in Beechville, Abbeyaun, Kilcullen, Co. Kildare and we are a company registered in Ireland under company number ??. The Proprietor is Maxine Strain who can be contacted, in writing at Beechville, Abbeyaun, Kilcullen, Co. Kildare and via email on firstname.lastname@example.org.
Information That We Collect
K-Leisure processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect from you is:
• Date of Birth
• Personal Email
• Postal Address
• Emergency Contact Number
• Mobile Telephone Number
• Special Category Data (i.e. health/medical information if applicable)
• Bank Details if applicable
We collect information in the below ways: –
• Online membership form
• Membership forms
• Activity Assessment forms
How We Use Your Personal Data (Legal Basis for Processing)
Swimsmooth.ie or Swimsmooth Ireland takes your privacy very seriously and we will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.
The purposes and reasons for processing your personal data are detailed below: –
• We collect your personal data in the performance of a contract to provide you with our service
• We collect and store your personal data as part of our legal obligation for legitimate business needs
• We will occasionally send you marketing/activity enrolment information where we have assessed that it is beneficial to you as a customer. Such information will be non-intrusive and is processed on the grounds of legitimate interests and informing you about updates to our services.
You have the right to access any personal information that K-Leisure processes about you and to request information about: –
• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed if applicable
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request the erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we will ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure. All data access requests must be submitted in writing or via email to the company Data Protection Officer. All data access requests must be specific in nature (time and date, location, information that would allow the DPO to identify the requestor from CCTV footage if requesting CCTV footage). If a request is not specific enough to identify the requestor then the access request will be rejected without prejudice and the requestor is free to resubmit a more specific request.
Sharing and Disclosing Your Personal Information
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. K Leisure uses a third-party to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with our instructions and they do not share your data with any other group. They comply fully with this privacy notice, the data protection laws, and any other appropriate confidentiality and security measures.
1. Point of Sale/Membership database system provider – Legendware
2. Direct Debit processing, Direct Marketing, Membership data verification and cleansing – Legend Leisure Services
3. Card Payments – Stripe (Online payments through the Wix Booking system).
4. Banking Services – Bank of Ireland
We use Wix Bookings for all of our membership management and bulk SMS and email communications. They act in the capacity of a processor on our behalf. The information we provide them is all the information collected on our membership forms, and all subsequent activity a member or guest has with Swimsmooth Ireland (Membership card logs, point of sale payments, bookings,
At Swimsmooth Ireland we take your privacy seriously and take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures in place, including: –
• Restricted access
• IT authentication
Transfers outside the EU
Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data. K-Leisure does not transfer or store any personal data outside the EU.
Consequences of Not Providing Your Data [if relying on statutory/contractual requirement basis]
You are not obligated to provide your personal information to Swimsmooth Ireland, however, as this information is required for us to provide you with our services, we will not be able to offer some/all our services without it.
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
We use the legitimate interests’ legal basis for processing the following:
Date – Purpose
Name – Identification for access
Emergency contact number – Safety
DOB – Membership category and or access point
Facial Image – Identification & access
Bank Details – Process payment for contract
Medical Information – Safety
Postal Address – Identification for access
What Are Cookies?
Disabling Cookies: You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.
The Cookies We Set:
In order to provide you with a great experience on this site, we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.
Third Party Cookies:
Hopefully, that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.
However, if you are still looking for more information you can contact us through one of our preferred contact methods.
How Long We Keep Your Data
Swimsmooth Ireland only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under IRL corporate law to keep your basic Membership payment record for a minimum of 6 years after which time it will be destroyed. Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
We retain all personal data collected for 36 months after the last date the data was accessed or used. Once the retention period expires your digital data will be redacted and no longer accessible
to staff. Physical copies of personal data will be destroyed in accordance with our data destruction procedure.
Special Categories Data
Owing to the products, services or treatments that we offer, Swimsmooth Ireland sometimes needs to process sensitive personal information (known as special category data) about you, to provide services relating to exercise or activity permission. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.
Where we rely on your consent for processing special category data, we will obtain your explicit consent through a signature. You can modify or withdraw consent at any time, which we will act on immediately unless there is a legitimate or legal reason for not doing so. If you consent to us collecting and using your health/medical for the purposes stated above, please contact us for relevant screening form.
Occasionally, Swimsmooth Ireland would like to contact you with offers, discounts, products, and services that we provide. If you consent to us using your contact details for this purpose, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options provided with each communication.
From time to time Swimsmooth Ireland will send information relating to operation changes or send updates relating to bookings a person has made. This category of communication is not deemed marketing, it is deemed operational, and a persons marketing consent will be omitted.
Swimsmooth Ireland occasionally send you information regarding offers, discounts, products and services by [email/SMS/) that have been identified as being beneficial to our customers and in our interests. Such information will be relevant to you as a customer and is non-intrusive and you will always have the option to opt-out/unsubscribe at any time. If you would prefer not to receive the above-mentioned marketing and offers:
• Unsubscribe from emails via the unsubscribe link at the bottom of all emails sent to you
• Email email@example.com and we will change your preferences.