Cookies Policy

Table of contents

What are cookies?

When you visit the Services, we may send one or more “cookies“ – small data files – to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Site. A cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience, but does not collect personal information about you. A persistent cookie remains on your computer after you close your browser so that it can be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser.

What cookies do we use?

Our Site uses the following types of cookies for the purposes set out below:

Category of cookies & Why we use these cookies

Strictly Necessary

  • These cookies are essential for websites on our services to perform their basic functions. These include those required to allow registered users to authenticate and perform account related functions, as well as to save the contents of virtual “carts” on the Service.

Functionality

  • These cookies are used to store preferences set by users such as account name, language, and location.

Security

  • We use these cookies to help identify and prevent potential security risks.

Analytics and Performance

  • Performance cookies collect information on how users interact with our websites, including what pages are visited most, as well as other analytical data. We use these details to improve how our websites function and to understand how users interact with them.

Customer Service

  • These cookies are used for services such as chat windows, Service usage, interaction, and monitoring, and help content delivery

Swim Buddies Cookies

Name& Function

_prpl_device_id_

  • Swim Buddies analytics.

_prpl_session_id

  • Swim Buddies analytics.

Token

  • Swim Buddies authentication

Third Party Applications

Third Party & Privacy Policy Link Description Beamer

  • We use Beamer to post feature updates and news announcements to our instructors.

Stripe

  • We use Stripe for payment processing and fraud detection

Google Analytics

  • We use Google Analytics to see where our users are visiting from and how they’re using the Service

How can I disable cookies?

You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Services and some features of the Service may not function properly. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

  • To provide our Services. For example, to set up and maintain your account, host your website, backup and restore your website, provide customer service, process payments and orders, and verify user information.
  • To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy and that will help them create and manage websites more efficiently or make our Services easier to use.
  • To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who have a particular plan with us or have been users for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many people purchased a lesson after receiving a marketing message), and understanding and forecasting user retention.
  • To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Propel and others, which may result in us, for example, declining a transaction or terminating Services.
  • To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
  • To customize the user experience. For example, to personalize your experience by serving you relevant notifications and recommending specific actions to enhance your learning experience, or improve your teaching ability, depending on how you’re using Propel.
  • To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Swim Buddies; texting you to verify your payment or to notify you of new lesson bookings; or calling you for customer service issues. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or

(2) The use is necessary for compliance with a legal obligation; or

(3) The use is necessary in order to protect your vital interests or those of another person; or

(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or

(5) You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on

Sharing Information

How We Share Information

We only share information that is absolutely necessary to complete lessons and provide our Service, with appropriate safeguards on your privacy.

  • Instructors: We may disclose information about you to instructors who need the information to provide Services to you. For example, instructors are provided with first name and last name of clients..
  • Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you or your site. This includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you); those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); and other third-party tools that help us manage operations.
  • To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Swim Buddies, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
  • Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
  • We have a policy that we do not sell our users’ data. We aren’t a data broker, we don’t sell your personal information to data brokers, and we don’t sell your information to other companies.

Information Shared Publicly

Information that you choose to make public will be disclosed publicly. That means information like your public profile, availability, reviews for instructors, and profile photos are all available to others. For example, if you post a review about an instructor, be aware that any content you write in the review will be made public (e.g., swimmer names, dates, situations).

How Long We Keep Information

We will retain your information for as long as your account is active or it is reasonably needed for the purposes set out in How and Why We Use Information unless you request that we remove your personal data as described below in Your Rights. We will only retain your personal data for so long as we reasonably need to use it for these purposes unless a longer retention period is required by law (for example for regulatory purposes). This may include keeping your personal data after you have deactivated your account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

Where We Store Information

When you use our services, your data may be sent to the United States and possibly other countries.

We and/or Third Parties we share your information with may transfer, store, use and process your information, including any Personal Information, to countries including the United States. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.

Your Rights

If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

  • Request access to your personal data;
  • Request correction or deletion of your personal data;
  • Object to our use and processing of your personal data;
  • Request that we limit our use and processing of your personal data; and
  • Request portability of your personal data.
  • You also have the right to make a complaint to a government supervisory authority.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it.

The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:

  • Identifiers (like your name, contact information, and device and online identifiers);
  • Commercial information (your billing information and purchase history, for example);
  • Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);
  • Internet or other electronic network activity information (such as your usage of our Services, like the actions you take as an administrator of a WordPress.com site);
  • Geolocation data (such as your location based on your IP address);
  • Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
  • Professional or employment-related information (for example, your company and team information if you are a Happy Tools user, or information you provide in a job application); and
  • Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect in the Information We Collect section above.

We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section.

If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:

  • Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
  • Request deletion of personal information we collect or maintain;
  • Opt out of any sale of personal information; and
  • Not receive discriminatory treatment for exercising your rights under the CCPA.

Contacting Us About These Rights

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, please scroll down to “How to Reach Us”.

When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

Typically, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, except in relation to withdrawing your consent, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Controllers

Swim Buddies Services are provided in Canada only. Swim Buddies is the company responsible for processing your personal data and thus is the controller for processing your personal information.

How to Reach Us

If you have any questions about our practices or this Privacy & Cookies Policy, please contact us at contactswimbuddies@gmail.com with “PRIVACY POLICY” in the subject line.

Our Policy on Children’s Privacy

Protecting the privacy of young children is especially important. Though lessons are suitable for most ages, the Services are not intended for children below 16. If you are under the age of 16, please do not submit any personal information through the Site.

We understand that participants in lessons may be under the age of 16. To assist your instructor with lesson planning, you may optionally provide a participant’s first name only after receiving the permission of the participant’s parent or legal guardian. The instructor may also collect information about progress or lesson plans. This data is only known to authorized Swim Buddies admins and the Instructor for the explicit purpose of enhancing a lesson and providing feedback, and it not used for promotional or marketing purposes.

If you do not wish a participants name to be stored, or permission was not granted, simply enter “n/a”, “undisclosed”, or similar, or leave the field blank where possible.

Links to Other Websites

This Privacy & Cookies Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Swim Buddies and as such we are not responsible for the content, accuracy, or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Your browsing and interaction on any other website, including those that have a link on our Site, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

Changes to Our Privacy & Cookies Policy

We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Platform or by sending an email to you. We will also update the “Last Updated” date at the top of this Privacy Policy. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email. Please refer back to this Privacy Policy on a regular basis.