This privacy policy is in two parts and is dated: May 2018.

Part 1: Deals with the European Union’s General Data Protection Regulations (GDPR), and its requirements regarding the collection and use of your personal data by Swim for Tri. This is set out in more detail below.

Part 2: This part sets out the practices ‘SFT’ follows in order to respect the privacy of all visitors to this website relating to the information we collect from this website

Part 1: GDPR The main trading address and registered office of Swim For Tri is: Swim For Tri, 144 Brettenham Road, London, E17 5BA United Kingdom Tel: 0207 247 2998

Registered in England.

Our Data Protection Officer can be contacted at: bookings@swimfortri.com What are your rights? If at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted, if you so wish. If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Office, using the email address above, who will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal data in accordance with the requirements of GDPR, then you are within your rights to lodge a complaint with the Information Commissioner’s Office (ICO). Unless otherwise agreed with you, we will only collect basic personal data about you, which does not include any ‘sensitive personal data’. This basic personal information will include: your name, work address, email address and job title.

The full list of your rights under GDPR is shown below:
The right to access the personal data we hold on you
The right to correct and update the personal data we hold on you
The right to have your personal data erased
The right to object to processing of your personal data
The right to data portability
The right to withdraw your consent to the processing at any time for any processing of personal data to which consent was sought.
The right to object to the processing of personal data where applicable
The right to lodge a complaint with the Information Commissioner’s Office. You can email them via: https://ico.org.uk/global/contact-us/email/, call them on 0303 123 1113, or write to them at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Data Collection

We need to know basic personal data, including: your name, work address, email address and job title, in order to provide you with our services, and to claim our right to be paid in return for our services, under our standard terms of business if we are contracted to work for your company. If you do not provide this information then we will be unable to provide the services you have requested. We will not collect any personal data from you that we do not need in order to provide and oversee the services we have agreed to provide you with.

Use of Data

All the personal data we hold about you will be processed by our staff. No third parties will have access to your personal data unless there is a legal obligation for us to provide them with this. We have set out below the legal bases for ‘SFT’ to process your data. Our authorised marketing agency has access to the data for the purposes of approved and compliant marketing activities only, as instructed by ‘SFT’, including the sending of marketing e-mails. They too are covered by the requirements of GDPR and may not use or share this data with any other party. We may also process your personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with providing you with services. We will also communicate with you information about other services we can offer you and update you about our activities. Where your information is used other than in accordance with one of these uses, we will first obtain your consent to that use. We take all reasonable steps to ensure that your personal data is processed securely.

How long do we keep data?

Typically we keep your personal data for a minimum of 6 years, after which time it will be destroyed if it is no longer required for the lawful purpose(s) for which it was obtained. If you consent to marketing, any information we use for this purpose will be kept with us until you notify us that you no longer wish to receive this information.

Sharing your personal data

Your personal data will only be shared with third parties including other data controllers where it is necessary for the performance of the data controllers’ tasks or where you first give us your prior consent. It is likely that we will need to share your data with: members of staff in ‘SFT’ other than our head of data privacy, our agents, suppliers and contractors. For example, we may ask a supplier to send out newsletters on our behalf, or to maintain our database software, or to provide us with administration, IT and other related services; Any personal data transferred to countries or territories outside the European Union will only be placed on systems complying with measures giving equivalent protection of personal rights, either through international agreements or contracts approved by the European Union.

Part 2 – Our Privacy Practices At ‘SFT’

We use fair information practices that are designed to protect your privacy. If you have questions or you do not feel that your concerns have been addressed in our privacy statement, or you just want to talk with us, please feel free to contact us by email at: bookings@swimfortri.com

Data Collection

We collect information that is voluntarily provided by visitors to this Site. The data that ‘SFT’ receives from visitors to this site includes: name, title, address, email address and telephone number, and any other information provided by visitors in email messages and attachments. Typically, this data is collected in order to assist visitors to: receive information about ‘SFT’ and the services we offer submit CVs or work history information contact us for further information.

It is our policy to limit the information collected to only the minimum information required to complete a site visitor’s request. It is ‘SFT’’s intention to not seek any sensitive information through our website, unless legally required for recruiting purposes. Sensitive information is defined as including data relating to race or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual life, or criminal record.

Use of User

Data User Data obtained by this website is used for ‘SFT’ internal business purposes and in connection with a visitor’s request. This data is not shared with others for unrelated purposes unless stated in this Privacy Policy or otherwise communicated to the visitor to the website. ‘SFT’ makes every practical effort to avoid excessive or irrelevant collection of data. If a visitor believes the website has collected excessive information, please contact us at bookings@swimfortri.com. Except for instances where visitors explicitly choose to receive specific ‘ABc’ marketing or other informational materials, ‘SFT’ will not use personal data collected from our Website to distribute marketing or informational materials. Third Parties It is ‘SFT’ policy only to disclose User Data to third parties under the following circumstances: when explicitly requested by the visitor when required to deliver publications or reference materials requested by the visitor when required to facilitate conferences or events hosted by a third party when required to meet any other request of a visitor. Categories of third parties that ‘SFT’ may share personally identifiable information with include National, Regional and local government entities. This Site does not collect or compile personally identifying information for the dissemination of or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties. Use of Cookies A cookie is a tiny element of data that a website can send to the computer browser of a visitor, so that this computer will be recognised by the site on their return. Cookies allow our web server to recognise a computer on connection to the Site, which in turn allows the server to make downloading of pages faster than on first viewing. In addition, cookies may also be used by us to establish statistics about the use of the Site by Internet users, by gathering and analysing data such as: most visited pages, time spent by users on each page, site performance, etc. By collecting and using such data our aim is to improve the quality of the Site. The data collected by our servers and/or through cookies that may be placed on your computer will not be kept for longer than is necessary to fulfil the purposes mentioned above. In any event, such information may not be kept for longer than one year. Navigation data about site viewers is automatically collected by our servers. If you do not wish to have this navigation data collected, we recommend that you do not use the Site. A visitor can also set their browser to block the recording of cookies on their hard drive to minimise the amount of data that may be collected about your navigating on the Site. The browser on a computer can be set to notify the user when a cookie is being recorded on their computer’s hard drive. Most browsers can also be set to keep cookies from being recorded on their computer. However, for optimal use of the Site, we recommend that visitors do not block the recording of cookies on their computer. ‘SFT’’s servers and computer systems are protected from outside intrusions. As a result, all data that may be collected about Site viewers through the use of cookies will be protected from unauthorised access. Cookies used on the Site are only active for the duration of the visit. Cookies used on this site are not stored on a visitor’s computer once you have closed your web browser. Information generated by the use of cookies may be compiled into an aggregate form so that no individual can be identified. We may at some stage use cookies to identify users when they visit the Site to use personalised services. In such circumstances these cookies may be kept on the hard drive of their computer following closure of the web browser. Cookies used in connection with such services enable us to build up a profile of our users and to develop personalised versions of the Site. For more information about cookies, please see the Information Commissioner’s website home page or the Interactive Advertising Bureau. A visitor may choose to not receive a cookie file by enabling his/her web browser to refuse cookies. The procedure for refusal of cookies may vary for different software products. Please check with your internet browser software help service or your software supplier if you wish to refuse cookies. Transfer of User Data outside the User Jurisdiction The Internet is a global environment. In order to provide a Site that works well, we may need to transfer User Data to locations outside the jurisdiction in which a visitor is viewing the Site (the User Jurisdiction) and process User Data outside the User Jurisdiction. If the User Jurisdiction is within the European Economic Area (the EEA) please note that such transfers and processing of personal data may be in locations outside the EEA. Any data sent or uploaded by users may be accessible in jurisdictions outside the User Jurisdiction (including outside the EEA). The level of data protection offered in such jurisdictions may be less than that offered within the User Jurisdiction or (as the case may be) within the EEA. User Data may be controlled and processed by our office. The location of our office may change from time to time and ‘SFT’ may acquire offices in any number of countries or territories at any time, any one or more of which may act as controllers of and/or process personal information of visitors. By continuing to use the Site and by providing any personal data (including sensitive personal data) to us via the Site or email addresses provided on the Site, visitors are consenting to such transfers, provided that they are in accordance with the purposes set out above and elsewhere in the Legal Notice and Privacy Policy. Please do not send us any personal data if you do not consent to the transfer of this information to locations outside the User Jurisdiction, including, if applicable, outside the EEA.

Third-party Links

There are several places throughout this Site that may link to other Websites that do not operate under ABc’s privacy practices. When visitors link to other Websites, SFT privacy practices no longer apply. We encourage visitors to review each site’s privacy policy before disclosing any personally identifiable information. Choices As a policy, visitors are not required to register to gain access to this Site. Personally identifiable information provided to ABc through this Site is provided voluntarily by visitors. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate Website area or in communications to our visitors; or a visitor may contact us at: bookings@swimfortri.com Access Each visitor has the right of access to personal data they have submitted through this Site. User updates of information should be handled by going back through the registration process.

Security

All members of staff of SFT are instructed to follow a company-wide security policy. Only authorised personnel are provided access to personally-identifiable information and these employees are required to agree to ensure confidentiality of this information. Modifications ‘SFT’ reserves the right to modify or amend this statement at any time. The effective date will be displayed at the beginning of this statement. To keep visitors informed, SFT will notify users of material changes to our Privacy Statement by prominently identifying a link on our website home page to the updated Privacy Policy for a period of not less than two weeks.

Consent

By continuing to use the Site and by providing any personal data (including sensitive personal data) to us via the Site or email addresses provided on the Site, visitors are consenting to our use of your personal data as set out in this Privacy Policy. Please do not send us any personal data if you do not want that information to be used by us in this manner.

Copyright

All documents, programmes, publications, designs, products, processes, software, technology, information, and ideas (Content) provided by or described in this Site are the property of SFT and/or its affiliates or suppliers and are protected by U.K. and international copyright laws and other intellectual property laws, unless stated otherwise. The Content is provided to users of this Site for informational purposes only. Except as expressly permitted below or by applicable law, users may not copy (except to the extent required in order to use the site in accordance with the Legal Notice), store in any medium (including in any other website), distribute, transmit, re-transmit, broadcast, modify, or otherwise make available or communicate to the public any part of the Site or systematically extract material from the Site or any document available through it or in any other way exploit commercially all or any part of the Site or any document available through it without our prior written permission. Users may print or save one copy of any page of the Site and documents available through it (other than documents provided by third parties) for their own personal use.

Cookie Legislation

What is a cookie? Cookies are small text files that are placed on your computer by websites that you visit. They are used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. What does a cookie do? A cookie stores information on your computer or mobile device, which is sent back to that website each time you visit. Sometimes this information is essential to access a website’s functions, for example, if you need to register for a seminar or apply for jobs, a cookie will allow the website to recognise your log-in details. Cookies can also be used to build a profile of your activity on a website: which pages you visit, how long you spend on each page, etc. A website may then use this information to tailor the pages that you see when you visit the site in the future. Our cookie policy We understand you need to reach the most relevant information quickly and easily. So, our main aim of using cookies is to provide you with the most optimised ‘user experience’ possible. We use cookies to help you navigate the website efficiently and perform certain functions. Our website analytics tool uses cookies in order to analyse how, when and where visitors use our websites, but this information is not tied to personally identifiable information. We only use this data to improve your experience. For example, we are able to find out what the most popular content is each week, and update our homepage to reflect that current interest. After reviewing the cookies we use (see list below) and the benefit they provide our visitors and members, we currently operate an ‘implied consent’ policy. This means that we assume you agree with the usage of our cookies. If you do not agree, we have provided guidance to help you to alter your browser settings to match the level of privacy you require (see ‘How to manage cookies via your browser settings’ section below). For more details about cookies, visit www.aboutcookies.org. 3. Terms of Use The information contained on the SFT website (Site) is owned and operated by SFT and is for general guidance on matters of interest only. The application and impact of laws can vary widely based on the specific facts involved. All information in this Site is provided on an “as is” basis, with no guarantee of completeness, accuracy, timeliness, or of the results obtained from the use of this information, and without warranty of any kind, express or implied, including but not limited to warranties of performance, merchantability, and fitness for a particular purpose. While we have made every attempt to ensure that the information contained in this Site has been obtained from reliable sources, SFT is not responsible for any errors or omissions, or for the results obtained from the use of this information. This site is for information only. Neither the content providers nor the publisher accept any legal responsibility for nor make any warranty with respect to the views expressed or procedures outlined on the site. Your use of this web site will be governed by and construed in accordance with the laws of England and Wales and any disputes will be decided only by the courts of England and Wales. General Information If you have any queries with regard to this web site please contact us at bookings@swimfortri.com.