Privacy Policy

Willesden Sunday Club

Privacy & Cookies Policy

Effective date: 21 September 2025

1. Introduction

Willesden Sunday Club (“we”, “us”, “our”) is committed to protecting the privacy and rights of individuals in accordance with:

  • the UK General Data Protection Regulation (UK GDPR);

  • the Data Protection Act 2018;

  • the Data (Use and Access) Act 2025;

  • the Privacy and Electronic Communications Regulations (PECR); and

  • any other applicable UK data protection law.

This policy explains how we collect, use, store, share and protect your personal data, the cookies we use, and your rights.

2. Data Controller

We are the data controller for the purposes of UK GDPR, meaning we decide how and why personal data is processed.

Contact details:

Luca Sai
Willesden Sunday Club
Address: Donnington Road, NW10 8QX
Email: willesdensundayclub@gmail.com

3. What personal data we collect

We may collect and process the following categories of personal data from you, depending on what services you use and what you tell us:

  • Basic identity & contact information: name, address, email address, phone number.

  • Age/DOB: especially for child members/pupils.

  • Medical/special needs / health information: relevant to swimming safety (e.g. asthma, allergies). This is “special category data”.

  • Emergency contact details: who to contact if there is an incident.

  • Payment information: bank account or card details, transaction records.

  • Usage data: how you use our website, classes, attendance records, communications (emails, phone etc.).

  • Communications preferences: how you want us to contact you (email, SMS, etc.).

4. Legal basis for processing your data

We process your personal data only when we have a lawful basis under UK GDPR, such as:

  • Contract: to provide swimming lessons, membership services, fulfil our obligations under any agreement with you.

  • Legal obligation: for instance, for safeguarding, health & safety, tax authorities.

  • Consent: particularly for special category data (medical info), for marketing, or for non-essential cookies.

  • Legitimate interests: where our interests are balanced against your rights (e.g. operational record-keeping, fraud prevention), provided these do not override your fundamental rights.

5. How we use your personal data

We use your data for the following purposes:

  • To enrol pupils / manage class bookings, payments, scheduling.

  • To ensure safety (e.g. emergency contacts, medical needs).

  • To communicate with you: updates, cancellations, class information.

  • To administer membership or pupil records.

  • To comply with legal obligations (e.g. tax, safeguarding).

  • For marketing, only if you have given your consent (e.g. newsletters, promotions).

  • For website analytics and improving our website / services.

6. Special category data

Medical and health information, or other sensitive data, is treated as “special category data” under UK GDPR. We will only collect and process special category data when:

  • you have given explicit consent, or

  • it is necessary for health and safety in the context of our swim lessons, or

  • another legal basis exists (e.g. legal obligation or vital interests).

We store such data securely and limit access to those staff who need to know.

7. Cookies, analytics & storage technologies

We use cookies and similar technologies on our website. Under PECR and the updated rules in the Data (Use and Access) Act 2025, certain lower-risk cookies (for analytics, functionality) may be used without explicit consent, while others (e.g. advertising, profiling) still require opt-in consent.

Types of cookies we use:

Types of Cookies We Use

1. Strictly Necessary / Essential Cookies

  • Purpose: Allow core site functions such as logging in, booking classes, and accessing secure areas.

  • Consent: Not required (these are exempt).

2. Functionality / Preference Cookies

  • Purpose: Remember your settings and preferences (e.g. language, region).

  • Consent: Sometimes required, depending on the type and purpose.

3. Analytics / Performance Cookies

  • Purpose: Help us understand how visitors use our site (e.g. traffic levels, pages visited).

  • Consent: May not always require consent if considered low-risk, but we generally ask for it.

4. Advertising / Targeting Cookies

  • Purpose: Track your browsing across sites to deliver relevant ads and marketing.

  • Consent: Always requires your explicit opt-in.

Your choices:

  • You can control or delete cookies via your browser settings.

  • We will provide a cookie banner/pop-up when you first visit our site, explaining our cookies, and offering to accept / reject non-essential ones.

  • You can change your preferences at any time via the site.

8. Who we share your data with

We may share your personal data with:

  • Staff and instructors, where necessary for teaching or safety.

  • Third-party service providers who help us (payment processors, booking systems, website hosting, email services).

  • Authorities / government bodies, where required by law (e.g. safeguarding, emergencies).

  • In an emergency, or where necessary to protect individuals.

We will ensure that any third parties who process data on our behalf adhere to UK data protection law and have appropriate security.

9. International transfers

If we transfer your personal data outside the UK (or EEA), we will ensure appropriate safeguards are in place (standard contractual clauses, adequacy decisions, etc.) in line with the law.

10. Data retention

We will keep your data only as long as needed for the purposes for which it was collected:

  • Membership / class data: while you are a pupil/member.

  • Medical / health records: as long as necessary for safety / legal obligations.

  • Financial / payment records: as required by tax / financial regulations (often 6-7 years).

  • Marketing or contact preferences: until you withdraw consent.

After that, data will be securely destroyed or anonymised.

11. Your rights

Under UK GDPR, you have rights including:

  • The right to be informed about how we process your data.

  • The right of access: you can request a copy of your personal data.

  • The right to rectification: ask us to correct inaccurate or incomplete data.

  • The right to erasure: in certain circumstances, ask us to delete your data.

  • The right to restrict processing in certain cases.

  • The right to data portability: in some cases, receive your data in a structured machine-readable way.

  • The right to object: particularly to marketing or profiling.

  • The right to withdraw consent at any time, where processing is based on consent.

  • The right to complain to the Information Commissioner’s Office (ICO) if you believe your data rights have been breached.

12. Automated decision-making & profiling

We do not usually make decisions based solely on automated processing / profiling which produce legal or similarly significant effects. If we do, we will inform you, explain the logic involved, provide safeguards, and offer you the chance to challenge / request human intervention.

13. Security

We take appropriate technical and organisational measures to protect your personal data from accidental loss, misuse, unauthorised access, disclosure or destruction. These include:

  • Secure storage, encryption, password protection.

  • Limiting access to staff who need the data.

  • Physical security for paper records.

  • Regular review of our security practices.

14. Children

Because many of our pupils are minors:

  • We collect data about children (name, age, medical info etc.) via parental / guardian consent.

  • Medical / special needs data is only processed with explicit consent.

  • Communications with children are made via parents / guardians where appropriate.

15. Changes to this policy

We may update this policy from time to time (for example, to reflect changes in the law, or how our services work). When we do, we will set a new “effective date” and, if changes are significant, we will notify you (e.g. via email or on our website).

16. Contact us

If you have any questions about how we handle your personal data, want to exercise any of your rights, or have any concerns, please contact us.
Contact details:

Luca Sai
Willesden Sunday Club
Address: Donnington Road, NW10 8QX
Email: willesdensundayclub@gmail.com

You can also contact the ICO:
Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
or via their website: ico.org.uk