1. Introduction

Strokeandglide respects the privacy of its customers and visitors. This Privacy Policy explains how personal information is collected, used, stored and shared when you visit our website, submit an enquiry, request a quotation or arrange swimming instruction services.

Our business is independently operated, and customer information is handled for legitimate business purposes in accordance with Singapore’s Personal Data Protection Act 2012 (PDPA) and the European Union General Data Protection Regulation (GDPR), where applicable.

By using our website or submitting an enquiry, you acknowledge that you have read this Privacy Policy. Where consent is required by law, we will request it separately.

2. Information We Collect

We may collect the following categories of personal information:

• Contact Information: Name, email address, telephone number and correspondence details.
• Enquiry Information: Swimming experience, requested instruction level, preferred session times and service requirements.
• Booking Information: Quotation details, appointment arrangements, order references and service records.
• Payment Information: Deposit amounts, outstanding balances, payment status and transaction references.
• Website Information: IP address, browser type, device information, website usage records and cookie preferences.
• Communication Records: Emails, customer enquiries, booking confirmations and related correspondence.

We only request information relevant to handling enquiries, arranging services and fulfilling customer orders.

3. How We Use Personal Information

Personal information may be used for the following purposes:

• Responding to customer enquiries and quotation requests.
• Assessing requested swimming instruction arrangements.
• Preparing quotations and confirming service requirements.
• Processing deposit payments and outstanding balances.
• Arranging appointments and coordinating agreed sessions.
• Sending booking confirmations and service updates.
• Handling cancellations, refunds and customer requests.
• Maintaining transaction records and fulfilling legal obligations.
• Reviewing website usage and improving website functionality, where permitted.

We do not use personal information for unrelated purposes without an appropriate legal basis.

4. Legal Basis for Processing

Where the GDPR applies, personal information is processed under one or more of the following legal grounds:

• Contractual Necessity: To respond to enquiries, prepare quotations and fulfil agreed service arrangements.
• Legal Obligations: To maintain financial records and comply with applicable legal requirements.
• Legitimate Interests: To manage customer communications, maintain business records and administer existing customer relationships, provided these interests do not override individual rights.
• Consent: For optional communications, non-essential cookies and other activities where consent is required.

Customers may withdraw consent at any time where processing is based on consent. Withdrawal does not affect processing lawfully carried out before the withdrawal.

5. Payment Information

Our website displays initial deposit amounts for swimming instruction services. These amounts are not the full service fees.

The payment arrangement follows this process:

1. The customer submits a quotation request.
2. Both parties discuss and assess the requested service.
3. The customer receives the agreed quotation and payment breakdown.
4. The customer pays the specified deposit.
5. The agreed service is delivered.
6. The outstanding balance is collected upon completion.

Payments are processed through Stripe, which acts as an independent payment service provider. Payment information required to process transactions may be handled directly by Stripe in accordance with its applicable privacy terms.

We may retain transaction references, payment confirmations, deposit amounts and outstanding balance records for order administration and accounting purposes. We do not intentionally retain complete payment card numbers or card security codes on our website.

6. Sharing of Personal Information

We may share relevant personal information with the following categories of recipients when necessary:

• Payment Service Providers: To process deposits, outstanding balances and refunds.
• Website Hosting Providers: To maintain website operations and store relevant business records.
• Email and Communication Providers: To manage customer enquiries and send booking notifications.
• Professional Advisers: Where necessary for accounting, legal or regulatory matters.
• Public Authorities: Where disclosure is required by applicable law or a lawful request.

We do not sell customers’ personal information to third parties.

Recipients are expected to handle relevant information in accordance with their applicable legal and contractual obligations.

7. International Data Transfers

As our business is based in Singapore and serves customers in Europe, personal information may be processed or transferred between Singapore, European countries and other countries where our service providers operate.

Where personal information is transferred outside the European Economic Area, appropriate transfer arrangements will be implemented in accordance with applicable GDPR requirements, including adequacy decisions or Standard Contractual Clauses where required.

For transfers outside Singapore, we will apply the relevant requirements of the PDPA concerning overseas recipients and comparable protection of personal information.

8. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected.

Retention periods may depend on:

• The duration of customer enquiries and service arrangements.
• Completion of bookings and settlement of outstanding payments.
• Applicable accounting and tax record-keeping requirements.
• The handling of refunds, complaints or contractual matters.
• Applicable statutory retention requirements.

When personal information is no longer required for these purposes, it will be deleted or anonymised in accordance with applicable requirements.

9. Data Protection

We maintain appropriate administrative and organisational arrangements when handling personal information.

Access to customer records is restricted to persons who require the information for relevant business purposes. Information handling procedures are reviewed periodically, and appropriate measures are taken when dealing with suspected data breaches.

Where a personal data breach meets the applicable notification requirements, the relevant authorities and affected individuals will be notified within the periods prescribed by law.

10. Cookies and Similar Technologies

Our website may use cookies and similar technologies to support essential website functions, remember customer preferences and understand website usage.

Cookies may include:

• Essential Cookies: Required for basic website functions, shopping processes and customer preferences.
• Preference Cookies: Used to remember selected website settings.
• Analytics Cookies: Used to understand website visits and browsing activity.
• Third-Party Cookies: May be placed by external service providers where their services are used.

Non-essential cookies will only be activated after the visitor has provided the required consent.

Visitors may change or withdraw their cookie preferences through the website’s cookie settings. Refusing non-essential cookies will not affect access to essential website functions.

Further details are provided in our Cookie Policy.

11. Your Privacy Rights

Where applicable under the GDPR, customers in the European Economic Area may exercise the following rights:

• Right of Access: Request a copy of personal information held about them.
• Right to Rectification: Request correction of inaccurate or incomplete information.
• Right to Erasure: Request deletion of personal information under applicable conditions.
• Right to Restriction: Request restriction of certain processing activities.
• Right to Object: Object to processing based on legitimate interests in applicable circumstances.
• Right to Data Portability: Request relevant information in a commonly used, machine-readable format where the legal conditions are met.
• Right to Withdraw Consent: Withdraw consent where processing relies on consent.
• Right to Lodge a Complaint: Submit a complaint to the competent data protection supervisory authority.

Under Singapore’s PDPA, individuals may also request access to their personal information and request corrections in accordance with applicable statutory requirements.

These rights are subject to relevant legal conditions and exceptions, including obligations to retain certain records.

12. Marketing Communications

We may send service-related communications concerning quotations, bookings, appointments, payments and order updates.

Promotional communications will only be sent where the required consent or other applicable legal basis has been obtained.

Customers may unsubscribe from promotional emails using the available unsubscribe option or by contacting us directly.

Requests to stop promotional communications will not affect essential messages relating to existing orders or services.

13. Children’s Privacy

Our website is intended for individuals who can lawfully enter into the relevant service arrangements.

Where swimming instruction is requested for a child, the enquiry and booking must be handled by a parent or legal guardian. We do not knowingly collect children’s personal information directly without the appropriate involvement and authorisation of a parent or legal guardian, where required by law.

14. Changes to This Privacy Policy

We may update this Privacy Policy when our business practices or applicable legal requirements change.

Any revised version will be published on this website with an updated revision date. Changes will apply from the date stated in the revised policy, subject to applicable legal requirements.

15. Contact Information

For privacy enquiries, access requests, correction requests or other matters concerning personal information, please contact us:

Brand Name: Strokeandglide
Registered Company Name: [Company Legal Name]
Website: www.strokeandglide.com
Email: swim@strokeandglide.com
Registered Address: [XXX]
Telephone: [XXX]
Country of Registration: Singapore

Please include sufficient information to help us identify your enquiry and respond appropriately.