Privacy Policy

Starswimmers GmbH („Starswimmers“) is committed to protecting and respecting your privacy. We don’t collect personal data and we don’t use cookies to collect personally identifiable information about you.

Starswimmers privacy notice

Starswimmers is committed to protecting your privacy. At all times we aim to respect any personal information relative to you. This Privacy Notice (‘Notice’) sets out our data processing practices when you interact with us and your rights and options regarding the ways in which your personal information is used.

This notice contains important information about your personal rights to privacy. Please read it carefully to understand how we use your personal information.

The provision of your personal information to us is voluntary.


1. We collect information about you:

1.1 When you give it to us directly

For example, personal information that you give us through our contact form or when you contact us by email or phone such as your name, the name of the person receiving swimming classes, your email, phone and address.

1.2 When we obtain it indirectly
For example, your personal information may be shared with us by third parties including, for example; analytics providers and search information providers.

1.3 When it is available publicly
Your personal information may be available to us from external publicly available sources. For example, depending on your privacy settings for social media services, we may access information from those accounts or services (for example when you choose to interact with us through platforms such as Facebook, LinkedIn or Twitter).

1.4 When you visit our website
When you visit our website, we automatically collect the following types of personal information:

a. Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.

b. Information about your visit to the websites, including the uniform resource locator (URL) clickstream to, through and from the site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.

c. We also collect and use your personal information by using cookies on our website – please see our Cookie Notice at the bottom of the page.

In general, we may combine your personal information from these different sources for the purposes set out in this notice.


2. What personal information do we process?

We may collect, store and otherwise process the following kinds of personal information:

a. your name and contact detail, including postal address, telephone number, email address and, where applicable, social media identity;

b. information about your computer/mobile device and your visits to and use of this website, including, for example, your IP address and geographical location;

c. information about our services which you use/which we consider may be of interest to you; and/or

d. any other information shared with us as per clause 1.

2.2 Do we process special categories of personal information?

The General Data Protection Regulation (‘GDPR’) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health.

In certain situations, Starswimmers receive and/or use these special categories of your personal information. We will only process these special categories of your personal information if there is a valid reason for doing so (e.g. tailoring the swimming classes to your needs) and where the GDPR allows us to do so.


3. How and why will we use your personal information?

Your personal information, however provided to us, will be used for the purposes specified in this notice. In particular, we may use your personal information.

a. to provide you with great quality swimming classes or information you have requested;

b. to answer your questions/requests and communicate with you in general;

c. to analyse and improve our services, activities, products or information (including our website);

d. to run/administer our website, keep the website safe and secure and ensure that content is presented in the most effective manner for you and for your device;

e. to satisfy legal obligations which are binding on us, and/or

f. for the establishment, defence and/or enforcement of legal claims.


4. Supporter research

We may also analyse your personal information to create a record of your interests and preferences. This allows us to ensure communications are relevant and timely, to contact you in the most appropriate and relevant way and in general to provide you with an improved user experience. It also helps us to understand the backgrounds of our clients.


5. Information Communications

We may use your contact details to provide you with information about our work, events, services and/ or products which we consider may be of interest to you.

Where we do this via email, SMS or telephone (if you are registered with the Telephone Preference Service), we will not do so without your prior consent.

You can opt out of receiving marketing emails from Starswimmers at any time by clicking the ‘unsubscribe’ link at the bottom of our emails.


6. Lawful bases

The GDPR requires us to rely on one or more lawful bases to process your personal information. We consider the grounds listed below to be relevant:

a. Where you have provided your consent for us to use your personal information, e.g. to contact you

b. Where necessary so that we can comply with a legal obligation to which we are subject.

c. Where necessary for the performance of a contract to which you are a party

d. Where it is in your/someone else’s vital interests (for example, in case of a medical emergency).

e. Where there is a ‘legitimate interest’ in us doing so.


7. Legitimate interests

The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights).

In broad terms, our ‘legitimate interests’ means the interests of running Starswimmers and providing swimming classes. However, ‘legitimate interests’ can also include your interests, such as when you have requested information or certain services from us.

When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).


8. Will we share your personal information?

We may need to disclose your personal information upon request to regulatory and government bodies as well as law enforcement agencies. We may also merge or partner with other organisations and, in so doing, acquire or transfer personal information but your personal information would continue to be used for the purposes set out above.


9. Security/storage of and access to your personal information

9.1 Starswimmers is committed to keeping your personal information safe and will limit access to the information within Starswimmers on a need-to-know basis.

9.2 In general, the personal information that we collect from you will be stored at a destination within the UK or European Economic Area (‘EEA’). Although we cannot exclude it, we do not intend to store your data out of the EEA.

9.3 Unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure – however, once we have received your personal information, we will use strict procedures and security features to try and prevent unauthorised access.


10. Exercising your Rights

a. Right of access – you can write to us to ask for confirmation of what personal information we hold about you and to request a copy of that information. Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply.

b. Right of erasure – at your request and where you are entitled to, we will delete your personal information from our records as far as we are required to do so. In many cases we would propose to suppress further communications with you, rather than delete it.

c. Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate/ up to date.

d. Right to restrict processing – you have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.

e. Right to object – you have the right to object to processing where we are (i) processing your personal information on the basis of the legitimate interests ground, (ii) using your personal information for direct marketing or (iii) using your information for research or statistical purposes.

Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you contact us using the details in section 15 below.

You are further entitled to make a complaint about us or the way we have processed your data to the data protection supervisory authority in your home country. In the UK this is the Information Commissioner’s Office. For further information on how to exercise this right, please contact us using the details below.


11. Changes to this notice

We may update this Notice from time to time so please check back periodically. We will notify you of significant changes by contacting you directly and by placing a notice on our website. This notice was last updated on 20 February 2021. Please also refer to our Ts & Cs which have further content which complements and, if applicable, supersedes this notice.

12. Links and third parties

We may at times link our website directly to other sites. This notice does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy notices of any external websites you visit via links on our website. Please also refer to our Ts & Cs which have further content which complements and, if applicable, supersedes this notice.


13. How to contact us

Please let us know if you have any questions or concerns about this notice or about the way in which Starswimmers processes your personal information by contacting us at the following channels:

Telephone: +49 176 7011 0661


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Performance cookies

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

Functional cookie

These cookies allow a website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Targeting cookies

These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.