Swimable Privacy Policy

Swimable (Suits Your Size Pty Ltd) is committed to protecting the privacy and personal information of our customers and staff, including children and their families. This policy outlines how we collect, use, store, and protect personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APP), and the Privacy and Other Legislation Amendment Act 2024 (Cth).

A copy of the Australian Privacy Principles may be obtained from the website of the Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

1. About this Policy

This policy applies to all personal information we collect and handle in connection with our swimming programs, including group and private lessons for infants, children, and adults.

2. Who do we collect information about?

We collect information about:

  • Children enrolled in our programs
  • Parents and legal guardians of enrolled children
  • Adult lesson participants
  • Prospective customers who enquire about our services
  • Our employees

Most of our student base is children under the age of 18. All personal and sensitive information related to children is therefore collected with the consent of a parent or guardian.

3. What information do we collect?

We collect the following types of information:

3.1  General Personal Information

We collect the following types of personal information:

  • Full name, date of birth, gender
  • Home address, email address, and phone numbers
  • Emergency contact names and numbers
  • Swimming ability, level assessments, and progress records
  • Attendance records
  • Other personal information required to comply with our policies and procedures

3.2 Sensitive Personal Information

Health information is classified as “sensitive” information under the Privacy Act and receives the highest level of protection. We will only collect and use (or disclose) information where required or authorised by law. Information we collect includes:

  • Medical conditions (such as epilepsy, heart conditions, and asthma)
  • Developmental conditions or disabilities that may affect participation or require instructor awareness
  • Dietary requirements and allergies (including anaphylaxis risks and any EpiPen requirements)
  • Current medications that may be relevant in case of an emergency
  • Any other health information provided for the safe delivery of lessons

3.3 Photography and Videography

Photography, videography, audio recordings, or live streaming by customers, their families, or visitors is strictly prohibited within Swimable’s premises. This applies to all areas of our facility, including the pool deck, corridors, and change rooms. We reserve the right to require immediate deletion of any recordings taken.

From time to time, Swimable may capture photographs or videos of lessons for the following purposes:

  • Stroke technique assessment and instructor training
  • Marketing and promotional materials (website, social media, printed materials).

Media will only be captured/recorded on official Swimable devices. Employees (or the parent/guardian of the employee if they are under 18) are informed and asked to sign a consent form before we publish any media containing their likeness online or on printed media. We will also always seek consent from adult students and the parent/guardian of students under 18 before publishing any media online or on printed promotional materials. Consent can be withdrawn at any time by contacting us.

4. Why do we collect personal information?

We collect and use personal information for the following purposes:

  • Managing enrolments, class schedules, and program delivery
  • Ensuring the health and safety of all participants, particularly through the collection and use of medical and health information
  • Communication regarding student progression, class changes, work schedules, and other information
  • Administering staff payroll and employment records
  • Complying with legal obligations (including child safety and work health and safety laws)
  • Improving our services and website
  • Marketing and promoting our program to current and prospective customers.

You do not have to give us this information. However, if you don’t, it may affect our ability to provide our services.

5. How do we collect information?

We collect information through:

  • Online enrolment and enquiry forms on our website
  • Our customer portal
  • Student questionnaires and medical disclosure forms
  • Email, phone, and face-to-face interactions
  • Employment forms
  • Third parties, such as secondary guardians or parents providing information about another customer, or referring health professionals
  • Our website, including via cookies and analytical tools

6. Third-party service providers and disclosure

We use several trusted third-party service providers and platforms to operate our business. Please see our Third-Party Service Providers and Disclosure Statement for further information.

7. Marketing Communications

We may use your personal information to send communications about Swimable programs, promotions, and news. You can unsubscribe from marketing communications at any time by:

  • Clicking the unsubscribe link in any marketing email we send
  • Contacting us in writing using the details in Section 11

Unsubscribing from marketing communications will not affect our ability to send you essential communications (e.g., schedule changes, invoices, or matters related to your/your child’s safety or enrolment).

8. How do we protect personal information?

We take a layered approach to data security, particularly given that we hold sensitive information about children and young people. Our security measures include:

  • Secure, password-protected access to systems and information stored digitally (including information stored in third-party providers)
  • Role-based access controls: Staff only access personal information relevant to their specific role
  • Multi-factor authentication enabled where available
  • Secure physical storage of any paper-based records containing personal information
  • Secure disposal of personal information when it is no longer required to provide services and in accordance with legal record-keeping obligations.

While we take reasonable steps to protect your personal information, we cannot guarantee the safety of the internet. Please ensure that you are using a secure network when providing your personal information to us to minimise risks associated with internet security. Additionally, any data sent through emails may not be completely secure during the transfer.

9. What do we do in case of a data breach?

In the event of a data breach that is likely to cause serious harm to affected individuals, we will:

  • Contain the breach and conduct an assessment as quickly as possible
  • Notify the Office of the Australian Information Commissioner (OAIC) when applicable and as soon as practicable
  • Directly notify affected individuals (or their parents/guardians)

If you believe a data breach may have occurred involving your or your child’s personal information, please contact us immediately.

10.  Accessing and controlling your personal information

You (or your parent/guardian) have the right to:

  • Request access to the personal information we hold about you
  • Request correction of any inaccurate, incomplete, or out of date information

To make an access or correction request, please contact us in writing. We will respond within 30 business days. No fee is charged for submitting access requests; however, an administrative fee may apply for providing copies of records. We may require identity verification (and verification of relationship to your child) before releasing any information.

11. Privacy enquiries and complaints

If you have any questions, concerns, or complaints about how we handle your data, please contact us:

Email: office@swimable.com.au

Phone: 0410 989 766 or 03 9521 1995

Office address: 27/28 Fulton St, St Kilda East, VIC, 3183

We aim to respond to you within 5 business days and aim to resolve your concern within 30 business days. If you are not satisfied with your response or we fail to respond within a reasonable time, you have the right to escalate your complaint to the Office of the Australian Information Commissioner (OAIC):

Website: www.oaic.gov.au

Phone: 1300 363 992

Postal address: GPO Box 5218, Sydney NSW, 2001

12. Updates to this policy

This Privacy Policy will be updated as our practices, technology, or legal obligations change. We may change this policy at any time, so we recommend you regularly check this page for the most recent version. For significant changes affecting how we handle your personal information, we will notify you directly by email.

Version Details:

Name Swimable
Owner Suits Your Size Pty Ltd trading as Swimable
Location

St Mary’s College

11 Westbury Street,

St Kilda East VIC, 3183
Date 18th June, 2026
Author: Shruthi Mahalingam

 

Third-Party Service Providers and Disclosure