Privacy Policy
Last updated: 4 August 2026
1. Who we are
Aqualearn Limited ("AquaLearn", "we", "us") provides swimming lessons across Croydon, Cheam and Sutton. We are the data controller for the personal information described in this policy.
| Company | Aqualearn Limited |
|---|---|
| Registered in | England and Wales, company number 17264192 |
| Registered address | 124 City Road, London, EC1V 2NX |
| swim@aqualearn.co.uk | |
| Website | https://www.aqualearn.co.uk |
2. What this policy covers
How we collect, use, store and share personal information when you:
- message us on WhatsApp
- book or attend swimming lessons
- fill in one of our registration or open-swim forms
- visit our website
- contact us by phone or email
3. Our WhatsApp assistant — please read this bit
When you first message our booking number, you are talking to an automated assistant, not a person. It answers questions about lessons, checks class availability, and either reserves a place for you or passes you to a member of our team.
What that means in practice:
- Your messages are processed by an AI service (Anthropic — see section 7) in order to understand what you're asking and reply. Your conversation is sent to them for that purpose.
- A reservation made by the assistant is not a confirmed booking. Every reservation is reviewed and confirmed by a member of our team before it becomes a place in a class. No decision that affects you is made by the assistant alone.
- You can ask for a person at any time. Just say so, and we'll pass you to a member of the team who will contact you directly.
- After your first enquiry, you deal with a person. Once you've been booked in or passed over, all further contact happens on our manager's number.
If you would rather not have your enquiry handled by an automated assistant, email us at swim@aqualearn.co.uk or call us instead.
4. What we collect
When you message us on WhatsApp
- Your phone number and your WhatsApp display name
- The content of the messages you send us, and our replies
- The date and time of those messages
When you book a lesson
- The swimmer's name and age
- Their swimming ability or level
- The parent or guardian's name, where the swimmer is a child
- A contact phone number and email address
- The venue, day and time booked, and the class type
On our registration and open-swim forms
- The above, plus
- Relevant medical conditions (asthma, epilepsy, allergies, and similar)
- Emergency contact details
- Whether you consent to photography or video
Payment
- We record that a payment is due and that it has been received.
- We are paid by bank transfer or cash. We do not have a card machine and we never collect or store card details.
On our website
- Standard technical information such as your IP address and browser type, and any cookies described in section 11.
5. Children's information
Most of our swimmers are children, so this section matters.
- A child's information is always provided to us by their parent or legal guardian, who is the person we deal with.
- We record the parent or guardian alongside every child booking, and we take instructions about that child only from them.
- We collect only what we need to teach a child safely: their name, age, swimming level, and any medical condition that affects them in the water.
- We do not market to children, profile them, or share their information with anyone outside the people listed in section 7.
- If a child is old enough to message us themselves, we will ask to speak to a parent or guardian before taking a booking.
If you are a parent or guardian and want to see, correct or delete what we hold about your child, email swim@aqualearn.co.uk and we will deal with it.
6. Why we use it, and our lawful basis
| What we use it for | Lawful basis (UK GDPR) |
|---|---|
| Answering your enquiry and telling you about availability | Legitimate interests — responding to someone who has contacted us |
| Taking and managing your booking, and teaching the lessons | Contract — to provide the lessons you've booked |
| Invoicing and taking payment | Contract, and legal obligation for our accounting records |
| Keeping swimmers safe in and around the water | Legitimate interests, and legal obligation for safeguarding |
| Medical and health information | Explicit consent, which you give on the registration form. You can withdraw it, though we may not be able to teach safely without it. |
| Photography and video | Consent. Entirely optional, and you can withdraw it at any time. |
| Sending you information about future terms or courses | Consent, which you can withdraw at any time |
Where we rely on legitimate interests, we've considered whether it would be unfair or unexpected to you. We think replying to an enquiry you sent us, and running the lessons you asked for, is neither. You can object — see section 9.
7. Who we share it with
We do not sell your information, and we do not share it for advertising.
We use the following service providers, who process information on our behalf:
| Provider | What they do | Where |
|---|---|---|
| Meta Platforms | Delivers WhatsApp messages between you and us | Ireland / USA |
| Anthropic | The AI service that reads your messages and drafts replies | USA |
| Stores our class registers and booking records (Google Sheets), and hosts our registration forms | EU / USA | |
| Cloudflare | Hosts the booking assistant and stores conversations briefly while it replies | Global network |
About the AI service: your conversation is sent to Anthropic so their Claude model can understand and answer it. Anthropic processes it on our behalf under contract, and does not use it to train their models.
Some of these providers are outside the UK. Where information is transferred abroad, it is protected by an appropriate safeguard recognised under UK data protection law — normally the International Data Transfer Addendum to the EU Standard Contractual Clauses.
We may also share information where we are legally required to (for example with a safeguarding authority, the police, or our accountants and insurers).
8. How long we keep it
| What | How long |
|---|---|
| Live WhatsApp conversation held by the assistant while it replies | 6 hours, then deleted automatically |
| The internal link our team uses to read a booking or enquiry in full | 30 days, then deleted automatically |
| Your WhatsApp chat history with our manager | Kept on their phone while you are a customer |
| Booking and class register records | While you are a customer, and for 2 years after your last lesson |
| Medical and emergency contact information | While the swimmer attends, then deleted at the end of that period |
| Invoices and payment records | 6 years, as required by UK tax law |
| Photographs and video, where consented | Until you withdraw consent, or 2 years, whichever is sooner |
9. Your rights
Under UK data protection law you can ask us to:
- See the information we hold about you
- Correct anything that's wrong
- Delete it, where we don't need it for a legal or contractual reason
- Restrict or object to how we use it
- Transfer it to another provider
- Withdraw consent at any time, where we rely on consent
Email swim@aqualearn.co.uk. We'll respond within one month and it's free. We may ask you to confirm who you are first.
If you're not happy with how we've handled it, you can complain to the Information Commissioner's Office — ico.org.uk/make-a-complaint or 0303 123 1113. We'd rather you came to us first so we can put it right.
10. How we keep it safe
- Access to our booking records is limited to the people who need it.
- Our booking assistant runs over encrypted connections, and all credentials are held in encrypted storage rather than in our code.
- Internal links to conversation records use long random addresses that cannot be guessed, are not indexed by search engines, and expire automatically.
- WhatsApp messages are encrypted in transit by WhatsApp.
- Our teachers hold enhanced DBS checks, and our lifeguards hold the NPLQ.
No system is completely secure, but if a breach ever put your rights at risk we will tell you and the ICO as required.
11. Cookies
Our website uses cookies that are necessary for it to work, and may use analytics cookies to understand how people use it. You can block or delete cookies in your browser settings; some parts of the site may not work properly if you do.
Our WhatsApp booking assistant does not use cookies.
12. Changes to this policy
If we change this policy we'll update the date at the top. If the change is significant, we'll tell customers directly.
13. Contact us
Aqualearn Limited
124 City Road, London, EC1V 2NX
swim@aqualearn.co.uk
For anything about your personal information, please put "Privacy" in the subject line.