Privacy Policy

1. Who we are

Swim London is operated by Swim London 10K Limited, a company registered in England and Wales under company number 17312082, with its registered office at:

2 Kildare Terrace
London
England
W2 5LX

Swim London 10K Limited is the data controller responsible for deciding how and why your personal information is collected and used.

In this policy, “Swim London”, “we”, “us” and “our” refer to Swim London 10K Limited.

For questions about this policy or how we use your personal information, contact:

Email: toby@swim.london
Post: Data Privacy, Swim London 10K Limited, 2 Kildare Terrace, London, W2 5LX

2. What this policy covers

This policy explains how we collect, use, store and share personal information when you:

• visit the Swim London website;
• register for, attend or participate in a Swim London event;
• join a waiting list or register your interest;
• volunteer, work or provide services at an event;
• contact us with a question, complaint or request;
• subscribe to our updates or marketing communications;
• participate in photography, filming, interviews or promotional activity; or
• otherwise interact with Swim London.

3. Personal information we collect

The information we collect will depend on how you interact with us.

Identity and contact information

This may include:

• your name;
• postal address;
• email address;
• telephone number;
• date of birth and age;
• gender, where relevant and appropriate;
• participant or registration number; and
• details of a parent or guardian where applicable.

Registration and participation information

This may include:

• the event or category you have entered;
• swimming experience, qualifications and previous event history;
• expected completion time or swimming pace;
• club or team details;
• wetsuit or equipment information;
• eligibility information;
• answers to registration and safety questions;
• signed declarations, waivers and terms;
• attendance, check-in and event completion information;
• timing, ranking and results;
• fundraising information; and
• communications relating to your participation.

Health, medical and accessibility information

To help us operate the event safely, we may collect:

• medical conditions;
• disabilities and accessibility requirements;
• allergies;
• injuries;
• medication information;
• relevant swimming or water-safety information;
• dietary requirements where relevant;
• emergency medical information; and
• any other information you choose or are required to provide about your health.

Health information is treated as special category personal data and receives additional protection.

Emergency contact information

We may collect the name, telephone number and relationship of your nominated emergency contact.

You should make sure that your emergency contact knows that you have provided their information to us and direct them to this privacy policy.

Payment and transaction information

This may include:

• ticket price and payment status;
• payment date and transaction reference;
• billing address;
• refund or cancellation information;
• discount or promotional code information; and
• limited payment information provided to us by our payment provider.

Payments may be processed directly by a specialist payment provider. Swim London will not normally receive or store your complete debit or credit card details.

Photographs, video and audio

Our events may be photographed, filmed or recorded. We may collect:

• photographs and video footage;
• interview recordings;
• audio recordings;
• testimonials; and
• social media content in which Swim London is tagged or mentioned.

We will provide reasonable event-day information about official photography and filming. Where appropriate, we will also provide a way for participants to raise concerns or request that particular images are not used.

Website and technical information

When you use our website or registration platform, we may collect:

• IP address;
• browser and device information;
• operating system;
• website usage and navigation information;
• cookie identifiers and preferences;
• referral source;
• registration platform activity;
• security and fraud-prevention information; and
• technical logs and error reports.

Communications and marketing information

This may include:

• messages and emails you send us;
• records of telephone or in-person conversations;
• survey and feedback responses;
• complaints and enquiries;
• your communication preferences;
• marketing consent records; and
• records of whether you opened or interacted with our communications.

Incident and safety information

Where an accident, safeguarding concern, withdrawal or other incident occurs, we may record:

• details of the incident;
• witness statements;
• medical treatment provided;
• relevant photographs or footage;
• communications with emergency services or authorities;
• insurance information; and
• subsequent investigation or claim information.

4. How we collect your information

We may collect personal information:

• directly from you;
• from someone registering or contacting us on your behalf;
• through our website and registration platform;
• from payment providers;
• from event suppliers and contractors;
• from timing, safety, medical and event-management teams;
• from photographers and videographers;
• from partner organisations and charity partners;
• from publicly available sources, including social media; and
• from emergency services, regulators or public authorities where appropriate.

5. How we use your information

We may use your personal information to:

• process and manage your registration;
• take and confirm payment;
• communicate essential event information;
• assess participant eligibility;
• plan event waves, timings and operational requirements;
• deliver the event safely;
• respond to medical, safety or emergency situations;
• provide reasonable adjustments and accessibility support;
• manage event timing, rankings and results;
• administer cancellations, refunds and transfers;
• communicate with your emergency contact where necessary;
• manage volunteers, contractors and suppliers;
• investigate accidents, complaints and incidents;
• maintain insurance, financial and legal records;
• prevent fraud, misuse and security incidents;
• improve our events, website and participant experience;
• publish event photographs, videos, reports and results;
• promote Swim London and future events;
• administer fundraising and charity partnerships;
• respond to enquiries and rights requests;
• comply with legal and regulatory obligations; and
• establish, exercise or defend legal claims.

6. Our lawful bases

Under UK data protection law, we must have a lawful basis for using your personal information.

We may rely on the following bases:

Contract

We process information where it is necessary to:

• register you for an event;
• provide the event services you have requested;
• process your payment;
• provide essential event communications; or
• fulfil our obligations under our participant terms and conditions.

Legal obligation

We process information where necessary to comply with legal obligations relating to areas such as:

• accounting and taxation;
• health and safety;
• insurance;
• safeguarding;
• law-enforcement requests; and
• regulatory reporting.

Legitimate interests

We may process information where it is necessary for our legitimate interests or those of another organisation, provided those interests are not overridden by your rights.

These interests may include:

• operating a safe and successful event;
• improving our services;
• maintaining event and participant records;
• preventing fraud and protecting our systems;
• promoting Swim London;
• publishing event results;
• managing photography and event coverage;
• working with event suppliers and partners; and
• establishing or defending legal claims.

Consent

We may rely on your consent for activities including:

• sending certain marketing communications;
• using non-essential cookies;
• processing health information where explicit consent is the appropriate condition; and
• using interviews, testimonials or identifiable promotional content in circumstances where consent is appropriate.

You may withdraw your consent at any time. Withdrawal will not affect processing that took place before consent was withdrawn.

Vital interests

In a genuine medical or safety emergency, we may use or share relevant information where this is necessary to protect your life or the life of another person.

7. Health and medical information

Health and medical information is special category personal data.

We will normally process this information because:

• it is necessary to administer your participation safely;
• we have your explicit consent; and
• in an emergency, processing may be necessary to protect your vital interests or those of another person.

Access to health information will be limited to people who reasonably need it for event safety, medical support, accessibility or emergency response.

This may include event management, water-safety personnel, medical providers, emergency services and other relevant event suppliers.

Providing certain health and safety information may be a condition of participation. If you do not provide information that we reasonably require to assess or manage your participation safely, we may be unable to allow you to participate.

8. Who we share information with

We may share personal information with organisations that help us plan, administer and deliver Swim London.

These may include:

• registration and ticketing providers;
• payment processors;
• website, hosting and technology providers;
• email and communications providers;
• event-management contractors;
• water-safety and rescue providers;
• medical and first-aid providers;
• timing and results providers;
• participant check-in and accreditation providers;
• transport, logistics and equipment suppliers;
• photographers, videographers and media providers;
• insurers, insurance brokers and claims handlers;
• accountants, lawyers and professional advisers;
• charity and fundraising partners;
• venue owners and landowners;
• the Port of London Authority and other relevant authorities;
• police, emergency services and public bodies; and
• regulators, courts and law-enforcement agencies where required.

We will only share information that is reasonably necessary for the recipient’s role.

Where a supplier processes information on our behalf, we will require it to protect the information, use it only for the agreed purpose and comply with applicable data protection requirements.

Some organisations, such as payment providers, medical providers, emergency services and public authorities, may act as independent data controllers. Their own privacy policies may also apply.

We will not sell your personal information.

We will not share your information with another organisation for its own marketing purposes unless you have been clearly informed and have given any consent required by law.

9. Event results

We may publish participant information in event results, including:

• participant name;
• participant number;
• age category or gender category, where applicable;
• club or team;
• completion status;
• finish time;
• ranking; and
• event penalties or disqualification status.

Results may be published on our website, registration or results platforms, social media channels and in event reports.

If there is a genuine safety or privacy reason why your name should not appear publicly, contact us before the event so we can consider an appropriate arrangement.

10. Photography and filming

Photography and filming may take place in public and event areas.

We may use event imagery for:

• event reporting;
• news and media coverage;
• our website;
• social media;
• promotional materials;
• sponsorship and partnership reporting;
• future event promotion; and
• Swim London’s historical archive.

We generally rely on our legitimate interests when capturing and using general event imagery. We will consider objections fairly, particularly where an individual is the main subject of an image.

We may seek separate consent for certain interviews, testimonials, case studies or specifically commissioned promotional content.

11. Marketing communications

Essential information about an event you have entered is not marketing. We may send you operational communications even where you have not agreed to receive marketing.

These communications may include:

• registration confirmation;
• safety requirements;
• training and preparation information;
• route or timetable updates;
• changes to the event;
• cancellation information; and
• post-event information directly connected with your participation.

We may also send information about future Swim London events, offers, fundraising activity and related opportunities where:

• you have consented; or
• we are otherwise permitted to do so under applicable electronic marketing rules.

You can unsubscribe from marketing at any time by using the unsubscribe link in an email or contacting us.

We may retain limited information on a suppression list to ensure that we respect your decision not to receive further marketing.

12. Cookies

Our website and third-party registration services may use cookies and similar technologies.

Essential cookies may be used where necessary to:

• operate the website;
• maintain security;
• process registration;
• remember privacy preferences; and
• provide services you request.

With your consent, we may also use analytics, advertising or other non-essential cookies to understand website use and improve our communications.

You can manage your choices through our cookie settings. Further information should be provided in our cookie notice or consent tool.

13. International transfers

Some of our technology and service providers may process personal information outside the United Kingdom.

Where personal information is transferred internationally, we will take appropriate steps to protect it. Depending on the destination and recipient, these steps may include:

• relying on UK adequacy regulations;
• using the UK International Data Transfer Agreement;
• using an approved UK addendum to standard contractual clauses; or
• applying another legally recognised transfer safeguard.

You may contact us for further information about the safeguards used for relevant international transfers.

14. How long we keep information

We will keep personal information only for as long as it is reasonably required for the purpose for which it was collected.

Our anticipated retention periods are:

• Registration, transaction and accounting records: normally six years after the end of the relevant financial year.
• General participant and operational records: normally three years after the event.
• Health, medical and emergency information: normally deleted or anonymised within 90 days after the event, unless it relates to an incident, complaint, insurance matter or legal claim.
• Incident, safeguarding and insurance records: for as long as reasonably required to investigate the matter, meet insurance requirements or deal with a potential or actual legal claim.
• Website security logs: normally up to 12 months.
• Enquiries and complaints: normally up to three years after the matter is closed.
• Marketing information: until you withdraw your consent, object to marketing or we determine that the information is no longer current.
• Marketing suppression records: for as long as necessary to make sure we continue to respect your opt-out.
• Timing and results information: potentially indefinitely as part of the public sporting and historical record.
• Photographs and video: for as long as reasonably useful for event promotion, reporting and archiving, subject to periodic review.

We may keep information for longer where required by law or where it is relevant to an investigation, dispute, safeguarding matter or legal claim.

We may retain anonymised information indefinitely because it can no longer identify an individual.

15. How we protect your information

We use appropriate organisational and technical measures designed to protect personal information against:

• accidental or unlawful loss;
• unauthorised access;
• alteration;
• disclosure;
• destruction; and
• misuse.

Measures may include access controls, password protection, staff and supplier confidentiality requirements, secure systems, data minimisation and procedures for managing suspected personal-data breaches.

No system is completely secure, but we regularly review the measures appropriate to the nature and sensitivity of the information we process.

16. Your data protection rights

Depending on the circumstances, you may have the right to:

• be informed about how your information is used;
• request access to your personal information;
• ask us to correct inaccurate or incomplete information;
• ask us to delete your information;
• ask us to restrict how your information is used;
• object to certain processing, including direct marketing;
• receive certain information in a portable format;
• withdraw consent where processing is based on consent; and
• complain to the Information Commissioner’s Office.

These rights are not absolute and may not apply in every situation. For example, we may need to retain certain information to comply with the law, manage an incident or defend a legal claim.

To exercise a right, contact us using the details at the beginning of this policy. We may ask for information to confirm your identity before responding.

You will not normally be charged for exercising your rights.

17. Automated decision-making

We do not currently make decisions that have legal or similarly significant effects on participants using solely automated processing.

We may use automated tools for routine purposes such as fraud screening, registration validation, communications and event administration, but significant decisions will involve appropriate human review.

18. Children

Where an event allows participation by someone under the age of 18, we may require information and authorisation from their parent or legal guardian.

Parents and guardians should ensure that children understand how their information will be used as far as reasonably possible.

We will take additional care when processing children’s information and will not knowingly send direct marketing to a child where doing so would be inappropriate or unlawful.

19. Third-party websites and services

Our website may contain links to websites, fundraising pages, registration platforms, payment providers or social media services operated by other organisations.

Those organisations are responsible for their own privacy practices. We recommend reviewing their privacy policies before providing personal information.

20. Changes to this policy

We may update this policy from time to time to reflect changes in:

• our events and services;
• the information we collect;
• our suppliers and partners;
• our legal obligations; or
• data protection guidance.

The latest version will be published on our website with an updated revision date.

Where a change materially affects how we use participant information, we will take reasonable steps to bring the change to the attention of affected individuals.

21. Complaints

We encourage you to contact us first if you are concerned about how we have handled your information so that we can try to resolve the matter.

You also have the right to complain to the Information Commissioner’s Office, the UK regulator for data protection.

Details of how to complain are available through the Information Commissioner’s Office website.