1. What Information Do We Collect?

Personal Information You Disclose to Us

In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information.

We collect personal information that you voluntarily provide to us when registering at the Sites or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or Apps or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Sites or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:

• Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.
• Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
• Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information Automatically Collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites or Apps.

We automatically collect certain information when you visit, use or navigate the Sites or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Sites or Apps, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Information Collected Through Our Apps

In Short: We may collect information regarding your geo-location, mobile device, push notifications, when you use our apps.

If you use our Apps, we may also collect the following information:

• Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, geolocation, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
• Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

Information Collected From Other Sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).

2. How Do We Use Your Information?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Sites or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To facilitate account creation and logon process with your Consent. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
• To send you marketing and promotional communications for Business Purposes. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "What Are Your Privacy Rights" below). We never share your phone number with third parties for their own marketing purposes (see "How Do We Use Your Phone Number?" below).
• To send administrative information to you for Business Purposes and/or Legal Reasons. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• Fulfill and manage your purchases for Contractual reasons. We may use your information to fulfill and manage your, payments, refunds, and transfers made through the Sites or Apps.
• Deliver targeted advertising to you for our Business Purposes. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
• Request Feedback for our Business Purposes. We may use your information to request feedback and to contact you about your use of our Sites or Apps.
• To protect our Sites for Business Purposes. We may use your information as part of our efforts to keep our Sites or Apps safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions and policies for Business Purposes and/or for Legal Reasons.
• To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites or Apps, products, services, marketing and your experience.

3. Will Your Information Be Shared With Anyone?

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We only share and disclose your information in the following situations:

• Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites or Apps, which will enable them to collect data about how you interact with the Sites or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We never share your phone number with third parties for their own marketing purposes (see "How Do We Use Your Phone Number?" below).
• With your Consent. We may disclose your personal information for any other purpose with your consent.

4. How Do We Use Your Phone Number?

In Short: We use your phone number to contact you about your registration and swim lessons, and to follow up if you asked about lessons. We do not sell your phone number or share it with anyone for their own marketing. We may use it to show you our own ads on Google and Facebook. After we match you with an instructor, you can text each other through a Sunsational number, so neither of you sees the other's personal phone number.

When you give us your phone number, such as when you register, start a registration or ask about our services, we may call you or send you text messages, including automated text messages, to:

• Give you important information about your registration and swim lesson package, such as your schedule, your instructor, your lessons and your payments.
• Follow up if you started a registration or asked about lessons, to see whether we can help.
• Answer your questions and provide customer support.
• Show you Sunsational ads on Google and Facebook, as described below.

We do not sell, rent or trade your phone number, and no mobile information will be shared with third parties or affiliates for their own marketing or promotional purposes. All of the categories of sharing described in this policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. We share your phone number only:

• With service providers that deliver our calls and text messages on our behalf. They may not use it for any other purpose.
• With the advertising platforms Google and Meta (Facebook), so they can show our own ads to our customers and to people who have asked about our services, and measure how well those ads work.

Messaging With Your Instructor

After we match you with a swim instructor, you and your instructor can text each other through a phone number provided by Sunsational. Messages are passed through our messaging provider, so your instructor does not see your personal phone number and you do not see theirs. You and your instructor can send text messages, photos, videos and files.

These conversations are not private from Sunsational. Our staff may read them, including any photos, videos and files, to provide customer support, resolve problems, and help keep students, clients and instructors safe. We keep these conversations for as long as we need them for these purposes (see "How Long Do We Keep Your Information?" below). Please do not send payment details or other sensitive information in these messages.

Text Messages

See our Text Messaging Terms for the full terms of our text messaging programs.

• Message frequency varies. Message and data rates may apply.
• Reply STOP to any text message to opt out at any time. Opting out applies only to the number you reply to. If we text you from more than one number, such as our office number and the number you use to message your instructor, reply STOP to each one you want to stop. We will send one message confirming that you have opted out. If you opt out of messages with your instructor, you will not be able to text them until you opt back in.
• Reply START to the same number to opt back in.
• If you opt out, we will use email or phone calls for important information about your registration and lessons.
• Reply HELP to any text message for help, or contact us at office@sunsationalswimschool.com or (888) 788-2140.
• Mobile carriers are not liable for delayed or undelivered messages.

This section applies even where another section of this policy says otherwise.

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. A cookie is a piece of data stored on a site visitor's hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site.

6. Do We Use Google Maps?

In Short: Yes, we use Google Maps for the purpose of providing better service.

This website, mobile application, or Facebook application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google's Privacy Policy, please refer to this link.

By using our Maps API Implementation, you agree to be bound by Google's Terms of Service.

7. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment.

9. What Are Your Privacy Rights?

In Short: You may review, change, or terminate your account at any time.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites or Apps.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

• Email us to request removal from our email marketing at office@sunsationalswimschool.com

Opting out of text messages: Reply STOP to any text message from us to stop receiving text messages (see "How Do We Use Your Phone Number?" above).

10. Do California Residents Have Specific Privacy Rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Sites or Apps, you have the right to request removal of unwanted data that you publicly post on the Sites or Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites or Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.

11. Do We Make Updates to This Policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Last updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

12. How Can You Contact Us About This Policy?

If you have any further questions or comments about this or any of our policies, email us at office@sunsationalswimschool.com or by mail to: