Who we are
The Swing Dance Company is the brand name for a collection of independently owned businesses running as franchises under Swing Dance Partnerships Limited. The franchise owners at present are all sole traders Brooke Garvey (t/a The Swing Dance Company) and Debbie Garvey (t/a Jivecourses). Each franchise owner pays a management fee to Swing Dance Partnerships Limited for services including management of The Swing Dance Company website.
All activities operate in line with the The Swing Dance Company’s policies. Information can be found at our website, the address is: https://theswingdancecompany.co.uk.
Whilst we treat our customers’ privacy and data with utmost importance, we are also realistic about the size and nature of our company, and our scope to handle the requirements of GDPR. Generally we aim to select reliable and trustworthy, world-leading suppliers for our technology needs who are subject to high levels of scrutiny under GDPR. We keep our systems and knowledge up-to-date, and strive to follow best practice.
We have a personal and trusting relationship with most of our customers and would encourage anybody with any concerns about our treatment of privacy and data to get in touch.
What personal data we collect and why we collect it
We collect both personal and anonymous data when you send us information or visit our website. In general, you may visit the website without telling us who you are, or revealing any personally identifiable information about yourself. However, when we do collect data it falls into one of the areas in the following paragraph.
Most information is collected when customers sign-up on our website to attend an event. Other ways we collect data include completing the “Join Our Mailing List” form on our website, by positively requesting to be added to our mailing list by email, or by completing a physical form when attending an event.
When booking for an event online, the contact details that we need include, title, first name, surname, postal address, email address and telephone number. This information is not normally collected unless it is provided voluntarily. It is necessary to collect such information in order to be able to make contact in the event of changes or cancellations to the event, and to advise you of associated or continuation events.
When you visit our websites, we may collect information about your visit; your usage of the Services, and your web browsing. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Websites or other websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies.
Event Registration Process
During the event registration process we collect information about you. This information may include but is not limited to:
- Your names
- Address
- Email address
- Phone number
- Location and traffic data (including partial IP address and browser type)
- Any other details that might be requested from you for the purpose of processing your registration or ticket purchase
Handling this data also allows us to:
- Send you important account/purchase/service information.
- Respond to your queries, refund requests, or complaints.
- Process payments and prevent fraudulent transactions. We do this on the basis of our legitimate business interests.
- Set up and administer your account, provide technical and customer support, and to verify your identity.
Billing Information
In order to process payments, we collect billing information on-site. Sensitive billing information is not stored on our server, but may be handled while in-transit to the payment processing server.
Please see the privacy policy of our processor Stripe.com at https://stripe.com/gb/privacy.
Masked billing information may be stored on our servers (only the last 4 digits of credit card numbers are stored: **** **** **** 1234).
Cookies
When you begin registering for an event and select a ticket quantity, a cookie will be used to track your registration. This cookie lasts 1 hour.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select "Remember Me", your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Email History
We keep a record of all email communications indefinitely. This is to ensure communication is successfully sent and its information is accurate. Emails received are retained for customer service purposes, but we do not use the information submitted through them for marketing purposes.
Event Check-In Record
When you attend an event, an event manager may record the time you check in or out of the event.
Data Retention
If you process a registration, the registration and its metadata are retained indefinitely. This is so that we can assist customers who request information about which courses, classes or events they have previously participated in, which is relevant in the case of advice being sought for future registrations.
For users that register a user account on our website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Contact forms
We keep emails that contain the contents of contact form submissions indefinitely for customer service purposes, but we do not use the information submitted through them for marketing purposes.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
Analytics
The Swing Dance Company website uses Google Analytics. Google Analytics mainly uses first-party cookies to report on visitor/user interactions on our website. Users may disable cookies or delete any individual cookie.
Google’s privacy policy can be found on this link https://policies.google.com/privacy?hl=en and information about opting out of google analytics can be found on this link https://policies.google.com/technologies/cookies
Legal Bases for Collecting and Using Information
Under the GDPR, there are a number of approved reasons (or "legal bases") a company might legitimately process a person's data. Below, we've outlined the most relevant legal bases under the GDPR.
Contractual necessity - When it is necessary to process booking data for classes or events in order that we can communicate essential information relating to that booking.
Consent - This is unambiguous, freely given consent, for example through accepting our cookie notice online or by joining our mailing list online, on physical forms, or by request on email. People have the right to withdraw consent, our marketing emails carry clear “unsubscribe” links.
Legitimate Interests - Our company's legitimate interests are the lawful basis on which we process marketing emails to our customers. This process is necessary to achieve our commercial interest as it is the only route to contacting our customers. It is considered that individual customers with whom we have had a relationship would reasonably expect us to contact them by email. As emails are sent infrequently, so the impact is minimal and they are unlikely to object when balanced against the individuals interests, rights and freedoms. All marketing emails carry unsubscribe links.
Who we share your data with
We do not sell any private personal information. We share data with the following specific companies in order to deliver our services. Where available links are provided to their own privacy policies;
Mailchimp - names, email addresses, phone numbers and details of previous events attended are held by Mailchimp on their servers in USA. They are certified as compliant under the EU-US Privacy Shield Framework. They provide services for our email marketing https://mailchimp.com/legal/privacy/
Textmagic.com - Any SMS communications are processed through textmagic.com, a UK based service. SMS messages are sent through their systems and numbers are held on their servers. https://textmagic.com/privacy-policy/
Stripe.com - provides online card transactions on this website. They are a US company and they are certified under the EU-US Privacy Shield Framework. https://stripe.com/gb/privacy
Google - we use Google cloud storage and the G Suite range of applications including Gmail, where contact names, mobile numbers and email addresses are stored. Google are certified under the EU-US Privacy Shield Framework https://policies.google.com/privacy?hl=en
WPEngine - web hosting company who host our website, including databases https://wpengine.co.uk/legal/privacy/
Transferring Information
Because several of The Swing Dance Company’s technology suppliers are based in the US, the information about you that we process may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA). When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. In the case of US based entities ensuring they have signed up to the EU-US Privacy Shield.
More generally we may share data with the following:
Franchisees, Employees and Independent Contractors: We may disclose information about you to our franchisees, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our employees and independent contractors to follow this Privacy Policy for personal information that we share with them.
Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us like payment providers, fraud prevention services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, our hosting provider, those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers), who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them.
To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect our rights, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury.
Business Transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that The Swing Dance Company goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
How we protect your data
We understand that treating your data safely and securely is extremely important. As a small company we have worked to build trust with our customers and that data security is a key component of this. When selecting technology partners and suppliers we always look for trusted, world leading organisations who can provide excellent systems, subject to the highest levels of scrutiny under GDPR.
Our own small administrative team keep their knowledge up-to-date and have a common-sense approach to security requirements. For example, the use of 2-step verification, by installing new system updates as soon as they are available, and following the latest advice about the treatment of emails, links and attachments to reduce malware, viruses and ransomware on our system. We use Security plug-ins on our website to protect it and the data contained within it.
When data could be accessed by 3rd party individuals, for example temporary or support staff, they would be provided with a temporary set of credentials and monitored whilst actively operating.
Choices
You have several choices available when it comes to limiting information about you:
Limit Access to Information On Your Mobile Device: Your mobile device operating system should provide you with the ability to discontinue our ability to collect stored information or location information via our mobile apps.
Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the unsubscribe instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about pre-booked courses and events.
Set Your Browser to Reject Cookies: You can usually choose to set your browser to remove or reject browser cookies.
What rights you have over your data
Under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
EU individuals also have the right to make a complaint to a government supervisory authority.
You can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us.
Brooke Garvey can be contacted at brooke@theswingdancecompany.co.uk or by post at 4 Winchester Road, Crampmoor, Romsey, SO51 9AL. Thank you for visiting the The Swing Dance Company website and reviewing our privacy policy.