1. Who We Are & How to Contact Us

Un.Con.Fused Digital Ltd | Registered in England and Wales | Company No: 14513006 | Trading as SwimPro360 (“we”, “our”, “us”) is a swimming performance tracking application operated as a sole trader / company registered in England and Wales.

• Data Controller: SwimPro360
• Privacy enquiries: privacy@swimpro360.com
• App support: appsupport@swimpro360.com
• Legal contact: legal@swimpro360.com

2. Data We Collect

• Account data – name, email address, club affiliation, role (coach / parent / swimmer).
• Performance data – swim results, personal bests, training logs, FINA points, race splits, attendance records.
• Minor athlete data – entered by a verified parent/guardian or club coach with parental consent on record.
• Device & technical data – device type, OS version, app version, crash logs (for debugging only).
• Usage analytics –anonymised feature interactions to improve the app. You can opt out in Settings → Privacy.
• Payment data – handled exclusively by Stripe. We receive only a subscription status confirmation — we never see or store card details.
• Support communications – messages you send via the in-app support form, stored to resolve your query.

3. Legal Basis for Processing (GDPR / UK GDPR)

• Contract – processing necessary to provide the service you subscribed to.
• Legitimate interests – anonymised analytics, crash reporting, fraud prevention.
• Consent – optional analytics, marketing emails, notifications (you can withdraw at any time). • Legal obligation — retaining billing records as required by UK tax law.

4. How We Use Your Data

• To provide app features: PB detection, FINA scoring, AI coaching insights, race analysis.
• To send transactional emails: support replies, account deletion confirmations, data export links.
• To process and manage subscriptions via Stripe.
• To improve app stability and performance via crash reporting.
• We never sell, rent, or share your personal data with third parties for marketing.

5. Children’s Data & COPPA / GDPR-K Compliance

SwimPro360 is designed for use by coaches and parents to track athletes who may be under 13 (US) or under 16 (EU/UK).

• Children do not create their own accounts. All data for minors is entered by an adult account holder (coach or parent) who confirms parental/guardian consent.
• We do not use children’s data for advertising, profiling, or any purpose beyond performance tracking.
• Children’s data is not shared with third parties except as described in Section 8.
• Parents or guardians may request access, correction, or deletion of a child’s data at any time: privacy@swimpro360.com

6. Data Storage, Retention & Security

• Data stored on secure servers (Base44 / Supabase, EU).
• Encrypted using TLS 1.2+ in transit and AES‑256 at rest.
• Retained for the lifetime of the account.
• Permanently erased within 30 days of account deletion.
• Anonymised aggregate data may be retained for analytics.
• Billing records retained for seven years under UK HMRC regulations.

7. Your Rights

Under GDPR / UK GDPR / CCPA you have the right to:

• Access
• Rectification
• Erasure (“Right to be Forgotten”)
• Restriction
• Portability
• Object
• Withdraw consent
• Lodge a complaint

To exercise your rights, contact privacy@swimpro360.com. You may also contact the UK ICO: ico.org.uk We respond within 30 days.

8. Third-Party Services & Data Processors

• Base44 / Supabase – backend hosting and database (EU servers).
• Stripe – payment processing. Your card data goes directly to Stripe and is never stored by us.
• Resend – transactional email delivery (support replies, confirmations only).
• Apple App Store / Google Play – app distribution and in‑app purchase processing.

All processors are bound by Data Processing Agreements and handle data only as instructed by us.

9. App Permissions

• Camera / Photo Library – optional; used only to upload a swimmer profile photo. Never accessed without your explicit action.
• Push Notifications – optional; used for gala reminders and PB alerts. Disable at any time in your device Settings or in Settings → Notifications.
• Location – optional; used only when you tap “Find Venue” when adding a gala. Never tracked in the background or stored without your action.

10. International Data Transfers

Your data is stored within the EU/EEA. If any transfer outside the EEA occurs (e.g. via Stripe’s global infrastructure), it is protected by Standard Contractual Clauses (SCCs) and UK IDTAs.

11. Subscriptions & Billing

Subscriptions are processed by Stripe. Prices are displayed in your local currency at the point of purchase. Subscriptions auto‑renew unless cancelled at least 24 hours before renewal. You can manage or cancel via Settings → Subscription or your device’s app store settings. Free trial periods are clearly stated before purchase. You will not be charged during a trial. Refund requests should be directed to Stripe or your app store.

12. Cookies & Tracking

The SwimPro360 mobile app does not use browser cookies. The web version may use essential session cookies required for authentication. No third‑party advertising trackers are used. You can opt out of anonymised analytics in Settings → Privacy.

13. Changes to This Policy

We will notify you of significant changes via an in‑app banner and email (where applicable). The “Last updated” date at the top of this page reflects the most recent revision. Continued use after the effective date of changes constitutes your acceptance.

For all privacy matters: privacy@swimpro360.com