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Privacy policy

Privacy policy

Introduction

Hilton Brown Swimming Ltd (we, us, our) complies with the Privacy Act 2020 when dealing with personal information. Personal information is information about an identifiable individual.
This policy explains how we collect, use, disclose and protect your personal information when you use our booking system (Udio), our website, or contact us. This policy does not limit or exclude any of your rights under the Act. For more
information, see www.privacy.org.nz.

Our details and Privacy Officer

Collecting agency: Hilton Brown Swimming Ltd (trading as Hilton Brown Swimming), our address is available on our website. Privacy Officer contact: info@hiltonbrownswimming.co.nz.

Changes to this policy

We may change this policy by uploading a revised policy onto the website. The change will apply from the date that we upload the revised policy.

What information we collect

We may collect personal information such as:

  • parent/guardian contact details (name, address, phone, email)
  • swimmer details (name, date of birth, and booking/class information)
  • attendance history and lesson progression information
  • communications with you (emails and enquiry or complaint history)
  • limited payment-related information (transaction references, dates, amounts,
    and payment status)
  • technical information from our website/online services (for example IP
    address, device/browser information, and usage data)

Children and young people

Most swimmers are children. A parent or legal guardian typically provides the child’s information and manages the booking. If we receive a request for access to a child’s personal information, we may need to confirm the requester is authorised to act on the child’s behalf. We may also consider the child’s age and maturity, and what is in the child’s best interests, before releasing information.

How we collect personal information

We collect personal information when you:

  • enter details in Udio or complete forms at reception
  • contact us by phone, email or other channels
  • use our website and online services (where applicable)

What you need to know at collection time

Providing personal information is generally voluntary. However, some information is needed to set up a booking, manage lessons, and take payment. If you do not provide the required information, we may be unable to confirm or maintain your
booking.

How we use your personal information

We use your personal information:

  • to verify your identity (where needed)
  • to provide services and products to you (including managing bookings and lesson placements)
  • to communicate with you about bookings, lessons, closures, and your account
  • to market our services and products (for example by text or email). You can opt out of marketing at any time by using the unsubscribe link in our emails (where available) or contacting us
  • to improve the services and products we provide
  • to collect money you owe us, including administering recurring payments through our payment provider
  • to respond to communications from you, including complaints
  • to conduct research and statistical analysis on an anonymised basis
  • to protect and enforce our legal rights and interests
  • for any other purpose authorised by you or permitted by law.

Payments (Payrix NZ Limited)

We use Payrix NZ Limited to process recurring payments. When you choose to pay by direct debit or credit/debit card, your bank account or card details are collected and stored by Payrix (not by Hilton Brown Swimming).

We receive payment outcomes and may store limited payment-related information such as transaction references, dates, amounts, and payment status to manage your account.

Disclosing your personal information

We may disclose your personal information to:

  • service providers that support our services and systems (including hosting, IT support, booking systems, and payment processors such as Payrix NZ Limited)
  • email and communications providers used to send service messages and marketing communications (for example Mailchimp, where used)
  • analytics and advertising partners used to measure campaigns and show our ads (for example Google, Meta (Facebook/Instagram), and TikTok, where used)
  • regulators or law enforcement where we are legally required or permitted to do so
  • others where you have authorised disclosure.

Some service providers may be located outside New Zealand. Where we disclose personal information outside New Zealand, we only do so where we believe on reasonable grounds that the recipient is subject to the Privacy Act 2020, is required to protect the information with comparable safeguards (for example under an agreement), or you authorise the disclosure after being told the information may not receive the same protection as it would in New Zealand.

Protecting your personal information

We take reasonable steps to keep your personal information safe from loss, unauthorised access, disclosure, alteration, or other misuse.

Retention and disposal

We keep personal information only for as long as needed for the purposes set out in this policy, including legal, accounting, and dispute resolution requirements. When it is no longer needed, we take reasonable steps to securely delete or anonymise it.

Accessing and correcting your personal information

Subject to the grounds for refusal in the Act, you have the right to access your readily retrievable personal information that we hold and request correction. If you want to exercise these rights, email info@hiltonbrownswimming.co.nz. We
may need evidence to confirm your identity. We may charge reasonable costs where permitted.

Privacy breaches

A privacy breach includes unauthorised or accidental access to, disclosure of, or loss of personal information. If a breach has caused, or is likely to cause, serious harm, we will notify affected individuals and the Office of the Privacy Commissioner as required by law.

Complaints

If you have concerns about how we handle your personal information, contact us at info@hiltonbrownswimming.co.nz and we will work with you to resolve the issue. You can also complain to the Office of the Privacy Commissioner.

Internet use, cookies and tracking

While we take reasonable steps to maintain secure systems, providing information over the internet is never completely risk-free.

We use cookies and similar technologies to:

  • keep our website working properly
  • understand how people use our website (analytics)
  • measure the performance of our marketing campaigns.

Depending on what features are enabled, our website and communications may use third-party tools (for example Google Analytics, Meta Pixel, TikTok Pixel, and email tracking) that collect information such as cookie identifiers, device information, and how you interact with our website or emails. You can disable cookies in your browser settings, and you may also be able to adjust advertising preferences directly within Google, Meta, or TikTok account settings. If you opt out of cookies, some website features may not work as intended.

Last updated: 16 February 2026