Privacy Policy

This policy details the kind of personal information that we collect in our business, including through the Website and/or the App, and the ways in which we use it.

In this privacy policy, the terms "we", "us" and "our" refer to Gr8 Apps Pty Ltd ACN 650 814 378. The term "Website" means the website located at www.swimclubconnect.com and the term "App" means our Swim Club Connect application for Android and iOS.

Australian Privacy Principles

In Australia, The Privacy Act 1988 (the "Privacy Act") is the principal piece of Australian legislation protecting the handling of personal information about individuals. In this privacy policy, the term "personal information" has the meaning in the Privacy Act and includes information about an identifiable individual, including their name, gender, date of birth, address, telephone and fax numbers, email address, drivers' licence details, credit information and history, banking details, photographs, employment details and if and where applicable, information that constitutes "sensitive information". "Personal information" includes an opinion about an identifiable individual.

"Sensitive information" is a subset of personal information and includes information about a person's racial or ethnic origin, health information, political opinions, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices and criminal record.

1. Collection of personal information

We collect some personal information about individuals. A significant amount of personal information is primarily collected by Club Administrators. However, because the information resides on our database we technically "collect" it, although we would not typically access or analyze it without a legitimate reason.

We collect personal information from individuals in circumstances such as the following:

• When we meet or deal with an individual from an organization wishing to do business with us.
• When a person signs up to become a user of the App and/or when a person becomes an administrator ("Club Administrator") of a swim club.
• When a Club Administrator registers swimmers and adds their information to the App, which may include names, dates of birth, gender, contact information, emergency contacts, and performance data.
• When a user posts content that includes personal information through the App.
• When a user visits the Website or uses the App and sends an enquiry through or makes a comment or other post, through an email or via a social media platform.
• When a user signs up to receive marketing information.
• When we evaluate job applicants and personnel, which may include the collection of details such as employment history and educational qualifications.
• Where you are required to pay to purchase goods or services through the App (such as club dues or club merchandise), we (or Stripe, our payment services provider) will collect financial information such as credit card information and billing address.
• When clubs upload files from third-party swimming management software (such as HyTek Meet Manager or Team Manager) that contain swimmer information.

2. Other types of information we collect

We collect information on visitors to the Website, including information on which areas of the Website are most often accessed and how long visitors visit those areas.

We collect information from the App and your use of it, including information to assist us to identify the device upon which you use the App, such as your device's IP address, operating system and your email addresses, location-based data, searches, and other information you may input into or access from the App.

We may utilise "cookies" which enable us to monitor traffic patterns and to serve you more efficiently if you revisit the Website. A cookie does not identify you personally, but it does identify your computer. You can set your browser to notify you when you receive a cookie, and this will provide you with an opportunity to either accept or reject it in each instance. Rejecting cookies may have the effect of limiting your access to parts of the Website.

We may collect information about your computer or device, including where available, your IP address, operating system, and browser type, for system administration and to report aggregated information. This is statistical data about our users' browsing actions and patterns and does not identify any individual.

3. Use and disclosure of personal information

We may use personal information for the purpose of marketing but only where such use complies with the Australian Privacy Principles.

We use the personal information collected from you for the purpose it was provided or collected, including in the following ways:

• To enable Club Administrator(s) to manage their swim clubs, communicate with club members, and organize swim meets.
• To display swimmer information and performance data when authorized by the club or during multi-club meet participation.
• For use for the purposes of collection described in section (1) above.
• To respond to enquiries received from you.
• To perform authorized financial transactions with you through our payment processor, Stripe.
• To enable the provision of location based services to you.
• To verify your identity and to assist you if you have forgotten any username or password.
• To communicate with you and provide you with information (whether by email, post, or other means) about our products or services, where you have requested or consented to receive this from us or where this provision is otherwise permitted under the Australian Privacy Principles.
• To notify you about changes to the Website or App.
• To ensure that content from the Website, App is presented in the most effective manner for you and for your device.
• To allow you to participate in interactive features of our Website or App when you choose to do so.
• To receive and address feedback or complaints from you.
• To protect our legal interests and fulfil our regulatory obligations (if and to the extent necessary).
• In other circumstances, with your prior consent.

All users and others with whom we interact have the option to opt out of receiving email marketing communications from us. If you do not wish to continue to receive electronic marketing communications from us and/or selected third parties, you should opt out by clicking on the "unsubscribe" link in any email communications that we might send you.

Except where otherwise stated by us in this privacy policy or the terms and conditions of our App, we will not, without your consent, sell or otherwise provide your personal information to a third party, or make any other use of your personal information, for any purpose which is not incidental to your use of the Website or the App.

We may disclose personal information, and you consent to us doing so, to our related entities for the purpose for which it was collected or otherwise advised under this policy.

We may disclose or make available personal information, and you consent to us doing so, to third parties who are engaged by us to perform functions or provide products and/or services on our behalf, such as third party hosting service providers (including Google Cloud Platform) and other providers of software products and related services (for the purpose of facilitating the operation of features of the Website and App and to collect and track certain data and information regarding the characteristics and activities of our users). In turn, those providers may utilise the services of other third parties to assist in these functions, on the condition that they do not use or disclose any personal information for extraneous purposes.

We may also disclose such information as required or permitted by any law, including in response to lawful requests by law enforcement or regulatory authorities.

4. Security and storage of personal information

All user data is stored using Google Cloud Firebase in the australia-southeast1 region (Sydney, Australia). This ensures compliance with Australian data sovereignty requirements and provides optimal performance for Australian users.

We take all reasonable steps to protect your personal information, including:

• Encryption of data in transit using industry-standard SSL/TLS protocols
• Encryption of sensitive data at rest
• Internal and external security measures, restricting access to personal information to those who have a legitimate need to know
• Regular security reviews and updates to maintain technological safeguards
• Secure authentication mechanisms for all user accounts
• Access logging and monitoring for administrative actions

We treat website and payment security seriously and endeavour to provide a secure, safe platform through which to conduct transactions. All payment processing is handled by Stripe, a PCI-DSS compliant payment processor. We do not store credit card information on our servers.

While we implement strong security measures, you acknowledge that no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

5. Swimmer Data Protection

For swim clubs using our services:

Swimmer Information Collection:

Swimmer data may include:

• Name and date of birth
• Gender/sex
• Club membership information
• Swimming performance data and meet results
• Emergency contact information (where provided by club)
• Parent/guardian contact information

Multi-Club Meet Data Sharing:

Competitive swimming, by its nature, involves sharing certain information during swim meets. When your club participates in a multi-club swim meet:

• Swimmer names, ages, gender, club affiliation, and entered events are shared with the meet organizer
• During the meet, all participating families can view swimmer information and results for all swimmers in that specific meet
• This visibility is limited to the participants of each specific meet
• Meet results including names, times, and placements may be retained for historical and statistical purposes
• Performance data may be used for club rankings, personal best tracking, and meet records

This data sharing is standard practice in competitive swimming and is necessary for meet management and competition. If you have concerns about your swimmer's participation in multi-club meets, please contact your Club Administrator.

Enhanced Protections for Swimmer Data:

• Swimmer records are subject to additional access restrictions beyond general user data
• Parent/guardian consent is required for swimmers under 18 years of age
• All Club Administrator access to swimmer information is logged and monitored
• Swimmers from different clubs cannot view each other's private contact information
• We are implementing enhanced parent-guardian verification processes

Data Minimization:

• We collect only the minimum personal information necessary for swim club management and meet participation
• Swimmer data is used solely for swim club operations, meet management, and related swimming activities
• No swimmer data is used for commercial marketing purposes
• Performance analytics are used for individual swimmer tracking and club statistics only

6. Third-Party Integrations and Data Sharing

HyTek Meet Manager and Team Manager:

Our App allows clubs to upload files from and export data to HyTek Meet Manager and Team Manager software formats. This functionality enables:

• Import of swimmer rosters and performance data from existing club management systems
• Export of meet entries and results in formats compatible with external meet management software
• Integration with widely-used swimming competition management tools

Club Administrator Responsibility: Club Administrators are responsible for ensuring they have appropriate consents from parents/guardians before uploading swimmer data from external sources or exporting data for external use. By uploading or exporting data, Club Administrators warrant that they have obtained necessary permissions.

Payment Processing - Stripe:

All payment processing (including club dues and merchandise purchases) is handled securely through Stripe Connect, our payment services provider. When you make payments through the App:

• Stripe collects and processes your payment information according to their privacy policy
• We do not store your credit card numbers on our servers
• Your payment information is transmitted securely using encryption
• We may receive limited transaction information (amount, date, success/failure status) but not your full card details

For more information on how Stripe handles your data, please see Stripe's Privacy Policy at: https://stripe.com/privacy

Google Services:

For information as to how Google uses data as a consequence of the use of the App, please see: How Google uses information from sites or apps that use our services.

Please note also that we may, in connection with Google Platform Products that we use, collect, process, or disclose information that identifies or can be used to infer an end user's precise geographic location, such as GPS, Wi-Fi or cell tower data. We will only send such information to Google in an encrypted state or via an encrypted channel.

Cloud Hosting:

Our services are hosted on Google Cloud Firebase infrastructure in the australia-southeast1 region (Sydney, Australia). This means your data is primarily stored on servers located within Australia, supporting Australian data sovereignty requirements. Google Cloud maintains appropriate security certifications and complies with international data protection standards. While the primary database is in Sydney, Google's infrastructure may involve some global services for redundancy, analytics, and platform functionality. By using our services, you consent to this data storage and processing arrangement.

7. Future Data Sharing with Swimming Organizations

We may in the future establish data sharing relationships with official swimming bodies such as Swimming Australia and state swimming organizations (e.g., Swimming Queensland, Swimming NSW). Such sharing would be for purposes including:

• Competition rankings and records verification
• Qualifying times for state and national competitions
• Swimmer registration and eligibility verification
• Statistical analysis and development of the sport

Important: We will notify all users and obtain appropriate consent before implementing any such data sharing arrangements. You will have the opportunity to opt-out, though this may limit your ability to participate in certain sanctioned competitions.

8. Sharing with businesses, individuals, and clubs we do not control

The App by its nature means that other third party businesses, individuals and clubs may obtain personal information from you during multi-club meets or other swimming activities, in respect of which we cannot exercise significant practical control. While we endeavour to have those third parties adhere to terms and conditions that require them to respect the privacy of personal information, we cannot guarantee that they will do so.

Parents and Club Administrators should exercise appropriate caution and judgment when sharing information through the App or during swimming activities.

9. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes outlined in this privacy policy:

General Data Retention:

• User account data: Retained while account is active plus 7 years after account closure (to comply with Australian business and tax record requirements)
• Swimming records and results: Retained for historical and statistical purposes unless deletion is specifically requested and legally permissible
• Communication logs and support tickets: Retained for 2 years for customer support purposes
• Financial transaction records: Retained for 7 years in accordance with Australian tax law requirements

Swim Club Data:

• Swimmer records: Retained while the swimmer is active in the club plus 7 years after departure
• Meet results and performance data: Retained indefinitely for historical records and personal best tracking, unless deletion is requested
• Club Administrator records: Retained per club requirements and for 7 years after administrator role ends

Deletion Rights:

Users and parents/guardians may request deletion of personal information at any time by contacting us at the details below. We will comply with deletion requests subject to:

• Legal retention requirements (e.g., tax and business records)
• Legitimate business needs (e.g., dispute resolution, contract enforcement)
• Historical swimming records (performance data may be retained in de-identified form for statistical purposes)

To request deletion of your data, please email: ad***@*************ct.com with "Data Deletion Request" in the subject line.

10. Age Verification and Parental Consent

Swim Club Connect is designed for use by swim clubs that include swimmers of all ages, including minors under 18 years of age.

Parental Consent Requirements:

• For swimmers under 18 years of age, a parent or legal guardian must provide consent for the collection and use of the swimmer's personal information
• Parents/guardians register on behalf of their minor swimmers and maintain control over their swimmer's information
• Club Administrators are responsible for verifying parent-guardian relationships before granting account access
• By registering a swimmer, parents/guardians warrant that they have legal authority to provide consent on behalf of the swimmer

Transition to Adult Accounts:

When a swimmer reaches 18 years of age, they may request to transition to their own account with direct control over their information. Please contact your Club Administrator or our support team to facilitate this transition.

Enhanced Verification:

We are implementing enhanced parent-guardian verification processes to strengthen protection of minors' data. These measures will include verification procedures for Club Administrators when adding new families to their clubs.

11. Data Breach Notification

We take data security seriously and have implemented measures to prevent unauthorized access to personal information. However, in the event of a data breach that is likely to result in serious harm to affected individuals, we will:

• Notify affected users as soon as practicable after becoming aware of the breach
• Notify the Office of the Australian Information Commissioner (OAIC) as required by the Privacy Act
• Provide information about the nature of the breach, the personal information affected, and steps being taken to address the breach
• Recommend steps that affected individuals can take to protect themselves

Notifications will be made in accordance with the requirements of the Privacy Act 1988 (Cth) and the Notifiable Data Breaches (NDB) scheme.

12. Questions, concerns, and access to your personal information

You are entitled to have access to any personal information relating to you which you have previously supplied to us. To obtain a copy of the personal information we hold about you please write to us using the contact details provided below.

Your Privacy Rights:

• Access your personal information
• Request correction of inaccurate data
• Request deletion of your data (subject to retention requirements)
• Opt-out of marketing communications
• Receive information about how your data is used
• Withdraw consent for data processing (where consent is the basis for processing)
• Restrict certain uses of your personal information

How to Exercise Your Rights:

To exercise any of these rights, please contact us at ad***@*************ct.com. We will respond to your request within a reasonable timeframe, typically within 30 days. We may need to verify your identity before processing your request.

13. Other

If at any time you provide or disclose personal information about someone other than yourself (such as registering your child as a swimmer), you must ensure and you warrant that you have that person's consent to provide such information for the purpose specified.

While this website and the App are not intended to target children for independent use, we recognize that minors participate in swimming clubs under parental supervision. We consider it is the responsibility of parents/guardians to monitor their children's use of our Website and App. For swimmers under 18, we work with parents/guardians and Club Administrators to ensure appropriate consent and oversight for swimmer data.

In the event that our business is ever sold, acquired, merged, liquidated, reorganised or otherwise transferred, we reserve the right to transfer to the extent permissible at law, our user databases, together with any personal information and non-personal information contained therein to a third party acquiring the assets. We will notify users of any such transfer and provide information about how personal information will be handled by the acquiring party.

14. Overseas Disclosure of Personal Information

We primarily store data within Australia using Google Cloud Firebase's Sydney data center (australia-southeast1 region). However, we may make personal information available to businesses located outside Australia for specific services:

• Google Cloud Platform / Firebase - primary data hosting (Sydney, Australia with Google's global infrastructure for redundancy and services)
• Google - analytics and platform services
• Stripe - payment processing services (United States)

While our primary database is located in Australia, Google's infrastructure may involve some data processing or backup functions that occur on servers outside Australia as part of Google's global cloud services. Google maintains appropriate security and privacy standards and complies with international data protection requirements.

These third party service providers agree that they will not use or disclose the personal information for unrelated or extraneous purposes. By using our services, you consent to this storage and limited overseas processing of your personal information.

15. Changes to and limitations of this policy

We reserve the right to make changes to this policy. Such changes will be updated on the Website and within the App following the making of such changes. We will notify users of material changes via email or through prominent notice in the App.

The Website and App may provide links to other third party sites as a service to our users. Our privacy policy described here does not apply to those sites. Please ensure that you review and agree with the terms and conditions and privacy policy of any linked website before providing any personal information.

This privacy policy should be read in conjunction with our Terms of Service.

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This privacy policy was last updated: October 24, 2025

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