SwingFIT Academies (DIFC) Limited and its affiliates (collectively the “Company”, “we” or “us”) is the data controller responsible for your personal data under this privacy policy, and we value your security and privacy. In accordance with the DIFC Law No.5 of 2020 as amended by DIFC Law No.1 of 2025 (the “Data Protection Law”) and our Terms and Conditions, this privacy policy (the “Policy”) outlines:
(i) the categories of personal data we collect; (ii) the legal basis and purpose for processing such data; (iii) your rights as a data subject, including your right to access, correct, erase, or restrict the processing of your personal data; (iv) how you may exercise those rights by contacting us via the communication channels provided below.
We may collect your personal data when you use our website or otherwise interact with us. You may at any time request access to, rectification of, or erasure of your personal data, or object to or restrict its processing, by contacting our Data Protection Officer or writing to us using the contact details provided in this Policy.
This is our official website: https://swingfitacademies.com/ What is included in this Policy
What data do we collect?
How do we collect your data?
Why do we process your data?
Do we share your data with third parties?
How do we protect your data?
How long do we keep your data?
Marketing
What are your data protection rights?
Cookies
What types of cookies do we use?
How to manage your cookies
Children
Privacy policies of other websites
Changes to our Policy
How to contact us
What data do we collect?
1.1. Data that you give us:
a. Name b. Email address c. Phone number d. Mailing address e. Social media handles f. Payment information (if applicable)
1.2. Data that we collect from you: a. Technical information (including but not limited to IP Address, operating system, unique device identifiers, time zone settings, browser information) b. Behavioural Data (including but not limited to browsing behaviour and interaction history on our website) c. Cookie data (see point 9 below) d. Records of correspondence between you and us
1.3. Any information relating to an identified or identifiable natural person provided to us or collected by us, on its own or in combination with other non personally identifiable information can be used to identify an individual specifically, shall be classified and treated as personal data under this Policy.
How do we collect your data?
We collect and process your data when you: a. Place an order or make a booking for any of our products or services. b. Voluntarily complete a customer survey or interact with any of our company communication channels, including via telephone, email, other digital forms and our social media platforms c. Use or view our website via your browser’s cookies
Why do we process your data? 3.1. The below table outlines: i. Our purposes for collecting your data ii. Our legal justifications (each a “legal basis”) under the Data Protection Law for each purpose iii. Categories of data that we use for each purpose
3.2. Here is an explanation of each legal basis to help you understand the table: a. Performance of a contract: When it is necessary for our Company or a third party to process your data to: i. Comply with obligations under a contract with you. This includes our obligations under the Terms and Conditions to avail our products and services ii. Verify information prior to you entering into a contract with us
b. Legitimate interest: When we have a legitimate interest in processing your data in a certain way, which is necessary and justifiable considering the risks the processing may pose. c. Consent: Where you have given your consent for the data to be processed for one or more specific purposes. d. Compliance with legal obligations: Where we must process your data to comply with a law.
Purpose Of Processing
Legal Basis
Categories Of Data Used
Providing you with our products or services
Performance of a contract
Name Email Address Phone Number Social Media Handles Payment Information Technical Information Cookie Data
Addressing any enquiries you have regarding the products and services
Legitimate interest
Name Email Address Phone Number Social Media Handles Payment Information Technical Information Cookie Data
Monitoring and improving our services
Legitimate interest
Name Email Address Phone Number Social Media Handles Technical Information Cookie Data
Conducting research and surveys
Consent
Name Email Address Phone Number Social Media Handles Technical Information Cookie Data
For marketing and advertising purposes
Consent
Name Email Address Phone Number Social Media Handles Technical Information
Processing on request of government or regulatory authorities
Compliance with legal obligations
Name Email Address Phone Number Payment Information
Technical Information Cookie Data
Establishing or defending legal claims
Legitimate interest
Name Email Address Phone Number Technical Information Cookie Data
3.3. We will take all steps reasonably necessary to ensure your personal data is processed fairly and lawfully, in accordance with the Data Protection Law and this Policy. 3.4. Unless otherwise notified, we do not ordinarily rely solely on automated decision making when processing your personal data.
Do we share your data with third parties?
4.1. We may share your information with third parties as follows: a. To our subsidiaries and affiliated entities, where permitted under applicable law b. To payment service providers to process payments c. To management partners who manage your bookings and provide us with customer management services d. To government or law enforcement authorities if requested or required under applicable law
4.2. In order to conduct our operations or fulfil regulatory obligations, we may transfer, process or store the personal data described in this Policy outside of the Dubai International Financial Centre (DIFC) including to countries that may not offer an equivalent level of data protection. Where such transfers occur, we take appropriate security measures and implement appropriate safeguards in accordance with the Data Protection Law to protect your personal data in accordance with this Policy.
4.3. We rely on you to provide accurate and complete personal data. We will update or rectify your personal data when you notify us of changes or inaccuracies, in accordance with this Policy and our obligations under applicable law.
How do we protect your data?
5.1. We make every effort to ensure that your data is secure on our systems. We have staff dedicated to maintaining our data protection and security policies, periodically reviewing them, conducting periodic assessments and scheduling regular internal training sessions for making sure that our employees are aware of our data protection and security practices. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, we cannot warrant or guarantee the security of any personal data you transmit to us, and you do so at your own risk.
We implement appropriate technical and organisational measures to ensure a level of security
appropriate to the risk, in accordance with the Data Protection Law.
5.2. We have established policies and procedures for securely managing information
and protecting personal data against unauthorized access. We continually assess our
data privacy information management and security practices. We do this in the following
ways:
a. Establishing policies and procedures for securely managing information
b. Limiting employee access to viewing only necessary information in order to perform their
duties
c. Protecting against unauthorized access to personal data by using data encryption,
anonymization and authentication as required
d. Requiring service providers with whom we do business to comply with relevant data
privacy legal and regulatory requirements
e. Monitoring our websites through recognized online privacy and security organizations
f. Engaging in regular third party audits of our policies and practices
g. Conducting background checks on employees and providing training to our employees
h. Maintaining a Data Breach Response Plan and notifying the DIFC Commissioner of Data
Protection and affected Data Subjects where required under the law
i. Ensuring personal data is retained only for as long as necessary and securely disposed
of, in accordance with our data retention policy
How long do we keep your data?
6.1. We keep your personal data only for as long as necessary to fulfill the purposes for which it was collected, which include: a. Providing you with our services; b. Maintaining the quality and performance of our products and services c. Supporting internal data analytics and decision-making processes; d. Addressing complaints, inquiries, feedback and disputes e. Complying with applicable legal, regulatory and contractual obligations f. Where applicable, meeting the minimum retention periods required under DIFC laws
6.2. Retention periods are determined in accordance with the nature of the data, our legal obligations (including those under DIFC law), and the purposes for which the data was collected and processed.
6.3. Where personal data is no longer required, it will be securely deleted, anonymised, or pseudonymised, unless further retention is required to comply with legal or regulatory obligations.
Marketing 7.1. If you have agreed to receive marketing communications from us and our partners, you may always opt out at a later date. You may withdraw your consent at any time or object to the processing of your personal data for direct marketing purposes. You have the right at any time to stop us from contacting you for marketing purposes.
7.2. Please note that we may continue to send you transactional or service-related e-
mails necessary for your use of our products or services.
7.3. Please note that if you unsubscribe from our marketing communications, this will
not affect promotional messages from third parties or unaffiliated marketers whose
services you accessed via our website. We do not control the marketing practices of
such third parties and you should contact them directly to exercise your opt-out rights.
7.4. Finally, we will remove your personal data from our direct marketing lists upon
request but please be aware that if such information is also held by a different third
party’s marketing directory through your request or election, you will need to request
removal with such third party directly.
What are your data protection rights? 8.1. You have the right to access information held about you. Your right of access can be exercised at any time and without the need to provide a reason, in accordance with the Data Protection Law.
8.2. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 8.3. You may also request that we restrict the processing of, erase, transfer the information you gave us from one organisation to another, or otherwise process your personal data in line with the relevant articles providing for such rights set out in the Data Protection Law.
8.4. We do not charge a fee for responding to your data subject access request unless the request is manifestly unfounded or excessive, in which case a reasonable fee may be charged or we may refuse to act on the request.
8.5. When you contact us about a potential personal data error or query, we will confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry. We will endeavor to send a correction notice to businesses or others whom we know to have received the inaccurate data, where required or appropriate. However, some third parties and third party sites may continue to process inaccurate data about you until their databases and display of data are refreshed or until you contact them personally to ensure the correction is made in their own files.
8.6. As set out in Article 39 of the DIFC Data Protection Law, we may not discriminate against you for exercising your rights by denying services or changing prices or quality of service, unless objectively justifiable and applied equally across all individuals accessing our services.
8.7. If you would like to exercise any of your data rights, please contact us via the details below.
We will respond to you within the timeframe required by law, which is generally 30 days. info@swingfitacademies.com +971 52 602 9389
Cookies
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our website, we may, with your consent (where required) collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.
What types of cookies do we use? There are a number of different types of cookies, however, our website uses:
a. Essential / Functional Cookies: These cookies are necessary for the operation of our website and cannot be switched off in our systems. They enable core functionality such as security, network management, and accessibility.
b. Preferences: These cookies remember your settings and preferences, such as language or location, to provide a more personalised experience.
c. Advertising / Marketing: These cookies track your browsing habits to help deliver advertising that is more relevant to you. We may share this information with advertising partners in accordance with applicable data protection laws. You will be asked to consent before we enable advertising cookies.
d. Analytics: We use analytics cookies to understand how visitors interact with our website by collecting and reporting information anonymously. These cookies help us measure and improve the performance of our site by collecting and reporting information such as the number of visitors, how they found the website, which pages are visited most often and how users navigate through the site. The data collected is anonymised and does not directly identify you. We may use third-party analytics services (such as Google Analytics) for this purpose. Where applicable, we ensure appropriate safeguards are in place in accordance with data protection requirements. These cookies are used to enhance site performance and user experience.
How to manage your cookies Before we store or access non-essential cookies on your device, we will ask for your explicit consent via a cookie banner or tool. You can choose to accept all cookies, reject all non- essential cookies, or manage preferences through our cookie settings interface.
Additionally, you can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
How to contact us If you have any questions or concerns about this Policy, please contact: info@swingfitacademies.com +971 52 602 9389
You may also contact the DIFC Commissioner of Data Protection’s Office at: Dubai International Financial Centre Authority Level 14, The Gate Building +971 4 362 2222 commissioner@dp.difc.ae
Children This website is not targeted, intended or expected to be of use to children. We do not knowingly collect or process personal data relating to individuals under the age of 18 without appropriate consent. If any of the company’s products or services are availed for use by children under the age of 18, whether through our website or by any other means, such use must be with the express consent of their parent or legal guardian. Parents or guardians who believe that we may have collected personal data from a minor without proper consent may contact us using the details in this Policy to request deletion.
Privacy policies of other websites Our website may contain links to third-party websites or services not operated or controlled by the Company. This Privacy Policy applies only to our website. Once you leave our website by following a link, we encourage you to review the privacy policy of the third-party site to understand how your personal data may be collected, processed or used. We are not responsible for the privacy practices, content or terms and conditions of any third- party websites. Accessing such websites is at your own risk.
Changes to our Policy We keep our Policy under regular review and may make changes to it from time to time. Where we make material changes to this Policy or to how we process your personal data, we will take appropriate steps to notify you, such as posting a notice on our website or contacting you directly via email (where feasible). Your continued use of our goods, services or website after such notice constitutes your understanding of the changes. We encourage you to periodically review this Policy for the latest information on our privacy practices.
