Privacy Policy
Last updated: [DATE]
This policy explains how [ACADEMY LEGAL NAME] ("the Academy", "we", "us"), located at [ADDRESS], Kuwait, collects, uses, shares and protects personal data when you book an assessment, enrol a child, use our online shop, or use this website and app. Because most of the people we serve are children, we treat their data with particular care.
1. Who is responsible for your data
[ACADEMY LEGAL NAME] (commercial registration [CR NUMBER]) is the controller of the personal data described here. Contact: [CONTACT EMAIL], [PHONE], [ADDRESS]. [Data protection contact / DPO, if appointed: NAME, EMAIL].
2. Data we collect
- Student data: name, date of birth, gender, photo (if provided), level, class, attendance, skill assessments, progress reports and certificates.
- Health information: medical notes, allergies and conditions you choose to share so coaches can keep your child safe in and around the water.
- Identity documents: copies of civil ID, passport or birth certificate, and signed agreements, where needed for registration, age verification or insurance.
- Parent / guardian data: name, mobile number, email, relationship to the student, and emergency contacts.
- Payment data: invoices, amounts, payment status and references. Card details are entered on the payment provider's page; we do not store full card numbers.
- Communications: WhatsApp, email and in-app messages with the Academy, including messages with our booking assistant (which may be processed by an AI service).
- Technical data: sign-in records, IP address, device/browser information and security logs used to protect the service (including anti-bot checks).
- We do not operate CCTV through this app. [Update if CCTV is used at the venue.]
3. Why we use it (purposes)
- Booking assessments, enrolment, class placement and scheduling.
- Running classes safely: attendance, coaching, skill tracking, medical awareness.
- Billing, payments, receipts and refunds.
- Contacting you about classes, changes, reminders and your child's progress (WhatsApp, email, SMS).
- Security, fraud and abuse prevention, and keeping the service working.
- Meeting legal, accounting and insurance obligations.
- [Marketing — only with your separate consent; you can opt out at any time.]
4. Legal basis and parental consent
We process children's data only with the consent of a parent or legal guardian, and to perform our agreement with you. Health information and identity documents are processed with your explicit consent and only for the purposes above. By registering a child you confirm that you are their parent or legal guardian. You may withdraw consent at any time (see section 8); some services may then no longer be possible. [Confirm the legal bases with counsel under applicable Kuwaiti regulation.]
5. Who we share data with
We never sell personal data. We share it only with service providers acting for us:
- Supabase — database, file storage and sign-in hosting ([HOSTING REGION]).
- Cloudflare — website hosting, security and anti-bot checks (Turnstile).
- WhatsApp (Meta Platforms) — messages and verification codes you receive on WhatsApp.
- [EMAIL PROVIDER] — sending emails such as confirmations and receipts.
- [PAYMENT GATEWAY, e.g. KNET / Bookypay] — processing payments.
- [AI PROVIDER] — the optional booking assistant and document reading (OCR).
- Authorities, insurers or professional advisers where required by law or to protect safety.
Some providers process data outside Kuwait. Where this happens we rely on appropriate safeguards. [Describe transfer safeguards / regulator approvals as required.]
6. How long we keep data (retention)
- Active student and guardian records: while the student is enrolled, plus [X] years.
- Identity documents and medical notes: until [X months] after the student leaves, then deleted.
- Invoices and payment records: [X] years, as required for accounting.
- Assessment bookings that do not lead to enrolment: [X months].
- Messages and chat transcripts: [X months].
- Security logs: [X days].
7. How we protect data
Access is limited by role (for example, coaches only see their own classes), data is encrypted in transit, identity documents are stored privately and opened through short-lived links, and activity is logged. No system is perfectly secure; we will notify you and the relevant authority of a serious breach as required by law.
8. Your rights
As a parent/guardian (or an adult student) you can ask us to:
- access a copy of the personal data we hold;
- correct inaccurate data;
- delete data we no longer need, or withdraw consent;
- stop marketing messages at any time.
Email [CONTACT EMAIL] to make a request. We will reply within [30] days. You may also complain to [RELEVANT KUWAITI AUTHORITY, e.g. CITRA].
9. Cookies and local storage
We use only what is needed to sign you in, remember your preferences and keep the service secure. We do not use advertising trackers. [Update if analytics are added.]
10. Changes and contact
We may update this policy and will show the new date above; significant changes will be communicated to registered parents. Questions: [CONTACT EMAIL], [PHONE], [ADDRESS].

