Privacy Policy

Who we are

Tumbl Swim is a trading name of Charlotte Bell Consulting Services Ltd, a company registered in England and Wales (company number 15840581) with its registered office at 46 Salisbury Road, EN11 0HX. We are the data controller for the personal data described in this policy.

This policy covers the Tumbl app at app.tumblswim.com.

Age requirement

Tumbl is only for adults aged 18 and over. We do not knowingly collect data from anyone under 18. If we learn that we hold data relating to someone under 18, we will delete it and close the account.

What data we collect

• Account details— your name and email address.
• Swimming videos— the videos you upload for analysis.
• Swimming background— information you share about your experience, goals and what you want to work on.
• Payment information— when you buy access, our payment provider collects the details needed to process your purchase. We receive a confirmation that payment was successful and a record of the transaction, but we do not see or store your full card details.
• Usage data— basic information about how you use the app, such as pages visited and features used, if you accept analytics cookies.

Why we collect it, and our lawful basis

We will never sell your data or share it publicly.

How your video is processed

Your videos are the most sensitive thing we handle, and we treat them that way. A video is uploaded, processed by AI to generate a draft analysis, and then reviewed by a qualified human coach before you see the result. Your assigned coach can view your videos and analysis. Nobody else inside Tumbl routinely accesses them.

We may use your videos and analysis data to improve how Tumbl recognises swimming technique. This is on by default because we believe it benefits all swimmers and poses low privacy risk — swim videos do not typically show identifiable features (swimmers wear caps and goggles). You have the right to object to this use at any time by turning it off in your account settings. If you do, we will exclude your videos from any future use for this purpose, including any you have already uploaded.

Automated decision-making

Although AI is part of how your analysis is generated, a human coach always reviews it before it is released to you. Decisions about your feedback are not made by AI alone.

Who we share data with

We use a small number of trusted providers to run Tumbl. They act as data processors on our behalf and can only use your data to deliver their part of the service. Categories of provider include:

• A cloud storage provider (for video storage)
• A cloud hosting and database provider (for the app itself)
• AI service providers (to generate the draft analysis)
• An authentication provider (for sign-in)
• A payment processor (for purchases)
• An email delivery provider (for service and marketing emails)
• An analytics provider (to understand how the app is used, EU-hosted)

We carry out due diligence on our providers and have data processing agreements in place with them. If you would like a current list of the specific providers we use, email [email protected] and we will share it.

Cookies and analytics

We use:

• Essential cookies— required for sign-in and core functionality. These are always active.
• Analytics cookies— only set if you accept them via our consent banner. These help us understand how the app is used so we can improve it, and may include recordings of anonymised user journeys to diagnose bugs and usability issues. Sensitive inputs are masked.

You can change your cookie preference at any time by clearing your browser cookies and revisiting the app.

Where your data is stored

Your data is stored securely with trusted cloud providers. Some of these providers are based outside the UK, including in the United States. Where this happens, transfers are protected using the UK International Data Transfer Agreement (or the UK Addendum to the EU Standard Contractual Clauses), which is the approved safeguard under UK GDPR for international transfers.

How long we keep your data

We keep your account and video data for as long as your account is active. If you ask us to delete your account, we will remove your videos and personal account data within 30 days.

We are legally required to keep records of financial transactions for six years under UK tax law. These records will be retained for that period even if your account is closed.

Your rights

Under UK GDPR, you have the right to:

• Access— request a copy of your personal data.
• Rectification— ask us to correct inaccurate information.
• Erasure— ask us to delete your data.
• Portability— receive your data in a portable format.
• Object or restrict— object to certain processing or ask us to restrict it.
• Withdraw consent— where we rely on consent (for example, marketing emails), you can withdraw it at any time.

Email [email protected] to exercise any of these rights. We will respond within one month.

If you are unhappy with how we handle your data, you have the right to complain to the UK Information Commissioner’s Office at ico.org.uk or on 0303 123 1113. We would appreciate the chance to put things right first.

Data breaches

If we ever experience a data breach that is likely to affect your rights, we will notify the Information Commissioner’s Office within 72 hours and contact affected users where required by law.

Marketing

We will only send you marketing emails if you have asked us to. Every marketing email includes an unsubscribe link, and you can opt out at any time.

Changes to this policy

We may update this policy as the service evolves. The date at the top will reflect any changes. We will notify you of significant changes by email.

Contact

Email [email protected] for any privacy question or to exercise your rights.