Effective Date: 11 August 2026
ActiveSwim is operated and managed by ActiveHQ Malaysia Sdn Bhd (“ActiveHQ”, “we”, “us” or “our”). We are committed to protecting the privacy and personal information of our customers, students, parents, guardians, website visitors and other individuals who interact with us.
This Privacy Policy and Personal Data Protection Notice explains how we collect, use, disclose, store and protect personal data when you visit our website, register for our swimming programmes, communicate with us, or otherwise interact with ActiveSwim.
This notice is made in accordance with the Personal Data Protection Act 2010 (Act 709) and applicable amendments, regulations and guidelines.
1. Personal Data We Collect
Depending on your interaction with us, we may collect and process the following information:
- Full name
- Parent or guardian’s name
- Child’s name
- Date of birth or age
- Contact number
- Email address
- Residential or mailing address
- Emergency contact information
- Swimming experience and programme information
- Information relating to class registration and attendance
- Payment and transaction information
- Communications and enquiries submitted to us
- Photographs and video recordings
- Website usage information, including IP address, browser type, device information and pages visited
- Information collected through cookies and similar technologies
- Any other information you voluntarily provide to us
We will only collect personal data that is reasonably necessary for the purposes described in this notice.
2. How We Collect Personal Data
We may collect personal data directly from you when you:
- Register for an ActiveSwim programme
- Enquire about our classes or services
- Complete a registration or enquiry form
- Contact us by telephone, email, WhatsApp, social media or other communication channels
- Make a payment or purchase
- Visit or use our website
- Participate in ActiveSwim activities, events or programmes
- Provide information about a child for whom you are the parent or legal guardian
- Interact with our online advertisements or marketing campaigns
We may also receive information from a parent or legal guardian when they register a child for our programmes.
3. How We Use Your Personal Data
We may use your personal data for the following purposes:
- Processing swimming programme registrations
- Managing classes, schedules and attendance
- Communicating with students, parents and guardians
- Responding to enquiries and requests
- Processing payments and maintaining transaction records
- Providing customer service and support
- Managing emergencies or incidents involving students
- Improving our programmes, services and website
- Sending important programme-related information
- Sending promotional and marketing communications where permitted
- Conducting surveys, feedback and customer research
- Measuring the effectiveness of our advertising
- Managing our relationship with customers
- Complying with applicable legal and regulatory requirements
- Protecting the safety, security and rights of our students, staff, customers and business
- Any other purposes reasonably necessary for operating our swimming school
4. Children’s Personal Data
ActiveSwim provides swimming programmes for children and therefore may collect personal data relating to minors.
Where a child is under the care of a parent or legal guardian, we expect registration and the provision of the child’s personal information to be completed or authorised by the child’s parent or legal guardian.
We may collect information such as a child’s name, age, date of birth, swimming experience, class information, attendance records and emergency contact details where reasonably necessary to provide our services and ensure the child’s safety.
We take reasonable steps to protect children’s personal data and will only use it for legitimate purposes connected with the operation and delivery of our swimming programmes.
We do not knowingly use children’s personal data for personalised advertising or upload children’s personal data to Google Ads customer-matching or similar advertising audiences.
Parents and legal guardians may contact us at any time to request access to, correction of, or information about the personal data we hold relating to their child, subject to applicable legal requirements.
5. Photographs and Video Recordings
From time to time, photographs and/or video recordings may be taken during ActiveSwim classes, events, activities, competitions or other programmes.
These photographs and recordings may include students, instructors, parents, guardians and other participants.
We may use photographs and video recordings for:
- ActiveSwim’s website
- Social media platforms
- Advertising and promotional campaigns
- Digital and printed marketing materials
- Promotional videos
- Educational or programme-related content
- Internal and external communications about ActiveSwim
- Other legitimate promotional purposes relating to ActiveSwim
Where photographs or recordings feature identifiable children, we encourage parents and guardians to inform us if they do not wish their child to be photographed or recorded for marketing purposes.
Parents or guardians may opt out of the use of their child’s identifiable photographs or video recordings for marketing purposes by contacting us.
If you request that a particular photograph or recording no longer be used for future marketing, we will take reasonable steps to comply with your request. Please note that we may not be able to remove materials that have already been printed, distributed, published by third parties, or shared on social media platforms outside our control.
6. Google Ads and Online Advertising
We use Google Ads and related Google advertising technologies to promote ActiveSwim and measure the effectiveness of our advertising campaigns.
Google and its advertising partners may use cookies, advertising identifiers and similar technologies to understand interactions with our website, measure advertising performance and, where applicable and permitted, display advertisements to people who may be interested in our services.
Depending on how our advertising services are configured, information such as website visits, interactions with advertisements, device information, approximate location and online activity may be processed for advertising measurement and related purposes.
We do not knowingly provide Google with children’s personal data for personalised advertising, Customer Match or similar audience-based advertising purposes.
Google requires advertisers to comply with applicable privacy laws and its own policies concerning customer data.
You can learn more about Google’s advertising practices and manage certain advertising preferences through Google’s advertising settings.
You may also be able to control or delete advertising cookies through your browser settings.
7. Cookies and Similar Technologies
Our website may use cookies and similar technologies to:
- Ensure the website functions correctly
- Remember preferences
- Understand how visitors use our website
- Improve website performance
- Measure advertising and marketing effectiveness
- Support online advertising and analytics
Cookies are small text files stored on your device when you visit a website.
You can control or delete cookies through your browser settings. Disabling certain cookies may affect the functionality of parts of our website.
Where required by applicable law, we will seek appropriate consent before using non-essential cookies or similar technologies.
8. Marketing Communications
We may use your contact information to provide information about ActiveSwim programmes, promotions, events, classes and other services where permitted by applicable law.
You may opt out of marketing communications at any time by:
- Following the unsubscribe instructions included in an electronic marketing message;
- Contacting us directly; or
- Informing a member of the ActiveSwim team that you no longer wish to receive marketing communications.
Opting out of marketing communications will not affect essential communications relating to an existing registration, payment, class, safety matter or other service you have requested.
9. Disclosure of Personal Data
We may disclose personal data where reasonably necessary to operate our business and provide our services.
This may include disclosure to:
- Our employees, instructors and authorised representatives
- Service providers who assist us with website hosting, payment processing, communications, marketing, advertising, analytics and IT services
- Professional advisers, auditors and consultants
- Government authorities, regulators or law enforcement agencies where required or permitted by law
- Other parties where you have provided consent or where disclosure is otherwise permitted or required by applicable law
Where we engage third-party service providers to process personal data on our behalf, we take reasonable steps to require appropriate confidentiality and security measures.
10. International Data Transfers
Some of our service providers, technology providers and advertising partners may process personal data on servers or systems located outside Malaysia.
Where personal data is transferred outside Malaysia, we will take reasonable steps to ensure that the transfer and subsequent processing are carried out in accordance with applicable data protection requirements.
11. Security of Personal Data
We take reasonable administrative, technical and organisational measures to protect personal data against unauthorised access, collection, use, disclosure, alteration, loss, misuse or destruction.
However, no method of transmission or electronic storage is completely secure. While we take reasonable precautions to protect your information, we cannot guarantee absolute security of information transmitted to or stored by us.
12. Retention of Personal Data
We will retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, to provide our services, to maintain appropriate business and financial records, or to comply with applicable legal and regulatory obligations.
When personal data is no longer required, we will take reasonable steps to securely delete, destroy or anonymise it.
13. Your Rights and Choices
Subject to applicable law and any relevant exceptions, you may have the right to:
- Request access to personal data that we hold about you
- Request correction of inaccurate or incomplete personal data
- Request information about how your personal data is being processed
- Withdraw consent for certain uses of your personal data
- Opt out of direct marketing communications
- Request that we stop using your information for certain purposes where applicable
If you wish to exercise any of these rights, please contact us using the details provided below.
For requests relating to a child, we may require the person making the request to demonstrate that they are the child’s parent or legal guardian.
14. Opting Out of Photography and Video Marketing
If you or your child do not wish to appear in ActiveSwim marketing photographs or videos, you may notify us at any time.
Please contact ActiveSwim and provide:
- Your name
- The student’s name, if applicable
- The relevant programme or class
- Your request regarding photography and/or video use
We will make reasonable efforts to respect your request and prevent future use of identifiable photographs or recordings for marketing purposes.
Please note that opting out of marketing photography does not necessarily mean that you or your child cannot appear incidentally in photographs or recordings taken during public or group activities. Where reasonably practicable, we will take steps to respect your preference.
15. Third-Party Websites
Our website and communications may contain links to websites, applications or services operated by third parties.
These third parties have their own privacy policies and practices. ActiveSwim is not responsible for the privacy practices, content or security of third-party websites.
We encourage you to review the privacy policy of any third-party website you visit.
16. Accuracy of Personal Data
We rely on the information provided to us being accurate and up to date.
Please inform us if any personal information you have provided to us changes or is inaccurate so that we can update our records.
17. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our business, services, technology, legal requirements or privacy practices.
Any updated version will be published on this website with the revised effective date.
We encourage you to review this Privacy Policy periodically.
18. Contact Us
If you have any questions about this Privacy Policy, wish to exercise your rights, make a privacy-related request, withdraw consent, or opt out of marketing, photography or video use, please contact us:
ActiveHQ Malaysia Sdn Bhd
202001030550 (1386870-T)
Trading as ActiveSwim
Penang, Malaysia
Email: enroll@swimmingschool.com.my
WhatsApp: https://wa.me/6043761383
When contacting us regarding personal data, please provide sufficient information for us to identify you and understand your request.
19. Complaints
If you believe that your personal data has been handled improperly or that we have not adequately addressed your privacy concerns, please contact us first so that we can investigate and respond to your concern.
You may also contact the Personal Data Protection Commissioner / Department of Personal Data Protection (JPDP) in Malaysia where appropriate.
Last Updated: 11 August 2026