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Privacy Policy

Last updated September 23, 2026.

At Splash Aquatics, families trust us with information about the people they care about most. Some of that information is personal, and some of it is sensitive: health details, diagnoses, and notes about how each swimmer learns best. We take that trust seriously.

This policy explains, in plain language, what information we collect, why we collect it, who we share it with, and the choices you have. If anything here is unclear, please reach out. We're happy to talk it through.

1. Who we are and what this policy covers

Splash Aquatics Inc. ("Splash," "we," "us") is a swim school serving swimmers of all ages and abilities across the Greater Toronto Area. We specialize in adaptive and neurodiverse-affirming instruction.

This policy applies to personal information we collect through:

  • Our website, splashaquatics.ca
  • Our booking portal, app.splashaquatics.ca
  • Our instructor portal, instructor.splashaquatics.ca, where our instructors record lesson notes and skill progress
  • The Splash Swim Shop, our online store
  • The Splash Pad, our mobile app
  • Phone calls, text messages, and emails with our team
  • Paper and digital forms, including intake forms and Google Forms
  • Our in-person lessons at our program locations

We handle personal information in line with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Canada's Anti-Spam Legislation (CASL), and other applicable privacy laws.

2. Information we collect

About you (the parent, guardian, caregiver, or adult swimmer)

  • Contact details: name, email address, phone number, and mailing address
  • Account details: login email, and a password if you choose to set one
  • Communication preferences: how you'd like to hear from us, and whether you've opted in to marketing
  • Payment information: our payment processor, Stripe, handles your card details. We never see or store your full card number. We keep a record of your transactions, credits, and balances.
  • Shipping details: if you order from the Swim Shop, we collect your shipping address

About the swimmer

Only the swimmer's name is required. Everything else is optional, and you choose what to share. Sharing more helps us create a safer, better lesson experience. The optional information may include:

  • Date of birth or age
  • Swim history and experience
  • Diagnoses, disabilities, and medical conditions
  • Allergies and medications
  • Sensory, communication, and behavioural notes: what helps, what to avoid, and what motivates
  • Emergency contacts

Information created during lessons

  • Instructor notes: observations our instructors record about each lesson
  • Skill progress: the skills your swimmer is working on and has achieved
  • Attendance: which lessons your swimmer attended or missed

Adaptive swim and OAP intake information

For adaptive swim sessions, including sessions that are eligible for the Ontario Autism Program (OAP), we collect a more detailed intake form. Families usually complete it as a PDF sent by email or through a Google Form. The form may include information about the swimmer's diagnosis, support needs, goals, and strategies that work well.

Phone calls and messages

  • Calls are recorded and transcribed. When you call Splash, you may speak with a member of our team or with our AI voice assistant. We record and transcribe calls to keep accurate notes, follow up on your request, and improve our service.
  • Call details: your phone number, the date and time of the call, and what was discussed
  • Emails and text messages you send us

Photos, videos, and testimonials

We take photos or videos of a swimmer only after a parent, guardian, or caregiver has signed our photo release form. If you share a testimonial, we ask your permission before we publish it, and we identify you only by your first name and last initial.

Website, app, and advertising data

When you visit our website or use our apps, we and our analytics and advertising partners collect some information automatically. This may include:

  • Your device and browser type
  • Your IP address and approximate location
  • The pages you visit, the links you click, and how you move through the site
  • Which ad or link brought you to us

This information is collected through cookies, pixels, and similar technologies. See Section 8 for details and your choices.

3. Why we use your information

We use personal information to:

  • Run lessons safely. We match swimmers with the right instructor and approach, prepare for medical and sensory needs, and respond in an emergency.
  • Manage bookings and accounts. This includes registration, scheduling, makeup lessons, credits, payments, and receipts.
  • Track and share progress. We record skill development so you, your swimmer, and our instructors can see how they're growing.
  • Support OAP-funded programming. We coordinate with our clinical partner, prepare attendance and billing records, and provide receipts that you can submit to AccessOAP.
  • Communicate with you. We send booking confirmations, schedule changes, and reminders, and we answer your questions.
  • Market our programs. With your consent, we send news, program announcements, and offers.
  • Improve our services. We try to understand how families use our website and booking tools so we can make them easier to use.
  • Fill Swim Shop orders. This covers processing, shipping, and supporting your purchases.
  • Meet our legal obligations. This includes tax and accounting requirements.

We only use your information for the purposes we've described. If we want to use it for something new, we'll ask you first.

4. Consent

  • Health and sensitive information: we collect it only with your express consent. Because it's optional, you decide what to share.
  • Swimmers under 18: a parent or legal guardian provides information and consent on the swimmer's behalf.
  • Adult swimmers who register through a caregiver: we rely on the caregiver's confirmation that they have the authority to act for the swimmer, such as a substitute decision-maker or someone with power of attorney. Wherever possible, we also respect the swimmer's own wishes.
  • Marketing emails and texts: we send these only if you opt in, either on our website or by checking the opt-in box when you create an account. You can unsubscribe at any time.
  • Photos and videos: we take them only with a signed photo release.

You can withdraw consent at any time (see Section 9). If you withdraw consent for information we need to deliver lessons safely, we'll explain how that affects what we can offer.

5. Who we share information with

We never sell your personal information. We share it only in the situations below.

Our clinical partner for adaptive and OAP sessions

Our adaptive swim sessions are overseen by a Registered Behaviour Analyst (RBA) at our clinical partner, Apex Educational Consulting Inc. For families in these sessions:

  • We share your intake form, attendance records, and billing information with our clinical partner.
  • Our clinical partner shares their intake and progress notes with your swimmer's instructors, so each lesson targets the right goals.

We do not send your information to the Ontario government or AccessOAP. You submit your receipts to AccessOAP yourself.

Our program locations

We run lessons at partner facilities. Some of them need limited information:

  • We Rock the Spectrum Brampton receives an end-of-session report listing clients and the amounts paid, as part of our facility arrangement.
  • ErinoakKids Brampton receives a paper client roster at reception to confirm that swimmers are ErinoakKids clients. This roster is not shared digitally.

We don't share health, diagnosis, or lesson information with our program locations.

Service providers

We use trusted companies to run our business. They may process your information only on our behalf, and only for the services they provide to us.

PurposeProvider

Booking platform database

Supabase (hosted in Canada)

Payments

Stripe

Email, documents, and forms

Google Workspace (Gmail, Google Forms, Google Drive)

Phone calls and text messages

Twilio

AI voice assistant, call recording, and transcription

Retell AI

Marketing and transactional email

SendGrid

Client relationship management

Twenty (hosted on Railway)

Online store

Medusa (hosted on Railway)

Shipping

ShipStation, Canada Post, and other shipping carriers

Website and app hosting

Vercel

Website analytics

PostHog and Google Analytics

Advertising

Meta (Facebook and Instagram), Google Ads, and Pinterest

AI assistance for administrative work

Anthropic (Claude)

Use of AI tools

We use AI tools to help our small team work efficiently. For example:

  • Our voice assistant answers calls.
  • AI helps us draft replies, prepare reports, and organize records.

Our team reviews and remains responsible for this work. We don't use AI to make decisions about your swimmer's eligibility, placement, or care without human review.

When the law requires it

We may disclose information if the law requires it, for example in response to a court order. We may also disclose it where someone's health or safety is at serious risk.

If our business changes

If Splash is reorganized, merged, or sold, personal information may be transferred to the new organization. It would remain protected under the terms of this policy.

6. Where your information is stored

Our main client database is hosted in Canada. Some of our service providers are based in, or store data in, the United States or other countries. When information is stored outside Canada, it's subject to the laws of that country, and authorities there may be able to access it. We choose providers that commit to protecting personal information.

7. How long we keep your information

We keep personal information only as long as we need it for the purposes in this policy, or as long as the law requires:

  • Account, swimmer, and lesson records: while your account is active, then for 3 years after your swimmer's last lesson, so returning families can pick up where they left off. After that, we delete the records or anonymize them.
  • Financial records: at least 6 years, as required by the Canada Revenue Agency.
  • Call recordings and transcripts: up to 12 months.
  • Records related to a safety incident involving a swimmer: longer where needed for legal purposes. This may include keeping records until a minor swimmer turns 20.
  • Marketing preferences: until you unsubscribe. After that, we keep a record of your unsubscribe request so we don't contact you again.

You can ask us to delete your information sooner (see Section 9).

8. Cookies, analytics, and advertising

We use cookies and similar tools to:

  • Keep things working, such as keeping you logged in to the booking portal
  • Understand our website, through PostHog and Google Analytics. This includes page views, clicks, and how visitors move through our site.
  • Advertise our programs, through the Meta Pixel, Google Ads, and the Pinterest Tag. These help us show ads to people who may be interested in Splash, and measure whether our ads work.

We keep advertising tools off the pages where you enter swimmer health information. Our advertising pixels run on our marketing website and Swim Shop only, not in the booking portal's registration and swimmer-profile areas.

Your choices:

  • You can block or delete cookies in your browser settings. Some parts of the booking portal may not work without essential cookies.
  • You can opt out of interest-based ads from Google at adssettings.google.com, from Meta in your Facebook or Instagram ad preferences, and from participating companies through the Digital Advertising Alliance of Canada at youradchoices.ca.
  • You can opt out of Google Analytics with Google's browser add-on at tools.google.com/dlpage/gaoptout.

9. Your rights and choices

You can:

  • Access your information. Ask what we hold about you or your swimmer, and get a copy.
  • Correct it. Update your account in the booking portal, or ask us to fix anything that's wrong.
  • Withdraw consent. For example, you can stop marketing messages or withdraw a photo release.
  • Ask us to delete it, subject to our legal obligations, such as keeping financial records.
  • Unsubscribe from marketing by using the link in any marketing email, replying STOP to a marketing text, or contacting us.

If you withdraw a photo release, we'll stop using the photos or videos going forward and remove them from our own channels. However, we can't always remove content that others have already shared.

To make a request, email info@splashaquatics.ca. We may need to verify your identity before sharing or changing information. We'll respond within 30 days. If we need more time, or can't fulfil part of a request, we'll let you know and explain why.

10. How we protect your information

We use reasonable safeguards to protect personal information from loss, theft, and unauthorized access. These include:

  • Role-based access: staff can only see the information they need for their role. For example, instructors see the notes they need for their own swimmers.
  • Encrypted connections to our websites and apps
  • Secure payment processing through Stripe
  • Confidentiality: our staff are required to keep client information confidential

No system is perfectly secure. If a privacy breach creates a real risk of significant harm to you, we'll notify you and the Office of the Privacy Commissioner of Canada, as the law requires.

A tip for families: please don't send highly sensitive information by regular email unless we ask for it. When in doubt, call us, or use the booking portal where you can.

11. Children's privacy

Our swimmers include children, and we take extra care with their information. Children don't create their own accounts. A parent or guardian registers them and makes decisions about their information. We don't knowingly collect personal information directly from children through our websites or apps.

12. Links to other sites

Our website may link to other sites, such as AccessOAP or our social media pages. Those sites have their own privacy practices, and this policy doesn't cover them.

13. Changes to this policy

We may update this policy as our programs and tools change. We'll post the new version here with a new "Last updated" date. If we make significant changes, we'll let you know by email or through the booking portal.

14. Contact us

If you have questions, requests, or concerns about your privacy, please contact our Privacy Officer:

Scott Hladun, Privacy Officer Splash Aquatics Inc. 1575 Stewart Cres., Milton, ON L9T 6P9 Email: info@splashaquatics.ca

If you're not satisfied with our response, you can contact the Office of the Privacy Commissioner of Canada at priv.gc.ca or 1-800-282-1376.