Privacy Policy

Kensington & Chelsea Gymnastics Academy Ltd (“KCGA”, “we”, “us”, “our”) is the data controller responsible for the personal information covered by this notice.

• Company number: 14181797.
• Registered office: Niddry Lodge, 51 Holland Street, London W8 7JB.
• ICO registration reference: ZB405979.
• Privacy contact: dr.kolimechkov@icloud.com.

Privacy enquiries and rights requests are handled through the privacy contact above. KCGA will keep under review whether its processing requires a statutory Data Protection Officer.

This notice covers KCGA’s website, contact forms, email, telephone and WhatsApp communications, waiting lists, trial sessions, group classes, personal coaching, children’s home lessons, events, Academy publications and voluntary research projects.

We normally receive information directly from an adult gymnast, a parent or guardian, or the gymnast where appropriate. We may also receive relevant information from KCGA coaches and staff, payment records, website and security services, venue providers, British Gymnastics, insurers, professional advisers, safeguarding bodies or public authorities where lawful and necessary.

• Identity and contact information: names, parent or guardian details, postal address, email address, telephone or WhatsApp number and emergency contacts.
• Gymnast and booking information: age or date of birth, preferred location, availability, experience, class placement, waiting-list status, bookings and attendance.
• Coaching information: goals, coach observations, participation, progression, assessment results and communications about the service.
• Payment and accounting information: fees due or paid, payment dates, bank-transfer references, invoices and financial records. KCGA does not ask for payment-card details through its website.
• Membership and insurance information: information reasonably needed to confirm applicable British Gymnastics membership or insurance requirements.
• Health, injury and additional-needs information: only where relevant to safe participation, appropriate adjustments, emergency response or safeguarding.
• Safeguarding and incident information: concerns, accident or incident records and relevant actions or communications.
• Photographs, video and audio: Academy activities, performances, events, interviews and completed publications.
• Research-project information: only where someone volunteers for a specific project after receiving separate information.
• Website and device information: IP address, browser or device details, page activity, consent choices, approximate location and security logs.

Most information about younger gymnasts is provided and managed by a parent or guardian. The adult providing it must have authority to do so and should help the child understand how KCGA uses it.

KCGA takes additional care with children’s information, limits collection to what is reasonably needed, uses age-appropriate explanations where relevant and gives particular weight to a child’s welfare, expectations and developing ability to exercise their own data rights.

• KCGA does not knowingly direct electronic marketing to children.
• Children’s full names are not published alongside photographs.
• A sufficiently mature child may exercise privacy rights personally; KCGA considers competence and the child’s best interests case by case.

Health information is special-category personal information. KCGA collects only what is reasonably necessary to assess safe participation, respond to an injury or emergency, consider an appropriate adjustment, meet safeguarding responsibilities or manage a legal claim.

KCGA must identify both an Article 6 lawful basis and an additional Article 9 condition. Depending on the purpose, KCGA may rely on steps connected with the coaching contract, legitimate interests in safe and appropriate service delivery, recognised legitimate interests for safeguarding, or vital interests in an emergency.

For the additional Article 9 condition, KCGA will normally rely on explicit consent for routine health or additional-needs information. Where consent is not appropriate or seeking it could prejudice protection, KCGA may rely on the safeguarding condition under the Data Protection Act 2018, vital interests or the establishment, exercise or defence of legal claims, as applicable.

KCGA selects the lawful basis that fits the particular purpose:

• Contract or steps before a contract: responding to coaching enquiries, assessing availability, administering bookings and delivering paid services.
• Legal obligation: accounting and tax records, responding to valid legal requirements and meeting applicable health, safety or regulatory duties.
• Legitimate interests: operating and improving the Academy, service administration, appropriate customer communication, preventing misuse, website and information security, managing complaints, insurance and legal claims, and producing responsible Academy communications and publications. KCGA assesses necessity, reasonable expectations and the effect on the individual, with extra weight given to children’s interests.
• Recognised legitimate interests: processing that is necessary to safeguard a child or another vulnerable individual.
• Vital interests: using or sharing information where genuinely necessary to protect someone’s life in an emergency.
• Consent: non-essential cookies or tracking where required, electronic marketing where consent is the appropriate route, voluntary research participation, and particular optional media or sensitive-information uses where KCGA expressly asks for consent.

Where KCGA relies on consent, it can be withdrawn as explained in this notice. Withdrawal does not make earlier lawful processing unlawful. KCGA will not retrospectively change lawful basis merely to avoid the consequences of a withdrawal.

KCGA uses contact, booking, attendance and payment information to respond to enquiries, offer suitable available options, administer waiting lists, confirm sessions, manage fees and communicate service or safety information.

Some information is necessary to enter into or perform the coaching contract. This normally includes the responsible adult’s contact details, the gymnast’s age, booking and payment information, emergency contact information and relevant safety information. If it is not provided, KCGA may be unable to offer or safely deliver the service.

Communications may take place by email, telephone or WhatsApp according to the route used by the family. WhatsApp is provided by Meta and should not be used to send unnecessary sensitive information. Families may request a different reasonable communication route.

Data protection law does not prevent KCGA from using or sharing relevant information when this is necessary and proportionate to protect a child or another person from neglect or physical, mental or emotional harm.

KCGA may record concerns, incidents, accidents and actions taken, and may share limited relevant information with its safeguarding lead, coaches, British Gymnastics, venue safeguarding contacts, insurers, medical or emergency services, local authorities, police or other appropriate bodies.

KCGA does not rely on consent where doing so would be inappropriate, unsafe or could undermine safeguarding. It may instead rely on recognised legitimate interests for safeguarding, a legal obligation, vital interests or another applicable legal condition. Access is restricted to people who reasonably need the information.

KCGA may photograph or record classes, events, performances and other Academy activities. Parents and guardians are informed about intended public uses, and KCGA seeks advance photography permission as an additional safeguarding choice. A decision not to give permission is respected.

KCGA may rely on legitimate interests to document genuine Academy activities, communicate responsibly about its work and produce educational, editorial and historical material. It considers the purpose, necessity, reasonable expectations, children’s particular interests and safeguards before doing so. For a particular use where KCGA expressly identifies consent as the lawful basis, the consent rules apply.

A change or withdrawal of photography permission applies to new capture and new uses of existing material. KCGA will take reasonable steps to remove standalone photographs or recordings from current promotional webpages and social-media posts under its control.

Completed magazines, newsletters, annual or event publications, films, recorded performances and episodes in an Academy video series form part of KCGA’s permanent publication and historical record. A later change in photography permission will not normally require KCGA to recall, withdraw, re-edit, delete or republish a completed work, or remove it from the publication archive.

KCGA relies, where appropriate, on legitimate interests in preserving an accurate educational, editorial and historical record and on freedom of expression and information. A request about a completed work is considered individually. KCGA may remove, restrict or alter access where required by law or where a substantiated safeguarding, safety or welfare concern outweighs those interests.

• Children’s full names are not published with photographs.
• Images are used only in connection with legitimate KCGA activities and are selected respectfully.
• Following withdrawal, KCGA will not extract material from a completed publication for a new and separate promotional use.
• An appointed photographer or media provider may handle files only for the agreed KCGA purpose and subject to appropriate confidentiality and security controls.

Ordinary KCGA membership or acceptance of the Terms is not consent to participate in scientific research. Research participation is voluntary and separate from routine coaching.

Before project-specific measurements or activities take place, KCGA will provide a separate participant information notice explaining the project, information collected, research team or collaborators, lawful bases, retention, sharing, withdrawal arrangements and intended outputs.

KCGA will obtain written informed consent from the adult participant or a child’s parent or guardian and, where appropriate, seek the child’s assent in an age-appropriate way. Refusal or withdrawal will not affect access to KCGA coaching.

Findings will normally be reported as anonymised group results. Information that has been irreversibly anonymised so that nobody can be identified is no longer personal information, although KCGA will continue to handle research material responsibly.

KCGA’s website uses cookies and similar storage or access technologies. Strictly necessary technologies support security, consent management and core website functions. Where consent is required under the Privacy and Electronic Communications Regulations, KCGA asks for a clear choice before using non-essential technologies.

The website currently uses or embeds services including:

• Google Analytics to understand website use and improve performance.
• Google reCAPTCHA to protect forms from spam and misuse.
• Google Maps and YouTube to display locations and video content.
• ShareThis to provide consent-management and social-sharing functionality.
• WordPress, Divi, hosting, caching and security services to deliver and protect the website.

These providers may receive device, browser, IP-address, page-interaction and consent information and may act as KCGA’s processor or as a separate controller for aspects of their services. Their own privacy information also applies.

You can use the website’s Privacy control to review or change available cookie choices. Browser controls can also block or delete cookies, although strictly necessary features may then work differently.

Service communications about an enquiry, booking, timetable, payment, safety matter or existing coaching arrangement are not treated as optional marketing.

For electronic marketing, KCGA relies on consent where required or on the limited existing-customer “soft opt-in” where legally available. The soft opt-in is used only for KCGA’s own similar services where the person was offered a clear opt-out when their details were collected and in every later message.

• KCGA does not buy marketing lists or sell contact details.
• Every electronic marketing message provides a simple way to opt out.
• KCGA may retain a minimal suppression record so that an opt-out is respected.
• Publicly available newsletter and magazine archives are completed publications; viewing them does not itself subscribe a person to marketing.

KCGA shares only information that is reasonably necessary for the relevant purpose. Recipients may include:

• KCGA coaches, authorised staff and appointed photographers or contractors who need access for their role.
• Website hosting, maintenance, security, analytics, consent-management, communications and cloud-service providers.
• Apple for KCGA email services and Meta where a family chooses WhatsApp communication.
• Google and ShareThis in connection with the website services described above.
• Venue operators where limited information is necessary for access, safety, incident handling or safeguarding.
• British Gymnastics, insurers, professional advisers, accountants and legal advisers where relevant. British Gymnastics generally receives membership information directly from families and acts under its own privacy information.
• Emergency services, safeguarding bodies, local authorities, police, courts, regulators or other public bodies where lawful and necessary.
• Research collaborators only as described in the separate information for an approved voluntary project.
• A purchaser, successor or adviser if KCGA undergoes a genuine business reorganisation, subject to appropriate confidentiality and lawful processing.

KCGA does not sell personal information and does not disclose it to third parties for their own unrelated marketing.

Some technology and communications providers operate internationally, so personal information may be made accessible from or processed in countries outside the UK.

Where UK international-transfer rules apply, KCGA takes reasonable steps to ensure the transfer is covered by UK adequacy regulations, including the UK Extension to the EU-US Data Privacy Framework where applicable, or by appropriate safeguards such as the UK International Data Transfer Agreement or UK Addendum. An applicable legal exception is used only where permitted and necessary.

You may contact KCGA for more information about the relevant transfer mechanism or how to obtain a copy of applicable safeguards, subject to lawful confidentiality restrictions.

KCGA keeps identifiable information only for as long as reasonably necessary for its stated purpose, legal duties, safeguarding, insurance and the establishment, exercise or defence of legal claims. Its standard approach is:

• Enquiries that do not lead to a booking: normally up to 24 months after the last meaningful contact, unless an earlier deletion request applies or a longer period is justified.
• Customer, booking, contract, invoice and accounting records: generally up to seven years after the relevant transaction or end of the customer relationship.
• Routine attendance, coaching and progression records: generally up to six years after last participation, with longer retention only where reasonably required for a child-related incident, safeguarding matter, insurance or legal claim.
• Health and additional-needs information: reviewed for continuing relevance and removed or minimised when no longer needed, unless connected with an incident, safeguarding record or legal claim.
• Safeguarding, accident and incident records: retained according to the nature of the concern, the individual’s age, applicable professional or insurer guidance and potential legal limitation periods. Retention is reviewed rather than applied indefinitely by default.
• Current promotional photographs and source media: reviewed periodically and retained only while relevant to the stated Academy purpose.
• Completed publications and publication archives: normally retained permanently as KCGA’s educational, editorial and historical record, subject to the individual review described in this notice.
• Marketing records: until the person opts out or the purpose ends, with a minimal suppression record retained to honour the opt-out.
• Research information: according to the project-specific participant information and research protocol.
• Website, cookie and security information: for the period set in the relevant service or consent controls and reviewed for necessity.

Information may be securely deleted, anonymised or aggregated when the identifiable form is no longer required.

KCGA uses proportionate technical and organisational measures intended to protect information against accidental loss, unauthorised access, misuse, alteration or disclosure. These include access controls, device and account protection, confidentiality expectations, data minimisation, appropriate backups, provider review and secure deletion practices.

Access is limited according to role and reasonable need. Providers that process information for KCGA are expected to act under appropriate contractual and security obligations.

No internet or storage system can be guaranteed completely secure. KCGA assesses suspected personal-data breaches, contains risk, records decisions and notifies the ICO and affected individuals where the law requires.

Depending on the purpose and lawful basis, you may have the right to:

• ask for access to personal information and a copy of it;
• ask for inaccurate or incomplete information to be corrected;
• ask for deletion or restriction in applicable circumstances;
• object to processing based on legitimate interests or recognised legitimate interests;
• object at any time to direct marketing;
• receive certain information in a portable format where applicable;
• withdraw consent at any time where consent is relied upon; and
• ask for human review if KCGA ever introduces a qualifying solely automated significant decision.

Your right to object: tell KCGA why processing based on legitimate interests affects your particular situation. KCGA will stop unless it can demonstrate compelling legitimate grounds that override the relevant rights and interests, or the processing is required for legal claims. An objection to direct marketing is absolute. An objection concerning a completed publication is considered using the publication, freedom-of-expression and child-welfare framework explained above.

Send a request or complaint to dr.kolimechkov@icloud.com. KCGA may request proportionate information to confirm identity. Rights requests are normally answered within one month, subject to lawful extensions. KCGA will acknowledge a data-protection complaint within 30 days and explain the outcome of its investigation.

If you remain dissatisfied, you may complain to the Information Commissioner’s Office (ICO): Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF; telephone 0303 123 1113.

KCGA reviews this notice when its services, providers or legal obligations change. The current version will remain available on this page. Material changes will be brought to the attention of affected families through an appropriate communication or before the relevant new processing begins.

Last updated: 27 August 2026