Privacy policy
Effective Date: July, 2026
1. Who We Are
This Privacy Policy applies to the website crewconnection.co.uk (the “Site”) and to the services provided by Crew Connection.
Crew Connection operates through two group entities:
Crew Connection Ltd, a company registered in England and Wales under company number 15588128, with its registered office at Unit 15 Somerville Court, Trinity Way, Adderbury, Oxon, OX17 3SN, United Kingdom (“Crew Connection Ltd”).
Crew Connection Inc, a corporation incorporated under the laws of the State of Delaware, United States, with its principal place of business at 131 Continental Dr, Suite 305, Newark, DE 19713, United States (“Crew Connection Inc”).
If you are a US-based client, Crew Connection Inc is the data controller (or “business,” as applicable under US state law) responsible for your personal data, regardless of which Program or package you are enrolled in. All other clients and website visitors are contracting with, and have their data controlled by, Crew Connection Ltd. References to “Crew Connection,” “we,” “us,” or “our” mean whichever of these entities applies to you as described above and as confirmed in your signed Services Agreement.
If you have questions about this Policy or how your data is handled, contact us at crew@crewconnection.co.uk
2. Information We Collect
When you use the Site, schedule a consultation, enrol in a Program, or otherwise interact with us, we may collect:
Contact details: name, email address, phone number, postal address.
Payment and billing information necessary to process transactions (handled via our payment processors; we do not store full card details ourselves).
Athlete and family information relevant to recruiting and coaching services: academic and athletic records, erg scores, training data, race results, video footage, college preferences, and related recruiting information.
Communications: messages, emails, and call/session notes (see Section 5, Session Recording and AI Notetaking).
Technical and log data: IP address, browser type, device information, and pages visited, collected automatically through cookies and analytics tools such as Google Analytics.
3. How We Use Your Information
We use the information we collect to:
provide and administer the Programs and services you have requested;
communicate with you about your enquiry, booking, or Program, including scheduling and coaching correspondence;
process payments;
maintain safeguarding records and respond to welfare concerns (see our separate Safeguarding Policy);
send you newsletters, updates, or marketing communications, where you have opted in or as otherwise permitted by law (you may opt out at any time);
improve our Site, services, and internal training, including through anonymised or aggregated analysis; and
comply with our legal and regulatory obligations.
4. Legal Basis for Processing (UK/EEA Clients)
Where Crew Connection Ltd processes your personal data, we rely on the following legal bases under the UK GDPR: performance of a contract with you (e.g. delivering a Program); our legitimate interests (e.g. improving our services, safeguarding, internal training); your consent (e.g. marketing communications, session recording where consent is sought); and compliance with a legal obligation.
5. Session Recording and AI Notetaking
Virtual coaching and advisory sessions may be recorded and/or processed using AI notetaking tools to generate notes, summaries, and transcripts (“Session Records”). Session Records are used to deliver services, support safeguarding and transparency, and for internal quality assurance and training. Your Services Agreement sets out the specific terms of your consent, retention (currently six years, unless a longer period is required for safeguarding or legal reasons), and how to withdraw consent.
6. Children’s Information
Our services are directed at student-athletes, many of whom are under 18. Where an Athlete is under 18, we collect and use their personal data with the involvement and consent of a parent or legal guardian, in line with the safeguarding provisions of our Services Agreement.
For clients of Crew Connection Inc, we do not knowingly collect personal information directly from children under 13 without verifiable parental consent, in accordance with the US Children’s Online Privacy Protection Act (COPPA). If you believe a child has provided us with personal data without appropriate consent, please contact us at crew@crewconnection.co.uk so we can address it.
7. Sharing of Information
We do not sell your personal data. We may share information with:
third-party service providers who support our operations (e.g. payment processors, scheduling and video-conferencing tools, our secure database provider, AI notetaking providers);
professional advisers;
safeguarding authorities or sports governing bodies (e.g. British Rowing, the U.S. Center for SafeSport, USRowing) where necessary to protect an Athlete or others; and
regulators or authorities where required by law.
Third parties are only permitted to use your data for the purposes we specify.
8. International Transfers
Because we operate across the UK and US, your data may be transferred between these jurisdictions and processed on servers located outside your home country. Where personal data originating in the UK/EEA is transferred outside the UK/EEA, we rely on appropriate safeguards, such as the UK’s International Data Transfer Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism.
9. Data Retention
We retain personal data for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. Session Records are retained for six years unless a longer period is required for safeguarding or legal reasons. Where data is no longer needed, we take steps to delete or anonymise it.
10. Cookies
The Site uses cookies and similar technologies to operate core functionality, remember preferences, and analyse Site usage (e.g. via Google Analytics). Where required by law, we will seek your consent before setting non-essential cookies. You can manage or disable cookies through your browser settings; doing so may affect certain Site features.
11. Security
We take reasonable technical and organisational measures to protect your personal data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
12. Your Rights: UK/EEA Clients
If Crew Connection Ltd is responsible for your data, you have the right, subject to certain conditions, to: access the personal data we hold about you; request correction of inaccurate data; request erasure of your data; object to or restrict certain processing; request data portability; and withdraw consent at any time where processing is based on consent. To exercise these rights, contact us at crew@crewconnection.co.uk. You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at ico.org.uk if you believe your data has been mishandled.
13. Your Rights: US Clients
If Crew Connection Inc is responsible for your data, you may have rights under applicable US state privacy laws based on your state of residence and our operations, which may include, without limitation, the Connecticut Data Privacy Act (CTDPA), the Delaware Personal Data Privacy Act, and other applicable state privacy laws, to access, correct, delete, or obtain a copy of your personal data, and to opt out of certain processing. To exercise these rights, contact us at crew@crewconnection.co.uk. Parents/guardians of children under 13 may contact us to review, delete, or refuse further collection of their child’s information under COPPA.
14. Links to Other Sites
The Site may contain links to third-party websites. We are not responsible for the content or privacy practices of those sites and encourage you to review their policies.
15. Changes to This Policy
We may update this Privacy Policy from time to time. The “Effective Date” above reflects the date of the latest revision. Continued use of the Site or our services after changes take effect constitutes acceptance of the revised Policy.
16. Contact Us
Questions about this Privacy Policy, or requests relating to your personal data, can be sent to crew@crewconnection.co.uk.
Crew Connection Ltd, Unit 15 Somerville Court, Trinity Way, Adderbury, Oxon, OX17 3SN, United Kingdom
Crew Connection Inc, 131 Continental Dr, Suite 305, Newark, DE 19713, United States
