Privacy Policy Pools Australia & NZ

Lynxight Australian Privacy Policy

Effective date: August 23, 2026 

This document (privacy policy) describes how Lynxight Ltd 1 Ha-Tsmikha St, Yokne’am Illit, 2066733, Israel (“Lynxight”; “we”, “us” and “our”) collects, uses, discloses and otherwise handles personal information (as defined in this privacy policy) that we collect from you, through our Lynxight drowning alert system installed in swimming pools (the “System”).  

For information about how we collect and handle personal information from individuals who communicate with us, including through their access to and use of our website, please refer to our Website Privacy Policy

About the Lynxight System:

Every year, a large number of people find themselves in distress situations in swimming pools. Pool visitors rely on lifeguards, and lifeguards can be supported with state-of-the-art technology to increase safety for swimmers.

The Lynxight System is an intelligent technology aiding and supporting the lifeguard staff at pools that have the Lynxight System installed. The System's goal is to recognize and alert the on-duty lifeguards of imminent dangers for swimmers in the swimming pool.

We take our obligations under the Privacy Act 1988 (Cth) (Privacy Act) seriously. We are committed to providing quality products and services. This privacy policy outlines our ongoing obligations to you in respect of how we manage your personal information, including in relation to the Australian Privacy Principles (APPs) under the Privacy Act. A copy of the APPs may be obtained from the website of the Office of the Australian Information Commissioner at www.oaic.gov.au. 

We operate in multiple jurisdictions, and aquatic facilities globally use the Lynxight System. Accordingly, our collection, use, disclosure and processing of your personal information may be regulated under different data protection laws. For our privacy policies regarding our operation in other jurisdictions, please visit our website at https://www.lynxight.com/legal/privacy-policy-pools

We reserve the right to change, replace or update this privacy policy from time to time, including to take into account changes to relevant privacy laws that apply to us. We will make the new version of the privacy policy available on our website. We encourage you to regularly review the website to ensure that you are familiar with our current privacy policy.

1. What is personal information and what personal information do we collect from you?

For the purposes of this privacy policy, personal information is any information or opinion about an identified individual or an individual who is reasonably identifiable, regardless of whether the information or opinion is true or not.

We collect personal information about individuals when they visit an aquatic facility where the Lynxight System has been deployed.  The personal information that we collect about an individual depends on the circumstances in which we collect personal information. Generally, when an individual is monitored by the Lynxight System, individual swimmers are reasonably unlikely to be identified from the footage. We are not provided and we do not collect information such as the name or contact information of the individual. 

However, the footage captured by the close circuit television cameras in operation at the aquatic facility and processed by the Lynxight System may at times allow for the identification of individuals from the footage. In such circumstances, we collect personal information of the individuals captured in the relevant footage. 

In addition, we may collect certain personal information about lifeguards, including their name and phone number, where we have been contractually engaged by a customer to collect such information in connection with an aquatic facility where the System is installed and operating, unless the operator of the aquatic facility has opted out of such collection.

How the Lynxight System works

The Lynxight System uses cameras that monitor the aquatic facility area and analyse the movements of swimmers as the footage is saved to an on-premise network video recorder (NVR) controlled by Lynxight and which cannot be accessed by third parties. If the System detects that a swimmer is in distress, it will alert the on-duty person, of the swimmer’s location 

The raw footage from the NVR is deleted within 7 days, or earlier if required by the aquatic facility operator, except in the following cases: video clips of alerts, i.e. false-alarm and true-alarm incidents, as well as safety incidents that did not trigger an alert, are transferred to Lynxight’s off-site storage system for quality assurance and system improvement purposes. These clips are deleted within 30 days, or earlier if required by the aquatic facility operator, unless selected for Lynxight System training and testing, in which case a minor subset of these clips may be retained for up to 5 years.

The System only needs to be able to visually distinguish the contours of one person from another and observe their movement. The person's name, face image or other identifier are not required and not used for the System's analysis

In many cases, the image quality of the footage is insufficient to allow identification of the persons being filmed. In a minority of cases, by combination of the resolution and orientation of the individuals, the footage would potentially allow identification of the person by persons familiar with the individual or when viewed in combination with other information.

This is a typical representation of the Lynxight System’s processed footage (but for the avoidance of doubt, please note that there may be times where the processed footage is more detailed with respect to individual swimmers in the pool): 

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We generally do not collect sensitive information about you. For the purposes of the foregoing, the Privacy Act defines sensitive information to include information or opinion about your racial or ethnic origin, political opinions, your membership of a political membership and/or membership of a trade union or other professional body, information relating to your religious or philosophical believes, information relating to your criminal record (if any), health information, genetic information, biometric information used for the purpose of automatic biometric verification or biometric identification, and biometric templates.

This privacy policy explains why we collect this personal information, how we may use this information and potential recipients of our usual disclosures of personal information. 

2. How we collect personal information about you?
   
   1. When you visit an aquatic facility with the System installed and operating: we record footage from our aquatic facility monitoring cameras and this footage may at times include footage of a resolution and images that amount to that includes personal information.
   2. When you work as a lifeguard at an aquatic facility that has the System installed and operating: we request that the aquatic facility operator provides us with your name and phone number. 
3. Anonymity and pseudonymity

Where it is lawful and reasonable for you to do so, you have the right to deal with us on an anonymous or pseudonymous basis. As permitted by law, and subject to the following, we will give you the option of not identifying yourself, or of using a pseudonym, in dealing with us. 

However, if you choose to interact with us in an anonymous or pseudonymous fashion, or you do not provide us with personal information on request, then we may be unable to provide you with the products or services you request.

Further, we reserve the right to verify your identity in certain circumstances. For example, we may need to verify your identity when you request that we provide certain products or services to you, in order to liaise with other service providers and in order to comply with our statutory and regulatory obligations. Additionally, when you request access to or correction of the personal information we hold about you, or when you wish to make a complaint regarding how we have handled your personal information, we reserve the right to verify your identity and contact details in order to facilitate its satisfaction of your access or correction request, or to investigate and to deal with your complaint.

We may create de-identified or anonymised data from video footage collected by the System by removing, blurring, redacting, or otherwise obscuring elements of the footage that may make an individual personally identifiable, such as their face, or through other means. Our use of de-identified or anonymised video footage is not subject to this privacy policy.

Regarding the video footage collected by the System, we note that Lynxight does not associate the footage with the names or identity of individuals. However, given the footage recorded may at times include personal information, by the nature of the video footage, in that case it will not be possible for you to be anonymous or pseudonymous. Should you wish not to have your footage collected as part of the System, you will not be able to visit aquatic facilities that have the System installed and should not go beyond the point in the aquatic facility indicated by signage informing you about the use of the System. 

4. Receipt of unsolicited personal information

Generally, we only collect personal information when it is specifically requested or when we take active steps to collect that information. From time to time, however, personal information about an individual may be provided or volunteered to us on an unsolicited basis.

Where we receive personal information on an unsolicited basis, then (in accordance with our statutory obligations), we will promptly determine whether such personal information could lawfully have been collected had we requested the information or had otherwise actively sought the provision of such information.

5. Why we collect personal information

We collect and use personal information for one or more of the following purposes:

• To provide the Lynxight system to the operators or owners of aquatic centres in Australia that you may visit from time to time;
• To train and continuously improve and refine the artificial intelligence engine that powers Lynxight’s drowning alert system;

For the avoidance of any doubt, we do not operate or use any computer program that uses any personal information to make decisions that could reasonably be expected to significantly affect the rights or interests of an individual.

6. What third parties do we disclose your personal information to, and why?

We may disclose personal information we collect to third parties but only on an as-needs basis and only to fulfil one or more of the purposes for which we collected the information, any secondary purpose related to the primary purpose(s) of collection, and otherwise as required or authorised by law.

1. Aquatic facility operators and customers. We may disclose video footage collected by the System to the operator of the relevant aquatic facility, where necessary for the operation of the System, the provision of our services, safety purposes, or the investigation and review of incidents and alerts.
2. Service providers. We may disclose or make video footage available to service providers that assist us in operating, hosting, maintaining, supporting, or improving the System, including cloud hosting and infrastructure providers. Such service providers may access the footage only to the extent necessary to provide services to us and are required to process it in accordance with our instructions and applicable data protection requirements.
3. As authorised or required by law. We may disclose video footage where required or authorised by applicable law or regulation, in response to a lawful request from a competent authority, or where reasonably necessary to establish, exercise, or defend legal claims. We may also disclose footage where reasonably necessary to investigate or respond to actual or suspected unlawful activity or threats to the safety or well-being of any person.
4. Professional advisers and insurers. We may disclose video footage to our professional advisers, including legal advisers, and to our insurers where reasonably necessary in connection with an incident, claim, legal proceeding, regulatory matter, or the establishment, exercise, or defence of our legal rights.
5. Change of ownership or control. If the ownership or control of all or part of our business changes, including as part of a merger, acquisition, restructuring, or sale of assets, video footage may be transferred to the relevant successor or acquiring entity, subject to applicable law and data protection requirements.

7. Disclosure of personal information to recipients located outside Australia. 
   
   1. As discussed above, we use AWS to store video clips of all safety events causing an alert by the System on servers in Luxemburg, whilst a subset of these clips is reviewed by Lynxight’s personnel in Israel. 
   2. Subject to the above, generally, we do not disclose personal information to recipients located outside Australia. 
   3. However, we may engage third party service providers that provide some or all of their services to us from location(s) outside Australia. If we do so and in the process disclose your personal information, then we will: 
      
      1. take reasonable steps to ensure that such service providers deal with the personal information to which they have access in a manner consistent with this privacy policy and in compliance with the requirements of the Privacy Act 1988 (Cth); or
      2. where reasonably possible, obtain your consent to the disclosure.
8. Security. We take reasonable steps to ensure that your personal information is kept secure and protected from misuse, interference and loss, and from unauthorised access, modification or disclosure. We use technical and organisational security measures designed to secure and protect personal information. Please note, however, that we cannot eliminate security risks associated with the storage and transmission of personal information.
9. Access to and correction of personal information
   
   1. We will provide access to your personal information within a reasonable period of time following our receipt of your request, unless an exception applies. The exceptions include: 
      
      1. where the access poses a serious threat to the life or health or safety of the individual, public health or public safety; 
      2. where giving access would have an unreasonable impact on the privacy of other individuals; 
      3. where the request is frivolous or vexatious; 
      4. where the request relates to existing or anticipated legal proceedings or to current negotiations between you and us; 
      5. the request is unlawful, would impede or prejudice any investigation of unlawful activity; or 
      6. where we are required or authorised by or under Australian law or a court/tribunal order to not comply with the request.
   2. Where we do not provide you with access to your personal information, we will explain to you the reason for denying access and provide details in relation to the relevant complaint process, should you not agree with our reasons. 
   3. While we will not charge a fee for making an access request, we are authorised by law to charge a reasonable fee to cover its costs incurred in providing access to your personal information, and we reserve the right to charge a reasonable fee to cover our costs incurred in providing access to your personal information.
   4. If you can establish that the personal information we hold about you is not accurate, complete or up-to-date, or is irrelevant or misleading, we will take reasonable steps to correct the information. If we have disclosed inaccurate, incomplete, out-of-date, irrelevant or misleading information to a third party, we will take reasonable steps to ensure that the recipient is aware of the correction.
   5. We may request from you information in order to verify your identity and your connection to the individual about whom you request personal information, if required. Further, we reserve the right to redact information included in the personal information, in order to protect the privacy of other individuals.
10. Complaints procedure. If you any query or complaint about how we have handled your personal information, please contact us, at the details set out below. We will provide a response to you within a reasonable time period following receipt, in accordance with applicable law. We reserve the right to verify the identity of the person making the complaint and to seek (where appropriate or reasonable) further information from the complainant about the circumstances of the complaint. We reserve the right to refuse to investigate or to otherwise deal with a complaint where permitted by law. For example, we may refuse to investigate or to otherwise deal with a complaint if we consider the complaint to be vexatious or frivolous. If you are not satisfied with our determination, then you may escalate the complaint to the Office of the Australian Information Commissioner. 
11. Contact us. For further information about our privacy policy or practices, or to request access to or correction of your personal information we hold about you, or to make a complaint, please contact us using the details below:
    
    1. Email: [email protected]
    2. Mail address: 1 Ha’Tmiha St., Yokneam Illit, 2066733, Israel

For more information about privacy generally, or if your concerns are not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.