You may request deletion of your personal data at any time, subject to legal and contractual obligations to retain certain information.

 

6. Data Sharing and Disclosure

6.1 We Do Not Sell Personal Data

212HK does not sell, rent, trade, or lease your personal information to third parties for commercial gain.

6.2 We May Share Data With

We may disclose your personal information to the following categories of recipients when necessary:

Service Providers and Business Partners:

• Payment processors and financial institutions for transaction processing
• Email and messaging service providers (for marketing and notifications)
• Website hosting and analytics providers (Google Analytics, Meta Business Suite)
• Customer relationship management (CRM) platforms
• Court reservation and facility management software providers
• Accounting and bookkeeping firms for financial management
• Legal and compliance advisors

All service providers are contractually obligated to maintain the confidentiality and security of your data and use it only for the purposes we specify.

Sponsorship and Marketing Partners:

• Pickleball equipment sponsors for co-branded promotions
• Event partners and tournament sponsors
• Media and content creation partners for feature articles or promotional videos

Legal and Regulatory Requirements:

• Government agencies, law enforcement, or regulatory bodies when required by law
• Courts or judicial authorities in response to legal process (subpoenas, court orders)
• The Privacy Commissioner for Personal Data (PCPD) if required to report data breaches
• Tax authorities for compliance with Hong Kong tax obligations

Business Transfers:

• In the event of a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any such change and provide an opportunity to opt-out if permitted by law.

With Your Consent:

• Any disclosure for purposes beyond those listed above will only occur with your prior, informed consent

 

7. International Data Transfers

Since 212HK operates primarily in Hong Kong, most data processing occurs within Hong Kong. However, if we transfer personal data to service providers located outside Hong Kong, we implement adequate safeguards including[3]:

• Standard contractual clauses with overseas recipients
• Data Processing Agreements ensuring equivalent protection standards
• Encryption and security measures during transmission
• Explicit consent from data subjects for such transfers where required

We comply with PDPO guidance on cross-border data transfers and do not transfer data to jurisdictions with inadequate data protection laws without appropriate safeguards.

 

 

8. Data Security

8.1 Security Measures

212HK implements reasonable technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, and loss, in compliance with PDPO Data Protection Principle 4[4]:

Technical Controls:

• Encryption of personal data in transit (SSL/TLS protocols)
• Password-protected access to member databases
• Secure payment processing with PCI DSS compliance
• Regular security audits and vulnerability assessments
• Firewalls and intrusion detection systems

Organizational Controls:

• Limited access to personal data (staff access on need-to-know basis)
• Data protection training for all staff members
• Confidentiality agreements with employees and contractors
• Regular data protection reviews and compliance audits
• Incident response procedures for data breaches

Facility Security:

• Access control systems limiting facility entry to authorized members
• Security cameras for surveillance and safety monitoring
• Staff presence during operating hours
• Emergency protocols for safety incidents 

8.2 Your Responsibility

While we implement robust security measures, no data security system is 100% foolproof. We encourage you to:

• Maintain the confidentiality of your membership login credentials
• Report suspicious activity or unauthorized access immediately
• Use strong, unique passwords for online accounts
• Avoid sharing personal information via unsecured communication channels
• Inform us of any data security concerns

 

9. Data Breach Notification

In the event of a data breach involving unauthorized access to or loss of personal data, 212HK will[5]:

• Assess the nature, scope, and potential impact of the breach
• Notify affected individuals without undue delay using contact information on file
• Report the breach to the Privacy Commissioner for Personal Data (PCPD) as required by law
• Provide information about steps taken to remediate the breach and prevent recurrence
• Offer guidance on protective measures individuals can take

For data breach inquiries or to report suspected breaches, please contact our Data Protection Officer at [privacy@212hk.com] or [+852 9500 9074].

 

10. Your Rights Under the PDPO

10.1 Right to Access

You have the right to request access to your personal data held by 212HK. We will provide you with:

• Confirmation of what personal data we hold about you
• Copies of your personal data in an intelligible format
• Information about the purposes and uses of your data
• Information about data retention and disclosure practices

To Submit an Access Request: Contact our Data Protection Officer with written identification proof.

10.2 Right to Correction

You have the right to request correction of inaccurate or incomplete personal data. If we agree that data is inaccurate, we will correct it promptly and notify relevant third parties who received the data.

10.3 Right to Deletion/Erasure

While the PDPO does not explicitly provide a right to erasure, you may request deletion of your personal data if:

• Data is no longer necessary for the original collection purpose
• You withdraw consent for processing
• You object to processing and we have no legitimate reason to continue

We will honor deletion requests except where legal or contractual obligations require retention.

10.4 Right to Opt-Out of Direct Marketing

You have the unconditional right to opt-out of direct marketing communications. You may:

• Unsubscribe from email lists using the link in promotional emails
• Reply "STOP" to SMS or WhatsApp marketing messages
• Request removal from our marketing database
• Update your preferences in your membership account

We will process opt-out requests within 7 business days.

10.5 Right to Lodge Complaints

If you believe your personal data rights have been violated, you may lodge a complaint with:

Office of the Privacy Commissioner for Personal Data (PCPD)

• Website: https://www.pcpd.org.hk
• Telephone: +852 2827 8888
• Address: 12/F, Citic Tower, 1 Tim Mei Avenue, Central, Hong Kong

 

11. Cookies and Website Technologies

11.1 What Are Cookies?

Cookies are small text files stored on your device that contain alphanumeric identifiers. We use cookies to:

• Maintain your login session
• Remember your preferences and language settings
• Track website usage for analytics and improvement
• Deliver personalized content and recommendations
• Target relevant advertising and marketing messages

11.2 Types of Cookies We Use

Essential Cookies: Required for website functionality (login, security)
Analytical Cookies: Measure site usage through Google Analytics and Meta Business Suite
Preference Cookies: Remember your choices and settings
Marketing Cookies: Track interactions with promotional content and campaigns

11.3 Cookie Consent and Control

• By continuing to use our website, you consent to our use of cookies
• You can modify browser settings to decline cookies or delete existing cookies
• Disabling cookies may affect website functionality and user experience
• We provide a cookie consent banner on first visit with options to accept, reject, or customize

 

12. Children's Privacy

212HK's services are not directed to children under 13 years old. We do not knowingly collect personal information from children without parental consent. If we become aware that a child has provided personal data:

• We will verify parental consent for continued processing
• We will take steps to delete the child's information if consent cannot be verified
• We will notify parents/guardians of any data collected

For children aged 13-18, we collect minimal data with appropriate safeguards and parental notification where applicable.

If you believe we have collected data from a child inappropriately, please contact our Data Protection Officer immediately.

 

13. Third-Party Links

Our website and social media channels may contain links to third-party websites, applications, and services (external sponsors, equipment suppliers, news outlets). This Privacy Policy does not apply to third-party services. We encourage you to:

• Review the privacy policies of third-party websites before providing information
• Understand that we are not responsible for third-party privacy practices
• Contact third parties directly with privacy concerns regarding their services

Links to our website from third parties do not imply endorsement or responsibility.

 

14. Marketing and Promotional Communications

14.1 Types of Marketing Communications

We may send marketing communications via:

• Email newsletters with facility updates, promotions, and event announcements
• SMS and WhatsApp messages for time-sensitive offers and notifications
• Social media posts and targeted advertising on Instagram, YouTube, and Meta platforms
• In-app notifications and website banners
• Direct mail for membership renewals and special offers

14.2 Consent Requirements

Opt-In Consent: For email, SMS, and WhatsApp marketing, we collect your prior express consent through:

• Checkboxes on membership forms
• Explicit sign-up for marketing lists
• Double opt-in confirmation via email

Legitimate Interest: For website analytics and retargeting ads, we rely on legitimate business interests with appropriate notice.

14.3 Opt-Out and Unsubscribe

You may withdraw marketing consent at any time:

• Click "Unsubscribe" in email footers
• Reply "STOP" to SMS/WhatsApp messages
• Update preferences in your membership account
• Contact our Data Protection Officer

We will honor opt-out requests within 7 business days.

 

 15. Data Protection by Design

212HK is committed to Data Protection by Design and by Default[4], incorporating privacy considerations into:

• New facility features and service offerings
• Technology implementations and software selections
• Tournament formats and membership structures
• Marketing campaigns and promotional initiatives
• Staff training programs and operational procedures

We conduct Data Protection Impact Assessments (DPIAs) for high-risk processing activities and maintain a Data Protection Officer to oversee compliance.

 

16. Appointment of Data Protection Officer

212HK has appointed a dedicated Data Protection Officer (DPO) responsible for:

• Monitoring PDPO compliance across all business operations
• Serving as the contact point for data subject requests
• Conducting data protection training and awareness
• Responding to Privacy Commissioner inquiries
• Investigating and remedying data breaches

Data Protection Officer Contact:

• Email: [emmanuel@212hk.com]
• Telephone: [+852.9506.1233]
• Address: 212HK, 15F, S22, 22 Heung Yip Road, Wong Chuk Hang, Hong Kong

 

17. Policy Updates and Changes

We may update this Privacy Policy from time to time to reflect:

• Changes in our data processing practices
• New services or features
• Updates to Hong Kong privacy laws
• Feedback from data subjects

When policies change:

• We will post the updated policy on our website with a revised effective date
• Significant changes will be communicated via email to registered members
• Continued use of our services after policy updates constitutes acceptance of changes
• You may request a copy of previous policy versions

 

 

18. Contact Information

18.1 Data Protection Officer

For questions about this Privacy Policy, to submit data subject requests, or to report data protection concerns:

212HK Data Protection Officer

• Email: [emmanuel@212hk.com]
• Telephone: [+852.9506.1233]
• Address: 212HK, 15F, S22, 22 Heung Yip Road, Wong Chuk Hang, Hong Kong
• Response Time: Within 14 business days

 18.2 Privacy Commissioner for Personal Data (PCPD)

For complaints about our data protection practices:

Office of the Privacy Commissioner for Personal Data

• Website: https://www.pcpd.org.hk
• Email: enquiry@pcpd.org.hk
• Telephone: +852 2827 8888
• Address: 12/F, Citic Tower, 1 Tim Mei Avenue, Central, Hong Kong
• Complaint Hotline: +852 2877 7888

 

19. Acknowledgment and Consent

By using 212HK facilities, registering for membership, participating in tournaments, or accessing our online services, you:

• Acknowledge that you have read and understood this Privacy Policy
• Consent to the collection and processing of your personal data as described
• Confirm that information you provide is accurate and complete
• Agree to comply with our Data Protection Principles and policies

If you do not agree with our data practices, please discontinue use of our services.

Last Updated: December 10, 2025

Version: 1.0

This Privacy Policy is effective as of the date listed above and applies to all personal data collected by 212HK Limited.

 

 

 

---