Privacy Policy

1. Introduction and company information

This Privacy Policy explains how Harbour Ace Tennis Academy collects, uses, discloses, stores, and protects personal data in connection with its tennis coaching, training, court booking, event, membership, and related services.

Harbour Ace Tennis Academy is the data user responsible for your personal data under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”).

Company name: Harbour Ace Tennis Academy
Address: Harbour Ace Tennis Academy, 12/F, The One, 100 Nathan Road, Tsim Sha Tsui, Kowloon, Hong Kong
Email: [email protected]
Phone: +852 2894 6728

By using our services, visiting our premises, communicating with us, or interacting with our website, you acknowledge that your personal data may be collected and processed in accordance with this Privacy Policy and applicable Hong Kong law.

2. Data collection and processing

Harbour Ace Tennis Academy may collect and process the following categories of personal data, depending on your interaction with us:

• Identification and contact information: name, gender, date of birth, nationality, phone number, email address, postal address, emergency contact details.
• Registration and account information: membership details, class enrolment records, booking information, attendance records, payment status, preferences, and communication history.
• Health and safety information: injury details, medical conditions, allergies, fitness limitations, emergency information, and any other information necessary to ensure safe participation in tennis activities, where provided by you or your guardian.
• Payment and transaction information: billing details, payment records, refund records, and limited payment-related information processed through third-party payment providers.
• Usage and technical information: IP address, browser type, device identifiers, cookies, website usage data, and log data when you use our website or digital services.
• Images and recordings: photographs, video recordings, and audio recordings taken during classes, events, competitions, or promotional activities, where permitted by law and/or consented to by you.
• Parental or guardian information: where services are provided to minors, we may collect parent or guardian contact details and consent records.

We may collect personal data directly from you, from your parent or guardian, from authorised representatives, from payment processors, from booking platforms, from coaches or staff, and from publicly available sources where lawful and appropriate.

You may choose not to provide certain personal data, but this may affect our ability to provide coaching, safety supervision, booking services, or membership administration.

3. Purpose of data processing

Harbour Ace Tennis Academy processes personal data for the following purposes:

• to register and manage memberships, class enrolments, court bookings, camps, clinics, tournaments, and other tennis-related services;
• to communicate with you regarding schedules, confirmations, cancellations, updates, fees, and service notices;
• to assess suitability for training, manage participation, and support safe delivery of coaching and sports activities;
• to maintain attendance, progress, performance, and administrative records;
• to process payments, issue receipts, handle refunds, and manage accounts;
• to respond to enquiries, complaints, and requests;
• to comply with legal, regulatory, tax, accounting, insurance, and record-keeping obligations;
• to protect the safety and security of participants, staff, visitors, and premises;
• to manage emergencies, injuries, and incident reporting;
• to conduct internal administration, planning, analytics, service improvement, and quality assurance;
• to send marketing communications, promotions, newsletters, and event information, where permitted by law and subject to your preferences;
• to create and use photographs, videos, or testimonials for promotional purposes, where permitted by law and/or consented to by you;
• to detect, prevent, and investigate fraud, misuse, or unlawful activity; and
• for any other purpose directly related to the above or for which you have provided consent.

4. Legal basis for processing

Under Hong Kong law, personal data must be collected and used for lawful purposes and in a fair and transparent manner. Harbour Ace Tennis Academy processes personal data on one or more of the following bases:

• Performance of a contract: to provide coaching, booking, membership, event, and related services.
• Compliance with legal obligations: to meet statutory, regulatory, tax, accounting, insurance, and safety requirements.
• Legitimate interests: to operate, secure, improve, and administer our business, provided such interests are not overridden by your rights and interests.
• Consent: for certain optional uses, including marketing communications, promotional photography or videography, and collection of sensitive information where required.
• Protection of vital interests: where necessary to protect the health or safety of a participant or other person.

Where we rely on consent, you may withdraw it at any time, subject to legal or contractual restrictions and reasonable notice.

5. Data sharing and third parties

Harbour Ace Tennis Academy may disclose personal data to the following categories of recipients where necessary and lawful:

• coaches, instructors, administrative staff, and authorised representatives of Harbour Ace Tennis Academy;
• payment service providers, banks, card processors, and accounting service providers;
• IT, cloud hosting, website, communications, and software service providers;
• venue operators, facility managers, tournament organisers, and event partners;
• insurance providers, medical or emergency responders, and safety personnel in the event of an incident or emergency;
• professional advisers such as lawyers, auditors, and consultants;
• government authorities, regulators, law enforcement agencies, or courts where required or permitted by law;
• marketing, photography, media, and promotional service providers, where applicable and lawful.

We require third parties to handle personal data in accordance with applicable privacy and security obligations and to use it only for the purposes we specify, unless otherwise required by law.

6. Data transfer to third countries

Some of our service providers may store or process personal data outside Hong Kong, including in jurisdictions that may have different data protection standards. Where personal data is transferred outside Hong Kong, Harbour Ace Tennis Academy will take reasonable steps to ensure that the transfer is lawful and that appropriate safeguards are in place to protect the data.

Such safeguards may include contractual protections, data processing agreements, security measures, and due diligence on recipients. By using our services, you acknowledge that cross-border processing may occur where necessary for the operation of our business and service providers.

7. Storage duration

Harbour Ace Tennis Academy retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by law.

Retention periods may vary depending on the type of data and the purpose of processing. In general:

• membership, booking, and transaction records are retained for the period necessary for administration, accounting, dispute resolution, and legal compliance;
• health and safety records are retained for as long as necessary to manage risk, incidents, and legal obligations;
• marketing data is retained until you opt out or withdraw consent, unless a longer period is required by law;
• website and technical logs are retained for a limited period for security, troubleshooting, and analytics purposes.

When personal data is no longer required, we will take reasonable steps to delete, destroy, or anonymise it securely.

8. User rights

Subject to applicable law, you may have the following rights in relation to your personal data held by Harbour Ace Tennis Academy:

• Access: to request confirmation of whether we hold your personal data and to obtain a copy of it.
• Rectification: to request correction of inaccurate, incomplete, or outdated personal data.
• Erasure: to request deletion of personal data where it is no longer necessary, subject to legal and operational requirements.
• Restriction: to request limitation of processing in certain circumstances.
• Data portability: to request, where applicable and technically feasible, a copy of certain data in a structured format.
• Objection: to object to certain processing based on legitimate interests or direct marketing.

To exercise any of these rights, please contact us using the details below. We may need to verify your identity before responding. We may also refuse or limit a request where permitted or required by law.

9. Withdrawal of consent

Where we rely on your consent to process personal data, you may withdraw that consent at any time by contacting Harbour Ace Tennis Academy. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

If you withdraw consent, we may still process your personal data where another lawful basis applies or where retention is required by law or for legitimate business purposes.

10. Right to complain

If you believe that Harbour Ace Tennis Academy has handled your personal data in a way that breaches the PDPO or this Privacy Policy, you may contact us first so that we can investigate and address your concern.

You also have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (“PCPD”).

Office of the Privacy Commissioner for Personal Data, Hong Kong
Website: https://www.pcpd.org.hk

11. Data security

Harbour Ace Tennis Academy takes reasonable and appropriate technical and organisational measures to protect personal data against unauthorised or accidental access, collection, use, disclosure, copying, modification, loss, or destruction.

These measures may include access controls, password protection, secure storage, staff confidentiality obligations, role-based permissions, encryption where appropriate, and regular review of security practices.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security.

12. Contact information

If you have any questions, requests, or complaints regarding this Privacy Policy or our handling of personal data, please contact:

Harbour Ace Tennis Academy
12/F, The One, 100 Nathan Road, Tsim Sha Tsui, Kowloon, Hong Kong
Email: [email protected]
Phone: +852 2894 6728

13. Changes to privacy policy

Harbour Ace Tennis Academy may update this Privacy Policy from time to time to reflect changes in our practices, services, legal requirements, or operational needs.

Any updated version will be posted or made available through our usual communication channels and will take effect from the date stated in the revised policy. We encourage you to review this Privacy Policy periodically.

Continued use of our services after changes are posted constitutes acceptance of the updated Privacy Policy, to the extent permitted by law.