Privacy Policy
At Elvariquegolf, we respect your privacy and are committed to handling personal data responsibly. This Privacy Policy explains how we collect, use, store, disclose, and protect personal information when you visit our website, book a consultation, communicate with us, or use our Golf Lessons, Golf Simulation, Swing Analysis, or Club Fitting services.
We handle personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") of Hong Kong and its applicable Data Protection Principles ("DPPs").
1. Personal Data We Collect
Depending on your interaction with Elvariquegolf, we may collect:
- Name, email address, and telephone number;
- Consultation and service booking details;
- Your selected service and golfing requirements;
- Information voluntarily provided during consultations;
- Communications between you and Elvariquegolf;
- Cancellation and refund information;
- Banking details where a refund by bank transfer is requested; and
- Other information reasonably required to administer our services.
In accordance with DPP1, we seek to collect personal data fairly and only to the extent reasonably necessary for a legitimate purpose connected with our business.
2. How We Use Personal Data
We may use your information to:
- Arrange and manage consultations;
- Respond to inquiries;
- Understand your golfing requirements;
- Develop tailored service plans and quotations;
- Confirm and administer service bookings;
- Communicate about scheduled sessions;
- Maintain payment and transaction records;
- Handle cancellations and determine refund eligibility;
- Process approved refunds;
- Resolve complaints or disputes; and
- Comply with applicable legal and regulatory obligations.
Personal data will not be used for an unrelated purpose unless permitted under the PDPO or the required consent has been obtained.
3. Consultation and Payment Information
Our website allows you to arrange a consultation but does not provide direct service purchasing or online payment facilities.
If you proceed after consultation, your service will be confirmed following full cash payment of the applicable quotation. We therefore do not collect payment-card information through our website.
Where you request an approved refund through bank transfer, we may collect the banking information necessary to process that refund. Such information will only be used for the refund and directly related administrative or legal purposes.
4. Disclosure of Personal Data
We do not sell personal data.
Where reasonably necessary, information may be disclosed to our authorized employees, professional advisers, banks processing refunds, service providers acting on our behalf, or government, regulatory, law-enforcement, and judicial authorities where disclosure is required or permitted by law.
Where third-party processors handle personal data for us, we will take appropriate contractual or other measures concerning data security and retention as required by the PDPO.
5. Data Security and Retention
In accordance with the PDPO, Elvariquegolf takes reasonably practicable measures to protect personal data against unauthorized or accidental access, processing, loss, erasure, or use.
Personal data will only be retained for as long as reasonably necessary for the purpose for which it was collected or to satisfy applicable business, accounting, dispute-resolution, or legal requirements. Information that is no longer required will be appropriately erased, subject to applicable law.
6. Accuracy of Information
We take reasonably practicable steps to maintain the accuracy of personal data having regard to the purposes for which it is used.
You should provide accurate information and notify us when relevant information changes. You may also request correction of inaccurate personal data in accordance with the PDPO.
7. Direct Marketing
If Elvariquegolf uses personal data for direct marketing, we will comply with the applicable requirements of the PDPO, including obtaining the required consent or indication of no objection before such use.
You may ask us to stop using your personal data for direct marketing at any time without charge by contacting plays@elvariquegolf.com.
8. Access and Correction Rights
Under the PDPO, you may have the right to request access to personal data we hold about you and request correction of inaccurate information.
Requests may be submitted to plays@elvariquegolf.com. We may verify your identity before processing a request and will handle requests within the applicable statutory requirements. Where permitted under the PDPO, a fee that is not excessive may apply to a data access request.
9. Personal Data of Minors
As our golfing services may be used by younger participants, we may process personal data concerning minors where reasonably necessary to arrange or provide services.
Where appropriate, we may require relevant information or authorization from a parent, guardian, or other responsible adult.
10. Your Rights and the PDPO
Our personal data practices are guided by the six DPPs under the PDPO covering the collection, accuracy and retention, use, security, transparency, and access and correction of personal data.
Nothing in this Privacy Policy is intended to restrict rights available under applicable Hong Kong law.
11. Changes to This Policy
Elvariquegolf may update this Privacy Policy to reflect changes to our operations, services, data-handling practices, or applicable legal requirements. The updated version will be published on our website.
12. Contact Us
For questions about this Privacy Policy, our handling of personal data, or a data access or correction request, please contact:
Elvariquegolf
Email: plays@elvariquegolf.com
We will handle privacy-related inquiries in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) and other applicable laws of the Hong Kong Special Administrative Region.