Privacy Policy
Last updated: May 14, 2026
ProActiv Sports ("ProActiv", "we", "us", "our") is the children's sports coaching enterprise founded in Hong Kong in 2011 and operating in Hong Kong and Singapore. This Privacy Policy explains how we collect, use, share, and protect personal data when you visit our website, enquire about our programmes, or enrol a child in our services.
We comply with the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") and the Singapore Personal Data Protection Act 2012 ("PDPA"). Where applicable, we also follow comparable principles from the EU/UK GDPR.
1. Who we are
The data controller responsible for personal data collected through this website is:
ProActiv Sports Limited
[Registered address, Hong Kong — TBC]
Email: privacy@proactivsports.com
For Singapore-related enquiries: [Singapore contact entity and address — TBC]
2. The personal data we collect
- From parents and guardians: name, email, phone number, billing address, emergency contact details, payment information (processed by our payment provider; we do not store full card numbers).
- About enrolled children: first name, age or date of birth, gender (optional), relevant medical or accessibility information voluntarily provided by the parent, photographs taken during sessions only where parental consent has been given.
- From website visitors: IP address, device and browser type, pages viewed, referring URL, and information collected via cookies and similar technologies (see Section 8).
- From correspondence: content of emails, enquiry forms, WhatsApp messages, and phone calls relating to enrolment or support.
We do not knowingly collect personal data directly from children under the age of 13 without parental consent. Where a child interacts with our website, we treat any personal data provided as the parent's responsibility.
3. How we use personal data
- Respond to enquiries and process bookings, enrolments, and payments.
- Deliver, supervise, and ensure the safety of classes, camps, parties, and other services.
- Communicate scheduling, safety, and operational information to parents.
- Send service updates and, with consent, marketing communications about ProActiv programmes.
- Comply with our legal, regulatory, accounting, and safeguarding obligations.
- Improve our website, services, and child-safety practices.
- Prevent fraud and protect the rights, property, and safety of ProActiv, our staff, and the children in our care.
4. Legal bases for processing
- Performance of a contract — to deliver the services you book with us.
- Consent — for marketing communications, photography, and non-essential cookies. Consent can be withdrawn at any time.
- Legal obligation — for safeguarding, tax, and regulatory record-keeping.
- Legitimate interests — to operate, secure, and improve our services, provided your rights do not override ours.
5. Sharing personal data
- Payment processors, booking-system providers, email and CRM platforms, hosting providers, analytics providers, and other service providers acting under contract.
- Partner venues, schools, and event hosts where a programme is delivered at their premises.
- Insurers, medical professionals, and emergency services where necessary for the safety of a child.
- Regulators, law enforcement, and other authorities where required by law.
- A successor entity in the event of a corporate transaction (merger, acquisition, or asset transfer).
We do not sell personal data.
6. International transfers
Because we operate across Hong Kong and Singapore and use international service providers, personal data may be transferred outside the jurisdiction in which it was collected. Where we transfer data internationally we apply safeguards consistent with the PDPO, the PDPA, and (where relevant) the UK/EU GDPR.
7. Data retention
We retain personal data only as long as needed for the purposes described in this policy or as required by law. Enrolment records are typically retained for the duration of the child's enrolment plus seven years for accounting and safeguarding purposes. Marketing data is retained until consent is withdrawn.
8. Cookies and analytics
Our website uses essential cookies required for the site to function and, with consent, analytics and performance cookies (e.g. PostHog, Google Analytics or equivalent). You can manage cookie preferences through our cookie banner and through your browser settings.
9. Children's data
- Only process children's data with the consent of a parent or legal guardian.
- Collect the minimum data needed to deliver safe, age-appropriate coaching.
- Do not use children's personal data for marketing.
- Do not publish identifiable photographs of children without specific parental consent.
- Train all coaches and staff on child-data handling and safeguarding.
10. Your rights
- Request access to the personal data we hold about you or your child.
- Request correction of inaccurate or incomplete data.
- Request deletion of data, subject to our legal retention obligations.
- Object to or restrict certain processing.
- Withdraw consent at any time.
- Lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD) or the Personal Data Protection Commission, Singapore (PDPC).
To exercise these rights, email privacy@proactivsports.com.
11. Security
We apply organisational and technical safeguards appropriate to the sensitivity of the personal data we handle, including access controls, encryption in transit, vetted vendors, and incident-response procedures. No system is perfectly secure, and we cannot guarantee absolute security.
12. Changes to this policy
We may update this Privacy Policy from time to time. The "Last updated" date at the top reflects the latest version. Where changes are material, we will notify enrolled families directly.
13. Contact
For privacy-related questions, contact privacy@proactivsports.com or write to us at our Hong Kong registered office (Section 1).
