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PRIVACY POLICY

PERSONAL DATA COLLECTION STATEMENT

TopRoll Fitness ("the Company") is committed to full compliance with the Personal Data (Privacy) Ordinance (Chapter 486) of the Hong Kong Special Administrative Region to ensure the protection, confidentiality, and security of all personal data under our stewardship. All employees, officers, and associated personnel are bound by strict adherence to these obligations.

This Personal Data Collection Statement ("Statement") outlines the policies governing the collection, utilization, retention, transfer, and disclosure of your personal data by the Company.

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1. PURPOSE AND COLLECTION OF PERSONAL DATA

Personal data is collected upon registration for membership services. While provision of such data is voluntary, failure to supply required information may result in the inability to process your membership application or deliver requested services.

Categories of personal data collected may include:

  • Full legal name

  • Gender designation

  • Hong Kong Identity Card/Passport number

  • Date of birth

  • Mobile telephone number

  • Email address

  • Residential address

  • Biometric information (e.g. facial features and fingerprints)

Specified purposes for data processing include:

  • Provision and administration of Company facilities and services

  • Communication initiatives including promotional activities and customer relations management

  • Establishment and maintenance of member accounts and records

  • Processing of service inquiries, feedback submissions, and complaint resolution

  • Financial transactions including billing procedures and outstanding balance recovery

  • Identity verification and authentication processes

  • Any ancillary purposes directly related to the above objectives

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2. DIRECT MARKETING UTILIZATION

The Company may employ your personal identifiers (including name, contact particulars, and residential information) for direct marketing communications regarding fitness, wellness, and lifestyle-related products and services. Such utilization will only occur upon obtaining your explicit consent or in the absence of prior objection.

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3. DATA DISCLOSURE PROTOCOLS

The Company maintains rigorous confidentiality standards regarding personal data. Disclosure may occur under the following circumstances:

  • To authorized agents and service providers for operational purposes specified in Section 1

  • When mandated by legal obligations to regulatory or governmental authorities

Transfer of personal data to affiliated entities for marketing purposes will only be executed upon receipt of your express written authorization.

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4. BIOMETRIC DATA PROCESSING

Where applicable:

  • Biometric data collection is mandatory for facility access authentication

  • Such data is exclusively utilized for membership verification purposes

  • Non-provision of biometric data may result in membership application rejection

  • No third-party dissemination of biometric information occurs

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5. DATA SECURITY MEASURES

The Company implements comprehensive technical and organizational safeguards to protect against unauthorized access, alteration, disclosure, or destruction of personal data (including biometric information). Access is restricted to authorized personnel on a strict need-to-know basis.

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6. DATA SUBJECT RIGHTS

You retain the right to:

  • Request access to and rectification of personal data

  • Withdraw consent for direct marketing communications

Formal requests must be submitted in writing to: privacy@toprollfitness.com
The Company will process all valid requests within a reasonable timeframe.

Personal data retention periods are limited to the duration necessary for fulfillment of original collection purposes. Upon membership termination, data will be securely disposed of in accordance with established protocols.

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7. GENERAL PROVISIONS

  • In the event of any discrepancy between language versions, the English text shall prevail

  • Website content is provided for informational purposes only and may be subject to modification without notice

  • The Company expressly disclaims liability for any inaccuracies or consequences resulting from reliance on such information

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This Statement constitutes the complete policy regarding personal data handling and supersedes all previous communications on this matter. The Company reserves the right to amend this Statement with appropriate notice to affected parties.

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