Privacy Policy

Privacy Policy

Our Privacy Approach

The website provides information and accepts consultation requests. It does not process payments or complete golf bookings. Consultation requests and partial reservations remain active for 48 hours. Final planning and payment occur at the office or designated Hong Kong business location.

Data We May Collect

Depending on the interaction, Linksphereia may collect:

  • Names, email addresses, telephone numbers, and correspondence;
  • Consultation preferences, requested dates, golfer numbers, course preferences, and facility requests;
  • Government-issued identification details and required participation documents;
  • Booking plans, quotes, payment records, attendance information, and incident records;
  • Cancellation communications and bank details provided for eligible refunds;
  • Website information such as IP address, browser type, device data, cookies, pages viewed, and inquiry timestamps; and
  • Access, correction, consent, complaint, and dispute records.

Why We Use Personal Data

Linksphereia may use personal data to respond to inquiries, manage consultation requests, maintain the 48-hour partial reservation, schedule office discussions, prepare tailored golf plans and quotes, receive office payments, issue booking details, administer course access, verify identity, communicate operational changes, enforce facility rules, address safety matters, process cancellations and refunds, resolve disputes, prevent misuse, maintain records, and meet legal obligations.

Data will be used only for notified purposes, reasonably related purposes, or purposes otherwise permitted by Hong Kong law. Where prescribed consent is required under the Personal Data (Privacy) Ordinance, Linksphereia will seek appropriate consent before collecting, using, or disclosing the relevant data.

Disclosure and Service Providers

Personal data may be shared with golf course operators, facility providers, payment or banking service providers, technology vendors, professional advisers, insurers, authorities, and other parties reasonably involved in delivering the requested service or fulfilling legal duties.

Linksphereia does not sell personal data. Service providers should receive only information reasonably necessary for their assigned functions and are expected to protect it through appropriate contractual or operational safeguards.

Data may be disclosed without consent where permitted or required by law, including for investigations, legal proceedings, emergency response, or protection of rights and safety.

Cookies and Website Records

Cookies and similar technologies may support essential website operation, remember preferences, measure visits, and identify performance issues. Browser settings may allow users to block or delete cookies, although some website functions may then operate differently.

Protection, Retention, and Transfers

Linksphereia uses reasonable administrative, physical, and technological safeguards designed to protect personal data against illegal or accidental access, collection, use, disclosure, copying, modification, loss, or disposal. No storage or transmission method is entirely free from risk.

Personal data is retained only while reasonably necessary for service delivery, refund administration, dispute management, operational records, and legal or regulatory requirements. When retention is no longer required, data will be securely deleted, destroyed, or anonymized.

If data is transferred outside Hong Kong, Linksphereia will take reasonable steps to ensure a standard of protection comparable to that required under the Personal Data (Privacy) Ordinance.

Individual Choices and Requests

Subject to lawful exceptions, individuals may request access to personal data held about them, information about its use or disclosure, or correction of inaccurate or incomplete data. They may also withdraw consent with reasonable notice.

Requests should be emailed to the Data Protection Contact at shot@linksphereia.com. Identity details and sufficient request details may be required. Linksphereia will respond within the statutory period required by the Personal Data (Privacy) Ordinance (normally within 40 days) or communicate when additional time is reasonably needed.

Incidents and Notifications

Linksphereia will assess suspected personal data incidents and take appropriate containment, investigation, remediation, and notification steps. Where required under applicable Hong Kong frameworks or regulatory expectations, Linksphereia will notify the relevant authority and affected individuals.

Legal Alignment and Fairness

This policy is governed by Hong Kong law and is intended to operate consistently with the Personal Data (Privacy) Ordinance (Cap. 486), the Trade Descriptions Ordinance, and the Control of Exemption Clauses Ordinance.

Nothing in this policy removes mandatory consumer rights, permits unfair practices, or excludes liability where exclusion would be unlawful. Any limitation will operate only where reasonable and legally enforceable.

Contact and Complaints

Privacy questions, access or correction requests, consent withdrawals, and complaints may be sent to shot@linksphereia.com. Include enough information for Linksphereia to identify the relevant interaction and review the request. Unresolved matters may be directed to the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong, subject to applicable law.