Privacy and Personal Data Management Policy

Privacy and Personal Data Management Policy

Last updated: 12 August 2026

1. Data controller

The ylonaquatic.com and Ylon Network services are operated by:

Hong Kong CheckpointCharlie Ltd
Company Registration No. 51548409
2301, Bayfield Building
99 Hennessy Road
Wanchai, Hong Kong
Hong Kong Special Administrative Region

Personal data enquiries:
contact@checkpointcharlie-ltd.com

In this policy, “YLON”, “we”, “us” and “our services” refer to Hong Kong CheckpointCharlie Ltd and the services it operates under the YLON and ylon-a¼ brands.

2. Purpose of this policy

This policy explains how we collect, use, retain and protect personal data in connection with:

  • the ylonaquatic.com website and its online sales services;

  • the Ylon Network application and professional directory;

  • our relationships with clubs, associations, coaches, individuals, resellers and distributors;

  • our information and contact-update campaigns;

  • secure forms used to confirm or correct an existing record;

  • contact requests, subscriptions and communication preferences.

3. Data we process

Depending on the nature of our relationship, we may process:

  • your first and last name;

  • your role within an organisation;

  • the name of your club, association or company;

  • your declared type of activity;

  • your main email address and additional contact details;

  • your telephone numbers;

  • your postal address, city, region and country;

  • your website;

  • your sport or sporting activity;

  • your communication preferences;

  • responses submitted through a contact-update form;

  • previous information and newly proposed information, so that they can be compared;

  • internal review and validation statuses;

  • unsubscribe choices and objections to communications;

  • certain technical security information, such as the submission date and non-directly readable hashes of the IP address or browser;

  • information required to manage an order, payment, delivery or commercial relationship.

We seek to collect only the information necessary for the purposes described in this policy.

4. Sources of data

Data may be obtained:

  • directly from you;

  • from your organisation or an authorised professional contact;

  • from a previous commercial relationship;

  • from historical contact lists used in connection with YLON’s activities;

  • from files provided to YLON for review or updating;

  • from publicly available professional, sporting federation or institutional sources;

  • from authorised partners or service providers where permitted by law.

When a historical record is presented to you through a secure form, its purpose is to allow you to verify, correct or complete the information already held.

5. Purposes of processing

We use data to:

  • manage our relationships with customers, prospects and partners;

  • process orders and provide requested services;

  • keep the details of clubs, organisations and professional contacts up to date;

  • identify missing, invalid, outdated or duplicated information;

  • compare a historical record with an existing record without automatically merging them;

  • send you a personal link through which you can confirm or correct your information;

  • record your response separately from historical data;

  • compare existing data with newly proposed information;

  • submit sensitive changes for human review;

  • manage communication preferences and objections;

  • secure forms, prevent abuse and maintain an audit trail;

  • comply with legal, accounting and administrative obligations;

  • improve our services and data quality.

Submitting a contact-update form does not necessarily result in automatic inclusion in the Ylon Network directory. The response may be reviewed before integration, particularly where reseller or distributor status is claimed.

6. Mandatory and optional information

Fields marked with an asterisk are mandatory in order to record and process your response correctly. Other fields are optional.

If mandatory information is not supplied, we may be unable to record or review the request.

Providing additional information for commercial communications is optional. Refusing communications does not prevent you from confirming or correcting your contact details.

If you provide another person’s contact details, you must ensure that the person is authorised to be nominated and is informed that their details are being supplied to us.

7. Legal grounds

Depending on the circumstances and applicable law, processing may be based on:

  • performance of a contract or steps requested before entering into a contract;

  • compliance with a legal obligation;

  • our legitimate interests in maintaining accurate professional contact details, securing our services and managing professional relationships;

  • your consent or indication of no objection where required by law;

  • the establishment, exercise or defence of legal claims.

Where consent is required, it must result from a free, specific, informed and explicit choice. You may withdraw it at any time without affecting processing lawfully carried out before withdrawal.

8. Communications and direct marketing

Where permitted by applicable law, we may send you information concerning YLON, our products, our services or the updating of your record.

Where consent or an indication of no objection is required, this choice is requested separately. No marketing consent is inferred merely because you confirm or correct your contact details.

Every communication must identify the sender and provide a simple way to object to further messages.

You may at any time:

  • use the unsubscribe link contained in our messages;

  • amend your preferences where a preference link is provided;

  • contact us using the details in this policy.

We may retain limited information in a suppression list to avoid contacting you again against your wishes.

9. Service providers and no sale of personal data

Hong Kong CheckpointCharlie Ltd does not sell, rent or disclose personal data to third parties for their own direct marketing activities.

Certain data is nevertheless processed, strictly to the extent necessary to provide their services, by our technical and contractual service providers, including:

  • OVHcloud, for hosting Ylon Network, its data and backups;

  • Brevo, for preparing, sending and technically monitoring email communications;

  • Stripe, PayPal and Airwallex, for payment processing and fraud prevention;

  • technical, accounting, legal or security providers whose services are necessary.

These providers act within the scope of the services entrusted to them. They are not authorised to use YLON’s contact database for their own marketing.

We may also disclose certain information where required by law, by a competent authority or to protect or defend our rights.

10. Location and international transfers

Hong Kong CheckpointCharlie Ltd is established in Hong Kong. The Ylon Network application and its main database are hosted by OVHcloud in France.

Because we operate internationally and use providers such as Brevo, Stripe, PayPal and Airwallex, certain data may be processed from the European Economic Area, Hong Kong or other countries in which these providers maintain infrastructure or authorised personnel.

Where necessary, we implement contractual, technical and organisational safeguards intended to preserve confidentiality and restrict processing to the purposes described in this policy.

For data subject to European data protection law, safeguards may include an adequacy decision, appropriate contractual clauses or another mechanism recognised under applicable law.

Personal data is not transferred to third parties for resale or use in their own direct marketing campaigns.

11. Retention periods

We apply the following retention periods unless a legal obligation requires a different period:

  • personal contact-update links remain valid for a maximum of twelve months, unless revoked earlier;

  • data relating to a prospect or historical contact list is retained for a maximum of three years from the latest contact or action initiated by that person;

  • contact-update responses and their comparison history are retained for three years after the latest response or validation, unless the record becomes part of an active relationship;

  • active contact data is retained for the duration of the relationship and for three years following its end or the latest relevant contact;

  • information strictly necessary to honour an objection to communications is retained for three years and used only to prevent further solicitation;

  • technical logs required for security and abuse prevention are retained for a maximum of twelve months, unless an incident requires longer retention;

  • requests sent to support or to the privacy contact are retained for three years after the latest exchange;

  • orders, invoices, payments and accounting documents are retained for at least seven years, in accordance with obligations applicable to businesses established in Hong Kong.

At the end of these periods, data is erased, anonymised or archived with restricted access where retention is required by law.

12. Security

We implement technical and organisational measures intended to protect personal data against:

  • unauthorised access;

  • loss or destruction;

  • alteration;

  • accidental disclosure;

  • use incompatible with the stated purposes.

Contact-update links are personal and should not be forwarded to another person without authorisation.

As no information system can guarantee absolute security, we regularly review and adapt our measures in light of risks and technical developments.

13. Your rights

Depending on applicable law and your circumstances, you may request:

  • access to your data;

  • correction of inaccurate information;

  • erasure of certain data;

  • restriction of processing;

  • objection to processing, particularly direct marketing;

  • withdrawal of consent;

  • data portability where applicable;

  • information about recipients and international transfers.

To exercise your rights, contact:

Hong Kong CheckpointCharlie Ltd
2301, Bayfield Building
99 Hennessy Road
Wanchai, Hong Kong
Hong Kong Special Administrative Region

contact@checkpointcharlie-ltd.com

We may request information reasonably necessary to verify your identity and prevent unauthorised access to personal data.

We respond within the periods required under applicable law.

You may also submit a complaint to the competent authority, including the Privacy Commissioner for Personal Data in Hong Kong or your local data protection authority where permitted by applicable law.

14. Cookies and browsing data

The ylonaquatic.com website may use cookies or similar technologies required for operation, security, preferences, statistics or commercial services.

Where prior consent is required for certain cookies, they should only be activated after you have made your choice.

Further information may be provided through our cookie management tool or a separate cookie policy.

15. Changes to this policy

We may update this policy to reflect:

  • changes to our services;

  • a change of service provider;

  • legal or regulatory developments;

  • changes to our security or retention practices.

The date of the latest update appears at the top of this page. Where a change is significant, additional notice may be provided.