Privacy Policy — Hong Kong Addendum (PDPO)
This addendum supplements our main Privacy Policy with the additional rights afforded to Hong Kong residents under the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO").
1. Compliance framework
We process your personal data in accordance with the PDPO and the guidance of the Privacy Commissioner for Personal Data (PCPD).
In addition to the main Privacy Policy, we adhere to the six PDPO Data Protection Principles (DPPs):
- Purpose & manner of collection (DPP1) — we collect only what's necessary, lawfully, and via fair means.
- Accuracy & duration of retention (DPP2) — we keep data only as long as needed.
- Use of personal data (DPP3) — we use data only for the purpose for which it was collected, or one directly related to it.
- Security (DPP4) — see main Policy § 10.
- Information availability (DPP5) — this Policy is publicly available.
- Access & correction (DPP6) — see § 3 below.
2. Privacy contact
Name: Kenet · Data Protection Officer · privacy@kizzlo.com
Email: privacy@kizzlo.com
Postal address: 60 Paya Lebar Road, #06-28 Paya Lebar Square, Singapore 409051
3. Your rights
3.1 Data Access Request (s. 18)
Under PDPO s. 18, you may request a copy of the personal data we hold about you. We respond within 40 days. We may charge a reasonable fee, but our practice is to provide the first request per year free of charge.
How to request: Settings → Help & Safety → Privacy Rights → Download my data, or email privacy@kizzlo.com.
3.2 Data Correction Request (s. 22)
Under PDPO s. 22, you may request correction of inaccurate personal data. We respond within 40 days.
3.3 Withdrawal of consent
Where processing relies on your consent (e.g. for marketing), you may withdraw it at any time in Settings → Privacy. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
3.4 Marketing opt-out (s. 35)
PDPO s. 35 gives you the right to require us to stop using your data for direct marketing. We honour this request immediately upon receipt. You can opt out in Settings → Privacy → Marketing emails.
We do not transfer your personal data to third parties for their direct marketing without your express written consent.
4. Doxxing protection (Crimes Ordinance s. 64)
Hong Kong's anti-doxxing law (Crimes (Amendment) Ordinance 2021) prohibits the disclosure of personal data without consent and with intent or reckless disregard as to whether the disclosure will cause psychological harm. We:
- Take down content reported as doxxing within 24 hours.
- Cooperate with the PCPD's removal orders under s. 66D.
- Preserve evidence for law-enforcement investigations.
To report doxxing, use the in-app Report flow or email abuse@kizzlo.com.
5. Cross-border transfers
PDPO s. 33 (regulating cross-border transfers) is not yet in force as of the effective date of this Policy. We nonetheless apply contractual safeguards (Standard Contractual Clauses in subprocessor DPAs) and technical controls (encryption, access logging) to all transfers — see main Policy § 8 and our subprocessor list.
6. Children
Kizzlo is for users 18 and older. We do not knowingly collect data from children.
7. Complaints to PCPD
If you are not satisfied with our handling of your personal data, you may complain to the Privacy Commissioner for Personal Data:
- Website: www.pcpd.org.hk
- Phone: +852 2827 2827
- Address: 12/F, Sunlight Tower, 248 Queen's Road East, Wan Chai, Hong Kong
8. Contact
Privacy / data rights: privacy@kizzlo.com
General support: support@kizzlo.com
Doxxing / abuse: abuse@kizzlo.com