Privacy Policy

Last updated: 21 May 2026 · Version 1.1 (AU)

1. Who we are

PKBL.asia is operated by C&L International Corp ("PKBL.asia", "we", "us", "our") — a Wyoming corporation, with mailing address 1712 Pioneer Avenue, Suite 115, Cheyenne, WY 82001, USA. We are the data controller for personal information collected through this website. We do not have an office, staff, or servers in Australia.

Our Data Protection Officer ("DPO") can be reached at dpo@pkbl.asia. Use this address for any privacy questions, access or correction requests, or complaints.

2. Scope of this policy

This policy describes how we collect, use, disclose and protect personal information through pkbl.asia and any sub-domains we operate. PKBL.asia is targeted at residents of Australia, and we have written this policy on the basis that the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs") apply to our handling of personal information of our Australian subscribers under section 5B of the Privacy Act. Although the small-business operator exemption in section 6D may apply to us by reason of our turnover, we apply the APPs in full to our handling of Australian subscribers' personal information as a matter of our standing privacy practices, regardless of whether the exemption is available.

Where you are located outside Australia, your local law may also apply; the protections in this policy apply to you regardless of where you live.

3. Personal information we collect

3.1 Information you give us

• Email address — when you subscribe to the newsletter via the signup form.
• First name and city — optional fields in our post-signup survey.
• Survey answers — your preferences about tournaments, retreats, coaching, gear, your skill level, and what you want to improve in your game. All survey questions are optional; you can skip any of them.
• Correspondence — if you contact us by email, we keep a record of the message and our reply.

Anonymity and pseudonymity (APP 2). You may use a pseudonym in the optional first-name field if you prefer. We can't deliver the newsletter anonymously — we need an email address to send it to you — so the anonymity option under APP 2.1 is not practicable for this service (APP 2.2(b)).

We do not collect sensitive information (such as health, racial, political or religious data) and ask you not to send any to us.

3.2 Information collected automatically

If you accept our cookie banner, we use Google Tag Manager and Google Analytics 4 to understand how visitors use the site. This collects:

• IP address (truncated by Google for analytics purposes)
• Approximate location (city / country level)
• Device type, browser, operating system, screen size
• Pages visited, referring URL, and time spent
• A randomly generated client identifier stored in a first-party cookie

If you decline the cookie banner, none of the above is collected. Our default state is "decline" — analytics only run after you click "Accept".

We do not currently use Meta Pixel, Google Ads remarketing, or other advertising trackers on the site. If we add advertising trackers in future, we will update this policy and ask for your consent at that time.

4. How we use your information

We collect and use your personal information for the purposes set out below. We rely on your consent, given when you submit the signup form or complete the survey, as the basis for the marketing-related uses (APP 6.1, APP 7.2):

We do not sell, rent, exchange, or otherwise trade your personal information to or with any third party for that party's benefit, service, or advantage. We will not use your personal information for any other purpose without first asking you.

5. Direct marketing and your right to unsubscribe

The PKBL.asia newsletter is a commercial electronic message under Australia's Spam Act 2003 (Cth). We:

• Include a clear, working unsubscribe link in every email.
• Process unsubscribe requests within 5 business days at most (and typically immediately), as required by section 18 of the Spam Act.
• Keep that unsubscribe facility working for at least 30 days after each email is sent.
• Identify the sender clearly in every email — the legal name "C&L International Corp", our mailing address, and a working contact (section 17 of the Spam Act).
• Keep an internal record of when you subscribed (and, if applicable, when you unsubscribed) to demonstrate compliance.

You can unsubscribe at any time by clicking the link in any email, or by emailing dpo@pkbl.asia. On request, we will also tell you the source of the email address we used to contact you (APP 7.6 / 7.7). Withdrawing consent doesn't affect anything we did before you withdrew it.

6. Who we share your information with

We share your information only with service providers who help us run PKBL.asia. They process your information on our instructions, under written agreements that limit them to that purpose. We do not sell or rent your personal information, and we don't give it to advertisers.

We may also disclose personal information if required by law, by a court order, or to protect the safety of any person — and we will tell you about it where we are legally allowed to.

7. Cross-border transfers

Your subscriber record is held by Bento, an Australian processor, and is stored primarily in Australia. Some of the providers above (Cloudflare, Google) are based outside Australia, and Bento may also store data in the United States and other countries, so your information will be transferred outside Australia in connection with our service. Under Australian Privacy Principle 8 we are required to take reasonable steps to ensure that overseas recipients handle your information consistently with the APPs. We do this by:

• Choosing service providers with recognised security certifications (e.g. our email provider, Bento, holds SOC 2 and ISO 27001 certifications; Cloudflare holds SOC 2 Type II, ISO 27001 and others).
• Executing each provider's Data Processing Addendum (DPA) — which incorporates standard contractual clauses or equivalent transfer safeguards. Bento's DPA is published at gdpr.bentonow.com.
• Limiting what data we share to what is needed for the specific purpose.

By providing your information, you consent to your personal information being disclosed to the recipients listed above located outside Australia (including the United States). You acknowledge that, where you so consent, we will not be required under APP 8.1 to take reasonable steps to ensure that those overseas recipients comply with the APPs, and that Australian privacy law may not apply to those recipients in respect of that information. Where APP 8.1 nevertheless applies, we take the reasonable steps set out above.

If you would like a list of the contractual safeguards we rely on, email dpo@pkbl.asia.

8. Cookies and similar technologies

We use Google Consent Mode v2: when you first arrive, all advertising and analytics cookies are denied by default. The cookie banner asks for your consent before any analytics cookies load. You can change your mind at any time by clearing your browser's cookies for pkbl.asia and re-visiting the site.

The cookies we may set, with your consent, are:

• Functional cookies (always on): a small banner-state cookie so we don't keep showing you the cookie prompt on every page.
• Analytics cookies (only after Accept): Google Analytics 4 cookies (typically _ga, _ga_*) used to count visitors and understand which content is useful.

We do not currently use cookies for advertising or third-party retargeting.

9. How long we keep your information

10. How we keep your information safe

We use reasonable technical and organisational safeguards (APP 11), including:

• HTTPS encryption on every page of the site.
• Cloudflare's network-level protections (firewall, bot mitigation, rate limiting).
• Service providers with recognised independent security certifications — Bento (SOC 2, ISO 27001) and Cloudflare (SOC 2 Type II, ISO 27001 and others).
• Multi-factor authentication on the admin accounts of every service we use.
• The principle of least privilege — we only see data we need.
• An internal data breach response plan.

No system is perfectly secure, but we treat the protection of your information as a serious obligation.

11. Data breach notification

Australia has a Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988. If a data breach happens that is likely to result in serious harm to you, we will:

• Assess the breach within 30 days of becoming aware of the suspected breach (section 26WH).
• Notify the Office of the Australian Information Commissioner ("OAIC") and affected individuals as soon as practicable, where notification is required (sections 26WK and 26WL).
• Take reasonable steps to contain the breach and prevent recurrence.

12. Your rights under the Privacy Act

You can exercise the following rights at any time by emailing dpo@pkbl.asia. We aim to respond within 30 days.

• Access (APP 12) — ask for a copy of the personal information we hold about you.
• Correction (APP 13) — ask us to correct anything that is inaccurate, out-of-date, incomplete, irrelevant or misleading.
• Withdrawal of consent — withdraw your consent for any purpose, at any time. We will stop the relevant processing as soon as reasonably possible.
• Stop receiving direct marketing (APP 7) — unsubscribe from the newsletter; ask us to tell you the source of your email address; or ask us not to use your information for any specified marketing purpose.
• Deletion — ask us to delete your subscriber record. We may keep a minimal suppression record so we don't re-add you (see section 9).
• Portability — on request we will send your data to you in a commonly used machine-readable format (we use CSV).
• Complaint — if you are not satisfied with our response, you can complain to the OAIC at www.oaic.gov.au, by phone on 1300 363 992, or by post to GPO Box 5288, Sydney NSW 2001.

We may need to verify your identity before acting on a request, so we know we are not giving your data to someone else.

13. Children

PKBL.asia is intended for adult pickleball players and players aged 16 or over. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and you believe your child has signed up, please email us at dpo@pkbl.asia and we will delete the record. The Office of the Australian Information Commissioner is registering a Children's Online Privacy Code by 10 December 2026; we will update this policy to reflect any additional obligations once the Code is in force.

14. Future services (retreats, tournaments, paid offerings)

If we begin offering paid services such as retreats or tournament entries, we will ask you for additional information (for example, payment details or — for retreats — travel and dietary information) at that time, with a separate consent. We will update this policy before that happens. The newsletter subscription on its own does not collect any payment, travel, or sensitive information.

15. Third-party listings (clubs, tournaments, coaches)

Our newsletter and any future directory may include information about third-party clubs, tournaments, retreats and coaches that is publicly available. We are not responsible for the privacy practices of these third parties. If you contact a listed organisation directly, that organisation handles your information under its own privacy policy.

16. Changes to this policy

We may update this policy from time to time. The "Last updated" date at the top of this page tells you when. If we make a material change to how we use your information, we will tell you in advance — by email if you are a subscriber, or by a notice on the site.

17. Contact us

For any privacy questions or requests:

• Email: dpo@pkbl.asia
• Postal: C&L International Corp, 1712 Pioneer Avenue, Suite 115, Cheyenne, WY 82001, USA
• OAIC complaints: www.oaic.gov.au · 1300 363 992 · GPO Box 5288, Sydney NSW 2001

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