Privacy Policy
The short version. PKBL.asia is a free weekly newsletter for pickleball players in Singapore. We collect your email address (and optionally a few survey answers about your game and preferences) so we can send you the newsletter and related updates about tournaments, retreats, coaching and gear.
We don't sell your data. You can unsubscribe in one click in any email, and you can ask us to delete your information at any time by emailing dpo@pkbl.asia.
1. Who we are
PKBL.asia is operated by C&L International LLC ("PKBL.asia", "we", "us", "our") — a Delaware limited liability company, with mailing address 215 S Wadsworth Blvd STE 400, Lakewood, CO 80226, USA. We are the data controller for personal data collected through this website.
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 data through pkbl.asia and any sub-domains we operate. PKBL.asia is targeted at residents of Singapore, and we have written this policy to comply with Singapore's Personal Data Protection Act 2012 ("PDPA"). Where you are located outside Singapore, your local law may also apply; the protections in this policy apply to you regardless of where you live.
3. Personal data 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.
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.
4. How we use your data, and the legal basis
Under the PDPA, we rely on your consent as the legal basis for most of what we do. The table below summarises each purpose and the consent we rely on:
| Purpose | Data used | Legal basis (PDPA) |
|---|---|---|
| Sending you the weekly newsletter | Email address, first name (if given) | Consent — given when you submit the signup form. |
| Tailoring newsletter content (segmenting by city, level, interests) | Survey answers, city | Consent — given when you complete the survey. Skipping the survey is fine and doesn't affect your subscription. |
| Sending occasional related updates (tournaments, retreats, coaching, gear) | Email address, survey answers | Consent — bundled into the newsletter subscription. You can opt out of these specifically by replying to any email or contacting our DPO. |
| Measuring website performance and improving the service | Cookie / analytics data (only after Accept) | Consent — given via the cookie banner. |
| Responding to enquiries you send us | Your email and message content | Consent or our legitimate interest in responding to you, whichever applies. |
| Keeping records of consent and unsubscribes for compliance | Email, timestamp, source | Legal obligation under the PDPA and Spam Control Act 2007. |
We will not use your personal data for any other purpose without first asking you.
5. Direct marketing and your right to unsubscribe
The PKBL.asia newsletter is a marketing message under Singapore's Spam Control Act 2007. We:
- Include a clear, working unsubscribe link in every email.
- Keep that unsubscribe facility working for at least 30 days after each email is sent.
- Stop sending you marketing emails within 10 business days of receiving your unsubscribe request, as required by the Spam Control Act.
- Where we send a bulk message that meets the Act's threshold, we include the "<ADV>" label as required.
- 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. Withdrawal of consent doesn't affect anything we did before you withdrew it.
6. Who we share your data with
We share your data only with service providers who help us run PKBL.asia. They process your data on our instructions, under written agreements that limit them to that purpose. We do not sell or rent your personal data, and we don't give it to advertisers.
| Service provider | Purpose | Where data is processed |
|---|---|---|
| Bento (Backpack Internet Pty. Ltd, trading as Bento Software) | Email service provider — stores your subscriber record and sends the newsletter. Acts as our processor. | Australia and the United States (with possible storage in other countries via Bento's infrastructure providers). |
| Cloudflare, Inc. | Website hosting (Cloudflare Pages), form processing (Cloudflare Workers), DNS, network security. | Global edge network; primary processing in the United States. |
| Google LLC | Tag management (Google Tag Manager) and analytics (Google Analytics 4) — only loaded if you accept the cookie banner. | United States; Google may transfer to other countries where it has data centres. |
We may also disclose personal data 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
Because the providers above are based in Australia, the United States and other countries outside Singapore, your data will be transferred outside Singapore when you subscribe. Under section 26 of the PDPA, we are required to ensure that data transferred overseas is protected to a standard comparable to the PDPA. We do this by:
- Choosing service providers with recognised security certifications (e.g. our email provider, Bento, holds SOC 2 and ISO 27001 certifications).
- 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.
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 use cookies for advertising or third-party retargeting.
9. How long we keep your data
| Data | Retention period |
|---|---|
| Newsletter subscriber record (email, name, city, survey answers, tags) | Until you unsubscribe or ask us to delete you, plus 12 months in a "suppression list" so we don't accidentally re-add you. When you ask us to delete your record, our email provider Bento removes it from active systems within 30 days and from encrypted backups within 90 days after that. |
| Unsubscribe request record | 3 years, to comply with our obligations under the Spam Control Act and PDPA. |
| Email correspondence | 3 years from the last reply, then deleted. |
| Server access logs (Cloudflare) | Up to 30 days. |
| Google Analytics 4 data | 14 months (the GA4 default). |
10. How we keep your data safe
We use reasonable technical and organisational safeguards, 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 — our email provider Bento holds SOC 2 and ISO 27001; our infrastructure provider Cloudflare holds SOC 2 Type II, ISO 27001 and other certifications.
- Multi-factor authentication on the admin accounts of every service we use.
- The principle of least privilege — staff only see data they need to do their job.
- An internal data breach response plan.
No system is perfectly secure, but we treat the protection of your data as a serious obligation.
11. Data breach notification
If a data breach happens that is likely to result in significant harm to you, or that affects 500 or more individuals, we will:
- Notify Singapore's Personal Data Protection Commission ("PDPC") within 3 calendar days of completing our assessment, as required by the PDPA.
- Notify affected individuals as soon as practicable when notification is required.
- Take reasonable steps to contain the breach and prevent recurrence.
12. Your rights under the PDPA
You can exercise the following rights at any time by emailing dpo@pkbl.asia. We aim to respond within 30 days.
- Access — ask for a copy of the personal data we hold about you.
- Correction — ask us to correct anything that is inaccurate or out of date.
- Withdrawal of consent — withdraw your consent for any purpose, at any time. We will stop the relevant processing as soon as reasonably possible.
- 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 — ask us to send your data to you, or to another provider, in a commonly used machine-readable format (we use CSV).
- Complaint — if you are not satisfied with our response, you can contact the PDPC at www.pdpc.gov.sg or call +65 6377 3131.
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. We do not knowingly collect personal data from children under 13. 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.
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 data 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 data, 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 LLC, 215 S Wadsworth Blvd STE 400, Lakewood, CO 80226, USA