Privacy Policy
for NON-EU Users.


GGHK Limited (“GGHK”, “we”, “us” or “our”) is committed to protecting and respecting the privacy of those viewing or using our website (“Website”) and using our applications or APIs (collectively, the “Apps”). The protection of your personal information is very important to us, and we understand our responsibilities to handle your personal information with care, to keep it secure and to comply with legal requirements.

If you visit, interact with us, or use our Website or our Apps through any channel, register to attend our events or programmes, download applications we make available to you, enter lucky draws or competitions, or sign up for our e-newsletter, we may collect and process certain personal information about you.

This privacy policy has been developed in accordance with the Personal Data (Privacy) Ordinance (Chapter 486) of the Laws of the Hong Kong Special Administrative Region (“Ordinance”). The Ordinance provides data subjects with rights to ascertain whether we hold personal data relating to them, to obtain a copy of that data, and to correct any data that is inaccurate. If you are subject to EU laws, please read our privacy policy for EEA users.

It may be necessary for us to gather information on you for a specific purpose. We will always inform you when we are collecting such information. It is our intention to respect your request for privacy, and we try our best to provide you with communication channels to facilitate this. Once all gathered information has been used for the intended purpose, it is destroyed or de-identified.

GGHK has created this Privacy Policy in order to demonstrate our firm commitment to protecting your privacy. The following discloses our information gathering methods and dissemination practices for our Website and our Apps. GGHK is not responsible for the privacy practices of other linked sites.



GGHK collects site visitors’ contact information (e.g., e-mail or street address) and demographic information (e.g., age, country of residence, preferred language etc.). This information is used by us to further our objectives. Contact information from the forms is used to send promotional materials and information to you. If data collected is to be displayed at a later date, due care will be given to keep it anonymous and you will be advised in advance. Users may opt out of receiving future mailings. Demographic information is used for our research requirements and to tailor your experience at our site, showing content of interest, and displaying the content according to your preferences. We may share with our advertisers, sponsors and partners such information on an aggregate basis. Users may opt out from receiving future mailings.

When you come to our Website/Apps, our server software records the domain name of your computer. We may also track the pages you visit. We do these things so that we can measure traffic, gauge the popularity of various parts of the Website, gain some general knowledge about our audience and compile aggregated statistics.

We may also use cookies to collect information on how you use the Website. If you refuse cookies, certain features of this Website may not be available to you. For further information, please refer to our Cookies Policy.

Data collected by GGHK is used only for the purposes indicated above. Personal information will not be disclosed to any third party except as follows: 

on a confidential basis to agents we use in the ordinary course of our business including the Federation of Gay Games, and fusesport, such as for data management and distribution of our promotional materials;

  • as we may be required to do so by laws; and
  • as you indicate your choice to receive promotional materials from third parties named in the forms.


GGHK will take reasonable steps to ensure that all information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment accessed only by authorised persons. However, we give no warranty against third parties hacking into the data or any unauthorised access to the data by anyone.



You can opt out from receiving information from us or to delete your information from our records at any time should you no longer wish to receive updates concerning our events, activities and promotions. To opt out, please send us an email: or click the “unsubscribe” button on the Website/Apps.



As a user of our Website and/or Apps, it may be necessary for you to provide us with your personal data when you register with us for any service and/or product. If your personal data is incomplete or incorrect, we may not be able to provide or continue to provide the services to you. We shall keep your personal data confidential at all times. Our policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of personal data will be in accordance with requirements under the Ordinance and this Personal Information Collection Statement. We may from time to time collect your personal data specifically for the purpose of events, activities or competitions (“Events”) organised or promoted by us.

  • Types of Personal Information that we Collect:

We may collect certain information from you when you use our Website and our Apps. This includes:

Contact details and basic user information including your name, age, email address, telephone number, country of residence, travel history, past and intended Gay Games attendance information;

Your marketing preferences including interests and market list assignments, marketing objections, preferred language, website or app data;

Usage information including how you use our Website or applications such as clicks and which pages have been shown to you, referring webpage address;

Device data and log information including IP addresses, device ID and type, and details about your use of our website, app, browsing history, search queries, browser type, session frequency, geolocation information, wireless and mobile network connection information; and

Cookies and tracking technologies including technologies cookies and web beacons and advertising IDs (more information about use of cookies can be found in our Cookies Policy).

  • We will permit you to provide the following special categories of personal data on a voluntary and optional basis on the basis of your consent:

Health data;

Sexual orientation; 

Gender Identity; and



  • How we Collect Personal Information:

Your personal information is collected by us either directly (for example, when you use our Website and Apps, register for our events or programmes, enter lucky draws or competitions, sign up for our e-newsletter, download our applications, or when you interact with us by contacting us for enquiries or providing feedback). You are under no obligation to provide the personal information when we seek to directly collect it from you. However, if you do not provide us with certain information marked as mandatory or with an asterisk on the relevant forms, we may not be able to process your submission, provide you with our services or respond to your enquiries.

We may receive information about you indirectly from other sources and combine such information with information we collect through our Website and Apps where this is necessary to help manage our relationship with you. These other sources may include third party software applications, advertising technologies, and social media platforms such as Facebook, Instagram, Twitter, WeChat, YouTube and Weibo. We may also use other social media platforms in the future.

If you provide us with information about other individuals, you must tell those individuals and let them know where they can find a copy of this Privacy Policy.

  • Purposes for which personal data are collected and used:

We may use the data collected and provided by you for one or more of the following purposes: 

to identify you for entry into lucky draw or any other promotional activities;

to contact you regarding your enquiries, notify you of the results of lucky draw/ promotional activities and the subsequent presentation or redemption arrangement;

for announcement and publicity of lucky draw/ promotional activities’ result;

for marketing and promotion purposes;

for identification and verification purposes;

for our own internal records, research and statistical purposes; and

for any other purpose pertaining to Events.

You are not required to provide the data. However, if you select not to supply the data as requested, your entry form or application form (as the case may be) will not be counted or processed or be eligible for the associated Events.

  • Please note that we are not required to comply with the provisions of the Data Principle 1(3) under the Ordinance in respect of any subsequent collection personal data from you if: 

the subsequent collection would be to repeat, without any material difference, what was done to comply with that principle in respect of the first collection; and

no more than 12 months have elapsed between the first collection and subsequent collection.

We will not, however, use your personal data for a new purpose without your prescribed consent.

  • Data Security

The data you provide to us will be stored at our office or servers of our agents in Hong Kong and the United States accessible only to our authorised employees and contractors and those to whom we give access. However, we give no warranty against third parties hacking into the data or any unauthorised access to the data by anyone.

GGHK will take reasonable steps to ensure that all information we collect, use or disclose is accurate, complete and up-to-date. You have the right (subject to various exceptions and in accordance with the Ordinance) to access certain personal data held by us about you and correct any inaccuracies. If you wish to access or correct your personal data, please contact us information provided in Section 5.

We may share your personal data with sponsors of Events or authorised agents or contractors for prize presentation, redemption or delivery (as appropriate) in connection with the associated Event. By entering the competition or promotion, you acknowledge and expressly agree with the above.




Where you have given your consent and have not subsequently opted out, we may use your personal data, including your contact information and demographic information to send marketing and promotional purposes to you. For example, we may send or show you updates on our Events and our sponsors by post, telephone or online (including by email or through your mobile phone). You may at any time require us to cease to use your personal data for direct marketing purposes.




The data you provide in this registration form may be transferred to our partners and vendors for the purpose of facilitating and analysing the Gay Games events.




We will keep your personal data only for as long as necessary to fulfil the purpose for which it is being collected. We may also retain archived personal data for statistical purposes. Your information that is no longer needed is either irreversibly anonymised or securely destroyed. Please note that we are not liable in an action for damages at the suit of other data users in respect of such erasure.




By submitting any entry form/application form, you certify that all information provided to us in the form is true and correct. You agree that the personal data given by you and collected by us from time to time may be used and disclosed for the foregoing purposes, and to such persons as may be appropriate in accordance with this Personal Information Collection Statement and this Privacy Policy.

This Personal Information Collection Statement and this Privacy Policy are subject to change without prior or separate notification. Any changes will be posted to our Website.



For enquiries, you may contact our data privacy officer at:

Full name of legal entity: GGHK Limited

Email address:

Postal address: Suite 701, 7/F, The L Plaza, 367-375 Queen’s Road Central, Hong Kong


Last updated March 2020