Whale Club is committed to respecting the privacy of our members, guests, associates and employees. The Whale Club Policy (the “Policy”) has been developed as a statement of principles and guidelines that governs how the Whale Club collects, uses, discloses, and protects personal information provided by our users. This policy applies to all personal data in Whale Club’s control, whether it is stored and/or processed by a third-party provider.
Whale Club is committed to maintaining the highest standards with respect to personal information and as such, this policy is subject to review to ensure currency and compliance with Hong Kong’s Personal Data (Privacy) Ordinance (PDPO), as amended from time to time.


Personal Information – Information about an identifiable individual and includes employee personal information but does not include contact information or work product information.
Contact Information – Information that allows an individual to be contacted at work. This includes name, position, business telephone number and address, business email and fax for the individual.
Work product information – Information that is prepared or collected by an employee as part of that individuals work responsibilities, but does not include information about an individual who did not prepare or collect the information.
Summarized or aggregated information – Records that have been stripped of information potentially identifying individuals, and which have been manipulated or combined to provide generalized, anonymous information. We may use your Personal Information to generate summarized data for internal use. Your identity and Personal Information will be kept anonymous and will be used for management and planning purposes.
Publicly available information is not considered Personal Information and is therefore not subject to this policy.


The Club can be expected to collect the following Personal Information with respect to Members, Guests, Associates and Employees:
a. Personal details such as name, birthdate and marital status
b. Contact details such as address, email, and telephone number
c. Payment details including credit card or banking information
d. Authentication credentials including username and IP address
e. Activities performed by users in their use/performance of service
f. Identification details such as photograph, video (surveillance) and biometric data
g. Occupation and professional associations if voluntarily provided by user
h. Emergency contact information if voluntarily provided by user
i. Information regarding guests you bring to the Club
j. Details on when you access the Club including the device used for entry and GPS data
k. Personal information such as allergies or medical conditions if voluntarily provided by user
Whale Club may also collect Personal Information from other sources including credit bureaus, employers or personal references, or other third parties who represent that they have the right to disclose the information.


Whale Club collects, uses, discloses and protects Personal Information for the following specific purposes:
1. To verify identity
2. To review and select prospective Club members
3. To review and select prospective employees
4. To maintain a record of all members and guests in the Club at any given time
5. To manage ongoing relationships with Managers, Associates and Employees
6. To enroll a member, guests, associate or employee in a specific program
7. To maintain accurate membership records
8. To process membership and other payments
9. To maintain employment records to ensure accurate salary, benefit, and related information
10. To monitor and assess employee performance
11. To facilitate the provision of services necessary for it to maintain and operate Whale Club as an organization and crypto’s organization
12. To track member and guest interests for development of new services and for marketing purposes
13. To comply with requirements established by applicable federal and provincial legislation
14. To provide necessary financial information to accountants, auditors, and other professional advisors as required
1. Such other reasons as a reasonable person would consider appropriate
The Club does not collect, use or disclose Personal Information other than for the purposes outlined above, save and except as required by law or as such collection, use and/or disclosure is permitted by PIPA without consent. While you are generally required to consent to the collection, use, or disclosure of Personal Information, such consent is not required in certain circumstances, and in such circumstances consent will not be sought.


Personal data is collected by fair and lawful means. Terminal City Club provides notice as to the purpose for which personal data is collected, used, discloses. Upon request, persons collecting Personal Information shall explain the identified purpose(s) or refer you to a designated person within the Club who will explain the purpose(s) for which the Personal Information is collected. Terminal City Club assumes no responsibility for obtaining and validating that appropriate consent has been obtained in respect to personal data transferred to our systems/websites/apps by staff, organizations and/or customers.
By submitting Personal Information to the Club, you agree that the Club may collect, use or disclose your Personal Information in accordance with this Policy and as permitted or required by law. Subject to legal and contractual requirements, you may refuse to withdraw your consent to certain of the identified purposes at any time by contacting the Club’s Privacy Officer or selecting to opt-out in the case of app and online services. If you refuse to deliver necessary Personal Information to the Club or if you wish to withdraw your consent, the Club may not be able to continue to provide you with certain services and/or information which may be of value to you; please contact the Club for more information regarding the implications of withdrawing consent.
When personal Information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identifies prior to use. Unless the new purpose is permitted or required by law, or is implied in the previously granted consent, your consent will be sought and obtained before the Personal Information is put to a new use.


Whale Club will collect, use, store, share, transmit, delete or otherwise process (collectively “process”) cookies and log files during our operation of the Whale Club’s website and Whale App, a platform dedicated to the custody and transaction of digital assets and the provision of related services (the “Services”).We may use “cookies” to gather some information such as:
1. Recording your visit, including your usage patterns
2. Analysing the number of visitors and general usage patterns
3. IP address, domain name and access time Other tracking technologies:
We do this to gather as much useful information as possible to help improve your and other Users of our Website’s experience. Only the information that you provide, or the choices you make while visiting a website can be stored in a cookie. For example, the site cannot determine your email address unless you choose to input this information. Allowing a website to create a cookie does not give that website or any other site access to the rest of your computer, and only the site that created the cookie can read it.
We may also collect information regarding your IP address, domain name and access time. This information is used for our own security purposes. As it is not linked to any personal information, it is separate from your personal data. In rare instances, IP addresses may be used to assist in deterring and/ or preventing abusive or criminal activity on the Website.Most internet browsers are initially set to accept cookies. If you prefer, you can set your browser to disable cookies. You can do this through your browser “help” setting/ function. However, by disabling cookies, you may not be able to take full advantage of our Website.
If you accept cookies during your use of our Website, you acknowledge that your information is being collected, stored, accessed, and used as described above


Whale Club may disclose Personal Information with third parties engaged to assist the Club in providing services or products to Members, Guests, Associates and Employees to carry out one or more of the purposes described above. These services are prohibited from using personal information for any purpose other than to provide this assistance and are require to protect personal information disclosed to them by the Club and to comply with general privacy principles and all applicable privacy laws.
The Club will never disclose, deliver up, rent or sell your Personal Information to any outside organization unless consent to such use is specifically granted in advance of such disclosure.


In order to protect the confidentiality of Personal Information, Whale Club employs various reasonable security safeguards appropriate to the format and sensitivity of Personal Information. However, because risks such as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction cannot be eliminated, Whale Club cannot guarantee the security of your information and will not be liable for its release and any consequences of its release.
With the exception of the on-line roster, which is accessible only to members and employees, only Whale Club’s employees with a business need-to-know, or whose duties reasonably so require, are granted access to other Personal Information about Members, Associates and/or Employees.
Whale Club shall keep Personal Information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where Personal Information has been used to make a decision about a Member, Associate, or Employee, the Club shall retain, for a period of time that is reasonably sufficient, or as required by law, to allow for access by the Member, Associate or employee, either the actual information or the rationale for making the decision, if such access is not in breach of PDPO, this Policy or the Rules.
Whale Club shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to Personal Information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.


Whale Club shall maintain procedures for addressing and responding to all inquiries or complaints from individuals regarding the Club’s handling of Personal Information. Whale Club’s Privacy Officer shall report all complaints in respect of the Club’s handling of Personal Information to the Executive Committee within 48 hours of receipt of each such complaint.
Whale Club shall investigate all complaints concerning compliance with this Policy. If a complaint is found to be justified, Whale Club shall take appropriate measures to address and/or resolve the complaint including, if necessary, amending this Policy and Whale Club’s procedures should this Policy and Whale Club’s procedures be found, by the Executive Committee, to be deficient in responding to any such complaint should this Policy and/or Whale Club’s procedures be found, by the Executive Committee, to be deficient in responding to any such complaint. An individual who brings such a complaint shall be informed of the outcome of the investigation regarding his or her complaint.


For more information regarding the Policy, please contact the Privacy Officer at email.
Find this policy online at