Privacy Policy for 24Solar Mobile App

1. Personal Information Collection Statement (PICS)

We collect and utilize your personal data parameters for the following specified "Personal Data Purposes" under the PDPO framework:

• Localized Event Matching: Utilizing your system Location Data to calculate and display sports matches and social gatherings happening within your proximity across Hong Kong geographic districts.
• Fitness Performance Analytics (planned feature — not yet active): A future version of the App may offer optional syncing with Apple Health or Google Fit to track step counts and active calorie burn during joined matches. This data will only be processed if you grant explicit system-level permission after the feature launches. The current version of the App does not collect, access, or process any health or fitness data.
• Account Administration: Processing age eligibility declarations to manage minimum age compliance, authenticating account creation tokens, and enabling interface notifications between hosts and attendees.
• Direct Marketing Communications: Delivering targeted promotions and district-based partner offers tailored to your indicated sports preferences, subject to your explicit opt-in.

2. Specific Data Elements We Process

• Registration Datasets: profile handle and verified email address obtained through Apple or Google sign-in. We do not currently collect your date of birth; age eligibility (18+) relies on your self-certification at registration. A future version may collect your date of birth to strengthen age verification, and any such collection will fall under the Account Administration purpose above.
• Location Metrics: Precise real-time geographical coordinates (GPS) and network IP address flags. This track is unlocked only if you grant system-level permissions.
• Health & Fitness Synced Data: Step logs and active calorie indicators synced from Apple Health or Google Fit, only once this feature is released and only with your explicit permission.
• Social Identity Metadata: Skill level self-assessments, optional user bio text, and profile graphics.

3. Location Services Control Mechanisms

Your device location updates are handled to enable nearby interface generation (e.g., "Find a basketball match in Mong Kok"). Tracking relies on your active preference selections ("Allow While Using the App" vs "Always Allow"). You can disable these tracking lines via your device operating system privacy panel at any time, though this will restrict map discovery modules.

4. Direct Marketing & Separate Opt-In Mandates

In alignment with the PDPO, we operate an unbundled, separate, explicit opt-in protocol for marketing actions:

• Targeted Marketing: We require your active consent to use your sports focus parameters to display local partner offers.
• Third-Party Data Transfers: We will not lease or sell your contact fields to third parties for commercial gain. Any structural data sharing with local sports complexes or F&B groups for marketing purposes requires an explicit, separate opt-in step from you.
• Opt-Out Rights: You maintain the right to cancel your marketing permissions at any point, free of charge, via the app preference panel.

5. Data Security, Retention, and Breach Protocols

• Security Architecture: We enforce modern data isolation and encryption standards to secure backend storage nodes. Personal parameters are visible only to event hosts and participants within active matches, restricted to your profile name and sports tier.
• Breach Management: In the event of a significant data leak, we will notify the Privacy Commissioner for Personal Data (PCPD) and affected Hong Kong users within rapid operational windows, following regulatory guidelines and compliance practices.
• Retention Timelines: We keep personal data records as long as your profile remains functionally active. Upon your formal deletion request, your data footprint is securely purged or anonymized within 30 days, except where continued data retention is required for ongoing legal compliance, regulatory duties, fraud-prevention tracking, platform security protection, system backups, or active dispute-resolution purposes.

6. Strict Age Gate and Data Protection

The 24Solar App is intended for and restricted to individuals who are 18 years of age or older. We do not knowingly collect or solicit personal data from anyone under the age of 18. If we discover that an account has been created by a minor in breach of our Terms of Use, we will take steps to delete all associated personal data from our systems within 30 days and terminate the account without liability.

7. Data Access and Correction Rights (DAR)

In accordance with your legal rights under the PDPO, you possess a statutory right to issue a formal Data Access Request to obtain a copy of the information files we hold regarding your identity, as well as the right to demand immediate Data Correction regarding any factual errors. As permitted under Section 28 of the PDPO, the Company reserves the right to charge a reasonable administrative fee for processing and executing any such Data Access Request. These protocols can be initiated by contacting our designated Data Protection Officer at: 24solar.app@gmail.com.