PRESS COURT LTD. PRIVACY POLICY
Effective Date: March 23, 2026
Last Updated: March 23, 2026
This Privacy Policy explains how Press Court Ltd. ("Press Court", "we", "us", "our"), a company incorporated in Bermuda with its registered office at 2 Par-la-Ville Road, Hamilton, HM 08, collects, uses, discloses and protects personal information in connection with our sports facility operations.
Press Court operates a pickleball and racquet sports facility which uses:
the PodPlay software platform for reservations, membership management and payments;
keyless entry systems for facility access; and
extensive video surveillance (CCTV) inside the facility and around the perimeter for security and monitoring play/usage.
We are committed to complying with Bermuda's Personal Information Protection Act 2016 (PIPA) and any related data protection legislation, and to using personal information in a manner that respects individuals' privacy rights[1][2].
This Privacy Policy applies to all personal information we process in relation to:
members and prospective members;
guests and visitors;
programme, league and event participants;
coaches and service providers;
employees, directors and officers; and
any individual whose personal information is captured by our CCTV systems, keyless entry systems or the PodPlay platform.
We collect only such personal information as is reasonably required for the purposes described in this Policy, in accordance with PIPA's proportionality principle[3].
Categories of Personal Information
Identity and Contact Information
Full name
Date of birth / age
Gender (where provided)
Mailing address
Email address
Telephone number
Emergency contact details
Copies or details of identification documents (e.g. passport or driver's licence) where needed to verify identity or eligibility
Membership and Account Information
Membership category, status and history
PodPlay account details and identifiers
Preferences (e.g. communications, play preferences)
Username and authentication credentials
Reservation, Usage and Access Information
Court and facility reservation history
Information about participation in events, leagues or clinics
Keyless entry data (e.g. access codes or digital keys)
Access logs (date, time and duration of entry/exit; doors or areas accessed)
Financial and Transaction Information
Billing address
Payment method and tokenised card details processed via PodPlay or other payment processors
Records of payments, refunds and charges
We do not store full card numbers on Press Court systems; these are handled by PCI DSS-compliant third-party payment processors.
Health and Safety Information
Health or medical information you choose to provide (e.g. relevant conditions, allergies or limitations) to allow us to manage risk and respond appropriately in emergencies
Incident and accident reports
CCTV and Video Surveillance Information
Video images (and associated metadata such as date, time and camera location) captured by cameras installed throughout the interior of the facility (including courts and common areas) and around the external perimeter
Still images extracted from video where needed for investigation or evidence
Cameras are not placed in washrooms, changing areas or other private spaces where there is a reasonable expectation of privacy[4][5].
Technical and Website/App Information
IP address, device identifiers, browser type and operating system
Usage data and log information collected through our website or through the PodPlay application (as further detailed in PodPlay's own privacy policy)
In accordance with PIPA's purpose limitation principle, we use personal information only for specified, lawful and reasonable purposes[6][7], including:
Membership administration – assessing and processing applications, creating and managing member profiles, administering benefits and communications
Reservations and facility operations – managing court bookings, events, leagues and programmes via PodPlay; optimising court and facility utilisation
Keyless access management – issuing, managing and revoking electronic access credentials; maintaining access logs; controlling entry during staffed and unstaffed hours
Security and safety – operating CCTV systems to deter, detect and investigate unauthorised access, criminal activity, vandalism, safety incidents and breaches of club rules; verifying use of access credentials; supporting response to incidents[4][5]
Payment processing and accounting – processing membership fees, booking fees and other payments; performing financial reconciliations and record-keeping
Communications and marketing – sending service messages, operational updates, policy changes and, where permitted, marketing communications about Press Court services, events and offers (with opt-out options)
Dispute resolution and enforcement – investigating and enforcing compliance with facility rules, membership terms and this Privacy Policy; handling complaints and disputes; exercising or defending legal claims
Legal and regulatory compliance – meeting obligations under Bermuda law (including PIPA), responding to lawful requests from regulators or law-enforcement authorities, and reporting data breaches where required[8]
Service improvement – analysing usage patterns and feedback to improve our operations, facility design, security measures and member experience
If we intend to use personal information for a materially new purpose, we will do so only where permitted by PIPA and, where required, after updating this Privacy Policy and/or seeking fresh consent.
We use personal information under one or more of the following bases recognised by PIPA[9]:
your consent, where this is required and can be reasonably demonstrated (e.g. direct marketing, some uses of images for promotional purposes);
where a reasonable person would consider the use to be fair and lawful in the circumstances and not unduly harmful to your rights;
where necessary to enter into or perform a contract with you (for example, administering your membership, bookings and access);
where required to comply with legal or regulatory obligations;
where necessary for legitimate interests such as ensuring safety, security and the effective management of the facility, provided these interests are balanced against your privacy rights.
You may withdraw consent at any time where processing is based on consent. Withdrawal may affect our ability to provide certain services (for example, if you withdraw consent to essential communications or to the use of particular sensitive information).
Because CCTV involves continuous monitoring and may capture sensitive personal information, we provide the following additional information in accordance with recent Bermuda Privacy Commissioner guidance[4][5]:
Purposes of CCTV
Security of the premises and property
Safety of members, guests and staff
Monitoring facility usage and compliance with rules
Investigating incidents, complaints and suspected misconduct
Deterring criminal activity and vandalism
Assisting law enforcement Transparency and Signage
Clear signage is displayed at entry points and within the facility to inform individuals that CCTV is in operation, the purposes of monitoring, and who is responsible for the system.
Data Minimisation and Privacy by Design
Cameras are positioned and configured to focus on Press Court premises and to avoid capturing areas not relevant to our purposes wherever reasonably possible
No cameras are placed in washrooms, changing areas or other private spaces
Camera angles and fields of view are regularly reviewed Retention Period
CCTV recordings are normally retained for approximately 90 days, after which they are automatically overwritten, unless a particular segment is preserved longer in connection with an incident, investigation, complaint, insurance claim or legal process[10].
Access and Disclosure
Access to CCTV footage is strictly limited to authorised Press Court personnel (and, where necessary, identified service providers) on a need-to-know basis
Footage may be disclosed to the Bermuda Police Service or other authorities where lawful and appropriate
Footage will not be disclosed to the media for entertainment purposes or placed on the internet except where required for legitimate purposes (e.g. public appeals for information in consultation with police)
Your Rights
You have the right to request access to CCTV footage that shows you, subject to verification of your identity and provided such access does not compromise the privacy rights of others or interfere with an investigation. Requests should be made in writing to the Data Privacy Officer.
By entering the facility you acknowledge that your image will be captured by CCTV as described in this Policy.
We do not sell or rent personal information. We may disclose personal information to:
Service Providers and Vendors
PodPlay (reservation, membership and payment platform provider)
Payment processors (e.g. Stripe, PayPal or other financial institutions)
Providers of keyless entry and security systems
IT, hosting, communications and support providers
Professional advisers (lawyers, accountants, insurers)
These third parties are engaged under arrangements that require them to protect personal information and to use it only for specified purposes on our behalf.
Sports Bodies or Rating Systems
Where you request, we may share relevant play or results data to organisations such as DUPR or other rating systems.
Regulators and Law Enforcement
Where required or permitted by law, we may disclose personal information, including CCTV footage and access logs, to:
The Privacy Commissioner for Bermuda (PrivCom)
The Bermuda Police Service
Courts or other public authorities
Other regulatory bodies Other Third Parties
In connection with a merger, acquisition, reorganisation or sale of Press Court's business, subject to appropriate safeguards
Where you have provided consent to the disclosure
Where necessary to protect the vital interests of any person
Some of our service providers (including PodPlay and certain payment and technology providers) may be located outside Bermuda. Where we transfer personal information to an "overseas third party" we will comply with PIPA section 15 by[11][12]:
assessing whether the overseas third party is located in a jurisdiction offering a level of protection comparable to PIPA (such as jurisdictions with APEC CBPR certification or similar recognised standards);
putting appropriate contractual and other safeguards in place (such as standard contractual clauses);
obtaining your consent where required; and
remaining responsible under PIPA for the protection of your personal information.
We will provide notice in this Policy or at the point of collection where your personal information may be processed in other jurisdictions.
Press Court implements appropriate technical and organisational measures to protect personal information against loss, unauthorised access, misuse, alteration and disclosure, in accordance with PIPA section 13[13], including:
Role-based access controls and authentication for systems containing personal information
Encryption and secure transmission of data where appropriate
Network security measures such as firewalls and intrusion detection
Secure configuration and maintenance of CCTV and keyless entry systems
Physical safeguards and restricted access to server rooms and security equipment
Regular security assessments and updates
Policies and training for staff and contractors regarding privacy and information security
Incident response and breach-handling procedures
Despite these measures, no system is completely secure. We encourage you to use strong passwords and to protect the credentials you use to access PodPlay and any other systems.
Accuracy
We take reasonable steps to ensure that personal information is accurate, complete and kept up to date as necessary for the purposes for which it is used[14]. You can help by promptly notifying the Data Privacy Officer of changes to your contact details or other information.
Retention
We retain personal information only for as long as reasonably necessary for the purposes described in this Policy or as required by law[15]. Typical retention periods include:
Membership records – for the duration of membership and up to 7 years thereafter for legal, tax and regulatory purposes
Financial records – for the period required by Bermuda tax and accounting laws (typically 7 years)
Access logs – for up to 2 years or as required for security, audit and dispute-resolution purposes
CCTV footage – as described in section 6 (typically 90 days unless preserved for specific purposes)
Incident and accident reports – for up to 10 years or as required for insurance and legal purposes
Deletion
When personal information is no longer required, we will securely delete or anonymise it in accordance with PIPA requirements.
Subject to applicable exceptions, you have rights under PIPA which include[16][17]: Right of Access (Section 17)
To request confirmation of whether we hold personal information about you and to obtain a copy of such information.
Right to Correction (Section 19)
To request correction of inaccurate or incomplete personal information. Right to Erasure / Blocking / Destruction (Section 19)
To request that we erase, block or destroy personal information in certain circumstances. Right to Object or Withdraw Consent
To object to particular uses or to withdraw consent where processing is based on consent. How to Exercise Your Rights
Requests should be made in writing to the Data Privacy Officer using the contact details below. We will:
Acknowledge your request within 5 business days
Respond substantively within 30 days (we may extend this by a further 30 days for complex requests, with notice to you)
Verify your identity before acting on a request
Provide reasons if we refuse or limit a request
We will not charge a fee for PIPA rights requests unless the request is manifestly unreasonable, excessive or repetitive[18].
If you have concerns about how we use your personal information, you may contact the Data Privacy Officer using the details below. Our process is:
Submission – you submit a written complaint to the Data Privacy Officer setting out your concerns and relevant details
Acknowledgement – we will acknowledge receipt within 5 business days
Investigation – the Data Privacy Officer will investigate and aim to resolve the matter within 30 days, requesting further information from you if needed
Response – we will provide a written response outlining findings and any steps taken
Escalation to the Privacy Commissioner
If you remain dissatisfied, you have the right to lodge a complaint with the Privacy Commissioner for Bermuda (PrivCom)[19]:
Email: [email protected]
Telephone: +1 (441) 543-7748
Website: www.privacy.bm
Address: Office of the Privacy Commissioner for Bermuda, 4th Floor, Craig Appin House, 8 Wesley Street, Hamilton HM 11, Bermuda
If there is a breach of security leading to the loss, unauthorised access, disclosure or other misuse of personal information which is likely to adversely affect individuals, we will comply with PIPA section 14 by[20]:
Taking immediate steps to contain and assess the breach (within 48 hours of discovery)
Notifying the Privacy Commissioner without undue delay (within 72 hours where practicable)
Notifying affected individuals directly and without undue delay where the breach is likely to adversely affect them
Providing information about the nature of the breach, its likely consequences, and measures taken or to be taken to address it
Documenting all breaches (whether or not reportable) and remedial actions taken
Where we collect personal information relating to children under 18 (for example junior members or participants), we will:
Obtain consent or authorisation from a parent or legal guardian where required by PIPA
Take account of the child's age and maturity in determining appropriate safeguards
Ensure that privacy notices are clear and age-appropriate
Apply heightened security and confidentiality measures to children's information
Parents and guardians have the right to access, correct or request erasure of their child's personal information by contacting the Data Privacy Officer.
In accordance with PIPA section 5, Press Court has appointed a Data Privacy Officer who is responsible for:
Overseeing compliance with this Privacy Policy and PIPA
Handling privacy-related enquiries and complaints
Serving as the point of contact with the Privacy Commissioner
Coordinating data breach response
Providing privacy training and guidance to Press Court personnel Contact details for the Data Privacy Officer are provided in section 17 below.
We may update this Privacy Policy from time to time, for example to reflect changes in law, Privacy Commissioner guidance, our practices or technology. We will:
Post the updated Policy at the facility and on our website
Update the "Last Updated" date at the top of this Policy
Notify material changes by email or via PodPlay notification where practicable
Comply with PIPA requirements regarding changes to privacy notices
Continued use of our facility or services following any update will constitute acceptance of the revised Policy. We encourage you to review this Policy periodically.
For questions about this Privacy Policy, to exercise your rights, or to make a complaint, please contact:
Data Privacy Officer
Press Court Ltd.
2 Par-la-Ville Road
Hamilton HM 08 Bermuda
Email: [email protected] Telephone: +1 (441) 232-2255
PCL collects personal data and information solely for membership, event registration and organisation, and communication purposes. PCL limits data collection to what is necessary to run the PCL as a sporting organization and registered Bermuda charity. The following categories of personal data will likely to be required and are not an exhaustive list:
Full name
Age
Gender
Mailing address
Credit card and banking information
Health information
Passport, driver’s licence, or other photo identification
Personal data will only be used for the purposes for which it is collected, ensuring transparency and respect for the rights of individual data subjects. Such purposes include but are not limited to:
Managing membership accounts
Organising and communicating events and tournaments, including by email distribution of PCL newsletter
Communicating important dates and information related to the PCL
At all times the collection of personal data shall be only for a specified, legitimate purpose and all reasonable efforts shall be made to ensure such data is relevant and not excessive. Data collection shall be limited to what is necessary and for the intended purposes and shall not go beyond what is required.
Express consent shall be obtained for the use of personal data in connection with an individual’s PCL membership, participation in PCL sponsored events and the PCL website.
All reasonable efforts will be made to obtain consent before using the image of any individual for external marketing or other purposes.
Consent may be revoked at any time by contacting the PCL Data Privacy Officer in writing, upon which and all reasonable efforts to remove such image will be made.
At all times, appropriate technical and organizational measures will be implemented to protect personal data collected from unauthorized access, loss or misuse. This includes storage solutions and access controls, and additional controls and security when transferring data to a third party such as, for example, to a foreign Pickleball Association for purposes of participating in an overseas event.
All reasonable efforts shall be made to ensure the personal data obtained is accurate and up to date. When a data subject provides updated information or notifies the PCL Data Privacy Officer that their data is inaccurate all reasonable efforts will be made to correct or update such personal data as required.
All rights of data subjects pursuant to PIPA and any other applicable law shall be observed, which shall include but not be limited to:
Access: the right to request what information is held by PCL
Correction: the right to request correction to any inaccurate or incomplete information
Erasure: the right to request that information be deleted or erased
To exercise any lawful data subject rights please contact the PCL Data Privacy Officer
Submission of Complaints: individuals can submit their complaint regarding the use and protection of their personal data via email to the PCL Data Privacy Officer.
Acknowledgment: confirmation of receipt of the complaint shall be provided within 5 business days.
Investigation: the PCL Data Privacy Officer shall conduct a thorough investigation within 30 days of receiving the complaint and shall document the findings and action taken.
Response: the PCL Data Privacy Officer shall provide a written response to the complainant, detailing the outcome and correction actions taken.
Escalation: any dissatisfied individual may escalate their complaint to the Privacy Commissioner.
Identification and Containment. As soon as possible, and no later than 48 hours, of becoming aware of a data breach all reasonable efforts shall be made to contain the breach and prevent further unauthorized access, damage or loss.
Assessment. The nature of the data breach shall be assessed by the PCL Data Privacy Officer, including the scope of the breach, the type of personal data involved and the potential consequences for affected individuals.
Notification. The PCL Data Privacy Officer shall notify affected individuals within the statutory prescribed time limits, indicating inter alia the nature and scope of the breach and whether any action by the individual is recommended to mitigate loss.
Report to the Privacy Commissioner. Within 72 hours of becoming aware of a data breach the PCL Data Privacy Officer shall notify the Privacy Commissioner, detailing the nature of the breach, its impact and the measures taken to address it.
Investigation. The PCL Data Privacy Officer shall lead a thorough investigation to determine how the breach occurred, the scope and impact, what corrective actions will be undertaken and a timeframe for implementation of corrective actions to prevent reoccurrence.
Documentation. A written report of all findings from the investigation shall be conducted by the PCL Data Privacy Officer and presented to the PCL board as soon as reasonably possible.
Review and update to this policy. The PCL Data Privacy Officer shall review this policy on findings from the data breach and investigation findings to ensure continued compliance with Bermuda data protection legislation.
Any transfers of personal data to third parties located outside of Bermuda, such as to other foreign Pickleball Associations, will be conducted in consultation with the PCL Data Privacy Officer and in compliance with Bermuda data privacy laws and any other applicable data privacy legislation. This may include contractual controls to ensure the adequate protection of data subjects.
A data subject that believes PCL have not complied with Bermuda data protection legislation or this privacy policy has the right to lodge a complaint with the Bermuda Privacy Commissioner. All such complaints shall be reviewed and addressed by the PCL Data Privacy Officer within the timeframes prescribed by Bermuda law.
Training shall be provided by the PCL Data Privacy Officer at least annually to the directors and officers and board committee members on Bermuda data protection legal requirements and best practices to foster a culture of compliance within PCL.
This policy shall be reviewed periodically and at least annually. Any changes will be posted on the PCL website with an updated effective date.
Data Privacy Officer Press Court Ltd.
2 Par-la-Ville Road
Hamilton HM 08 Bermuda
Email: [email protected] Telephone: +1 (441) 232-2255