Privacy Policy
Last updated: 2026-05-04
Data Controller
This service is operated by an individual based in Hong Kong SAR. For privacy questions, contact privacy@tunnelcamps.com.
DPO: not appointed (small operator). The privacy@ inbox is the single channel for data-protection requests.
Data we collect
- Account info: email, password (stored as a salted hash), first / last / nickname, language preference.
- Profile context (optional): home tunnel city / country / name; profile photo if uploaded; coach / manager role and the invite code used.
- Activity: camp registrations, slot applications, flight wishes, chat messages you send, notification preferences, and your cookie consent state.
- Technical: IP address (server-side only, anonymized in error logs); cookies for sign-in, language, and your consent choice.
Purposes and legal basis
- Run your account and provide the camp / chat features — Contract performance (GDPR Art. 6(1)(b)).
- Send transactional email (sign-up confirm, password reset, slot notifications, weekly chat digest) — Legitimate interest (Art. 6(1)(f)).
- Send product updates and new-camp announcements — Consent given at sign-up (Art. 6(1)(a)); revocable from /profile or via the unsubscribe link in every marketing email.
- Detect bugs and keep the service stable (Sentry) — Legitimate interest with strict PII scrubbing; the analytics SDK loads only after you opt in to the Analytics cookie bucket.
- Comply with applicable legal obligations and respond to lawful requests — Legal obligation (Art. 6(1)(c)).
Sub-processors
Personal data is processed by the following sub-processors. Each implements appropriate safeguards for international data transfers under the EU-US Data Privacy Framework and / or the Standard Contractual Clauses (Art. 46(2)(c) GDPR):
- Supabase Inc. (United States — database + authentication)
- Resend Inc. (United States — transactional + marketing email)
- Functional Software, Inc. d/b/a Sentry (United States — error monitoring)
- Vercel Inc. (United States — hosting + edge runtime)
International transfers
Personal data is stored in the United States (AWS us-west-2). Transfers from the EU / UK / EEA rely on the EU-US Data Privacy Framework certification of the receiving sub-processor where it is on the active DPF list, and on the Standard Contractual Clauses (Art. 46(2)(c) GDPR) otherwise.
Retention
- Account data: kept while your account is active; permanently deleted within 30 days of account deletion. Chat conversations you participated in are removed from both sides when either party deletes their account (per the schema's cascade — see Cookie Policy and the export's _notice for context).
- Sentry error events: 30 to 90 days depending on event type, then automatically purged.
- Operational audit log entries (camp / slot / invite events): retained for security and fraud investigation, typically not exceeding 12 months. Entries are FK-free at the database level so they survive account deletion in anonymous form.
- Cookie consent record (tc-consent): 12 months in your browser, after which we re-prompt. Account-level marketing opt-in is tied to the account and removed with it.
Your rights
You may request access, rectification, erasure, restriction, portability, or object to processing. To exercise these rights, use the buttons at /profile → "Data & account" (download your data, delete your account) or email privacy@tunnelcamps.com for everything else. You also have the right to lodge a complaint with Hong Kong's PCPD or, for EU / UK users, your local supervisory authority.
Automated decision-making
We do not perform automated decision-making that produces legal effects on you. Slot assignment is performed manually by coaches; cookie consent gating is a deterministic check, not an automated decision about you.
Children
The service is intended for users 16 years and older. Accounts of underage users will be deleted upon notice. If you are a parent or guardian and believe a minor has registered, contact privacy@tunnelcamps.com.
Updates to this policy
Material changes are notified via email (to your account address) and an in-app banner. Continued use 30 days after notification constitutes acceptance. The "Last updated" date at the top of this page is the canonical version marker.
Governing law
This policy is governed by the laws of the Hong Kong Special Administrative Region.