Privacy Policy
Last updated: 7 July 2026
Data controller. The Breakout Circle is operated by Momentum Mindset Limited, a company incorporated in Hong Kong (Company Registration No. [COMPANY REGISTRATION NUMBER]) with its registered office at Room 1203, 12/F, Tower 3, China Hong Kong City, 33 Canton Road, Tsim Sha Tsui, Hong Kong ("the Company", "we", "us", "our"). Privacy contact: support@breakoutcircle.com.
1. What this policy covers
This policy explains what personal data we collect through breakoutcircle.com and the membership Service, how we use it, who we share it with, and the rights you have. We handle personal data in accordance with the Hong Kong Personal Data (Privacy) Ordinance (PDPO) and, where they apply to you, other data protection laws such as the EU/UK GDPR and applicable US state privacy laws.
2. Personal data we collect
- Account and membership data: name, email address, password, membership package, and account settings.
- Waiting list data: first name, email address, and the package you are interested in.
- Billing data: your payment is processed by our third-party payment provider through a secure checkout. We receive confirmation of payment, the amount, and limited card metadata (such as card type and last four digits). We do not store your full card number.
- Community content: messages, posts, and other content you choose to share in community spaces.
- Support communications: emails and messages you send us.
- Usage and technical data: IP address, device and browser information, pages viewed, and similar analytics data collected through cookies or similar technologies.
3. How we use personal data
- to provide the Service, including your account, content access, live sessions, events, and community;
- to process payments, manage renewals, and send billing receipts and important service notices;
- to manage the waiting list and contact you when a membership spot opens;
- to respond to support requests;
- to send marketing emails about the Service, where permitted; you can opt out at any time using the unsubscribe link or by contacting us;
- to keep the Service secure, prevent fraud and abuse, and enforce our Terms;
- to comply with legal and regulatory obligations.
Where the GDPR or similar laws apply, we rely on the following legal bases: performance of a contract (providing the Service), consent (marketing and the waiting list), legitimate interests (security, service improvement), and legal obligation (tax and accounting records).
4. Who we share data with
- Payment providers to process subscription payments securely.
- Service providers that host our website and infrastructure (for example our hosting and content delivery provider), send our emails, and provide analytics, in each case only to the extent needed to run the Service.
- Community platform providers, where community features run on a third-party platform.
- Professional advisers and authorities where required by law, to enforce our rights, or in connection with a business reorganisation or sale.
We do not sell your personal data.
5. International transfers
We operate globally and our members and service providers are located in different countries. Your personal data may be transferred to and processed in jurisdictions other than your own, including Hong Kong and the United States. Where required, we use appropriate safeguards for such transfers, such as contractual protections.
6. How long we keep data
We keep personal data only as long as needed for the purposes above: account data for as long as your membership is active and for a reasonable period afterwards; billing records for as long as tax and accounting laws require; waiting list data until you join, ask to be removed, or the list is cleared; and support correspondence for a reasonable period after the issue is resolved.
7. Your rights
Under the PDPO you have the right to request access to and correction of your personal data. Depending on where you live, you may also have rights to erasure, portability, restriction of or objection to processing, and the right to withdraw consent at any time. To exercise any of these rights, email support@breakoutcircle.com. You also have the right to complain to your local data protection authority; in Hong Kong this is the Office of the Privacy Commissioner for Personal Data (PCPD).
8. Cookies
We use strictly necessary cookies to make the website work and, where enabled, analytics cookies to understand how the site is used. You can control cookies through your browser settings. Blocking some cookies may affect how the site functions.
9. Security
We use appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, and reputable hosting providers. No online service can be guaranteed 100% secure, but we work to protect your data and will notify you and the relevant authorities of any breach where the law requires.
10. Children
The Service is for adults. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us personal data, contact us and we will delete it.
11. Changes to this policy
We may update this policy from time to time. Material changes will be notified by email or through the Service. The "Last updated" date at the top shows the current version.
12. Contact
Privacy questions or requests: support@breakoutcircle.com, or write to our registered office listed above.