Legal

Privacy Policy

Harbourly Pte. Ltd.  ·  Last updated: 7 June 2026

1. Introduction

This Privacy Policy explains how Harbourly Pte. Ltd. (UEN: 202620829G) (“Harbourly”, “we”, “us”, or “our”) collects, uses, discloses, and protects your personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”) of Singapore.

This policy applies to your use of our website at https://www.harbourly.gg (the “Website”). Harbourly is an online marketplace for esports coaching services. The Website is currently in a pre-launch phase and operates as a waitlist registration platform. An updated Privacy Policy covering the full marketplace (including coaching sessions, payments, and account features) will be published prior to platform launch.

By using our Website and providing your personal data, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal data as described herein.

2. Personal Data We Collect

2.1 Information You Provide Directly

When you join our waitlist or contact us, we may collect your name, email address, and any other information you voluntarily submit through our forms or correspondence.

2.2 Information Collected Automatically

When you visit our Website, we may automatically collect technical data including your IP address, browser type and version, device type and operating system, pages visited and time spent on our Website, referring URL, and approximate geographic location (derived from your IP address).

2.3 Cookies and Similar Technologies

We use cookies and similar tracking technologies to monitor activity on our Website and to improve your experience. Cookies are small data files stored on your device. You may configure your browser to refuse cookies or to alert you when cookies are being sent. If you disable cookies, some features of the Website may not function properly.

We use Vercel Analytics and may use Google Analytics to understand how visitors interact with our Website. These services may collect data such as pages viewed, session duration, and general geographic information. You can learn more about how Google uses data at https://policies.google.com/privacy/partners.

3. Purposes for Collecting and Using Your Personal Data

We collect and use your personal data for the following purposes:

• to process and manage your waitlist registration;
• to communicate with you about Harbourly, including product updates, launch announcements, and waitlist status;
• to respond to your enquiries, feedback, or requests;
• to operate, maintain, and improve our Website;
• to analyse Website usage and trends to improve user experience;
• to detect, prevent, and address technical issues, fraud, or security incidents;
• to comply with applicable laws, regulations, and legal processes; and
• for any other purpose directly related to the above, or for which we obtain your consent.

We will not use your personal data for purposes beyond what is described in this Privacy Policy without first obtaining your consent, unless such use is permitted or required by law.

4. Disclosure of Your Personal Data

We do not sell your personal data. We may share your personal data with the following categories of recipients, only to the extent necessary for the purposes set out in this Privacy Policy:

4.1 Service Providers

We engage third-party service providers to help us operate our Website and deliver our services. These providers are contractually obligated to protect your personal data and may only use it in accordance with our instructions. Our current service providers include Vercel (website hosting, United States), Supabase (database infrastructure, United States), and Stripe (payment processing, United States — to be activated at platform launch).

4.2 Legal and Regulatory

We may disclose your personal data if required to do so by law or in response to valid requests by public authorities, or if we believe in good faith that such disclosure is necessary to comply with a legal obligation, protect and defend the rights or property of Harbourly, prevent or investigate possible wrongdoing, or protect the personal safety of users or the public.

4.3 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of all or substantially all of our assets, your personal data may be transferred to the acquiring entity. We will notify you before your personal data is transferred and becomes subject to a different privacy policy.

5. Transfer of Personal Data Outside Singapore

Some of our service providers are located outside Singapore, including in the United States. Where we transfer your personal data overseas, we take reasonable steps to ensure that the recipient provides a standard of protection to the personal data that is comparable to the protection under the PDPA, in accordance with the Transfer Limitation Obligation under the PDPA.

6. Protection of Your Personal Data

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks. These measures include the use of encryption for data in transit (HTTPS/TLS), access controls limiting who within our organisation can access personal data, and the selection of service providers with strong security practices.

However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to use commercially reasonable means to protect your personal data, we cannot guarantee its absolute security.

7. Retention of Your Personal Data

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Specifically, waitlist registration data will be retained until platform launch, after which you will be invited to create a full account. If you do not create an account within 6 months of launch, your waitlist data will be deleted. Communications and enquiry records will be retained for up to 2 years for reference purposes.

When your personal data is no longer required, we will delete or anonymise it in a reasonable timeframe.

8. Your Rights Under the PDPA

8.1 Right of Access

You may request access to your personal data that we hold, as well as information about the ways in which your personal data has been or may have been used or disclosed in the past year.

8.2 Right of Correction

You may request the correction of any error or omission in your personal data that we hold.

8.3 Right to Withdraw Consent

You may withdraw your consent for the collection, use, or disclosure of your personal data at any time by contacting us at the details set out in Section 11. Upon receiving your withdrawal request, we will inform you of the likely consequences of withdrawing consent (for example, removal from the waitlist). We will then cease to collect, use, or disclose your personal data unless required or permitted by law to do so.

Please note that the withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal.

9. Personal Data of Minors

The Harbourly waitlist is open to individuals aged 13 and above. If you are between the ages of 13 and 18, you must obtain the consent of your parent or legal guardian before providing any personal data to us.

We do not knowingly collect personal data from individuals under the age of 13. If we become aware that we have collected personal data from an individual under 13 without parental consent, we will take steps to delete such data promptly.

If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us at the details set out in Section 11.

10. Data Breach Notification

In the event of a data breach that is likely to result in significant harm to affected individuals, we will notify the Personal Data Protection Commission (“PDPC”) and the affected individuals as soon as practicable, in accordance with the mandatory data breach notification requirements under the PDPA.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated Privacy Policy on our Website with a revised “Last updated” date. We encourage you to review this Privacy Policy periodically.

12. Contact Us

If you have any questions, requests, or complaints regarding this Privacy Policy or our handling of your personal data, please contact us at:

We will respond to your request or complaint within 30 business days.

If you are not satisfied with our response, you may lodge a complaint with the Personal Data Protection Commission: