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ARTICLE · 06 OCTOBER 2025

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Personal Data And Direct Marketing: Key Takeaways From The Credit Base Conviction

Mayer Brown
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Credit Base (HK) Limited ("Credit Base"), a Hong Kong-based debt collection agency, was recently convicted of two direct marketing offences under the Personal Data (Privacy) Ordinance ("PDPO").

Hong KongPrivacy
Gabriela Kennedy
Gabriela Kennedy
Joanna Wong
Joanna Wong
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Introduction

Credit Base (HK) Limited ("Credit Base"), a Hong Kong-based debt collection agency, was recently convicted of two direct marketing offences under the Personal Data (Privacy) Ordinance ("PDPO"). The West Kowloon Magistrates' Court imposed fines totaling HKD 5,000 for these violations. The Privacy Commissioner for Personal Data ("PCPD") welcomed the court's ruling.

Background

In November 2023, Credit Base sent a marketing letter to the complainant that included the complainant's Chinese full name and residential address. After receiving the letter, the complainant contacted Credit Base and noted that his personal data was obtained from his District Court filings. Credit Base used this data to send an unsolicited letter to the complainant by post, promoting its debt collection services. Before the use of the complainant's personal data, Credit Base did not notify him of such use, and also failed to obtain his consent for using his personal data

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