# Day: July 21, 2024

### The Basics of Playing Dominoes

A domino is a flat, thumb-sized rectangular block of clay or wood with either blank or marked faces that bear from one to six pips (or dots). 28 such tiles form a complete set of dominoes. Several games may be played with them, using lines and angular patterns of dominoes to form structures such as walls or towers.

The word domino also refers to the act of a player making the first play in a game. Known as the “set,” the “down” or the “lead,” it is this play that starts a chain of plays that ultimately determines the winner of the game.

Various games of domino use different rules for determining who begins the game and how many tiles to draw for a hand. If a player draws more than the number of tiles he is permitted to have for his hand, these extra dominoes are known as overdraws. Overdraws are returned to the stock and reshuffled before players draw their hands again.

Once a player has his dominoes, the next thing to do is decide where to seat himself. The easiest way to do this is by lot. After the stock of dominoes has been shuffled, each player draws a tile and places it in front of him in such a way that the other players cannot see its pips. The player who draws the highest numbered domino seats himself to his left, the next player to his right and so on.

Some games use a special type of double called a spinner. Depending on the rules of the game, a spinner can be played in two ways: with the line of play, lengthwise; or across the line of play, crosswise. If a player makes a play with a spinner, the corresponding end of that domino is added to the end of the line of play and the other side is played as a new start to the next turn.

Most domino games involve a long line of dominoes being joined together and the way that this happens is often a large part of the fun of the game. Each domino is matched to another with its matching ends, and then positioned on the table so that the two dominoes touch completely on each of their four sides. The result is a long chain of dominoes that gradually takes the shape of a snake-line.

While the majority of domino games are blocking or scoring games, there are also a few solitaire and trick-taking games that may be played with a single person. These games were once popular in some parts of the world to circumvent religious prohibitions against playing cards. They use a basic structure of the game, but each player has a very unique strategy for winning.

### Personal Data Transfer Regulations in Hong Kong

#### Padraig Walsh from Tanner De Witt

The global business environment is increasingly interconnected. As a result, cross-border transfers of personal data are common and it is essential that businesses understand the impact of regulation imposed on such transfers. In this article, Padraig Walsh, head of the Hong Kong data privacy team at Tanner De Witt, provides an overview of key points to consider for such transfers in the context of Hong Kong.

There is no statutory restriction in the PDPO on the transfer of personal data outside Hong Kong. However, there are a number of obligations that should be considered by any Hong Kong business involved in such transfers. These include the obligation to identify and adopt supplementary measures where the assessment reveals that the level of protection afforded by the foreign jurisdiction does not meet the standards in the PDPO. This might involve technical measures such as encryption, pseudonymisation or split processing; or contractual measures such as audit and inspection obligations, beach notification, compliance support and co-operation obligations.

In addition, there are requirements to notify the PDPO of any such transfers and of the underlying grounds (DPP 1(3)). There is also an obligation to ensure that a transfer takes place in accordance with the PDPO’s data processing principles (DPP 2). It is important to bear in mind that the PDPO does not provide for extra-territorial application of its provisions – unlike several other data privacy regimes which contain some element of such extension. Consequently, the only way that the PDPO’s transfer restrictions might be applied in practice is through its contractual arrangements with data importers.

As mentioned, there are a growing number of circumstances in which it will be necessary for any Hong Kong business that is involved in the transfer of personal data outside of Hong Kong to carry out a transfer impact assessment (DPP 8(2)). Such an assessment might be required in connection with a data export to an EEA country or a contractual arrangement with a data importer from an EEA country. Similarly, such an assessment might be required in connection with any transfers to non-EEA countries.

Whether or not section 33 of the PDPO will be implemented in practice remains to be seen. However, there are a number of reasons why such implementation might be difficult. One reason is that the current interpretation of ‘personal data’ in the PDPO is broadly similar to the definition in other legislative regimes such as the GDPR and PIPL and, accordingly, it may be difficult to distinguish between such data and data that is not personal data. There is also a risk that such a restriction on the transfer of personal data could adversely affect Hong Kong’s reputation as a business hub, and as an investment destination. Such risks will likely have to be weighed up carefully against the need for Hong Kong to maintain its competitive advantage in the global economy. This will have to be a balance that is ultimately left to the market.

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