Officers said they seized computers, mobiles and cameras after searching two flats and an office, with one confiscated laptop containing some 30,000 photos and videos.
The website had been running since 2017 and had more than 50,000 members, police said, adding that contributors were paid up to HK$400 a time for upskirt material.
“They asked their members to take upskirt pictures in various public places like malls and trains,” said Michael Cheung from the force’s cyber security and technology crime bureau.
Cheung added that the faces of the victims were included, which helped the website boost its views and sales.
Two men, aged 33 and 36, were arrested in Sha Tin and Hung Hom last Friday, officers said.
Police said their investigation into the website was ongoing and more arrests could be made.