Our Privacy Policy
Last Updated: April 2025
This Privacy Policy applies to the access and use of wooliholdings.com (the “Website”) and will assist you to understand how we collect, use, disclose and process any personal information (“Personal Data”) as governed by the Personal Data Protection Act 2012 of the Singapore Statutes (“PDPA”).
It is also intended to help you in making an informed decision before providing us with any Personal Data.
Personal Data refers to data, whether true or not, about an individual who can be identified from that data (such as your name, contact details, date of birth, gender, identity card/passport number, e-mail address); or from that data and other information to which an organization has or is likely to have access.
Further, your access and use of our Website, the information made available4 there and the services we provide on our Website are all subject to this Privacy Policy.
Should you, at any time, require any further information or clarification on this Privacy Policy or how we may manage, protect and/or process your Personal Data, please do not hesitate to contact our Data Protection Officer at info@wooliholings.com.
Your Consent to Our Privacy Policy
By accessing or using the Website, submitting your Personal Data through forms, registering an account, or otherwise providing Personal Data to us, you signify that you have read, understood, and agree to our collection, use, disclosure, and processing of your Personal Data in accordance with this Privacy Policy. We typically obtain your consent before or at the time of collecting Personal Data, often through explicit means like checkboxes or specific actions confirming agreement.
Please do not provide any Personal Data to us if you do not accept this Privacy Policy.
If you are under 18 years of age, please do not provide any Personal Data to us about yourself without parental/guardian consent.
How We Collect Personal Data
Personal Data can be collected in the many ways you may interact with us or provide them to us. For instance, Personal Data may be collected by us in instances such as, but not limited to, when you:
Browse this Website;
Register yourself on this Website for the purpose of creating an account or receiving information or downloadable brochures (including Newsletters) and marketing materials from us;
Make enquiries with us via forms or other contact methods;
Place orders for our services and/or transacting with us;
Use our services;
Communicate with us, whether via online methods, postal mail, telephone, OTT messaging, or any combination thereof;
Apply for potential employment with us, or enquire about possible opportunities to work with us or collaborate;
Provide Personal Data on this Website for any other purposes as you may consent to,8 from time to time.
What Personal Data We Collect
Depending on how you interact with us, the Personal Data we collect may include:
When you browse our Website: IP address, browser type, operating system, pages visited, usage patterns, and other technical data collected via cookies and analytics tools (see "Browser Data and Cookies" below).
When you register, enquire, or contact us: Name, email address, phone number, company name (if applicable), the content of your message or enquiry.
When you place orders or use our services: Account login details, transaction details, business information necessary for service provision. (Note: Payment information is typically processed directly by secure third-party payment processors, and we may only receive confirmation details).
When you apply for employment: Information included in your resume or application, such as employment history, education background, qualifications, and contact details.
You are under no obligation to provide Personal Data. However, should you decide not to provide necessary Personal Data (like your name and contact details for an enquiry), we may not be able to attend to your interest, answer your queries, or provide certain services, and you may not be able to access or use certain features of this Website.
Purpose of Collection, Use and Disclosure of Personal Data
Personal information which you provide to us may be used, disclosed, and/or processed by us, for the purposes of facilitating your business9 requirements with us and keeping you informed, the scope of which may include:
Carrying out identity checks;
Deciding whether to engage in a business relationship with you;
Providing services based on your requirements, including financial reporting, regulatory reporting, management reporting, audit and record keeping purposes (if applicable);
Administering and maintaining your account with us;
General management and reporting purposes, such as invoicing and account management;
Communicating with you on matters relating to your account or services;
Keeping clients and contacts informed of our services, industry developments, offerings, seminars, and events, only if you have separately provided explicit consent to receive such marketing communications;
In connection with any claims, actions or proceedings (including drafting documents, obtaining legal advice, facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
Responding to queries or feedback from you;
Coaching employees for customer service quality assurance;
For recruitment and employment-related purposes;
Notifying you about important changes to our Privacy Policy, Terms of Service, or other service delivery matters affecting you.
Other Uses
Apart from such uses as mentioned above, Personal Data may also be used to:
Compile statistical information, create reports, and conduct research (including data analytics, surveys, profiling) for market analysis, and/or for improving our products, services and facilities;
Perform due diligence checks (including know-your-client checks and anti-money laundering checks) in accordance with legal or regulatory obligations (whether Singapore or foreign) and risk management procedures applicable to us or our affiliates/associated companies;
Detect and prevent any fraud, unlawful activity, misconduct or complaints, and/or investigate any such acts or suspicion thereof;
Initiate and/or pursue any form of legal redress;
Comply with orders, directions, requirements, guidelines and/or requests made or existing under any applicable laws, and/or by or from any courts, governmental, statutory or regulatory bodies (whether Singapore or elsewhere);
Conduct direct marketing via email, telephone, and/or other means only if you have separately indicated your explicit consent to receiving such materials;
Facilitate services from third-party service providers to whom relevant Personal Data must be disclosed, provided you have previously consented to such disclosure.
Exceptions to the Requirement of Consent
Notwithstanding anything to the contrary in the foregoing, the Second, Third and Fourth Schedules of the PDPA (publicly available ahttps://sso.agc.gov.sg/Act/PDPA2012) set out specific situations where the collection, use, and disclosure of Personal Data without consent are permitted by law.
Disclosure and Transfer of Personal Data to Third Parties and/or Outside of Singapore
We do not disclose Personal Data to third parties except when required by law; when we have your consent or deemed consent; or where we engage third parties such as data intermediaries or subcontractors specifically to assist us (e.g., cloud hosting providers, payment processors, analytics providers). Any such third parties are contractually bound to keep Personal Data confidential and use it only for the purposes we specify.
We will endeavour to provide adequate protection and supervision over the handling of your Personal Data transferred to third parties.
If Personal Data is transferred outside of Singapore, we will take appropriate steps to ensure that the recipient is legally bound to provide a standard of protection comparable to that under the PDPA (e.g., through appropriate contractual clauses or by ensuring the recipient country has comparable laws).
Your Rights Regarding Your Personal Data
Access: You may request access to your Personal Data collected by us at any time by notifying our Data Protection Officer. We will respond within a reasonable time and provide access in accordance with PDPA requirements. We may charge a reasonable fee for processing access requests, as permitted by the PDPA.
Correction: If you believe any information we hold about you is incorrect, incomplete, or outdated, please contact our Data Protection Officer. We will correct the information within a reasonable time in accordance with PDPA requirements.
Withdrawal of Consent: You may withdraw your consent to our collection, use, and/or disclosure of18 your Personal Data at any time by notifying our Data Protection Officer. We will process your request within a reasonable time and cease such activities, unless required or authorised under applicable law. Withdrawal may affect our ability to provide certain services to you.
Data Portability: You may have the right under the PDPA to request the transfer of certain Personal Data you have provided to us to another organization in a commonly used machine-readable format. This right is subject to applicable regulations and conditions under the PDPA.
Unsubscribe from Marketing: You may choose to unsubscribe from our marketing mailing lists or elect not to receive further marketing information by contacting our Data Protection Officer or using the “unsubscribe” function provided in automated emails.
Security and Management of Personal Data
We implement reasonable security arrangements including administrative, physical, and technical measures (such as access controls, encryption where appropriate, and staff training) to protect the Personal Data in our possession or under our control from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot be held responsible for unauthorised access or disclosure by third parties attributable to factors beyond our reasonable control.
While we strive for accuracy, we rely on you to provide accurate, truthful, and complete Personal Data and to update us of any changes.
Retention of Personal Data
We will cease to retain Personal Data as soon as it is reasonable to assume that the purpose for which it was collected is no longer being served by retention and retention is no longer necessary for legal or business purposes. We will make reasonable efforts to ensure such Personal Data is destroyed or anonymized securely.
Data Breach Notification
In the event of a data breach that is likely to result in significant harm to individuals or is of a significant scale, we are obligated under the PDPA to assess the breach and notify the Personal Data Protection Commission (PDPC) and affected individuals as soon as practicable, in accordance with PDPA requirements.
Data Protection Officer
We have appointed a Data Protection Officer who can be reached via e-mail at [email address removed].
Please contact our Data Protection Officer if you have any queries, complaints, or grievances regarding our handling of Personal Data, or if you wish to exercise any of your rights mentioned above.
Browser Data and Cookies
We automatically collect information sent by your computer when you browse our Website, including your browser type, IP address, and pages visited. This data may be collected for analysis to improve our Website and is generally not used in association with identifiable personal information.
We may use “cookies” (small data files sent to your browser) to store and track information about your usage. Cookies help us understand user frequency, profiles, and preferences. You can choose to accept or decline cookies via your browser settings, though declining may limit your ability to use certain Website features.
Updates on our Privacy Policy
We reserve the right to review and make changes to our Privacy Policy from time to time. The most current version will govern our collection, use, and disclosure of Personal Data and will be posted on this Website with an updated "Last Updated" date. Your continued use of our Website or services after changes constitutes your agreement to the revised Privacy Policy. You are encouraged to visit this page regularly.
General
Your consent given pursuant to this Policy is additional to and does not supersede any other consents you may have provided to us regarding the processing of your Personal Data.
Where the PDPA permits us to collect, use, or disclose your Personal Data without consent, such permission granted by law shall continue to apply.
