As used in this Policy, “You” means an individual who is visiting and/or using (a) our website and/or (b) [our applications]; and “Personal Data” refers to data about you, whether true or not, from which you may be identified, or from such data in combination with other information to which the organisation may have access and includes such meaning as otherwise defined in the PDPA, as amended from time to time.

This Privacy Policy describes how we A WELLNESS HOLDINGS LTD. (UEN No. 20240877C), its respective subsidiaries, related companies and jointly controlled entities (collectively, the “Group”), collect, process and use your Personal Data (hereinafter defined) in compliance with the Personal Data Protection Act 2012 of Singapore (the “PDPA”). We encourage you to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By signing up for or using any products, services or campaigns (the “Services”) offered by the Group or submitting information to or otherwise communicating with the Group, you agree and consent to the Group, as well as its respective representatives and/or agents, collecting, using and disclosing your Personal Data in accordance with this Privacy Policy. 

We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your use of our Services constitutes your acknowledgement and acceptance of such changes.

This Privacy Policy does not supersede or replace any other consents you may have previously or separately provided to us in respect of your Personal Data, and your consent to this Privacy Policy is in addition to any other rights which any of the Companies may have at law to collect, use or disclose your Personal Data.

This Privacy Policy and your use of this website shall be governed in all respects by the laws of Singapore.

1. Collection & Consent

1.1 Personal Data may be collected from you in one or more of the following ways when you:

(a) order or purchase products or services from us;

(b) post a feedback or interact with our customer service officers, eg. via meetings, emails or telephone calls (which may be recorded for training, quality control, business and/or other lawful purposes);


(c) register for warranty for a product you purchase or make a gift redemption;

(d) use some of our services including establishing any online accounts with us;

(e) request that we contact you, be included in an email or other mailing list;

(f) respond to our promotions, campaigns or other initiatives or attend our events;

(g) have been referred to us from our business partners and/or third parties, including third party social networking services when you choose to connect with those services;

(h) visit our websites;

(i) take part in any contest, survey or promotion conducted by us and/or our business partners (including submission of photographs);

(j) visit our premises, through our CCTV recordings and/or photo taking or video recording at events; 

(k) provide or contemplate providing security to us for a transaction;

(l) submit your Personal Data to us for any other reasons; and/or

(m) when we collect your Personal Data by other lawful means.

1.2 Unless permitted by applicable laws, we will not collect Personal Data without your consent.

1.3 You warrant and represent to us that (a) Personal Data which you disclose to us is accurate and complete; and (b) where you volunteer Personal Data of another person to us, that you are authorised by such other person to disclose such Personal Data to us, and that such Personal Data is accurate and complete.

1.4 You shall consult your parent or guardian before giving us your Personal Data if you are under the age of eighteen.

2. Purposes for which we may collect, use and/or disclose your Personal Data

2.1 Your Personal Data may be collected, used and/or disclosed for the following purposes:

(a) to verify and process your personal particulars and payments;

(b) to provide goods and services to you;

(c) to respond and deal with enquiries, complaints and other customer-care matters or otherwise communicate with you; 

(d) to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;

(e) to manage payment, billing, account, credit checks and debt-recovery matters;

(f) to send you information, promotions, updates, and marketing and advertising materials in relation to our goods and services and that of our group companies;

(g) to manage, develop and improve our business and operations to serve you better;

(h) to carry out marketing promotions and campaigns, contests and lucky draws and personalising your experience at our customer touchpoints;

(i) to carry out market research and customer surveys;
(j) to conduct investigations or audits or carry out crime and fraud prevention and risk management activities;

(k) to comply with legal and regulatory requirements;

(l) to enforce our legal rights and obligations;

(m) to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales);

(n) for other purposes for which we have obtained your consent; and

(o) for any other purposes reasonably necessary, ancillary or related to the above specified purposes.

2.2 Your Personal Data may be disclosed for the purposes indicated in clause 2.1 above to our officers and employees, third parties, affiliates, service providers, advisors where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you, which include without limitation, the following persons or entities:

(a) banks, credit card companies, and payment vendors;

(b) debt collection agencies;

(c) credit information companies;

(d) logistics and courier services companies;

(e) call centre services providers;

(f) our business partners and authorised distributors, dealers or resellers;

(g) relevant government regulators or authorities or law enforcement agencies;

(h) our insurers and advisors, including consultants, auditors and lawyers;

(i) data intermediaries; and

(j) any other party to whom you authorise us to disclose your Personal Data to.

Save for relevant government regulators and authorities or law enforcement agencies, we will ensure that such parties receiving your Personal Data (i) are under duty of confidentiality to us with respect to the use, holding, processing, retention and/or transfer of your Personal Data; and (ii) have the need to know or handle such Personal Data.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way and for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

2.3 If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.

2.4 Your Personal Data may be transferred, stored and/or processed in a country or territory outside Singapore and you consent to any such transfer, storage and/or processing of your Personal Data outside Singapore. If we do so, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA. 

This includes without limitation ensuring that any party coming into contact with the Personal Data outside Singapore:

(a) complies with the PDPA and accompanying guidelines issued by the relevant regulatory authorities, all applicable laws and regulations and this Privacy Policy (the “Data Standards”) and shall not do or permit anything to be done which might cause such party or us to breach the Data Standards;

(b) takes all appropriate measures to ensure such compliance by implementing such data handling principles as provided by us from time to time and to maintain appropriate technical and organisational measures thereby providing a standard of protection for the Personal Data that is comparable to the protection under the PDPA; and

(c) protects your Personal Data by making reasonable security arrangements to prevent unauthorised access, use, disclosure and/or modification.

3. Withdrawal of Consent & Access

3.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on our email or other marketing messages.

3.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it. 

3.3 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 3.1 above. 

3.3 We will, at your request, endeavour to provide you with an account of your Personal Data in our possession or control within a reasonable time. Such account shall be in respect of how your Personal Data has been or may have been generally used or disclosed within the year before the date of your request. Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.

3.4 We reserve the right to charge a reasonable administrative fee for carrying out your request.

3.5 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

4. Accuracy & Correction

4.1 We will endeavour to ensure that your Personal Data we use is sufficiently accurate and complete in making any decision that impacts you.

4.2 We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below. 

4.3 We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

5. Protection, Policies and Procedures

5.1 We will endeavour to protect your Personal Data in our possession or control against risks of unauthorised access, collection, use, disclosure, copying, modification, disposal or destruction, through reasonable and appropriate security measures. We strive to ensure that our systems are secure and that they meet industry standards. To prevent unauthorised access, maintain data accuracy and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the Personal Data we collect. 

5.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. 

6. Retention of Personal Data

6.1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

6.2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes. 

7. Cookies
7.1 In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files which are stored on your hard drive and allocated to the browser used by you and through which the agency which sets the cookie (in this case the Group) is provided with particular pieces of information. Cookies cannot execute applications or transfer viruses to your computer. Their purpose is to make the online service generally more user-friendly and effective. Although we gather Information on our website activity, such as data on the number of visitors, the pages they visit, the duration of their stay, etc. Such information is collected on an aggregated and anonymous basis, which means no Personal Data is associated with this data and gathered through the use of web server logs and cookies. We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.

7.2 Use of cookies: Our website uses the following types of cookies, the scope and functioning of which are explained below:-

(a) Transient cookies – Transient cookies are automatically deleted when you close your browser. This particularly includes session cookies. These store a so-called session ID, through which different requests by your browser may be allocated to a single session. This enables your computer to be recognised when you return to this Website. Session cookies are deleted when you log out or close the browser.

(b) Persistent cookies – Persistent cookies are deleted automatically after a pre-set period, which may differ depending on the type of cookie. You may at any time delete cookies in your browser’s security settings.

7.3 By accessing and using our website and services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us or our representatives or agents. You may configure your browser settings according to your preferences and, for example, reject the acceptance of third-party cookies or all cookies. This may mean, however, that you will not be able to use all functions of this Website or Applications.

8. Third-Party Links and Products on Our Services

Our website and/or services may link to third-party websites and services that are outside our control. For example, we may enable you to share certain materials on the services with others through social networking services such as Facebook. We are not responsible for the security or privacy of any information collected by websites or other services. You should exercise caution, and review the privacy statements applicable to the third-party websites and services you use. To the fullest extent permitted under laws, we cannot be responsible for a third party’s acts, omissions, data policies or their use of cookies nor the content or security of any third party websites, even if linked to our website. Any such liability is expressly disclaimed and excluded.

9. Data Protection Officer

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data  protection policies and procedures, or if you wish to make any request, in the following manner:

Contact person: [Philip Wee]
Email address: [dpo@awhl.com.sg]
Contact number: [6238 8811]