PRIVACY and COOKIES POLICY
Last updated on May 28, 2020
Wolols ("us", "we", or "our") operates the website (hereinafter referred to as the "Service").
This website and/or mobile app is operated by Wolols Publishing Pte Ltd, a company registered in Singapore, with company number 202011109R, and whose registered office is at Blk 461 Choa Chu Kang Avenue 4 #06-85 Singapore 680461 (“we”, “us”, or “our”).
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.
Content in this privacy and cookies policy
Service is the www.wolols.com website operated by Wolols Publishing Pte Ltd
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
“Personal Data” as defined under the PDPA refers to data collected, whether true or not, about an individual who can be identified from that data, or from the data and other information to which an organization has or is likely to have access.
The Public will be notified of the purposes that personal data is collected, used, disclosed and/or processed and obtain consent unless an exception under the law permits that no prior consent is needed by Wolols to collect and process personal data.
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small files stored on your device (computer or mobile device).
Data Protection Officer / Data Controller
We comply with all applicable primary and data protection laws in accordance with Singapore’s Personal Data Protection Act 2012 (“PDPA”). It is Wolols responsibility to properly manage, protect and process personal data. Should the Public at any time, have any queries relating to personal data, they may contact Wolols Data Protection Officer (“DPO”) at firstname.lastname@example.org
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you, as described below. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us at email@example.com
Types of Data Collected
The Services are designed partly for children. Therefore, we are aware that we must be extra cautious when processing personal information.
The part of the Services where anyone can enter personal information directly are the Subscription, contact form and, Events (competition, book events, marketing events) when is active. These services are directed for parents and guardians. We anticipate and assume that we will be collecting personal information only from parents or guardians.
If you are under the age of 13, you may only use the Services and provide personal information if you have the consent of, and are supervised by, a parent or guardian.
While using our Service, we may ask you to provide us with certain personal identifiable information that can be used to contact or identify you ("Personal Data"). Personal identifiable information may include, but is not limited to:
First name and last name
country and another geolocation information
date of birth
responses to any customer satisfaction surveys or market research (unless these are provided anonymously)
any information you (or your child) submits as part of a competition
information about your device (such as your IP address or another device identifier) and your (or your child’s) usage or the Services through cookies (and similar technologies) as further described below
If you contact us with a complaint or query, we may keep a record of any correspondence sent to our customer service team
How and when we collect your personal information
We may collect personal information from you when you/your children:
participate in, access or sign up to any of the Services’ activities, online content, newsletters, events or competitions;
contact our customer service teams or request information from us in any other way;
respond to communications from us;
participate in our customer satisfaction surveys or other market research; or
communicate with us via social networking websites, third party apps or similar technologies.
When you browse or otherwise use the Services, we will also collect certain information about your device and your use of the Services using cookies and similar technologies as further described below.
We will indicate where any personal information we have requested is mandatory or optional. Please note that if you decide not to provide certain information which we have indicated is mandatory, in some circumstances, this may mean we are unable to provide you with a certain service or product.
Cookies and Usage Data
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
Use of Data
How we may use your personal information
We (or third-party data processors acting on our behalf) may collect, store and use your personal information for the following purposes:
• to contact prize winners of competitions;
• to identify you/your child as the winner of a particular competition;
• to send out newsletters you have subscribed to;
• to provide you with services that you request;
• for system administration purposes and for internal operations (including troubleshooting, data analysis, and testing) to ensure the Services operate properly;
• to analyze your use of the Services to improve the user experience and to ensure that content is presented in the most effective manner for you and for your device;
• to notify you of any changes to the Services;
• where you have given us your consent or we are otherwise permitted by law, to contact you with products and services which we think may interest you/your children – you can unsubscribe from our marketing communications at any time;
• for security and fraud prevention;
• to ensure that our Services are safe and secure; and
• to comply with applicable laws and regulations.
We may also collect information about visitors and users of the Services for the purposes of aggregate statistics or reporting purposes.
Wolols, in resume, use the collected data for various purposes:
To provide and maintain our Service
To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our Service
To monitor the usage of our Service
To detect, prevent and address technical issues
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Retention of Data
Wolols will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
How we keep your personal information
We take steps to ensure that the personal information we collect is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymized.
Where we have collected personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
Transfer of Data
Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside Singapore and choose to provide information to us, please note that we transfer the data, including Personal Data, to Singapore and process it there.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, Wolols may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Wolols may disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation
To protect and defend the rights or property of Wolols
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect against legal liability
The instances listed above are not intended to be exhaustive. For more information, please visit https://sso.agc.gov.sg/Search/Content?Phrase=PDPA&PhraseType=AllTheseWords&In=InForce_Act_SL&Within=title.
In the event whereby Wolols discloses the Public’s personal data to third parties with the Public’s consent, Wolols will employ the best efforts to safeguard the Public’s personal data.
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We take appropriate technical and organizational measures to safeguard the personal information that we hold about you and regularly review our security measures to consider new technologies and methods, to safeguard your data. Please note that no transmission over the Internet can ever be guaranteed secure and we consequently cannot guarantee the security of any personal information that we receive over the Internet.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Wolols aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at firstname.lastname@example.org
In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Wolols relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Your Data Protection Rights under Singapore's Personal Data Protection Act 2012 (“PDPA”)
Access and Correction
The Public may request to update the personal data in Wolols’ records by submitting a written request to the DPO through email or letter. For a request to update personal data, once Wolols has sufficient information from the Public, Wolols will:
Provide or correct the Public’s relevant or personal data within 30 days. If Wolols is unable to do so within the said 30 days, Wolols will notify the Public of the soonest practicable time within which correction can be made. (Note: The PDPA exempts certain types of personal data from being subject to the Public’s correction request as well as provides for situations when correction need not be made by Wolols despite the Public’s request); and
Send the corrected personal data to organizations to which the personal data was disclosed by Wolols within a year before the date the correction was made, unless the other organization does not need the corrected personal data for any legal business purpose. Though, Wolols may, if the Public gives consent, send the corrected personal data only to specific organizations to which the personal data was disclosed by Wolols within one (1) year before the date the correction was made.
Request to Withdraw Consent
The Public may withdraw their consent for the collection, use and/or disclosure of their personal data by submitting their request to Wolols’ DPO through email or letter.
Wolols will process the Public’s request within seven (7) working days from the date the request for withdrawal of consent was made, and will thereafter not collect, use and/or disclose the Public’s personal data.
However, the Public’s withdrawal of consent could result in certain legal consequences arising from such withdrawal. Depending on the extent of the withdrawal of consent, it may mean that Wolols will not be able to continue with the existing relationship with the Public and the contract that the Public has with Wolols will have to be terminated.
Management of Data (Accuracy, Completeness, Protection And Retention)
Wolols will take reasonable efforts to ensure that the Public’s personal data is accurate and complete. Wolols will not be responsible for relying on inaccurate or incomplete data arising from the Public not updating Wolols of any changes in their personal data that was initially provided.
Wolols will also put in place reasonable security arrangements to ensure that all personal data is adequately protected and secured. However, Wolols cannot assume responsibility for any unauthorized use of the Public’s personal data by third parties.
Wolols will also put in place measures such that the Public’s personal data in Wolols’ possession or under Wolols’ control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data, and (ii) retention is no longer necessary for any other legal or business purposes.
If the Public’s personal data is to be transferred out of Singapore, Wolols will comply with the PDPA in doing so. Wolols will also take appropriate steps to ascertain that the foreign recipient organization of the personal data is bound by legally enforceable obligations that are in-line with the requirements under the Act.
The Public may contact Wolols’ DPO through email or letter if they have any complaints or grievances with regard to the handling of personal data or Wolols’ compliance with the PDPA.
Data Protection Officer
Wolols Publishing Pte Ltd
Blk 461 Choa Chu Kang Avenue 4 #06-85
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
Wolols may process your Personal Data because:
We need to perform a contract with you
You have given us permission to do so
The processing is in our legitimate interests and it is not overridden by your rights
To comply with the law
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:
We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.
Wolols email campaigns and landing pages
MailChimp automatically places single-pixel gifs, also known as web beacons, in every email sent by Wolols through MailChimp platform. These are tiny graphic files that contain unique identifiers that enable MailChimp and Wolols to recognize when their Contacts have opened an email or clicked certain links. These technologies record each Contact’s email address, IP address, date, and time associated with each open and click for a campaign. MailChimp use this data to create reports for our Members about how an email campaign performed and what actions Contacts took.
Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:
Facebook and Instagram
Facebook and Instagram remarketing service are provided by The Facebook Company Products.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
Pinterest remarketing service is provided by Pinterest Inc.
You can opt-out from Pinterest's interest-based ads by enabling the "Do Not Track" functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
If you choose to purchase a product or service from wolols.com online, wolols.com only stores enough information concerning your transaction as to permit it to verify your instructions and reconcile payment information from its merchant clearance system, as well as to proceed with the delivery by email of the digital product purchased.
We process online payments through PayPal, who can be contacted here: https://www.paypal.com
Wolols.com does not store your credit card number, CVV code or card expiry date.
As part of Wolols’ efforts to ensure that Wolols properly manages, protects and processes the Public’s personal data, Wolols will review the policies, procedures and processes from time to time.
Wolols reserves the right to amend the terms set forth under this Data Protection Policy at Wolols’ absolute discretion. All amended Data Protection Policy will be posted on Wolols’ website.
Or by mail:
Wolols Publishing Pte Ltd
Blk 461 Choa Chu Kang Avenue 4 #06-85