Privacy Policy

Who We Are and Where This Policy Applies

This policy applies to personal data that HuOrgCology Global Pte. Ltd. (UEN 201707207H), trading as HOC ("HOC", "we" or "us"), collects through this website, by email, on WeChat and while providing our services.

It covers individuals in Singapore and around the world, including foreign individuals and overseas-based companies that use our services, and the owners, directors, shareholders and staff of those companies.

It is written to meet Singapore's Personal Data Protection Act 2012 (PDPA). It also reflects widely accepted international data protection principles: collect only what is needed, use it only for stated purposes, keep it accurate and secure, keep it no longer than necessary, and be open about what we do.

If the data protection law of another country applies to us in relation to you, we will handle your data in line with that law to the extent it applies.

Our Role

When we act for ourselves. We are responsible for the personal data we collect about people who enquire about our services, our clients' contacts, and our own suppliers and staff. This covers handling enquiries, onboarding, billing and our own legal and regulatory obligations.

When we act for our clients. When we process personal data on a client's behalf, for example employee details for payroll or data protection support, we act as the client's data intermediary (called a data processor under some countries' laws). We process that data only for the purpose and on the instructions of the client, keep it secure, and do not keep it longer than needed. The client remains responsible for its own compliance, including telling its people how their data is used.

Data about other people. If you give us personal data about someone else, such as a co-director, shareholder, beneficial owner or employee, you confirm that you have the authority or consent to do so. You also confirm that they have been told how it will be used. Please keep the data you give us accurate and up to date.

Information We Collect

Enquiry Details

When you use the Request a Free Consultation form, we collect your name, email address, phone number and company name.

When you submit the form, we email your request to our team and show you a WeChat QR code and WeChat ID (HOCPartners) so you can connect with us directly. You choose whether to add us on WeChat.

If you contact us by email or WeChat, we also collect your contact details and the content of your messages and any attachments.

If you email our Data Protection Officer directly, we collect your name, email address and the content of your message.

Identity and Due Diligence Information

Once you engage us, or where the law requires it before we can act, we may collect details such as:

• your full name and former names, nationality and date of birth
• your passport or national identity number and a copy of the document
• residential and business addresses, occupation and tax residency
• your role and shareholding in a company
• information about the source of funds or wealth

We collect this only where it is needed for a service, such as setting up a company, or to meet legal duties such as customer due diligence and anti-money-laundering checks. We collect national identity numbers and copies only where the law requires or a service clearly needs them.

Business Information

To deliver our services we may collect company registration details, financial and accounting records, tax information, employee information and other data that a service needs.

Website Technical Data

When you visit this website, our hosting provider, Cloudflare, records technical data such as your IP address, browser and device type, the pages requested and the date and time. We use it to keep the website secure and available, to block abuse and to limit repeated form submissions.

We do not currently use Google Analytics, Cloudflare Web Analytics or any other analytics or advertising cookies on this website. If that changes, we will update this policy first and, where required, ask for your consent.

Sensitive Information

We do not need, and ask you not to send us, information about your health, religion, race, political opinions or biometric data. If a service does require any of this, we will tell you why and ask for your specific consent first.

How We Use Your Information

Service Delivery

To provide our services, including company set-up in Singapore, company secretary services, Single Family Office set-up and management, management consulting, and our finance, people, personal data and technology solutions.

Communication

To reply to your enquiry, prepare a quotation, give service updates and send important notices about your engagement.

Compliance and Legal Obligations

To meet legal and regulatory requirements in Singapore and, where relevant, in other countries connected to your service, including ACRA filings, tax compliance, customer due diligence, statutory reporting and responding to lawful requests from authorities.

Business Operations and Protection

To manage billing and accounts, keep records, protect the website and our systems against spam and abuse, prevent fraud, and establish, exercise or defend legal claims.

Marketing

We use your details to reply to the request you made. We send marketing messages only with your consent, we respect Singapore's Do Not Call Registry and similar rules in other countries where they apply, and you can withdraw your consent to marketing at any time.

On What Basis

We rely on:

• your consent, for example the box you tick on our form
• what is needed to enter into or perform a contract with you
• our legal obligations
• where the law allows, our legitimate interests, such as those in this section, having weighed them against the effect on you

We do not sell personal data.

New Purposes and Automated Decisions

We use personal data only for the purposes in this policy and purposes closely connected to them. If we want to use it for a new purpose, we will tell you and, where the law requires, ask for your consent first.

We do not make decisions that have legal or similarly significant effects on you by fully automated means.

Who We Share Your Information With

We share personal data only as needed for the purposes above, with:

• Government agencies and regulators, such as ACRA, IRAS, the Ministry of Manpower and the CPF Board in Singapore and, where your service involves another country, the corresponding company registry, tax and other authorities there, when a filing or the law requires it.
• Authorities in other countries, directly or through Singapore authorities, where the law requires it, for example for tax reporting.
• Banks, auditors, lawyers, tax advisers and other professionals, where your service involves them or you ask us to.
• Your own business contacts, such as a foreign parent company, co-directors, shareholders and advisers, where your service involves them or you ask us to. For example, we may send company documents to an overseas parent company.
• Companies in the HOC group that work with us to deliver services.
• Service providers that support our operations, listed in the next section.
• Courts, law enforcement and other authorities, where the law requires or allows it.
• A buyer or successor, if our business is restructured or sold, on terms that protect your data.

We share only what the recipient needs, and we do not share personal data with anyone for their own marketing. Where a provider handles data for us, we require it to protect that data and use it only for our purposes.

Service Providers and Where Your Data Is Processed

We use the following providers when you use our website or contact us:

• Cloudflare, Inc. hosts and delivers this website, runs the security checks and rate limits that protect it, and keeps request logs.
• Resend delivers the email created when you submit the Request a Free Consultation form to our mailbox. It may keep a copy of that email and delivery records for a limited period under its own terms.
• HostGator, our email hosting provider, stores our mailbox, including the enquiries and emails you send us. Its servers are in the United States.
• WeChat (Tencent) carries your messages if you contact us there. Its own privacy policy applies to how it handles them.

HOC is based in Singapore, so personal data collected from individuals outside Singapore is transferred to and processed in Singapore. Cloudflare and Resend operate internationally, and our mailbox is hosted in the United States, so your data may also be processed in the United States and other countries.

When personal data leaves the country where it was collected, we take steps to make sure it receives a standard of protection comparable to the PDPA. These steps include using providers that commit to data protection in their contracts and terms, and sending only the data needed.

If you ask us to send your data to someone in another country, such as an overseas parent company or adviser, or your service requires it, we will send it there. Once it reaches them, their own country's laws apply, so please consider what you ask us to send. You can ask our Data Protection Officer for more information about the safeguards we use for overseas transfers.

Data Protection and Security

Our Approach

We handle personal data in line with Singapore's PDPA, and with the data protection law of another country where that law applies to us.

Security Measures

We make reasonable security arrangements to protect personal data, including encrypted connections (HTTPS) on this website, access limited to staff who need the data, confidentiality obligations on our people, and contracts with our providers.

No method of sending or storing data is completely secure, so we cannot guarantee absolute security. Please use the secure method we give you for sensitive documents.

Data Breaches

If a breach affects personal data we hold, we will assess it promptly. Where the law requires, we will notify the Personal Data Protection Commission of Singapore, any other data protection authority that has jurisdiction, and the affected individuals, within the time the law sets. If we hold the data for a client, we will tell the client without delay.

Data Retention

We keep personal data only for as long as we need it for the purpose it was collected, or for legal or business reasons.

For enquiries that do not lead to an engagement, we keep the details only as long as needed to follow up and to keep a record of the enquiry, and then delete or anonymise them.

For clients, we keep records while we act for you and afterwards as the law requires. For example, accounting and customer due diligence records are generally kept for at least five years.

When data is no longer needed, we delete it, anonymise it or return it securely.

Your Rights

Under Singapore's PDPA, you have the right to:

• ask for access to the personal data we hold about you and how it has been used or disclosed
• ask us to correct inaccurate or incomplete data
• withdraw your consent to our collecting, using or disclosing your data

You may also ask us to delete personal data we no longer need to keep. We will do so unless the law, or a legitimate need such as handling a dispute, requires us to keep it.

Depending on where you live, the law of your country may give you further rights, such as the right to object to or restrict our processing, to opt out of direct marketing, or to receive your data in a portable format. If you think such rights apply, please tell us and we will consider your request under that law.

How to Make a Request

Email our Data Protection Officer at dpo@huorgcology.com. We may ask you to confirm who you are before we act.

We aim to reply within 30 days, and if we need longer we will tell you why.

We may charge a reasonable fee for an access request where the law allows, and will tell you the amount first. We may refuse or limit a request where the law permits, and we will explain why.

If You Withdraw Consent

We will act on your withdrawal within a reasonable time and tell you what it means for you. If you withdraw consent we need for a service, we may be unable to continue that service. We may still keep data we are legally required to keep, or need to handle a dispute.

Complaints

Please contact us first so we can put things right. You may also contact the Personal Data Protection Commission of Singapore or the data protection authority in your own country.

Other Matters

Cookies and Similar Technologies

This website does not currently use analytics, advertising or tracking cookies. We do not use a cookie consent banner because we do not currently set any cookies that require one.

If we introduce analytics, advertising cookies or a bot-detection check such as Cloudflare Turnstile in future, we will update this policy first and add a cookie banner where consent is required.

Links to Other Services

Our website links to WeChat and may link to other sites. We are not responsible for how those services handle your data, so please read their privacy policies.

Children

Our services are for businesses and their owners and are not directed at anyone under 18. If we learn that we hold data from a child without a parent's consent, we will delete it.

Changes to This Policy

We may update this policy from time to time. The "Last updated" date at the top shows when it last changed, and we will tell existing clients about any important change.

If we provide a translation of this policy, the English version prevails.

Contact Us

For privacy-related enquiries or to exercise your data protection rights, please contact us:

Data Protection Officer
HuOrgCology Global Pte. Ltd. (UEN 201707207H), trading as HOC
Email: dpo@huorgcology.com