Privacy Policy

 

The type of personal data that Adler may collect from individuals will depend upon the particular transaction and the dealing. Normally the personal data collected by Adler may include an individual’s:

• name, title, address;

• personal identification and/or passport number;

• telephone number; email address and online passwords;

• records of communications with Adler;

• responses to market surveys and contests conducted by Adler or on Adler’s behalf;

• credit card or debit card information;

• camera or video footage that identifies individuals (including CCTV footage);

• website usage information.

Adler only collects, uses and discloses personal data with an individual’s consent or deemed consent or as otherwise permitted under the PDPA or other applicable laws and regulations.

Personal Data will, generally, only be collected and used for the primary purposes of:

Adler takes reasonable steps to ensure the individual is aware of:

• conducting, improving, maintaining and developing a business relationship.

• processing, servicing or enforcing transactions and sending related communications;

• identification and verification purposes in connection with any of the services or products that may be supplied to individuals;

• responding to individual’s queries;

• administering contests or market surveys conducted by Adler or on Adler’s behalf

• marketing (such as providing individuals with information about our products and promotional notices and offers);

• improving the Adler’s website;

• the likely use of the information;

• the means of requesting Adler on the provision of personal data that is in the possession of Adler;

• the means of withdrawing any consent in respect of the collection, use or disclosure of the personal data that is in the possession of Adler;

• the identity and contact details of the organisation;

• any law requiring collection of the information; and the main consequences of failure to provide the information.  

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How Adler will disclose your Personal Data

• Adler discloses personal data:

• for the primary purpose for which it was collected; or

• for purposes that a reasonable person will consider appropriate in the circumstances; or

• where the individual has consented; or

• for direct marketing by Adler where consent has been given but giving individuals the opportunity to opt out of such direct marketing; or

• where permitted under the PDPA or other applicable law or if required by law.

Adler does not disclose your personal data for any secondary purposes unless your consent has been given or if so permitted or required under the PDPA or other applicable laws and regulations.

Adler will not sell or license any personal data that it collects from an individual.

There may be other situations where we may collect and use personal data, which are outside a person’s reasonable expectation. When this occurs, Adler is committed to providing the individual with an explanation for the possible use of the personal data when asking for the individual’s consent.  

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Accuracy and Correction of Personal Data

Adler discloses personal data:

• Adler takes steps to ensure information is accurate and up-to-date by updating its records whenever changes to information come to its attention.

• Adler disregards information which seems, on a reasonable basis, be inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession.

• If an individual has submitted personal data to Adler electronically or otherwise, and would like it corrected, then a written request should be sent by email to the Webmaster at admin@adler.sg or to the address below.

• Adler will comply with an individual’s request to correct their personal data as soon as practicable.

• If Adler disagrees with any request to correct an individual’s personal data on reasonable grounds, Adler shall annotate the personal data with the correction that was requested but not made.

 

 Withdrawal of Consent

An individual may withdraw his consent for the collection, use or disclosure of personal data by giving Adler reasonable notice by sending a written request (a) by email to the Webmaster at admin@adler.sg or (b) to the address below. Adler shall inform the individual of the likely consequences of the withdrawal of the consent. Adler will cease to collect, use or disclose the personal data upon such withdrawal unless otherwise permitted or required by the PDPA or other applicable laws and regulations.

 

 Using our Website

As with most websites, when you visit the Adler website or use an application on the Adler website, Adler may record anonymous information such as IP address (where not used to identify a specific individual), time, date, referring URL, pages accessed and documents downloaded, type of browser and operating system.

Adler also uses “cookies”. A cookie is a small file that stays on your computer until, depending on whether it is a sessional or persistent cookie, you turn your computer off or it expires. Cookies may collect and store your personal data. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the Adler website Adler, but may be limited in the use of some of the features.

The Adler websites may contain links to or from other websites. Adler is not responsible for the privacy practices of other websites. This privacy policy applies only to the information we collect on the Adler website. We encourage you to read the privacy policies of other websites you link to from Adler’s website.  

 

Security of your Personal Data

Adler will take reasonable steps to ensure that personal data is securely stored.

Adler protects personal data from misuse or loss by restricting access to the information in electronic format and by appropriate physical and communications security.

Any data destroyed is disposed of in a manner that protects the privacy of personal data in an appropriate manner.  

 

Dealing with Unsolicited Information

Adler takes all reasonable steps to ensure that all unsolicited information is destroyed immediately.  Access to Personal Data If an individual wishes to be provided with information regarding their Personal Data that is in the possession or under the control of Adler or the ways in which such Personal Data has been used or disclosed by Adler in the year preceding such request, then that person needs to send a written request by email to the Webmaster at admin@adler.sgor to the address as detailed below. Adler will handle such requests as soon as reasonably possible in accordance with the PDPA.  

 

Anonymity when dealing with Adler

Adler allows individuals the option not to identify themselves when dealing with it, where practicable.  

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Cross-border Disclosure

Any personal data provided to Adler may be transferred to, stored by or disclosed to an overseas recipient. For example, Adler may use a server hosted overseas to store data, which may include your personal data.

Your personal data may also be processed by employees or by other third parties operating outside of Singapore, who work for Adler, or by the representatives and employees of Adler’s associate companies. Adler will take reasonable steps, in the circumstances, before your personal data is disclosed to an overseas recipient, to ensure that the overseas recipient provide a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.  

 

Sensitive Information

Adler does not collect sensitive information without the individual’s consent and unless it is specifically relevant and necessary for Adler’s primary purposes of conducting, improving, maintaining and developing a business relationship. All sensitive information is collected and used in accordance with this privacy policy. Adler does not use government identifiers (e.g. tax file numbers) to identify individuals.  

 

DNC Registry

Adler complies with all provisions regarding the DNC Registry under the PDPA.  

 

Other Important Information

Adler reserves the right to modify this privacy policy at any time. A current version of this policy will be published on Adler’s website or may be obtained free of charge upon request.  

 

Further Information

If you have any queries or concerns about Adler’s privacy policy, please contact:

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Webmaster, Adler International Pte Ltd, 52 Ubi Ave 3, #04-39/40 Frontier, Singapore 408867 Email: admin@adler.sg.