This Privacy Policy sets out how we, Gister Private Limited (herein and after “ADBRO” also “WE”, “US”), and our associated companies (hereafter collectively referred to as "the Companies") may collect, use, disclose, transfer and store your Personal Information (as defined below). We are interested in and are committed to protecting your privacy. The Companies may share your Personal Information and use it in a manner and for purposes that are consistent with this Privacy Policy and going under the Personal Data Protection Act 2012 of Singapore (PDPA).
This Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations in which we have engaged to collect, use, disclose, or process personal data for our purposes.
Personal data means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
We generally do not collect your data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us after (i) you have been notified of the purposes for which the data is collected, and (ii) you have provided consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws.
We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose that has not been notified to you (except where permitted or authorized by law).
We may collect your personal information when you:
The information that we collect includes information that can identify you ("Personal Data"), including, but not limited to, cookie files, geofencing, clickstream Data, IP address, URL tracking, date/time of visit on the website, browser information (e.g. browser name, language and version), email address, or other personal information that you send to us.
We may collect and use your personal data for any or all of the following purposes:
We may disclose your personal data with our subsidiaries, affiliated companies (the Companies), and trusted third-party service providers working under the instruction of ADBRO, such as an email service provider, hosting provider, or data center, exclusively for storage purposes. Such third parties who provide services on our behalf are authorized to use your personal information only as strictly necessary to provide these services to us.
We will also ensure that overseas organizations we work with observe strict confidentiality and data protection obligations.
Also we may disclose your personal data complying with any applicable laws to assist in law enforcement and investigations conducted by any governmental or regulatory authority.
In compliance with the PDPA, we may collect, use, or disclose your personal data without your consent for the legitimate interests of ADBRO or another person. In relying on the legitimate interests exception of the PDPA, ADBRO will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
In line with the legitimate interests’ exception, we will collect, use, or disclose your personal data for the following purposes:
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 collecting, 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.
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.
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 services to you and we shall, in such circumstances, notify you before completing the processing of your request. If you should decide to cancel your withdrawal of consent, please inform us in writing manner or via email to our Data Protection Officer.
Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about how we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. In general, our response will be within ten (10) business days. 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).
To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have introduced appropriate administrative, physical, and technical measures such as authentication, and access controls to prevent unauthorized access to information, regular patching of operating system and other software, and security review regularly.
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.
We generally rely on personal data provided by you. 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.
We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data or remove how 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.
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and 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.
Our Website may contain links to websites owned or operated by third parties that do not operate under this Privacy Policy. These third-party websites contain their own privacy policies and practices and their owners or operators are responsible for informing you about their privacy policies and practices. We are not responsible for the privacy policies and practices of websites owned or operated by third parties that are linked to our website.
You may contact our Data Protection Officer if you have any inquiries or feedback on our privacy policy and procedures, or if you wish to make any request, in the following manner:
This Policy applies in conjunction with any other notices, policies, contractual clauses, and consent clauses that apply to the collection, use, and disclosure of your personal data by us.
This Policy does not describe ADBRO data practices relating to information that ADBRO collects through its advertising services.
We may revise this Policy from time to time. Visitors will be informed about any essential changes through banners on the website. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. ABDRO will not alter your rights under this Privacy Policy without your explicit consent. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.
Effective date: 01/11/2023
Last updated: 01/11/2023