Personal Data: any information which identifies an individual or information relating to an individual who can be identified (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data does not include anonymous data or data that has had the identity of an individual permanently removed.
Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.
Special Categories of Personal Data: any data which reveals details about sensitive issues such as an individual’s race or ethnicity, religious or philosophical beliefs, sexual relations, sexual orientation, political opinions, trade union membership, information about health, genetic and/or bio metric data.
Personal Data which you directly and voluntarily submit to obtain our services or clarification relating to our services which may include your name, address, national identification number, date of birth, email address, contact information.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use this website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
When you visit this website or use any of our mobile applications, we may also collect, use, store and share aggregated, anonymized, statistical or demographic data (Aggregated Data ). Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law, as it cannot directly or indirectly reveal your identity.
Aggregated Data may include the time and length of your visit to this website, the pages you have visited on this website, as well as details of the website you visited immediately prior to visiting this website. We may also record the name of your internet service provider. We use this information only to measure site activity and to develop ideas for improving our services.
For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, or we are required that information mandatorily to provide the services you are looking for and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In these circumstances, we have the right to cancel or refuse to accept the services you are looking for, but we will notify you if this is the case at the time.
In the event we have reason to believe that any Personal Data provided by you is false, inaccurate, a misstatement of fact, a misrepresentation, an act of identity theft, a violation of any third party right or similar circumstance we have the right to refuse any services you require, terminate our contract if any, with you and where relevant, report you to the requisite regulatory authorities.
Direct interactions. You (or an agent acting on your behalf) may give us your Personal Data by corresponding with us by post, phone, email, directly through the website or otherwise. This includes Personal Data provided to us when you:
This website. As you interact with this website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see paragraph 6 below and our Cookie Policy for further details.
Our mobile website and mobile applications. Our mobile website and mobile applications have the ability to access mobile device information to better serve our clients.
Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources such as set out below:
Purpose/Activity | Type of data | Lawful basis for processing (including our legitimate interest to give you the best and most secure user experience.) |
---|---|---|
To manage our relationship with you which will include:
| Technical Usage Marketing and Communications | Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how clients use our web services) Necessary for our legitimate interests to present you with the right kinds of products and services Necessary for our legitimate interest in improving our web services |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Technical | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Usage Marketing and Communications Technical | Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve this website, services, marketing, client relationships and experiences | Technical Usage | Necessary for our legitimate interests (to define types of clients for our services, to keep this website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about services that may be of interest to you | Technical Usage | Necessary for our legitimate interests (to develop our services and grow our business) |
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.
We will request your express consent before we share your Personal Data with any company outside the Group for marketing purposes.
We may have to share your Personal Data with the parties set out below for the purposes set out in paragraphs 5 and 6 above
Other companies in the Group, outstations, branches and offices based in Sri Lanka and other countries who are acting as joint controllers or processors.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
We are part of the John Keells Group that is one of Sri Lanka’s largest conglomerates listed in the Colombo Stock Exchange, and we operate in many different jurisdictions hence, accordingly, it may be necessary to transfer your data outside Sri Lanka.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please bear in mind that we cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you may ask us to delete your data.
In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you and you can no longer be identified by it) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:
If you wish to exercise any of the rights set out above, please reach out to us on the contact information provided above.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may use CCTV across our premises to ensure the safety of all our customers, patrons, employees and business partners. In particular, we may use CCTV footage to monitor the behaviour of all persons within our premises and where relevant to aid investigations into potential or actual criminal, fraudulent incidents or other incidents of a related nature. We may share such footage with law enforcement authorities and/or the courts of law, as relevant to assist with investigations or any court action.
We may amend this Privacy Policy from time to time in accordance with applicable laws, regulations, best practices and John Keells Group policy and the updated version will be posted on this website. We request that you revisit this website from time to time for updates on the Privacy Policy.
The Privacy Policy may be translated into different languages, and in the event of any inconsistency among the versions, the English version shall prevail.
If you have any comments, questions, concerns or complaints about the contents of this Privacy Policy or the way in which we use your information, we encourage you to contact us by using the information provided above in this regard.
Personal Data: any information which identifies an individual or information relating to an individual who can be identified (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data does not include anonymous data or data that has had the identity of an individual permanently removed.
Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.
Special Categories of Personal Data: any data which reveals details about sensitive issues such as an individual’s race or ethnicity, religious or philosophical beliefs, sexual relations, sexual orientation, political opinions, trade union membership, information about health, genetic and/or bio metric data.
Personal Data which you directly and voluntarily submit to obtain our services or clarification relating to our services which may include your name, address, national identification number, date of birth, email address, contact information.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use this website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
When you visit this website or use any of our mobile applications, we may also collect, use, store and share aggregated, anonymized, statistical or demographic data (Aggregated Data ). Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law, as it cannot directly or indirectly reveal your identity.
Aggregated Data may include the time and length of your visit to this website, the pages you have visited on this website, as well as details of the website you visited immediately prior to visiting this website. We may also record the name of your internet service provider. We use this information only to measure site activity and to develop ideas for improving our services.
For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, or we are required that information mandatorily to provide the services you are looking for and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In these circumstances, we have the right to cancel or refuse to accept the services you are looking for, but we will notify you if this is the case at the time.
In the event we have reason to believe that any Personal Data provided by you is false, inaccurate, a misstatement of fact, a misrepresentation, an act of identity theft, a violation of any third party right or similar circumstance we have the right to refuse any services you require, terminate our contract if any, with you and where relevant, report you to the requisite regulatory authorities.
Direct interactions. You (or an agent acting on your behalf) may give us your Personal Data by corresponding with us by post, phone, email, directly through the website or otherwise. This includes Personal Data provided to us when you:
This website. As you interact with this website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see paragraph 6 below and our Cookie Policy for further details.
Our mobile website and mobile applications. Our mobile website and mobile applications have the ability to access mobile device information to better serve our clients.
Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources such as set out below:
Purpose/Activity | Type of data | Lawful basis for processing (including our legitimate interest to give you the best and most secure user experience.) |
---|---|---|
To manage our relationship with you which will include:
| Technical Usage Marketing and Communications | Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how clients use our web services) Necessary for our legitimate interests to present you with the right kinds of products and services Necessary for our legitimate interest in improving our web services |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Technical | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Usage Marketing and Communications Technical | Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve this website, services, marketing, client relationships and experiences | Technical Usage | Necessary for our legitimate interests (to define types of clients for our services, to keep this website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about services that may be of interest to you | Technical Usage | Necessary for our legitimate interests (to develop our services and grow our business) |
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.
We will request your express consent before we share your Personal Data with any company outside the Group for marketing purposes.
We may have to share your Personal Data with the parties set out below for the purposes set out in paragraphs 5 and 6 above
Other companies in the Group, outstations, branches and offices based in Sri Lanka and other countries who are acting as joint controllers or processors.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
We are part of the John Keells Group that is one of Sri Lanka’s largest conglomerates listed in the Colombo Stock Exchange, and we operate in many different jurisdictions hence, accordingly, it may be necessary to transfer your data outside Sri Lanka.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please bear in mind that we cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you may ask us to delete your data.
In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you and you can no longer be identified by it) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:
If you wish to exercise any of the rights set out above, please reach out to us on the contact information provided above.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may use CCTV across our premises to ensure the safety of all our customers, patrons, employees and business partners. In particular, we may use CCTV footage to monitor the behaviour of all persons within our premises and where relevant to aid investigations into potential or actual criminal, fraudulent incidents or other incidents of a related nature. We may share such footage with law enforcement authorities and/or the courts of law, as relevant to assist with investigations or any court action.
We may amend this Privacy Policy from time to time in accordance with applicable laws, regulations, best practices and John Keells Group policy and the updated version will be posted on this website. We request that you revisit this website from time to time for updates on the Privacy Policy.
The Privacy Policy may be translated into different languages, and in the event of any inconsistency among the versions, the English version shall prevail.
If you have any comments, questions, concerns or complaints about the contents of this Privacy Policy or the way in which we use your information, we encourage you to contact us by using the information provided above in this regard.