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Version: 1.1

Dated: 3^rd August 2021

Axiata Digital Labs (Private) Limited its subsidiaries and associates/affiliates (hereinafter collectively referred to as “ADL” “us” “we” or “our”) are committed to protecting the personal data of our customers, shareholders, business partners, visitors, employment candidates and employees and the personal data of individuals who work for, or act on behalf of our customers and/or business partners (collectively referred to as “data subject”) that has been provided to us.

At ADL, we take privacy seriously and all our activities are underpinned by our T.R.U.S.T principles of being Transparent, respecting your Rights, in our Use of your personal data, including robust Cyber Security practices and taking due care when the Transfer of personal data is required.

When processing your personal data ADL will ensure that:

Your personal data will be processed lawfully and in a transparent manner so that you are aware of all processing activities connected with your personal data.

Your personal data will be collected by us only for the purposes listed out below and not further processed in a manner that is incompatible with those purposes.

We will only collect personal data that is limited to and required for the purposes listed out below and will not collect more personal data than is required.

Your personal data will be accurate and, where necessary, kept up to date.

Your personal data will be kept in a form which permits identification for no longer than is necessary for the purposes for which that personal data is processed.

Your personal data will be processed in a manner that ensures appropriate security of the personal data.

This privacy notice (“Privacy Notice”) explains:

What and how personal data is collected and further processed by us; For what purposes it is collected and further processed by us; Sources (if any) of personal data;
To whom personal data is disclosed; and

How to access and update your personal data and where to go for further information in respect of the personal data.

If you provide us with personal data of another individual, you hereby represent that you have obtained consent from that individual prior to providing their personal data to us. References to ‘your personal data’ in this Privacy Notice would include such individual’s personal data that you provide to us.

This Privacy Notice should be read together with the terms and conditions specific to the products and/or services you are availing yourself of. In the event of a discrepancy between this Notice and such specific terms and conditions, this Notice shall prevail to the extent of such discrepancy.

We may from time to time amend, modify, vary or update this Privacy Notice by posting the new Notice here and/or on our other platforms and you are bound by such modifications, variations or updates, should you continue to use our products and/or services.

PERSONAL DATA ABOUT CHILDREN

If you are under the age of 18, we take it that you have obtained the consent of your parent, guardian or person who has parental responsibility over you before sending us your personal data (for example, your name, address and email address etc.).

WHAT PERSONAL DATA DO WE COLLECT?

The types of personal data we collect or obtain may vary according to our relationship with you and may include the following:

For Customers

Contact information (such as name, address, email address and telephone number etc.);

Identification information (such as national identity card, passport, driver’s licence, date of birth, IP addresses, internet cookies etc.);

Demographic information (such as age, marital status, gender etc.);

Photographs, such as those that you may submit for contests or prize-winning competitions or upload onto our platforms;

Location information;

Financial information;

Any footage captured or recorded by our surveillance camera (CCTV) system; and Any recordings of calls placed by you to our customer care centres.

Details of beneficiary/next-of-kin; Any footage captured or recorded by our surveillance camera (CCTV) system; any recordings of calls placed by you to us; and Religious beliefs.

For Business Partners and Suppliers

Contact information (such as name, address, email address and telephone number etc.);

Identification information (such as national identity card, passport, driver’s licence, date of birth, IP addresses, internet cookies etc.);

Business information (such as name of organisation, name of the employer, job title, department, etc.); and Any footage captured or recorded by our surveillance camera (CCTV) system.

For Visitors (to any of our Premises/Offices/Online Platforms)

Contact information (such as name, address, email address and telephone number etc.);

Identification information (such as national identity card, passport, driver’s licence, date of birth, IP addresses, internet cookies etc.);

Business Information (such as name of organization, name of the employer, job title, department, etc.); Race; Nationality; Photographs; and

Any footage captured or recorded by our surveillance camera (CCTV) system.

For Employment Candidates and Employees

Contact information (such as name, address, telephone number, email address, etc.);

Identification information (such as national identity card, passport, driver’s licence, date of birth, IP addresses, internet cookies etc.);

Academic and professional information (such as educational and professional qualifications and licences etc.);

Employment history (such as previous job title, previous employer, referees etc.);

Biometrics;
Gender;
Race;

Nationality;

Age;

Emergency contact information (such as name, address, telephone number, e-mail address etc.);

Marital status;

Details of beneficiary/next-of-kin;

Financial information (such as direct deposit account etc.);

IT information (such as log files, software/hardware inventories, user activities etc.);

Photographs;

Any footage captured or recorded by our surveillance camera (CCTV) system;

Additional employment history (such as performance and disciplinary records, medical, hospitalisation and annual leave records, salary details etc);

Results of your health tests and medical reports, if any; Philosophical and political views or affiliations; Religious beliefs; and Criminal Record and Police reports.

Additional Personal Data that We Collect

We may during times of a crisis such as a war, terrorism, riots, a natural disaster or a disease outbreak etc. collect:

Your health and physical condition; The health condition of individuals in your household; Results of your health tests and medical reports, if any; Your body temperature; Your location; and Political views or affiliations.

WHEN DO WE COLLECT YOUR PERSONAL DATA?

We may collect or obtain your personal data:

For Customers

When you use our network, products and/or services (including through our call centres, dealers, and sales channels).

When you contact us or register for information relating to our network, products and/or services or for any other purposes.

When you communicate with us (such as via SMS, telephone calls, other digital channels, emails, questionnaires or surveys etc.).

When you use or interact with any of our digital applications, visit any of our websites or social media pages. When you participate in any of our promotional events, incentives or loyalty programs.

When you visit any of our premises.
From external agencies (such as screening or investigation agencies).

From our internal database pursuant to your relationship with our subsidiaries or associates/affiliates.

From our surveillance camera (CCTV) system.

For Business Partners and Suppliers

When you use our network, products and/or services.

When you communicate with us (such as via SMS, telephone calls, other digital channels, emails, questionnaires or surveys etc.).

When you use or interact with any of our digital applications, visit any of our websites or social media pages.

When you visit any of our premises.

From external agencies (such as screening or investigation agencies).

From our internal database pursuant to your relationship with our, subsidiaries or associates/affiliates.

From our surveillance camera (CCTV) system.

For Visitors (to any of our Premises/Offices/Online Platforms)

When you complete our visitor log book or visitor entry form. When you provide us with your identification document(s).

When you communicate with us (such as via SMS, telephone calls, other digital channels, emails, questionnaires or surveys etc.).

When you provide your host with information. From our surveillance camera (CCTV) system.

For Employment Candidates and Employees

When you make an application to us.

When you communicate with us (such as via SMS, telephone calls, other digital channels, emails, questionnaires or surveys etc.).

From external agencies (such as credit reference agencies, screening or investigation agencies). When you visit any of our premises.
From your referee.
From your previous employer(s).

From anyone with whom you may have or had a business relationship with.

From your or our recruiter, recruitment agency or recruitment website/platform.

From your health and physical advisor (such as a doctor or a dentist).

From our internal database pursuant to your relationship with our subsidiaries or associates/affiliates.

From our surveillance camera (CCTV) system.

HOW DO WE USE YOUR PERSONAL DATA?

Your personal data may be used or processed for the purpose of:

For Customers

Providing you with our products and/or services that you have contracted for.
Notifying you about benefits and changes to the features of our products and services.
Providing you with our latest offers, campaigns and promotions (where you subscribe to such updates). Sending you service messages about our subscription or account registration.

Compliance with laws and legal, contractual and/or regulatory obligations and protecting or exercising our legal, contractual and/or regulatory rights and remedies.

Sending you information via telephone calls, text messages or other digital channels, emails, etc. or social media about products and services offered by our subsidiaries, associates/affiliates and selected third parties that we think may interest you. (You may unsubscribe from such messages).

Responding to complaints or account enquiries. Administering debt recoveries.

Verifying your identity when required (you may misplace your password or security information for example, and we may then need to request for other personal data to protect your data from unauthorized access).

Undertaking market and product analysis based on your use of our products and/or services (achieved by analysing your service preferences) and for product and/or service enhancements and improvements.

Other legitimate purposes.

For Business Partners and Suppliers

Business execution.

Organisation and management of the business.

Health, safety and security.

Compliance with laws and legal, contractual and/or regulatory obligations and protecting or exercising our legal, contractual and/or regulatory rights and remedies.

Protecting our assets and interests. Other legitimate purposes.

For Visitors (to any of our Premises/Offices/Online Platforms)

Health, safety and security.

Compliance with laws and legal, contractual and/or regulatory obligations and protecting or exercising our legal, contractual and/or regulatory rights and remedies.

Other legitimate purposes.

For Employment Candidates

Identifying and evaluating candidates for potential employment, as well as for future roles that may become available.

Record keeping in relation to recruiting and hiring. Conducting background checks.

Compliance with laws and legal, contractual and/or regulatory obligations and protecting or exercising our legal, contractual and/or regulatory rights and remedies.

Contacting you or your emergency contact in emergency situations where the health or safety of one or more individuals may be endangered.

Other legitimate purposes.

For Employees (in addition to the purposes set out for Employment Candidates above)

Career progression and personal development.
Administration and management of salary and employment benefits.
Short term and long-term incentive plans.
Employment and industrial relations disputes, including but not limited to litigation.
Corporate exercises undertaken by our subsidiaries or associates/affiliates. Management of performance.
Application of work and travel permits and immigration/emigration requirements.
Loans, insurance and medical purposes.
Disciplinary actions or terminations.
Ensuring health and safety.
Accounting, financial reporting and business planning.
Security monitoring.
Organizing team-building activities and other business-related events.
Internal or external investigations.
Research, salary surveys and for audit purpose.
Compliance with reasons stated in your contract of employment with us.
Any legal or regulatory request or demand.
Other legitimate purposes.

WHOM DO WE DISCLOSE YOUR PERSONAL DATA TO?

We may disclose your personal data:

For Customers

To our subsidiaries and associates/affiliates. To other carriers and operators when routing international calls.

To third parties when disclosure is necessary or reasonable to protect our rights, protect your security, investigate fraud or respond to a law enforcement request.

To our service providers, field engineers, contractors, subcontractors or any other third-party performing work on our behalf or at our instruction.

To any public authority, governmental, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which we are subjected to or as permitted by applicable law.

To our business partners for our marketing activities, which you have consented to/not opted out of. To third parties for credit checks and fraud management.

To any parties that act as our payment channels, including to validate your information, as and when required.

To third parties for carrying out analytics to understand how you use our products and/or services. To third parties for research and development purposes.
To our dealers or agents.

If we are involved in a sale or business transaction (e.g., merger or acquisition), we will retain a legitimate interest in disclosing or transferring your personal data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring or target entity and its advisors.

To third parties for the purposes set out under “How do we use your personal data?”.

For Business Partners and Suppliers

To our subsidiaries and associates/affiliates.
To our third-party agents, service providers, consultants, advisors, contractors and/or subcontractors.

To third parties for the purposes set out under “How do we use your personal data?”.

For Visitors (to any of our Premises/Offices/Online Platforms)

We do not routinely share or transfer your personal data with any external organizations or third parties. However, where and whenever we share or transfer your personal data, it shall be for the purposes set out under “How do we use your personal data?” and we shall do so in accordance with this Privacy Notice.

Further we will disclose your personal data if required by any public authority, governmental, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which we are subjected to or as permitted by applicable law.

For Employment Candidates and Employees

To our subsidiaries and associates/affiliates. To background verification providers.

To any other third-party organizations providing administration or other services.

To any third-party organizations involved in any corporate exercises undertaken by us or our subsidiaries or associates/affiliates.

To third parties for the purposes set out under “How do we use your personal data?”.

We use reasonable efforts in accordance with industry best practices to ensure that the above-mentioned maintain the confidentiality and integrity of your personal data and are restricted from using your personal data for any unauthorised purpose.

In addition to the above, our service providers may, in the course of providing you the products and/or services, collect your personal data via other channels such as when you are redirected to their individual websites/mobile applications or platforms.

We strongly advise you to review the privacy notice of every such service provider. We have no control over and assume no responsibility for the content, privacy notices or practices of any service provider to the fullest extent permitted by the law.

TRANSFERS OF PERSONAL DATA

We may transfer your personal data across geographical borders to other entities. Where your personal data has been transferred to members of our subsidiaries, associates/affiliates and/or to third parties located outside of Sri Lanka, the transfer of your personal data is carried out under organizational, contractual and legal measures and with reasonably adequate levels of protection implemented as well as any additional local legal requirements for the parties receiving this data in order to safeguard your personal data.

HOW DO WE STORE AND PROTECT YOUR PERSONAL DATA?

We may collect and store your personal data in electronic or physical form, depending on the requirement. Such personal data may be stored at our and third party premises within IT Systems (e.g. external cloud storage, internal or third-party management systems, e-mails, databases, hard drives etc.), and physical warehouses etc.

We endeavour, where practicable, to process your personal data in a safe environment by preventing any unauthorized or unlawful processing of personal data or accidental disclosure, loss or destruction of, or damage to, such personal data. We have implemented various physical, technical and administrative security measures to protect your personal data and our network from unauthorized access.

Some of these measures include:

encryption of personal data;
strict adherence to privacy and security practices;
periodic security assessment and reviews to upgrade our practices; and
restriction of access to such personal data to personnel who have a need to know such personal data.

The security of your personal data is important to us but remember that no method of transmission over the Internet, securing while processing, 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.

HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We will retain your personal data only for as long as such data is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws or a legitimate business requirement. In all cases such personal data may be held for a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose).

Once personal data surpasses its retention period and if there is no valid reason to retain such personal data, the personal data will be securely disposed of.

WHAT ARE YOUR RIGHTS?

We respect your rights and privacy by taking steps to ensure that your personal data is accurate and up-to-date. Any inaccurate information that is brought to our attention shall be corrected within a reasonable period of time from the receipt of a written notification by you of the same sent to us via the below mentioned contact options. Any requested amendments may be subject to applicable laws and regulations.

We shall make available (to the extent possible) your personal data in our possession or control within a reasonable time at a reasonable cost.

You may request us to stop sending our communications to you by contacting us via the below mentioned contact details. These choices do not apply to the receipt of mandatory product or service communications that are considered as part of certain ADL products or services, which you may receive periodically, unless you cancel the subscription to our products or services.

CONSEQUENCES OF NOT PROVIDING YOUR PERSONAL DATA

We may require collection of certain personal data about you and failure to provide such information may:

Result in us being unable to process your application and/or provide you with our product and/or services.

Result in us being unable to respond to your requests on our products and/or services.

Limit or prevent access to certain features on our website, weblinks or digital platforms.

Result in us being unable to update you on the latest updates regarding any promotions, our services/products or launches.

Result in your inability to receive invitations to promotional activities organized by us.

Negatively affect our ability to communicate with you.

Result in us being unable to process your requests relating to your shareholding.

Result in us being unable to inform you of shareholder meetings and conduct direct remittance of dividends to your bank accounts.

Result in our inability to enter into a contract with you or a counter-party or continuing to contract with you or a counter-party.

Negatively impact your chances of being selected for any potential employment, engagement or internship. Be in violation of any applicable law or regulation that requires us to collect such personal data.

BY SUBMITTING PERSONAL DATA TO US, YOU ACKNOWLEDGE THAT:

You have read and understood this Privacy Notice and agree and consent to the use, processing, disclosure and transfer of personal data as set out herein.

All information and representations provided by you are true and correct to the best of your knowledge, and you have not knowingly omitted any relevant information.

WHOM CAN YOU CONTACT FOR MORE INFORMATION?

If you have any questions or complaints about this Notice or about our privacy and information handling practices, kindly reach out to our Data Privacy Officer via the following methods:

Address: Parkland, 33 Park Street, Level 11, Colombo, Western Province 00200, Sri Lanka

Telephone: +94773064720

Email: ravindra.thalagahawatta@axiatadigitallabs.com

UPDATES TO THE PRIVACY NOTICE

We reserve the right to amend, modify, vary or update this Privacy Notice, at our sole discretion from time to time, as and when the need arises. The most recently published Privacy Notice shall prevail over any of its previous versions and the version number and date will be updated accordingly. We have no obligation to inform you of any variations and you are encouraged to check this Privacy Notice from time to time to stay informed of any changes. You agree to adhere to the terms of the Privacy Notice including any variations.

What are cookies?

A cookie is a small file that can be placed on your device that allows us to recognize and remember you. It is sent to your browser and stored on your computer’s hard drive or tablet or mobile device. When you visit our sites, we may collect information from you automatically through cookies and other tracking technologies.

What are web beacons?

Web Beacon is a transparent graphic image placed on websites/e-mails to monitor user activity. Web beacons are similar to cookies and are often used in combination with cookies.

What do we use cookies for?

Like most providers of online services, we use cookies to provide, secure and improve our services, including by remembering your preferences, recognizing you when you visit our website and personalizing and tailoring ads to your interests. To accomplish these purposes, we also may link information from cookies with other personal information we hold about you.

What are the different types of cookies?

First-party cookies

First-party cookies are placed on your device directly by us. For example, we use first-party cookies to adapt our website to your browser’s language preferences and to better understand your use of our website.

Third-party cookies

Third-party cookies are placed on your device by our partners and service providers. For example, we use third-party cookies to measure user numbers on our website or to enable you to share content with others across social media platforms.

Session cookies

Session cookies are used for a variety of reasons, including to learn more about your use of our website during one single browser session and to help you to use our website more efficiently. Session cookies last only until you close your browser.

Persistent cookies

Persistent cookies are primarily used to help you quickly sign-in to our website again and for analytical purposes. Persistent cookies have a longer lifespan and aren’t automatically deleted when you close your browser.

Based on functionality, cookies can be classified as below:

Functionality	Description
Necessary cookies	These cookies are strictly necessary to provide you with services available through our website and to use some of its features, such as access to secure areas.
Analytics cookies	These cookies help us understand how our website is being used, how effective marketing campaigns are, and help us customize and improve our websites for you.
Marketing cookies	These cookies record your visit to our website, the pages you have visited (including, in the case of interest-based advertising, the pages of other websites) and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. Without these cookies, you will be able to use and enjoy all the features of our website but the ads you see will not be tailored to your preferences.
Preference Cookies	Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.

By using our website, you consent to the use of these cookies. If you do not wish to accept any cookies or certain types of cookies/web beacons, you can change your browser’s settings to delete cookies that have already been set and to not accept new cookies.

Cookie preferences

Users can mostly control their cookie preferences by managing the browser settings. For more information about these controls and to exercise your cookie preferences, visit your browser or device’s help material.

Please however note, that, if you delete cookies or do not accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not get displayed properly.

Changes to this cookie policy

We may periodically update this policy to comply with privacy regulations, describe new website features, or to add and/or remove cookies that we use.

Other information

For more information on how Axiata Digital Labs (Private) Limited manages your personal data received through the website, please read Axiata Digital Labs (Private) Limited’s privacy notice.

How to contact us

If you have any questions or concerns about this policy or its implementation, please contact us at upekkha.batuvantudave@axiatadigitallabs.com.

Axiata Digital Labs (Private) Limited is a part of Axiata Group Berhad (together referred to as “ADL”, “us” or “we” or “our”). Respecting and protecting your privacy is an integral part of our business and we do not view this as an obligation, but rather as a commitment to maintain your confidence and trust. Our Privacy Position can be summarized by our below guiding Privacy and Data Protection principles:

TRANSPARENT: We are TRANSPARENT about what, why and how we collect and protect YOUR PERSONAL DATA so that YOU can make informed decisions.

RIGHTS: We respect YOUR RIGHTS as individuals, so YOU are in control of YOUR PERSONAL DATA.

USE: We USE YOUR PERSONAL DATA for specific and stated purposes and keep it for as long as required only.

SECURITY: We have established robust CYBER SECURITY PRACTICES in line with leading industry standards to protect YOUR PERSONAL DATA that YOU have shared with us.

TRANSFER: We take due care when TRANSFERRING YOUR PERSONAL DATA to third parties such as vendors, contractors, business partners and government authorities.

This notice applies to personal data that we collect, generate or use when you subscribe to any of our products and services, use our applications or visit any of our websites. We advise you to read this notice alongside Terms and Conditions of our products/ services as they may contain product/service specific information on how we process your personal data.

This privacy notice applies to:

All the services offered by Axiata
Existing, past as well as potential customers/clients

Information we collect and use

. This notice explains how we collect and use your personal data when:

You use our network, products or services (including call centers)
You contact us with a question about our products and services
You use our applications or visit any of websites
You contact us for any other purpose(s).

The types of personal information that ADL may collect for the performance of our services to you include, but are not limited to:

Contact information (such as name, address, email address and telephone number)
Identification information (such as passport identification number, tax registration number or social security number, driver’s license, date of birth)
Demographic information (such as age range, marital status, gender)
Photographs, such as those that you may submit for contests or prize-winning competitions
Product specific information (such as preference, closed user groups (CUGs), friends and family who you chose to include in your service plan, credit limit)
Banking information (such as direct debit and related bill payment banking transactions)
Service account information (such as call usage, account balances, transaction history, credit information, billing, loyalty points).

ADL collects and uses your personal information with your knowledge and consent and typically when you:

Use ADL’s wide range of products and services that are offered or for which you may choose to opt-in
Make customer enquiries, register for information or other services
Respond to communications from us (such as SMS, emails, questionnaires or surveys)
Interact with ADL’s websites, such as submitting an application form, completing survey form, use online services. (If your browser has Internet cookies enabled, it can facilitate ADL’s tracking of personal preferences, pages visited etc.)
Participate on ADL’s social media pages, such as Facebook
Participate in ADL’s promotional events, incentive or loyalty programs
Provide information through ADL’s customer call centers, dealers and sales channels or any other affiliates or business dealings with ADL by which you have consented to provide your personal information.

Your personal data may be collected, used or otherwise processed by us for, amongst others, for the following purposes:

To provide you with our products, services, latest offers and promotions (where you subscribe to such updates)
which may be of interest to you
To notify you about benefits and changes to the features of our products and services
To conduct research for analytical purposes
To publish your information (which may include your name, profile picture and such other relevant personal data) on our website, social media and our printing materials
To inform you of any upcoming event and updates
To inform you of any upcoming event and updates;
To use your information for participation in our events or award;
To use your information for e-commerce
For your participation in contest
To send you service messages about our subscription or account registration
To use your information for participation in our customer surveys or meetings
Enable us to send you information by e-mail, telecommunication means (telephone calls or text messages) or social media about products and services offered by selected third parties that we think may interest you

The above shall hereinafter be referred to as the “Purposes”.

Information about Children

If you are under the age of 18, you are required to obtain the consent of your parents or legal guardian before using our network, products and/or services.

Effects arising from failure to provide Personal Data

You will be able to access our website without providing your personal data. However, where any activity/services on our website/weblink requires us to collect certain personal data about you, failure to provide such information may:

Result in us being unable to respond to your requests on our products/services
Limit and/or prevent access to certain features on our website/weblinks
Result in us being unable to update you on latest updates regarding any promotions, our services/products or launches
Result in your inability to receive invitation to promotional activities organized by us.

Data Retention and Storage

Your personal data that has been collected and processed shall be retained for as long as required to meet the purposes mentioned above. We may store your personal data to provide the services you have requested, or for other essential purposes, such as complying with our legal obligations, resolving disputes, and enforcing our policies. The retention period for storage of personal data is based on the requirements of applicable laws. However, in the absence of any relevant laws, personal data will be stored where it is required for business purposes.

This personal data may be stored in:

Hard copy, or
Electronic format

We may keep your data in data centers or warehouses that are managed either by us or by service providers on our behalf. All our facilities, systems and products have been equipped with required security controls to ensure protection of personal data.

Security

We endeavor to process your information in a safe environment by preventing any unauthorized or unlawful processing of personal data or accidental loss or destruction of, or damage to such information. We have implemented various physical, technical and administrative security measures to protect your personal data and our network from unauthorized access. These measures include:

Disclosure

We keep your personal data confidential and do not share it with non-affiliated companies, except: (a) to provide products or services you have requested, (b) when we have your consent or (c) under the following circumstances:

When we have to meet our legal obligations and to prevent and detect crime as per the law. We will share your personal data with any person to whom we are compelled or required to do so under law or in response to a competent regulatory or government agency and industry regulators
When we believe it necessary to share the personal data or enforce ADL’s rights, usage terms, intellectual or physical property or for safety of ADL or associated parties
We may share your information if ADL is acquired by or merged with another company or for any legal claim, where ADL is required to do so
We may share your personal data with our auditors, consultants, accountants, insurers or other financial and/or professional advisers
When any other person reasonably requires your personal data in order for us to operate and maintain our business or carry out the activities set out in the Purposes.

We make sure that our service providers and agents maintain the confidentiality of your personal data and are restricted from using such information for any unauthorized purpose. ADL will ensure through formally executed contracts that the service providers are committed to “same level of protection to your information”, as per the applicable data protection laws and regulations.

Communication Preferences and Choices

ADL takes reasonable steps to keep your personal data accurate, complete and up to date. You still may stop the delivery of promotional e-mail or other ADL communications by contacting us on the below mentioned contact details. These choices do not apply to the receipt of mandatory product or service communications that are considered part of certain ADL products or services, which you may receive periodically, unless you cancel the product or service.

Furthermore, ADL does not require that you provide us with personal information. The decision to provide personal information is voluntary. However, if you do not wish to provide the personal information requested, you may not be able to proceed with the activity or receive the benefit for which the personal information is being requested.

Cross Border Data Transfer

With your consent, we may transfer your personal data across geographical borders to other entities, provided they ensure the same level of protection as us. The transfer of personal data is carried out under our standard contracts with appropriate data protection clauses or data transfer agreements with similar rights and obligations for the parties receiving this information to protect the security and confidentiality of your personal data.

ADL does not sell, trade, transfer or otherwise share your personal information, except in the following instances:

With Axiata group companies, where necessary and within the limits of applicable law
As required by law, such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution or similar legal process
With other carriers and operators when routing international calls
When we believe in good faith that disclosure is necessary to protect our rights, protect your security, investigate fraud or respond to a law enforcement request
With ADL’s service providers, field engineers, contractors who work on our behalf and who do not have an independent right to use the information to which they have access or that we disclose to them
With our business partners for ADL’s marketing activities, in such case no specific personally identifiable information is provided, as such information is generally aggregated
With third parties for research and development purposes
With our subsidiaries and affiliates, such as ADL dealers.

Third parties must in all cases agree to a strict duty to keep all personal information confidential and to use it only for the purpose for which it was obtained.

Exercise Your Rights

We respect your rights and privacy and we manifest our stand by taking steps to ensure that your personal data is accurate and up-to-date. As our obligation under the Personal Data Protection Act, 2010 we assure you that:

You have the right to know what personal data we have about you
You have the right to request a copy of your personal data
You have the right to correct your personal data, in case it is incorrect or incomplete
You have the right to withdraw your consent from our processing of your personal data
You can also ask us to restrict how we use your personal data where it is likely to cause damage or distress
You have the right to prevent processing of your personal data where it is so conducted or is going to be conducted for purposes of direct marketing.

For exercising your rights, you can reach out to us through the details under Contact Us section given below.

By submitting your personal data to us, you acknowledge that:

You have read and understood this Privacy Notice and agree to the use of your personal data as set out herein
Your personal data may be transferred and processed worldwide, including countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice

All your representations are true and correct to the best of your knowledge, and you have not knowingly omitted any related information of adverse nature.

Contact Us

If you have any questions or complaints about this notice, our privacy and information handling practices, you can contact us at

Address: Parkland Building, 33 Park Street, Level 11, Colombo, Western Province 00200, Sri Lanka

E-mail ID: info@axiatadigitallabs.com

Phone Number: +94 76 676 6300

Contact Details of our Data Privacy office are as follows: upekkha.batuvantudave@axiatadigitallabs.com

Dispute Resolution

In cases of any suspected/actual violation of your privacy, in relation to your information that we process or store, you can lodge a complaint with the relevant regulatory authority or any other tribunal/court of competent jurisdiction.

Updates to the Privacy Notice

ADL reserves the right to update this privacy notice, as and when need arises. This notice shall prevail over any of its previous versions. We highly recommend that you check back here from time to time to stay informed of any changes.

Version Info

This notice was published on 30th of March 2020 and last updated on 15th May 2020.

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