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23. PRIVACY POLICY

PRIVACY POLICY

INTRODUCTION

We, at Polycrome Holdings (Private) Limited (hereinafter referred to as “Polycrome”) (PV No. 88099) having its registered office at No. 333/9, Old Kesbewa Road, Rattanapitiya, Boralesgamuwa  are pleased to provide our policy on privacy (Polycrome Privacy Policy) for the users of our web site www.polycrome.lk.  

We may gather, process, store and disclose information collected from users of our website and in this regard assure that, we take all reasonable and legitimate efforts to safeguard the privacy of the users of our website, www.polycrome.lk. However, we will collect your personal information only if you voluntarily submit such information to us. You can always refuse to submit such personal information, except that it may prevent you from engaging in certain actions using our website. 

This Privacy Policy explains our procedures relating to the information privacy on personal data we process through your use of our website, services, products, and our mobile application (“App”), related mobile applications and any other reasonably acceptable sources. (collectively “Services”)

Prior to using our services, we request you to carefully read this Privacy Policy. This Policy sets out the purposes why and how we collect your personal data, including how we use, store and disclose them.

This Policy further provides you ways to effect your rights of access, to change, delete, update or protect your personal data as well as the steps we have taken to ensure confidentiality and integrity of the same, prevention of unlawful processing and loss and destruction of your data. 

DEFINITIONS

“Personal Information“ means any information collected, recorded and/or stored by way of electronic medium or otherwise and that can be used by itself to distinctively recognize, identify, reach out to and/or contact, or trace an individual, or can be used with information available from other external sources to exclusively identify an individual.

Personally sensitive data includes communication records,  contents, transaction information, precise location information including but not limited to identification details such as name, date of birth, address, telephone numbers, email addresses, job or profession including designation,  names of the parents and spouses and all information well and sufficiently included in the paperwork used as proof of identity and address.

Personal data or information of sensitive nature such as financial information in the form of individual bank account, credit card, debit card or details of other payment instruments, passwords or authentication information for any of our products has been considered as a part of personal information for the purpose of this policy. 

PURPOSE OF COLLECTION OF PERSONAL INFORMATION

Polycrome Holdings (Pvt) Ltd and its subsidiary Companies may gather, collect, store, manage, process and disclose your personal information properly in accordance with all the applicable and relevant laws and regulations for a number of business and regulatory purposes.

  1. Confirm your identity 

When you place an order to purchase a product or a service from our website, we process your personal information in order to confirm your identity.

  1. Complete a purchase

We will use your data to complete transactions you made online effectively and deliver the product to you and also to correspond with you regarding the delivery date and time. In this process, we will pass your details to a Third Party bank and delivery service provider to swiftly and safely deliver product to you.

  1. Customer service

In order to promptly respond to your queries and any requests for service or assistance, as a customer oriented Company, we consider it as our priority to attend to your queries and requests with regard to our Products and assist you in the fastest possible time. In this process, we have to collect and store your personal information in our data base.

  1. Market research

    We consider our Customer’s needs and requirements our priority and therefore in order to personalise our products and designs to suit your needs, we may process your profile data and usage data. We may request you to take part in our routine surveys, recommend products and ask your feedback to further enhance and improve them, resolve concerns and problems with our products and services. If you do not wish to participate in such activities, you are able to opt-out by contacting us with a written request.

  1. As a part of our legal compliance procedure 

As a responsible entity, we comply with all applicable laws and regulations, legal process and any requirement by the Government authorities to share our customer information. For this reason, we are bound to collect, process and store your information. Further, we do so in order to protect our privacy, safety and rights and that of other users of our services including you.   

HOW WE DO IT

  1. During the course of our valued business relationship with you, we may gather your personal information at the point when you choose to purchase our Products and services through our online platforms or communicate with us for various other reasons. 
  2. We also collect your information when you choose to submit your details via enrollment forms and other authorised third parties who provide us with various services relating to your personal information such as managing, processing, accumulating, safeguarding and sharing the same on behalf of us. Such Third parties may include consultants, our service providers, sub-contractors, sales representatives and others who provide similar services.
  3. When you use our services, by way of making telephone calls, emailing and browsing of our online platforms, we may gather and store your information with regard to your call details, location, and other information you provide in the process and also history of your browsing on our website and other applicable channels.
  4. We use advanced technological techniques such as ‘Cookies’ to retain records of the actions you carry out on our website. These records are used for analyzing, and processing purposes to offer you a better service. Whilst doing so, we may collect your personal data. 

USES AND DISCLOSURE OF YOUR PERSONAL DATA

We may use and/or disclose your Personal Data to the following recipients only for the specific reasons mentioned below: 

  1. We may utilise your personal information for internal assessments, measures, operations and related activities of the Company or any other lawful purpose of the Company. The purpose of this exercise would be for us to provide you with better services.

  1. In order to provide you our services, we are compelled to disclose your personal information with our business partners who offer services so that you can use our websites and services, such as devices, networks and systems.

  1. We may disclose your personal information with our Third Party service providers who execute certain business related roles for us such as processing of credit and debit card payments, customer support services, IT and related technology services, data analysis, website hosting and other similar services.

  1. We may also disclose your personal information with government authorities who are permitted under law to obtain your information in order to comply with applicable laws, regulations, legal process and to respond to requests from public and government authorities. 

  1. We may disclose your personal information for the purposes specifically detailed in this Privacy Policy with other entities of our group of Companies. 

  1. We may disclose your personal information with our affiliates or other third party in the event of any merger, reorganization, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock. Under such circumstances, we will notify you by way of a notice appearing in our website and/or an electronic mail with regard to any change in ownership, and your choices with regard to the disclosure of your personal data to such third parties. 

CONSENT

  1. Once this Policy is accepted by you and you register with your personal data, or when you commence using our services and does not specifically and explicitly oppose the contents of this Policy, it is considered that you have fully understood the same and agree with this Policy. 

  1. At any time while you are browsing our site, if you do not wish to share browsing information, you may opt out of receiving the cookies from our site by making appropriate changes to your browser privacy settings. 

  1. In the event you do not wish to share your personal information or consent for using such data, or prefer to withdraw your already given consent for processing of the personal information gathered by us, we reserve our right to discontinue the services for which we sought your personal information.

YOUR RIGHTS RELATING TO YOUR PERSONAL DATA 

  1. We respect your rights and your control over your personal data. In that sense, you have all the right to request us to perform any changes, deletions or update your personal data in our possession. 

  1. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes. 

  1. You may exercise any of the following rights by emailing us: 

    1. Make a request in order to access to the personal data that we may process about you.

    1. If you prefer to correct, inaccurate or incomplete personal data about you;

    1. Request restrictions, temporarily or permanently, on our processing of some or all personal data about you;

    1. Request deletion of personal data about you;

    1. Request transfer of personal data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; 

    1. Opt-out or object to our use of personal data about you where our use is based on your consent or our legitimate interests. 

SECURITY

  1. In order to prevent any unauthorized and /or unlawful access to your information, we have taken all necessary technical and security measures. We will further guarantee that there will not be any destruction, loss or damage to your personal information. 

  1. You are required to submit to us only the accurate personal information which are up to date and devoid of any misleading data. Details of your past orders, payments and pending orders and other communication are stored in our data base and you may access detailed information of the same by logging in to your account.

  1. You are strongly advised to restrain from sharing your full credit or debit card details in unencrypted e-mail correspondence with us. We have taken all necessary steps to protect the gathering of your information as well as storage and disclosure of the same. We may request proof of your identity prior to disclosing personal information to you, as a security measure. You are kindly requested to take steps to avoid any unauthorized access to your password and to your computer. We do not assume any responsibility for misuse of passwords unless such is our fault.

  1. We state with responsibility that we do not, at any point of time, share your personal information with third parties for any commercial purposes, which could lead to unauthorized invasion of your privacy. 

MINORS

  1. We do not sell any of our Products or services to minors, who are below 18 years of age and we do not therefore gather any personal information knowingly relating to minors. By using our website, you hereby warrant that you are above 18 years of age and that you have read and understand the terms and conditions of this Policy. 

  1. If a minor access your account and make purchases using your account, we consider that you hereby consent to the processing of personal information of the minor and accept and bound by the terms and conditions of this Privacy Policy and take responsibility for their actions. 

AMENDMENTS TO PRIVACY POLICY

We reserve the right to make amendments and modify this Privacy Policy according to the latest legal and regulatory requirements of Sri Lanka. Any amendments made will be shown on this website. You are kindly advised to regularly check our current Privacy Policy to get to know as to how we are dedicated to safeguard your personal information and offer you with better and improved content on our website in order to augment your experience.

FEEDBACK, CONCERNS AND CONTACTING US

We take it as our priority to protect and safeguard your valuable personal information and privacy and we welcome your continued support in this regard.

If you wish to provide any feedback, have any concerns regarding our privacy policy and protection of your personal information please reach us in writing at info@polycrome.lk.

Last  updated : 06/2022