John Keells Holdings PLC (“JKH”, “we” “our” and “us”) is a company registered in Sri Lanka with the company registration number PQ 14 and our registered office is at No. 117, Sir Chittampalam A. Gardiner Mawatha, Colombo 2, Sri Lanka.
Your privacy is important to us, and we want to assure you that the Personal Data we collect about you will be treated with care. This Privacy Policy will inform you about how we look after your Personal Data when you avail of services on visiting our website, interact with us over the phone, via email, through our mobile applications or otherwise by using any of our social media platforms, or contract with us, your privacy rights and the protection afforded by law.
By accepting the terms of the Privacy Policy, contracting with us and/or continuing to avail our services, you agree that you have read, understood and agreed to this Privacy Policy.
This Privacy Policy uses a number of definitions which are set out below:
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.
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how we collect and process your Personal
Data through your use of our website, including any data you may provide when you apply for
a career at JKH. This website is not intended for children, and we do not knowingly collect
data relating to children unless provided by their parents or guardians.
It is important that you read this Privacy Policy together with any other privacy notice or
fair processing notice we may provide on differing occasions when we are collecting or
processing Personal Data about you so that you are fully aware of how and why we are using
your data. This Privacy Policy supplements the other notices and is not intended to override
them.
Data Controller JKH is the Data Controller of all Personal Data relating to our clients, investors, employees and third-party individual contacts, as well as any other Personal Data used in our business for our own commercial purposes. This means that we are responsible for determining when, why and how to Process Personal Data and for establishing practices and policies in line with applicable data protection law.
Contact Us Should you have any inquiries in relation to this Policy please contact the following:
Contact details.
Full name of legal entity: John Keells Holdings PLC
Designation: Head of Corporate Communications
Postal address: No. 117, Sir Chittampalam A. Gardiner Mawatha, Colombo 2, Sri Lanka.
Email address: [email protected]
Your duty to provide accurate information and inform us of changes It is important that the Personal Data we hold about you is accurate, valid and current. It is your obligation as well to keep us informed if your Personal Data changes during the continuant of your relationship with us.
Your duty to ensure the security of your own
personal devices
It is important that you ensure the security of the devices used to transfer Personal Data
to us as no data transmissions over the Internet can be guaranteed to be 100% secure.
Therefore, it shall be your responsibility to secure such devises against security and cyber
risks.
We will also not ask for your Personal Data or account information (as applicable) by any
unsolicited means of communication. Therefore, you are responsible for keeping your Personal
Data and account information secure and not sharing it with others.
Third party consent In the event you provide us with any personal information or data on behalf of another person Including any Personal Data, for the purposes of providing products and services, an inquiry with us or for any appointment, related contract or requirement, you confirm that that information and data has been obtained by you and provided to us with the prior specific consent of such person who has fully apprised himself/herself of terms and conditions of this privacy policy. Such third-party Personal Data or information provided by you shall be accurate, up to date, valid and not include any false, inaccurate information, any misstatements of fact, misrepresentations or the like.
Third-party links This website may include links to third-party websites, plug-ins and applications which are not maintained or controlled by us. Clicking on those links or enabling those connections may allow third parties to collect or share data about you based on their own terms of use and privacy. We do not control these third-party websites and are not responsible for their privacy statements. When you leave this website, we encourage you to read the Privacy Policy of every website you visit. We are not responsible for any third- party actions or their security controls in respect of any Personal Data they may collect or process via their website, service or otherwise.
Personal Data
We may collect, use, store and transfer different kinds of Personal Data about you and those
of third parties you disclose to us which we have grouped together as follows:
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 or services.
Marketing and Communications Data includes your preferences in receiving marketing from us
and our third parties and your communication 0preferences.
Aggregated Data
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.
If you fail to provide Personal Data or provide inaccurate or false, Personal
Data
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.
We use different methods to collect data from and about you including through:
Direct interactions. You (or a person 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:
• give us feedback;
• making complaints on our services.
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:
• analytics providers within and/or outside Sri Lanka (such as Google based analytics
providers);
• advertising networks based within and/or outside Sri Lanka;
• search information providers within or outside Sri Lanka.
We will only use your Personal Data in the manner permitted by law. Most commonly, we will
rely on the following types of lawful basis to process your Personal Data:
Legitimate Interests: the interests of JKH in conducting and managing our business in order
to give you the highest standard of service and the best and most secure experience. We make
sure we consider and balance any potential impact on you (both positive and negative) and
your rights before we process your Personal Data for our legitimate interests. We do not use
your Personal Data for activities where our interests are overridden by the impact on you
(unless we have your express consent or are otherwise required or permitted to by law). You
can obtain further information about how we assess our legitimate interests against any
potential impact on you in respect of specific activities by contacting us.
Performance of Contract: processing and using your data is necessary for the performance of
any contract to which you are a party or to take steps at your request before entering into
such a contract and the provision of the same to our service providers, agents and other
parties as required for the purpose of facilitating the performance of the contract with
you.
Comply with a legal or regulatory obligations: processing, use and disclosure of your
Personal Data may be necessary in order to ensure compliance with legal or regulatory
obligations to which we are subject or to comply with requests by Government, law
enforcement, regulatory, judicial or related authorities in relation to obligations arising
under law, regulation, national or public security or related inquiry.
Purposes for which we will use your Personal Data
We have set out below, in a table format, a description of primary ways we will use your
Personal Data, and which types of legal basis we rely on to do so. However, it may not be an
exhaustive list and we will be able to provide additional information you may require in
that regard upon request. We have also identified what our legitimate interests are where
appropriate. We may process your Personal Data for more than one lawful basis depending on
the specific purpose for which we are using your data.
| 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 |
|
| To administer and protect our business and this website | Technical |
|
| 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 |
|
| To use data analytics to improve this website, services, marketing, client relationships and experiences | Technical Usage |
|
| To make suggestions and recommendations to you about services that may be of interest to you | Technical Usage |
|
Cookies
This website makes use of cookies to measure site activity and to enhance your experience in
searching our services. Cookies are alphanumeric identifiers that are sent to your computer
when you visit websites and online services. If your web browser’s preferences are set to
accept it, the cookie is stored on your computer’s hard drive. Cookies enable our and other
websites to recognize your preferences and to tailor content to you. You can set your
browser to refuse all or some browser cookies, or to alert you when websites set or access
cookies. If you disable or refuse cookies, please note that some parts of this website may
become inaccessible or not function properly. For more information about the cookies we use,
please see our Cookie Policy.
Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible
with the original purpose. If you wish to get an explanation as to how the processing for
the new purpose is compatible with the original purpose, please contact us. If we need to
use your Personal Data for an unrelated purpose, we will notify you and we will explain the
legal basis which allows us to do so.
We strive to provide you with choices regarding certain Personal Data uses, particularly
around marketing and advertising.
Third-party marketing
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 above.
Internal Third Parties
Other companies in the Group, associates of the Company, outstation branches and offices
based in Sri Lanka and other countries who are acting as joint controllers or
processors.
External Third Parties
• Service providers, contractors, and agents acting as processors based on who provides
services such as data processing and analytics, marketing and research, revenue optimization
and other services to John Keells Holdings in connection with the operations of the business
of The John Keells Holdings Group.
• Business partners of JKH associated with its sectors such as leisure, transportation,
retail, etc.
• Professional advisers or those acting as processors or joint controllers, including
lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance
and accounting services.
• With any law enforcement authority or governmental institution for security or any other
investigative purpose.
• Regulators and other authorities acting as processors or joint controllers who require
reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or
our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a
change happens to our business, then the new owners may use your Personal Data in the same
way as set out in this Privacy Policy.
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.
How long will you use my Personal Data for?
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.
Your Legal Rights
Under certain circumstances, you have the following rights under data protection laws in
relation to your Personal Data:
• Request access to your Personal Data (commonly known as a “data subject access request”).
This enables you to receive a copy of the Personal Data we hold about you and to check that
we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have
any incomplete or inaccurate data we hold about you corrected, though we may need to verify
the accuracy of the new data you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove
Personal Data where there is no good reason for us continuing to process it. You also have
the right to ask us to delete or remove your Personal Data where you have successfully
exercised your right to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your Personal Data to comply with
local law. Note, however, that we may not always be able to comply with your request of
erasure for specific legal reasons which will be notified to you, if applicable, at the time
of your request.
• Object to processing of your Personal Data where we are relying on a legitimate interest
(or those of a third party) and there is something about your particular situation which
makes you want to object to processing on this ground as you feel it impacts on your
fundamental rights and freedoms. You also have the right to object where we are processing
your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we
have compelling legitimate grounds to process your information which override your rights
and freedoms.
• Request restriction of processing of your Personal Data. This enables you to ask us to
suspend the processing of your Personal Data in the following scenarios: (a) if you want us
to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not
want us to erase it; (c) where you need us to hold the data even if we no longer require it
as you need it to establish, exercise or defend legal claims; or (d) you have objected to
our use of your data but we need to verify whether we have overriding legitimate grounds to
use it.
• Request the transfer of your Personal Data to you or to a third party. We will provide to
you, or a third party you have chosen, your Personal Data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated information which
you initially provided consent for us to use or where we used the information to perform a
contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal
Data. However, this will not affect the lawfulness of any processing carried out before you
withdraw your consent. If you withdraw your consent, we may not be able to provide certain
services to you. We will advise you if this is the case at the time you withdraw your
consent.
If you wish to exercise any of the rights set out above, please reach out to us on the
contact information provided above.
No fee usually required
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 unfounded, unreasonable,
repetitive or excessive. Alternatively, we may refuse to comply with your request in these
circumstances.
What we may need from you
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.
Time limit to respond
We will use all best endeavours to respond to all legitimate requests within twenty-one
days. Occasionally, it may take us longer if your request is particularly complex or you
have made a number of requests. We will keep you updated in such case.
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.
