John Keells Holdings (“JKH”) acting through John Keells Research (“JKR”) 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.
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, sex life, sexual orientation, political opinions, trade union membership, information about health or genetic and bio metric data.
Important Information and Who We Are
Data Protection Officer
Full name of legal entity: John Keells Holdings PLC
Name or title of DPO: Data Protection Officer
Postal address: No. 117, Sir Chittampalam A. Gardiner Mawatha, Colombo 2, Sri Lanka.
Your duty to inform us of changes
It is important that the Personal Data we hold about you is accurate and current. It is your obligation as well to keep us informed if your Personal Data changes during your relationship with us.
The Data We Collect About You
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
- 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/promotional information from us and our third parties and your communication preferences.
When you visit this website or use any JKH mobile applications, we may also collect, use, store and share aggregated, anonymised, 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.
If you fail to provide 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 your 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.
How is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You (or an agent acting on your behalf) may give us your Personal Data by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide to us when you:
- give us feedback;
- make a complaint on our services.
- 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 such as Google based outside Sri Lanka;
- advertising networks based within and/or outside Sri Lanka;
- search information providers within or outside Sri Lanka
How We Use Your Personal Data
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/JKR 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 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.
- Comply with a legal or regulatory obligation: processing your Personal Data may be necessary for compliance with a legal or regulatory obligation to which we are subject.
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:|
– personalizing your usage experience
– improving our services
|– 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 reorganization or group restructuring exercise)|
– Necessary to comply with a legal obligation
|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)|
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.
We will request your express consent before we share your Personal Data with any company outside the Group for marketing purposes.
Disclosures of Your Personal Data
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, outstations, 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 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.
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 have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised 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.
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 unauthorised 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 can ask us to delete your data..
In some circumstances we may anonymise 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 such data 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 contact us.
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 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.