Privacy Policy

Privacy Policy


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.

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 the services of JKR when you visit our website, your privacy rights and how the law protects you.

By continuing to avail JKR’s 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, sex life, sexual orientation, political opinions, trade union membership, information about health or genetic and bio metric data.

Important Information and Who We Are

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 the John Keells Research website, including any data you may provide when you apply for a career at JKH/JKR. This website is not intended for children and we do not knowingly collect data relating to children unless provided by the 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 specific 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

John Keells Holdings PLC 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 JKH is responsible for determining when, why and how to Process Personal Data and for establishing practices and policies in line with applicable data protection law. This Privacy Policy is issued on behalf of the Group so when we mention “John Keells Holdings”, “John Keells”, “JKH”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the Group responsible for processing your data. We will let you know which entity will be the controller for your data when you interact with us. John Keells Holdings PLC is the controller for this website.

Data Protection Officer

John Keells Holdings has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

Contact details

Full name of legal entity: John Keells Holdings PLC

Name or title of DPO: Data Protection Officer

Email address:

Postal address: No. 117, Sir Chittampalam A. Gardiner Mawatha, Colombo 2, Sri Lanka.

Telephone number:

Fax number:

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications which are not maintained or controlled by JKR. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. 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.

The Data We Collect About You

Personal Data

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.

Aggregated Data

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.
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

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.
  • 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 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 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/ActivityType of dataLawful 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 experiencesTechnical UsageNecessary 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)


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.

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.
  • 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.

Data Security

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.

Data Retention

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.

Changes to this Privacy Policy

JKR will amend this Privacy Policy from time to time in accordance with applicable laws and regulations, 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. Historic versions of this Privacy Policy can be obtained by contacting us.
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 or concerns about the contents of this Privacy Policy or the way in which we use your information, we encourage you to contact us to see if we can help resolve the issue in the first instance.