Effective date: 18 February 2020
Dialog Axiata PLC (“Dialog”, “we”, “us”), a company incorporated under the laws of the Democratic Socialist Republic of Sri Lanka, bearing company registration number PQ 38, and having its registered office at 475, Union Place, Colombo 2, owns and operates Nenasa (“App”).
The App allow users to access the content available on the Ministry of Education learning portal ‘e- Thaksalawa’ on an on-demand basis.
1. CHILDREN’S PRIVACY
The App does not process or collect personal data of children. Personal data is data that will allow us to identify your child. We may require your child’s/your personal data to be entered for purposes of creating your account, however this data will be irreversibly anonymised in such a way that neither Dialog nor any of our third-party service providers will be able to view or collect that personal information in its original form.
The only exception to the above is in relation to your mobile phone number which will be processed by us in an encrypted form in order for us to provide you with the services via the App.
If you are a parent or guardian and you are aware that your child/children have provided us with personal data without your consent, please contact us at email@example.com. If we become aware that we have collected personal data from children without parental consent, we will take steps to remove that personal data from our servers.
2. DATA ABOUT YOU THAT WE COLLECT
We collect your data in order to provide and improve, where appropriate, our services offered through the App to you.
The information we collect about you includes the following;
- Your mobile phone number;
- Your date of birth;
- Your gender;
- Your school;
- The district of your school;
- Your current grade; and
- The medium of language you study in.
When you use the App, it may use technology to automatically collect;
- Usage details- This includes traffic data, logs and other communication data and the resources that you access and use on or through the App.
3. USE AND DISCLOSURE OF YOUR DATA
We may use your data for the following purposes:
- To provide the functionality of the App and its services and related support. We engage in this activity to manage our contractual relationship with you and/or to comply with legal obligations.
- To create and administer accounts, and provide you with related assistance (e.g., technical help, answer inquiries, etc.).
- Tocarryoutobligationsandenforceourrightsarisingfromanycontractsenteredinto between you and us.
- To send administrative information to you, for example, information regarding our services and changes to our terms, conditions, and policies.
- To provide you with personalised content.
- To accomplish our business purposes. We engage in this activity where we have a legitimate interest to do so or to comply with a legal obligation.
- To protect and defend the rights or property of Dialog.
- To prevent or investigate possible wrongdoing in connection with the App.
- To verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
- To protect the personal safety of users of the App or the public.
- To protect against legal liability.
- Torespondtolegalduties,suchasrequestsfromtheregulatoryandlawenforcement authorities.
- To improve the design of our App and services. We engage in this activity because we have a legitimate interest to do so.
- Wemayrecordanonymous/aggregatedinformation(suchasthetime,dateandURL of the request) of you accessing the App. This information shall be used by us to improve the user experience of the App and monitor performance of the App. Such analysis of these anonymous/aggregated information may be conducted by us or our authorised third-party representatives.
- We may use your data to carry out research and product analysis.
We may disclose your data for the following purposes:
- To our service partners and third-party service providers.
- To the Ministry of Education.
- To business partners in the context of a corporate transaction.
- 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 data to a third party in the event of any reorganisation, 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 regulatory and law enforcement agencies.
4. LENGTH OF TIME THAT WE KEEP YOUR DATA
The duration of data storage shall be for as long as it is necessary or permitted in relation to providing services to you and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide you our services (for example, for as long as you have an App account with us or keep using our services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your usage for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or law enforcement investigations).
5. TRANSFER OF YOUR DATA
Your data may be transferred to, and maintained on, computers maintained by third party service providers that provide a storage service.
6. YOUR CHOICES REGARDING YOUR PERSONAL DATA
You may request the exercise of the rights set forth by sending us an email at firstname.lastname@example.org.
The right to withdraw consent – You have the right to withdraw consent given for us to process your personal data at any time, under certain conditions.
The right to object to processing – You have the right to object to further processing of your personal data, under certain conditions.
The right to access – You have the right to access your personal data that is processed by us, under certain conditions.
The right to rectification – You have the right to request that we correct personal data that you believe is inaccurate. You also have the right to request us to complete the personal data that you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right in relation to automated decision making – You have the right to request us to review a decision of ours based solely on automated processing, which affects your rights and freedoms.
Please note that we may need to retain certain personal data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. Also, in some of the above situations, where you withdraw consent or request erasure for example, you will no longer be able to take advantage of services which require such personal data.
We will not advertise or market any products or services to you via the App.
8. APP SECURITY
We work to protect the security of your data during transmission by using appropriate encryption methods. The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security.
10. METHODS OF CONTACTING US
- By email: email@example.com
- By visiting our website: https://www.dialog.lk/nenasa-app
- By phone number: +94 777 678 678