1. Introduction
ohn Keells Foundation (“JKF”, “we” “our” and “us”) is a formal charity duly incorporated under the laws of Sri Lanka and registered under Voluntary Social Service Organizations (Registration & Supervision) Act No, 31 of 1980 (as amended) 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.
2. Definitions
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.
3. 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 our website.. 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
JKF is the Data Controller of all Personal Data relating to our artists, benefactors, employees and third-party individual contacts, as well as any other Personal Data used in our service for our own promotional 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 Foundation
Designation: Head of Corporate Social Responsibility
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 displaying or purchasing art and related 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.
4. The Data We Collect
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.
5. How is Your Personal Data Collected?
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.
6. 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 JKF in conducting and managing our service 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.
