Axiata Digital Labs (Private) Limited is a part of Axiata Group Berhad (together referred to as “ADL”, “us” or “we” or “our”). Respecting and protecting your privacy is an integral part of our business and we do not view this as an obligation, but rather as a commitment to maintain your confidence and trust. Our Privacy Position can be summarized by our below guiding Privacy and Data Protection principles:
TRANSPARENT: We are TRANSPARENT about what, why and how we collect and protect YOUR PERSONAL DATA so that YOU can make informed decisions.
RIGHTS: We respect YOUR RIGHTS as individuals, so YOU are in control of YOUR PERSONAL DATA.
USE: We USE YOUR PERSONAL DATA for specific and stated purposes and keep it for as long as required only.
SECURITY: We have established robust CYBER SECURITY PRACTICES in line with leading industry standards to protect YOUR PERSONAL DATA that YOU have shared with us.
TRANSFER: We take due care when TRANSFERRING YOUR PERSONAL DATA to third parties such as vendors, contractors, business partners and government authorities.
This notice applies to personal data that we collect, generate or use when you subscribe to any of our products and services, use our applications or visit any of our websites. We advise you to read this notice alongside Terms and Conditions of our products/ services as they may contain product/service specific information on how we process your personal data.
This privacy notice applies to:
- All the services offered by Axiata
- Existing, past as well as potential customers/clients
Information we collect and use
. This notice explains how we collect and use your personal data when:
- You use our network, products or services (including call centers)
- You contact us with a question about our products and services
- You use our applications or visit any of websites
- You contact us for any other purpose(s).
The types of personal information that ADL may collect for the performance of our services to you include, but are not limited to:
- Contact information (such as name, address, email address and telephone number)
- Identification information (such as passport identification number, tax registration number or social security number, driver’s license, date of birth)
- Demographic information (such as age range, marital status, gender)
- Photographs, such as those that you may submit for contests or prize-winning competitions
- Product specific information (such as preference, closed user groups (CUGs), friends and family who you chose to include in your service plan, credit limit)
- Banking information (such as direct debit and related bill payment banking transactions)
- Service account information (such as call usage, account balances, transaction history, credit information, billing, loyalty points).
ADL collects and uses your personal information with your knowledge and consent and typically when you:
- Use ADL’s wide range of products and services that are offered or for which you may choose to opt-in
- Make customer enquiries, register for information or other services
- Respond to communications from us (such as SMS, emails, questionnaires or surveys)
- Interact with ADL’s websites, such as submitting an application form, completing survey form, use online services. (If your browser has Internet cookies enabled, it can facilitate ADL’s tracking of personal preferences, pages visited etc.)
- Participate on ADL’s social media pages, such as Facebook
- Participate in ADL’s promotional events, incentive or loyalty programs
- Provide information through ADL’s customer call centers, dealers and sales channels or any other affiliates or business dealings with ADL by which you have consented to provide your personal information.
Your personal data may be collected, used or otherwise processed by us for, amongst others, for the following purposes:
- To provide you with our products, services, latest offers and promotions (where you subscribe to such updates)
- which may be of interest to you
- To notify you about benefits and changes to the features of our products and services
- To conduct research for analytical purposes
- To publish your information (which may include your name, profile picture and such other relevant personal data) on our website, social media and our printing materials
- To inform you of any upcoming event and updates
- To inform you of any upcoming event and updates;
- To use your information for participation in our events or award;
- To use your information for e-commerce
- For your participation in contest
- To send you service messages about our subscription or account registration
- To use your information for participation in our customer surveys or meetings
- Enable us to send you information by e-mail, telecommunication means (telephone calls or text messages) or social media about products and services offered by selected third parties that we think may interest you
The above shall hereinafter be referred to as the “Purposes”.
Information about Children
If you are under the age of 18, you are required to obtain the consent of your parents or legal guardian before using our network, products and/or services.
Effects arising from failure to provide Personal Data
You will be able to access our website without providing your personal data. However, where any activity/services on our website/weblink requires us to collect certain personal data about you, failure to provide such information may:
- Result in us being unable to respond to your requests on our products/services
- Limit and/or prevent access to certain features on our website/weblinks
- Result in us being unable to update you on latest updates regarding any promotions, our services/products or launches
- Result in your inability to receive invitation to promotional activities organized by us.
Data Retention and Storage
Your personal data that has been collected and processed shall be retained for as long as required to meet the purposes mentioned above. We may store your personal data to provide the services you have requested, or for other essential purposes, such as complying with our legal obligations, resolving disputes, and enforcing our policies. The retention period for storage of personal data is based on the requirements of applicable laws. However, in the absence of any relevant laws, personal data will be stored where it is required for business purposes.
This personal data may be stored in:
- Hard copy, or
- Electronic format
We may keep your data in data centers or warehouses that are managed either by us or by service providers on our behalf. All our facilities, systems and products have been equipped with required security controls to ensure protection of personal data.
We endeavor to process your information in a safe environment by preventing any unauthorized or unlawful processing of personal data or accidental loss or destruction of, or damage to such information. We have implemented various physical, technical and administrative security measures to protect your personal data and our network from unauthorized access. These measures include:
We keep your personal data confidential and do not share it with non-affiliated companies, except: (a) to provide products or services you have requested, (b) when we have your consent or (c) under the following circumstances:
- When we have to meet our legal obligations and to prevent and detect crime as per the law. We will share your personal data with any person to whom we are compelled or required to do so under law or in response to a competent regulatory or government agency and industry regulators
- When we believe it necessary to share the personal data or enforce ADL’s rights, usage terms, intellectual or physical property or for safety of ADL or associated parties
- We may share your information if ADL is acquired by or merged with another company or for any legal claim, where ADL is required to do so
- We may share your personal data with our auditors, consultants, accountants, insurers or other financial and/or professional advisers
- When any other person reasonably requires your personal data in order for us to operate and maintain our business or carry out the activities set out in the Purposes.
We make sure that our service providers and agents maintain the confidentiality of your personal data and are restricted from using such information for any unauthorized purpose. ADL will ensure through formally executed contracts that the service providers are committed to “same level of protection to your information”, as per the applicable data protection laws and regulations.
Communication Preferences and Choices
ADL takes reasonable steps to keep your personal data accurate, complete and up to date. You still may stop the delivery of promotional e-mail or other ADL communications by contacting us on the below mentioned contact details. These choices do not apply to the receipt of mandatory product or service communications that are considered part of certain ADL products or services, which you may receive periodically, unless you cancel the product or service.
Furthermore, ADL does not require that you provide us with personal information. The decision to provide personal information is voluntary. However, if you do not wish to provide the personal information requested, you may not be able to proceed with the activity or receive the benefit for which the personal information is being requested.
Cross Border Data Transfer
With your consent, we may transfer your personal data across geographical borders to other entities, provided they ensure the same level of protection as us. The transfer of personal data is carried out under our standard contracts with appropriate data protection clauses or data transfer agreements with similar rights and obligations for the parties receiving this information to protect the security and confidentiality of your personal data.
ADL does not sell, trade, transfer or otherwise share your personal information, except in the following instances:
- With Axiata group companies, where necessary and within the limits of applicable law
- As required by law, such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution or similar legal process
- With other carriers and operators when routing international calls
- When we believe in good faith that disclosure is necessary to protect our rights, protect your security, investigate fraud or respond to a law enforcement request
- With ADL’s service providers, field engineers, contractors who work on our behalf and who do not have an independent right to use the information to which they have access or that we disclose to them
- With our business partners for ADL’s marketing activities, in such case no specific personally identifiable information is provided, as such information is generally aggregated
- With third parties for research and development purposes
- With our subsidiaries and affiliates, such as ADL dealers.
Third parties must in all cases agree to a strict duty to keep all personal information confidential and to use it only for the purpose for which it was obtained.
Exercise Your Rights
We respect your rights and privacy and we manifest our stand by taking steps to ensure that your personal data is accurate and up-to-date. As our obligation under the Personal Data Protection Act, 2010 we assure you that:
- You have the right to know what personal data we have about you
- You have the right to request a copy of your personal data
- You have the right to correct your personal data, in case it is incorrect or incomplete
- You have the right to withdraw your consent from our processing of your personal data
- You can also ask us to restrict how we use your personal data where it is likely to cause damage or distress
- You have the right to prevent processing of your personal data where it is so conducted or is going to be conducted for purposes of direct marketing.
For exercising your rights, you can reach out to us through the details under Contact Us section given below.
By submitting your personal data to us, you acknowledge that:
- You have read and understood this Privacy Notice and agree to the use of your personal data as set out herein
- Your personal data may be transferred and processed worldwide, including countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice
- All your representations are true and correct to the best of your knowledge, and you have not knowingly omitted any related information of adverse nature.
If you have any questions or complaints about this notice, our privacy and information handling practices, you can contact us at
Address: Parkland Building, 33 Park Street, Level 11, Colombo, Western Province 00200, Sri Lanka
E-mail ID: firstname.lastname@example.org
Phone Number: +94 76 676 6300
Contact Details of our Data Privacy office are as follows: email@example.com
In cases of any suspected/actual violation of your privacy, in relation to your information that we process or store, you can lodge a complaint with the relevant regulatory authority or any other tribunal/court of competent jurisdiction.
Updates to the Privacy Notice
ADL reserves the right to update this privacy notice, as and when need arises. This notice shall prevail over any of its previous versions. We highly recommend that you check back here from time to time to stay informed of any changes.
This notice was published on 30th of March 2020 and last updated on 15th May 2020.