Lanka Marine Services (Pvt) Ltd (“LMS”, “we” “our” and “us”) is a company registered in Sri Lanka with the company registration number PV 475 and our registered office is at No. 117, Sir Chittampalam A. Gardiner Mawatha, Colombo 02, 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.
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.
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, including any data you may provide when you apply for a career at LMS. 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
LMS 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 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: Lanka Marine Services (Pvt) Ltd
Designation: Data Protection Officer
Postal address: No. 117, Sir Chittampalam A. Gardiner Mawatha, Colombo 02, Sri Lanka.
Email address: Thejana.trp@keells.com
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 providing products and 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.
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.
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: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 LMS 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 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.
| 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:
|
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 re-organization or group restructuring exercise) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Usage Marketing and Communications Technical | Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy) |
| 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) |
| To make suggestions and recommendations to you about services that may be of interest to you | Technical Usage | Necessary for our legitimate interests (to develop our services and grow our business) |
Cookies
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.
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, associates of the Company, outstation branches and offices based in Sri Lanka and other countries who are acting as joint controllers or processors.
External Third Parties
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 are part of the John Keells Group that is one of Sri Lanka’s largest conglomerates listed in the Colombo Stock Exchange, and we operate in many different jurisdictions hence, accordingly, it may be necessary to transfer your data outside Sri Lanka.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized 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.
Please bear in mind that we cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.
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 unauthorized 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 may ask us to delete your data.
In some circumstances we may anonymize 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 this information indefinitely without further notice to you.
Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:
If you wish to exercise any of the rights set out above, please reach out to us on the contact information provided above.
No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, unreasonable, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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 will use all best endeavours to respond to all legitimate requests within twenty-one days. Occasionally, it may take us longer if your request is particularly complex or you have made a number of requests. We will keep you updated in such case.
We may use CCTV across our premises to ensure the safety of all our customers, patrons, employees and business partners. In particular, we may use CCTV footage to monitor the behaviour of all persons within our premises and where relevant to aid investigations into potential or actual criminal, fraudulent incidents or other incidents of a related nature. We may share such footage with law enforcement authorities and/or the courts of law, as relevant to assist with investigations or any court action.
We may amend this Privacy Policy from time to time in accordance with applicable laws, regulations, best practices and John Keells Group policy 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.
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, concerns or complaints about the contents of this Privacy Policy or the way in which we use your information, we encourage you to contact us by using the information provided above in this regard.