Introduction

Sri Lanka Telecom PLC (herein after referred to as SLT) has a firm commitment to safeguard privacy of users accessing SLT Smart Home Platform. This Privacy Policy for SLT Smart Home Platform (hereinafter referred to as the ‘Policy’) sets out SLT’s commitment to privacy of the users of the Platform.

This Policy is applicable for the subscribers (hereinafter referred to as the ‘Users’) who have registered for the SLT Smart Home Product (hereinafter referred to as the ‘Product’) who intends to register for the SLT Smart Home product and access/monitor/control their smart home appliances/sensors/CCTV devises remotely through the Mobile App or Webpage which shall serve as an interphase for such access/monitor/control (hereinafter referred to as the ‘Platform’)  

The Users understand that the User’s personal data shall be entered in to the SLT system by the Users during the process of registering the User for the Product. As such Users shall be solely responsible for any submission/entry of inaccurate or incomplete data.

Users, having read and having satisfied themselves of the Policy hereinafter recited consents to register for the Product and continue to use or access the Portal and such continued access shall mean User’s consent to the collection, storing, processing and analyzing of the User’s data. Process shall mean and include but not be limited to collect, store, preserve, alter, retrieve, disclose, transmit, align, combine or carry out logical or arithmetic operations. In the event the User is not satisfied with the privacy commitment under this Policy, they shall refrain from registering for the Product.   

Data collected 

Users understand that it is essential for SLT to collect personal data for the purpose of provisioning of services/the Product to the Users via this Platform. Users shall not provide any personal data belonging/relating to another person. 

SLT may collect Personal Data inter alia registration information, profile information, device/sensor alerts, alarms & other related information, CCTV recordings/footages, information on communications with SLT, information published on the Platform covering but not limited to title, name, gender, date of birth, email address, telephone number, mobile number, fax number, customer address, device/appliance location, device/appliance address, photos, audio visual recordings, media, IP address payment details, payment card details, purchase selections or bank account details of the User (hereinafter referred to as ‘Personal Dat

Data usage 

SLT will utilize Personal Data to provide the Product to the Users and/or to enable the Users access, monitor and control their smart home appliances/sensors remotely and watch live recordings of the CCTV camara operations. Further such Personal Data may be used by SLT for analyzing, authentication, research and development to improve the Product, to comply with laws/law enforcing authorities/court orders/local authorities/regulatory bodies and to make copies (Primary Purpose). 
    
SLT may send useful information to the Users, provided that Users have marked “I Agree to Receive Messages” Tick box displayed on Portal for the purpose of being contacted. This would indicate the User’s free, specific, informed and unambiguous consent. Subject to obtaining User consent, SLT may contact Users via email, SMS or any other consented means with details of other products and services offered through this Portal for the purposes of marketing, advertising and promoting of other products and services and/or other than those delivered under this Portal (Secondary Purpose). In the event the Users do not wish to receive any unsolicited marketing communications from SLT, they can opt out from such communications at any time by clicking unsubscribe link in the emails or the SMS or though the through the Platform.

Information shared with third parties
Users understand that, in general, the third-party providers on the Portal engaged by SLT for service provisioning and maintenance including but not limited to suppliers, partners or developers of the Product will only collect, use and disclose Personal Data only for the Primary Purpose under this Policy. 

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect of the purchase-related transactions. 

Further, SLT may share such information as required by to comply with laws/legal requirements/law enforcing authorities’/court orders/requests of local authorities, regulatory bodies, under dispute resolution mechanisms and in case of change of control and permitted recipients.

Unless the same is required for achieving of the Primary Purpose or by Law or Regulations, SLT shall NOT sell or disclose User Data to third parties without obtaining prior consent of the User.

Retention of data
Users shall understand that SLT shall retain Personal Data up to the period the same is necessary for the purpose/s they are being processed. However, the Users shall understand that SLT may store and retain Personal Data for archiving purposes obligatory/entitled under the law. Further, SLT shall be obliged/entitled to retain Personal Data without erasure or further processing in the event the same is required for evidentiary purposes or retention purposes under a written law or for a criminal investigation or judicial proceeding. 

Security of data
Personal Data will be treated as confidential and be protected from unauthorized disclosure or modification through reasonable physical, administrative and technical safeguards.

It should be noted that, Users are solely responsible for the protecting their passwords and their devices against unauthorized access. 

Users can typically end the signed in session by either signing out and/or clearing the cookies. When using a public or shared computer, User shall sign out and/or clear cookies in order to protect their account and personal User Data.

User shall be solely responsible for password protection, proper sign-out and such other acts of securing their data and keep SLT indemnified of repercussions of failure to do so.

Consent of the User
Users understand that registration and the continued use of the Product through the Platform amounts to granting of the consent for the use of Personal Data for achieving of the Primary Purpose as detailed under this Policy.

Any use of the Personal Data by SLT for a Secondary Purpose as defined herein will be made with the consent of the User. For avoidance of doubt, the User understands that, once the consent is given, SLT may, from time to time, send pop-ups, alerts and messages to the User of any new product or service available with SLT without further consent of the User.

Rights of SLT
SLT may with the consent of the User, use the Persona Data collected or processed for any Secondary Purpose other than the purpose of delivering Product under the Portal.

SLT may refuse to collect additional data, which are not required for purpose of delivering of services/Product under the Platform or refuse to make any changes to the collected data unless legitimate proof is provided in the process of rectifying inaccurate or incomplete Personal Data of the Users.

SLT shall be entitled to retain Personal Data without erasure or further processing in the event the same is required for evidentiary purposes or retention purposes under a written law or for a criminal investigation or judicial proceeding.

SLT shall have the right to grant or refuse any request by the User for rectification, completion, erasure or refraining from further processing due to technical and operational feasibility of SLT to act on such request amongst any other reasons made available under any written law. However, SLT shall inform the User of such decision of SLT. 
SLT reserves the right to impose any fees for grant of any requests made by the Users.

Using Data for secondary purpose
In the event the Users have given their consent, by ticking to the “I Agree to Receive the Messages” box, SLT may use any telecommunication services, electronic or any other similar means for the purpose of disseminating messages in writing, electronically, orally, in pictorial or video forms for any Secondary Purpose. Any such message will be considered a solicited message for direct marketing to promote goods or services or to promote any person, entity or organization. Each time a solicited message is sent by SLT via the Portal for any Secondary Purpose, the User will be given the option of opting-out of receiving solicited messages. 

Exceptions to this Policy
The laws of the Democratic Socialist Republic of Sri Lanka will supersede over this Policy.

This Policy shall not be applicable in the event a User is redirected to another website/portal or a frame of another site or application which may have a link to Portal. SLT shall not be responsible for the privacy practices or content of those third parties or other sites and SLT encourage Users to read the privacy policies of such third parties or sites. 

Changes to this Privacy Policy
SLT may update this Policy from time to time in response to changes in legal, technical or business environment. Changes to this Policy will take effect immediately upon its posting on the Website/platform. User can check the latest update by checking the “last updated date and time” displayed at the bottom of this Privacy Policy.

Last updated on: 21.02.2023