(Effective Date: January 2023)
This Policy sets out:
- The types of information we may collect or that app users (“you“) may provide when you download, install, register with, access or use the AnyAds.lk mobile application software (“App“) and any of the services accessible through the App available on “anyads.lk” or other sites of ours (the “Service Sites“, and collectively with the App, “AnyAds.lk“) regarding the collection, use, storage, transfer, and protection of your personal data.
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
We will only use your personal information in accordance with this Policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.
This Policy applies only to information we collect through or in connection with AnyAds, in email, text, and other electronic communications sent through or in connection with Karrot. This Policy DOES NOT apply to information that:
- We collect offline.
- You provide to or is collected by any third party.
SCOPE AND CONSENT
Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, do not download, register with, or use the App or visit the Service Sites.
By downloading, registering with, using or visiting the App and/or the Service Sites, you indicate that you understand, accept and consent to us for the collection, use, disclosure and retention of your personal information as described in this Policy.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect information about you through:
- Direct interactions with you when you provide it to us, for example, by filling in applications or corresponding with us.
- Automated technologies or interactions, when you use the App or the Services Sites, for example, usage details, and IP addresses.
The types of information that we collect include:
- Personal information that we can reasonably use to directly or indirectly identify you, such as your telephone number, internet protocol (IP) address, username or other similar identifier, and any other identifier we may use to contact you (“personal information“).
- Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. We may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific app feature.
- Technical information, including your device type, time zone setting, and usage details.
Information You Provide to Us
When you download, register with, or use the App or access, use or visit the Service Sites, we may ask you to provide:
- Information by filling in forms in Karrot. This includes information you provide when registering to use the App and/or Service Sites, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with the App.
- Records and copies of your correspondence, including phone numbers, if you contact us.
- Your responses to surveys that we might ask you to complete for research or other purposes.
- Details of transactions you carry out through the App and/or Service Sites.
- Your search queries on Karrot.
You may also provide information (including without limitation profile images, photos, videos, or other digital content) for publication or display (“posted“) on public areas of the App and/or the Service Sites (collectively, “User Contributions“). You post and transmit User Contributions to others at your own risk. We cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we do not guarantee that unauthorized persons will not view your User Contributions.
Automatic Information Collection and Tracking Technologies
When you download, access, and use the App, it may automatically collect:
- Usage details. When you access and use the App or the Service Sites, we may automatically collect certain details of your access to and use of the App or the Service Sites, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.
- Device information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, mobile network information, and the device’s telephone number.
- Stored information and files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
- Location information. The App collects real-time information about the location of your device to determine and authenticate your location for purposes of determining your “neighbourhood” market (which is generally a maximum of a 25 KM radius surrounding your location) and the local bulletin board that you can post and transact on.
The information we collect automatically is statistical information and may include personal information. We may maintain it or associate it with personal information we collect in other ways, or that you provide to us. This usage information helps us to improve our App and to deliver a more personalized service, including by helping us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences and customize our App according to your individual interests.
- Speed up your searches.
- Recognize you when you use the App.
If you do not want us to collect this information, do not download the App or delete it from your device. For more information, see How We Use Your Information. Note, however, that opting out of the App’s collection of location information will cause its location-based features to be disabled.
Third-Party Information Collection
When you use the App or its content, certain third parties collect information about you or your device. These third parties may include:
- Other users of the App
- Analytics companies.
You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access this website to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
For more information about how you can opt out of receiving targeted advertising, see Choices About How We Use and Disclose Your Information.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
- To verify accounts and your activity.
- To provide you with the App and its contents.
- To provide you with information, products or services that you request from us.
- To fulfill the purposes for which you provided it or that were described when it was collected or any other purpose for which you provide it.
- To determine your “neighbourhood” market for purposes of the App and the Services Sites.
- To carry out our obligations and enforce our rights in any contracts with you, including for billing and collection or to comply with legal requirements.
- To notify you when App updates are available, and of changes to any products or services we offer or provide through it.
- To improve our App, products or services, or customer relationships and experiences.
- To detect and remedy violations of our terms or policies.
- To respond to user inquiries.
- To combat harmful conduct, detect and prevent fraud, suspicious activity, spam and other bad experiences
- To maintain the integrity of our App and Services Sites, and promote safety and security on and off of our App and Service Sites
- For online and offline marketing purposes.
- To allow you to participate in interactive features, social media, or other features on our App.
- To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
- For any other purpose with your consent.
Usage information that we collect helps us to improve our App and to deliver a better and more personalized experience, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our App according to your individual interests.
- Speed up your searches.
- Recognize you when you use the App.
We use location information we collect to: (i) determine your “neighbourhood” market for purposes of the App and the Services Sites; (ii) deliver content and advertisements to you in respect of such market; and (iii) to verify your identity and prevent fraud, suspicious activity, spam and other violations of our terms or policies.
We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please do not download the App or delete it from your device.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates.
- According to applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Daangn Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Daangn Inc. about our customers and users is among the assets transferred.
- To contractors, service providers, and other third parties we use to support our business, such as analytics and search engine providers that help us optimize and improve our services. We contractually require these third parties to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process personal information following the same standards set out in this policy.
- For any other purpose we disclose when you provide the information with your consent.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request, according to applicable law.
- To enforce our rights arising from any contracts between you and us, including the App terms and conditions.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Daangn Inc., its affiliates, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and credit risk reduction.
TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer personal information that we collect or that you provide us to contractors, service providers, and other third parties we use to support the App (such as analytics providers that assist us with App improvement and optimization) and who are contractually obligated to keep personal information confidential, to use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to other countries with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information. Whenever we engage a service provider, we require that its privacy and security standards comply with this policy and applicable Canadian laws.
By submitting your personal information or engaging with the App, you consent to this transfer, storage, or processing.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Location Information. In order to deliver our services, the App will collect and use real-time information about your device’s location. If you block the use of location information, the App may be inaccessible or not function properly.
- Promotional Offers from the Company. If you have opted in to receive certain emails and/or push notifications from us but no longer wish for us to use your contact information to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to email@example.com or by opting out of receiving promotional push notifications in the App. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a product purchase, warranty registration, product service experience, or other transactions. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to firstname.lastname@example.org.
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on secure servers. Any data, information and transactions will be encrypted using SSL technology and/or AES (256-bit Advanced Encryption Standard). Once we have received your information, we will use strict security features and procedures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way. We will collect and store personal data on your devices using application data caches and browser web storage (including HTML5 and other technology).
The safety and security of your information also depends on you. Where we have given you (or you have chosen) a password for access to certain parts of our App, you are responsible for keeping it confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App like message boards, which any user can view. Certain services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any App privacy settings or security measures.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize or aggregate your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.
You can review and change your personal information by logging into the App and visiting your account profile page.
If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at @dasunjanaka-djgmail-com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
- Information protected by solicitor-client privilege.
- Information that is part of a formal dispute resolution process.
- Information that is about another individual that would reveal their personal information or confidential commercial information.
- Information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at @dasunjanaka-djgmail-com.
CHILDREN UNDER THE AGE OF 16
Our App is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the App. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this App or on or through any of its features/register on the App, make any purchases through the App, use any of the interactive or public comment features of this App, or provide any information about yourself to us, including your name, address, telephone number, email address, or any user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at @dasunjanaka-djgmail-com
WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at @dasunjanaka-djgmail-com Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
Privacy officer : Dasun Janaka
Kaduwela, Sri Lanka
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information and our compliance with this policy and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.