Telecard (Private) Limited (“Telecard”, “we”, “us”), a fully owned subsidiary of Dialog Broadband Networks (Private) Limited, which in turn is a fully owned subsidiary of Dialog Axiata PLC and incorporated under the laws of the Democratic Socialist Republic of Sri Lanka, bearing company registration number PV 21669, having its registered office at 475, Union Place, Colombo 2, owns and operates FinPal (“App”).

The App offers the below Services:

  • Applying for an EZ Loan and any other loan facilities introduced by Telecard from time to time;
  • Viewing your current loan agreement;
  • Requesting a new loan ("re-loan" request);
  • Executing a new loan agreement;
  • Viewing your current loan status;
  • Viewing your loan history;
  • Viewing your current payment schedule;
  • Viewing your transaction history; and
  • Viewing your Profile.

This Privacy Policy seeks to provide you with information regarding the manner in which we use the data collected about you (i.e., personal data) in connection with your use of the App and to inform you of the rights you enjoy as a user of the App.

1. PERSONAL DATA ABOUT YOU THAT WE COLLECT

We collect your personal data in order to provide and improve, where appropriate, our services offered through the App to you.

The information we collect about you includes the following;

  • Your name, postal and physical address, phone number and email address;
  • Your National Identity Card or Passport Number;
  • Your Personal Identity Number (PIN);
  • Your credit and debit information which includes your bank account number, your eZ Cash transactions and other financial information;
  • Your contact with us which includes messages, correspondences and call recordings when you make a call to our centre;
  • Your account information on the App;
  • Location of your mobile phone from time to time;
  • Details of your eZ Cash transactions;
  • Your salary range;
  • Your search queries on the App; and
  • Your responses to our online surveys.

In addition to the above when you use the App, it may use technology to automatically collect;

  • Usage details- This includes traffic data, location data, logs and other communication data and the resources that you access and use on or through the App.
  • Device information- This is information about your internet connection including the unique device identifier, IP address, operating system, browser type and your device’s telephone number, if access is through a mobile device.
  • Location information- The site may collect real-time information about your location.
  • Behavioural tracking- The site may collect information about your activities over time and across third party websites or other online services.

2. USE AND DISCLOSURE OF YOUR PERSONAL DATA

Telecard may use your personal data for the following purposes:

  • To provide the functionality of the App and its services and related support. We engage in this activity to manage our contractual relationship with you and/or to comply with legal obligations.
    • To create and administer accounts, fulfil and record transactions, and provide you with related assistance (e.g., technical help, answer inquiries, etc.).
    • To carry out obligations and enforce our rights arising from any contracts entered into between you and us.
    • To send administrative information to you, for example, information regarding our services and changes to our terms, conditions, and policies.
    • You shall be required to provide us with standard information such as your Login ID, Password, and Personal Information for verification purposes when accessing the App, to make available the Services requested by you. It shall be your sole responsibility to maintain the confidentiality of your Login ID and Password.
  • To provide you with marketing and promotional materials and opportunities.
    • To send you marketing communications and offer other materials that we believe may be of interest to you, such as to send you newsletters or other direct marketing communications. We engage in this activity where you have consented.
    • To allow you to participate in interactive features on the App. We engage in this activity to manage our contractual relationship with you.
  • To accomplish our business purposes. We engage in this activity where we have a legitimate interest to do so or to comply with a legal obligation.
    • To protect and defend the rights or property of Telecard.
    • To prevent or investigate possible wrongdoing in connection with the App.
    • To verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
    • To protect the personal safety of users of the App or the public.
    • To protect against legal liability.
    • To respond to legal duties, such as requests from the public and law enforcement authorities.
    • To carry out activities connected with the running of our business such as personal training, network monitoring, testing and maintenance of our systems etc.
  • To improve the design of our App and services. We engage in this activity because we have a legitimate interest to do so.
    • We may record anonymous/aggregated information (such as the time, date and URL of the request) of you accessing the App. This information shall be used by us to improve the user experience of our websites and monitor performance of these websites. Such analysis of these anonymous/aggregated information may be conducted by us or our authorised third-party representative.
    • We may use your data to carry out research, market and product analysis.

We may disclose your personal data:

  • To our parent company, subsidiary and affiliates for the purposes described in this Privacy Policy.
  • To our service partners and third-party service providers;
    • Including those who provide services such as our agents or contractors, merchants, banks, Credit Reference Bureau and our dealers.
    • To permit them to send you marketing communications, consistent with your choices.
  • To business partners in the context of a corporate transaction.
    • If we are involved in a sale or business transaction (e.g., merger or acquisition), we will retain a legitimate interest in disclosing or transferring your personal data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring or target entity and its advisors.
  • For the purposes of fraud prevention and to business scoring agencies.
  • To data collection agencies.
  • When requested for by regulatory and law enforcement agencies.

3. LENGTH OF TIME THAT TELECARD KEEPS YOUR PERSONAL DATA

The duration of personal data storage shall be for as long as it is necessary or permitted in relation to providing services to you and consistent with applicable law. The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide you our services (for example, for as long as you have an App account with us or keep using our services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position such as in regard to applicable statutes of limitations, litigation or law enforcement investigations).

4. TRANSFER OF YOUR PERSONAL DATA

Your personal data may be transferred to, and maintained on, computers maintained by third party service providers that provide a storage service.

5. INTEREST-BASED ADVERTISING

We use remarketing as well as Interest-based advertising with third party analytic tools. These third parties may display our advertisements on websites across the Internet. You may configure and personalize your current browser/client application to refuse, reject or delete the collection of information for Interest Based Advertising.

6. COOKIES

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from the App and stored on your computer’s hard drive.

We may use Cookies to collect such information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.

We may also use persistent cookies to record details such as a unique user identity and general registration details on your PC. This helps us recognize you on subsequent visits to the App so that you don’t have to re-enter your registration details each time you visit our website us and allows us to carry out the activities mentioned above.

7. YOUR CHOICES REGARDING YOUR PERSONAL DATA

You may request the exercise of the rights set forth by sending us an email at services@finpal.lk.

The right to withdraw consent – You have the right to withdraw consent at any time, under certain conditions.

The right to object to processing – You have the right to object to Telecard’s further processing of your personal data, under certain conditions.

The right to access – You have the right to access your personal data that is processed by Telecard, under certain conditions.

The right to rectification – You have the right to request that Telecard correct personal data that you believe is inaccurate. You also have the right to request Telecard to complete the personal data that you believe is incomplete.

The right to erasure – You have the right to request that Telecard erase your personal data, under certain conditions.

The right in relation to automated decision making – You have the right to request Telecard to review a decision of ours based solely on automated processing, which affects your rights and freedoms.

Please note that we may need to retain certain personal data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

Also, in some of the above situations, where you withdraw consent or request erasure for example, you will no longer be able to take advantage of services which require such personal data.

8. MARKETING

Telecard would like to send you information about our products and services that we think you might like, as well as those of our service partners and partner companies that we think you might like based on the information you have provided us with and your usage of the App. If you have agreed to receive such marketing, you can always opt out at a later date using the options available in the App Settings and/or in relevant marketing communications where appropriate.

9. CHILDREN’S PRIVACY

Our service does not address anyone under the age of 18. We do not knowingly collect personal data from anyone under the age of 18. If you are a parent or guardian and you are aware that your child/children have provided us with personal data, please contact us at services@finpal.lk. If we become aware that we have collected personal data from children without verification of parental consent, we will take steps to remove that personal data from our servers.

10. APP SECURITY

We work to protect the security of your data during transmission by using appropriate encryption methods. The security of your personal data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

11. CHANGES TO THE PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you prior to any changes becoming effective and update the "effective date" and “version” at the top of this Privacy Policy. By continuing to access of use the App after those changes have become effective, you agree to be bound by the revised Privacy Policy

12. METHODS OF CONTACTING US

If you have any questions about this Privacy Policy, please contact us: