Privacy Policy
1. Introduction
1.1 We are committed to safeguarding the privacy of
our customers, website visitors and software users.
1.2 This policy applies where we are acting as a data
controller with respect to the personal data of our customers, website visitors
and software users; in other words, where we determine the purposes and means
of the processing of that personal data.
1.3 We may deploy Google AdSense/Admob advertising in
some/all of our software where it may use an anonymous identifier, a random
string or a character that is used for the same purpose as cookie on platforms
including certain mobile devices, where cookie technology is not available. AdSense/Admob
is advertising service provided by Google Inc. through which third parties may
be using cookies, web beacons, and other technologies to collect information
and usage as a result of ad serving. If you are in European Union, we will ask
you to consent to our use of Ad technology providers when you first use our software.
1.4 Our software incorporates privacy controls which
affect how we will process your personal data. By using the privacy controls,
you can specify whether you would like to receive relevant advertising and
limit the publication of your information.
1.5 In this policy, "we", "us" and
"our" refer to Innovemind Pvt Ltd. For more information about
us, see Section 13.
2. Credit
2.1 This document was created using a template from
SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we
may process;
(b) in the case of personal data that we did not
obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal
data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website,
software and services ("usage data"). The usage data may
include your IP address, geographical location, device type, operating system
and version, referral source, length of visit, page views and navigation paths,
as well as information about the timing, frequency and pattern of your service
use. The sources of the usage data are Apple iTunes, Galaxy Store, Huawei Store,
Google Analytics, Google Play or Google Admob.
This usage data may be processed for the purposes of analysing the use of the website,
software and services. The legal basis for this processing is consent OR our
legitimate interests, namely monitoring and improving our website, software and
services.
3.3 We may process your account data ("account
data"). The account data may include your name, telehpone number or email address. The
source of the account data is you or your employer. The account data may be
processed for the purposes of operating our website, software, providing our
services, ensuring the security of our website, software and services,
maintaining back-ups of our databases and communicating with you. The legal
basis for this processing is consent OR our legitimate interests, namely the
proper administration of our website, software and business OR the performance
of a contract between you and us and/or taking steps, at your request, to enter
into such a contract.
3.4 We may process your information included in your
personal profile on our website, software ("profile data").
The profile data may include your name, address, telephone number, email
address, profile pictures, vehicle details, location and employment details.
The profile data may be processed for the purposes of enabling and monitoring
your use of our website, software and services. The legal basis for this
processing is consent OR our legitimate interests, namely the proper
administration of our website, software and business OR the performance of a
contract between you and us and/or taking steps, at you request, to enter into
such a contract.
3.5 We may process your personal data that are
provided in the course of the use of our services ("service data").
The service data may include details of services you have requested or we
have provided. The source of the service data is you or your employer. The
service data may be processed for the purposes of operating our website, software,
providing our services, ensuring the security of our website and services,
maintaining back-ups of our databases and communicating with you. The legal
basis for this processing is consent OR our legitimate interests, namely the
proper administration of our website, software and business OR the performance
of a contract between you and us and/or taking steps, at your request, to enter
into such a contract.
3.6 We may process information that you post for
publication on our website, software or through our services ("publication
data"). The publication data may be processed for the purposes of
enabling such publication and administering our website, software and services.
The legal basis for this processing is consent OR our legitimate interests,
namely the proper administration of our website, software and business OR the
performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract.
3.7 We may process information contained in any
enquiry you submit to us regarding goods and/or services ("enquiry data").
The enquiry data may be processed for the purposes of offering, marketing and
selling relevant goods and/or services to you. The legal basis for this
processing is consent.
3.8 We may process information relating to our
customer relationships, including customer contact information ("customer
relationship data"). The customer relationship data may include your
name, your employer, your job title or role, your contact details, and
information contained in communications between us and you or your employer.
The source of the customer relationship data is you or your employer. The customer
relationship data may be processed for the purposes of managing our
relationships with customers, communicating with customers, keeping records of
those communications and promoting our products and services to customers. The
legal basis for this processing is consent OR our legitimate interests, namely
the proper management of our customer relationships.
3.9 We may process information relating to
transactions, including purchases of goods and services, that you enter into
with us and/or through our website or software ("transaction data").
The transaction data may include your contact details, your card details and
the transaction details. The transaction data may be processed for the purpose
of supplying the purchased goods and services and keeping proper records of
those transactions. The legal basis for this processing is the performance of a
contract between you and us and/or taking steps, at your request, to enter into
such a contract and our legitimate interests, namely the proper administration
of our software, website and business.
3.10 We may process information that you provide to us
for the purpose of subscribing to our notifications and/or newsletters ("notification
data"). The notification data may be processed for the purposes of
sending you the relevant notifications and/or newsletters. The legal basis for
this processing is consent OR the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract OR.
3.11 We may process information contained in or relating
to any communication that you send to us ("correspondence data").
The correspondence data may include the communication content and metadata
associated with the communication. Our software, website will generate the
metadata associated with communications made using the website contact forms.
The correspondence data may be processed for the purposes of communicating with
you and record-keeping. The legal basis for this processing is our legitimate
interests, namely the proper administration of our software, website and
business and communications with users.
3.13 We may process any of your personal data identified
in this policy where necessary for the establishment, exercise or defence of
legal claims, whether in court proceedings or in an administrative or
out-of-court procedure. The legal basis for this processing is our legitimate
interests, namely the protection and assertion of our legal rights, your legal
rights and the legal rights of others.
3.14 We may process any of your personal data identified
in this policy where necessary for the purposes of obtaining or maintaining
insurance coverage, managing risks, or obtaining professional advice. The legal
basis for this processing is our legitimate interests, namely the proper protection
of our business against risks.
3.15 In addition to the specific purposes for which we
may process your personal data set out in this Section 3, we may also process
any of your personal data where such processing is necessary for compliance
with a legal obligation to which we are subject, or in order to protect your
vital interests or the vital interests of another natural person.
3.16 Please do not supply any other person's personal
data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member
of our group of companies (this means our subsidiaries, our ultimate holding
company and all its subsidiaries) insofar as reasonably necessary for the
purposes, and on the legal bases, set out in this policy. Information about our
group of companies can be found at www.taximet.com.
4.2 We may disclose your personal data to our insurers
and/or professional advisers insofar as reasonably necessary for the purposes
of obtaining or maintaining insurance coverage, managing risks, obtaining
professional advice, or the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose your personal data to our suppliers
or subcontractors identified at https://apps.admob.com,
https://firebase.google.com, https://squareup.com insofar as reasonably
necessary for the proper administration of our software, website and
business.
4.4 Financial transactions relating to our website,
software and services are handled by our payment services providers, Apple, Google,
Square. We will share transaction data with our payment services providers
only to the extent necessary for the purposes of processing your payments,
refunding such payments and dealing with complaints and queries relating to
such payments and refunds. You can find information about the payment services
providers' privacy policies and practices at https://www.apple.com/au/apple-pay/, https://pay.google.com/about/, https://squareup.com/us/en/point-of-sale.
4.5 We may disclose your profile data to one or more
of those selected third party suppliers of goods and services identified on our
website, software for the purpose of enabling them to contact you so that they
can offer, market and sell to you relevant goods and/or services. Each such
third party will act as a data controller in relation to the enquiry data that
we supply to it; and upon contacting you, each such third party will supply to
you a copy of its own privacy policy, which will govern that third party's use
of your personal data.
4.6 In addition to the specific disclosures of
personal data set out in this Section 4, we may disclose your personal data
where such disclosure is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital
interests of another natural person. We may also disclose your personal data
where such disclosure is necessary for the establishment, exercise or defence
of legal claims, whether in court proceedings or in an administrative or
out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about
the circumstances in which your personal data may be transferred to countries
outside the European Economic Area (EEA).
5.2 We have offices and facilities in Ingiriya, Sri Lanka.
5.3 The hosting facilities for our website, software
are situated in United States.
5.4 You acknowledge that personal data that you submit
for publication through our software, website or services may be available, via
the internet, around the world. We cannot prevent the use (or misuse) of such
personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention
policies and procedure, which are designed to help ensure that we comply with
our legal obligations in relation to the retention and deletion of personal
data.
6.2 Personal data that we process for any purpose or
purposes shall not be kept for longer than is necessary for that purpose or
those purposes.
6.3 We will retain your personal data as follows:
(a) Personal data category or categories will
be retained for a minimum period of three months following date of
collection, and for a maximum period of two years following date
of stop usage.
6.5 Notwithstanding the other provisions of this
Section 6, we may retain your personal data where such retention is necessary
for compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
7. Amendments
7.1 We may update this policy from time to time by
publishing a new version on our website.
7.2 You should check this page occasionally to ensure
you are happy with any changes to this policy.
7.3 We may notify you of significant changes to this
policy by email or through the private messaging system on our software, website.
8. Your rights
8.1 In this Section 8, we have summarised the rights
that you have under data protection law. Some of the rights are complex, and
not all of the details have been included in our summaries. Accordingly, you
should read the relevant laws and guidance from the regulatory authorities for
a full explanation of these rights.
8.2 Your principal rights under data protection law
are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority;
and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether
or not we process your personal data and, where we do, access to the personal
data, together with certain additional information. That additional information
includes details of the purposes of the processing, the categories of personal
data concerned and the recipients of the personal data. Providing the rights
and freedoms of others are not affected, we will supply to you a copy of your
personal data. The first copy will be provided free of charge, but additional
copies may be subject to a reasonable fee. You can access your personal data
when logged into our software, website.
8.4 You have the right to have any inaccurate personal
data about you rectified and, taking into account the purposes of the
processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the
erasure of your personal data without undue delay. Those circumstances include:
the personal data are no longer necessary in relation to the purposes for which
they were collected or otherwise processed; you withdraw consent to
consent-based processing; you object to the processing under certain rules of
applicable data protection law; the processing is for direct marketing
purposes; and the personal data have been unlawfully processed. However, there
are exclusions of the right to erasure. The general exclusions include where
processing is necessary: for exercising the right of freedom of expression and
information; for compliance with a legal obligation; or for the establishment,
exercise or defence of legal claims.
8.6 In some circumstances you have the right to
restrict the processing of your personal data. Those circumstances are: you
contest the accuracy of the personal data; processing is unlawful but you
oppose erasure; we no longer need the personal data for the purposes of our
processing, but you require personal data for the establishment, exercise or
defence of legal claims; and you have objected to processing, pending the
verification of that objection. Where processing has been restricted on this
basis, we may continue to store your personal data. However, we will only
otherwise process it: with your consent; for the establishment, exercise or
defence of legal claims; for the protection of the rights of another natural or
legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of
your personal data on grounds relating to your particular situation, but only
to the extent that the legal basis for the processing is that the processing is
necessary for: the performance of a task carried out in the public interest or
in the exercise of any official authority vested in us; or the purposes of the
legitimate interests pursued by us or by a third party. If you make such an
objection, we will cease to process the personal information unless we can
demonstrate compelling legitimate grounds for the processing which override
your interests, rights and freedoms, or the processing is for the
establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of
your personal data for direct marketing purposes (including profiling for
direct marketing purposes). If you make such an objection, we will cease to
process your personal data for this purpose.
8.9 You have the right to object to our processing of
your personal data for scientific or historical research purposes or
statistical purposes on grounds relating to your particular situation, unless
the processing is necessary for the performance of a task carried out for
reasons of public interest.
8.10 To the extent that the legal basis for our
processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance
of a contract to which you are party or in order to take steps at your request
prior to entering into a contract,
and such processing is carried out by automated
means, you have the right to receive your personal data from us in a
structured, commonly used and machine-readable format. However, this right does
not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your
personal information infringes data protection laws, you have a legal right to
lodge a complaint with a supervisory authority responsible for data protection.
You may do so in the EU member state of your habitual residence, your place of
work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our
processing of your personal information is consent, you have the right to
withdraw that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.
8.13 You may exercise any of your rights in relation to
your personal data by written notice to us OR by e-mail, in addition to
the other methods specified in this Section 8.
9. About cookies
9.1 A cookie is a file containing an identifier (a
string of letters and numbers) that is sent by a web server to a web browser
and is stored by the browser. The identifier is then sent back to the server
each time the browser requests a page from the server.
9.2 Cookies may be either "persistent"
cookies or "session" cookies: a persistent cookie will be stored by a
web browser and will remain valid until its set expiry date, unless deleted by
the user before the expiry date; a session cookie, on the other hand, will
expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information
that personally identifies a user, but personal information that we store about
you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
10.1 We use cookies for the following purposes:
(a) authentication - we use cookies to identify you
when you visit our website and as you navigate our website (cookies used for
this purpose are: identify cookies);
(b) status - we use cookies to help us to determine if
you are logged into our website (cookies used for this purpose are: identify
cookies);
(c) personalisation - we use cookies to store
information about your preferences and to personalise the website for you
(cookies used for this purpose are: identify cookies);
(d) security - we use cookies as an element of the
security measures used to protect user accounts, including preventing
fraudulent use of login credentials, and to protect our website and services
generally (cookies used for this purpose are: identify cookies);
(e) advertising - we use cookies to help us to display
advertisements that will be relevant to you (cookies used for this purpose are:
identify cookies);
(f) analysis - we use cookies to help us to analyse
the use and performance of our website and services (cookies used for this
purpose are: identify cookies); and
(g) cookie consent - we use cookies to store your
preferences in relation to the use of cookies more generally (cookies used for
this purpose are: identify cookies).
11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies
may be stored on your computer when you visit our website.
11.2 We use Apple, Google Analytics/ Firebase Analytics to
analyse the use of our website, software. Google Analytics/ Firebase Analytics gather
information about website, software use by means of cookies. The information
gathered relating to our website, software is used to create reports about the
use of our website, software. Google's privacy policy is available at: https://www.google.com/policies/privacy/.
Apple's privacy policy is available at: https://www.apple.com/au/legal/privacy/.
The relevant cookies are: identify cookies.
11.3 We publish Google AdSense/Admob interest-based
advertisements on our website, software. These are tailored by Google to
reflect your interests. To determine your interests, Google will track your
behaviour on our website, software and on other websites, software across the
web using cookies. OR We publish Google AdSense/Admob advertisements on our website,
software. To determine your interests, Google will track your behaviour on our website,
software, software and on other websites, software across the web using
cookies. This behaviour tracking allows Google to tailor the advertisements
that you see on other websites, software to reflect your interests (but we do
not publish interest-based advertisements on our website, software). You can
view, delete or add interest categories associated with your browser by
visiting: https://adssettings.google.com.
You can also opt out of the AdSense partner network cookie using those settings
or using the Network Advertising Initiative's multi-cookie opt-out mechanism
at: http://optout.networkadvertising.org.
However, these opt-out mechanisms themselves use cookies, and if you clear the
cookies from your browser your opt-out will not be maintained. To ensure that
an opt-out is maintained in respect of a particular browser, you may wish to
consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.
The relevant cookies are: identify cookies.
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies
and to delete cookies. The methods for doing so vary from browser to browser,
and from version to version. You can however obtain up-to-date information
about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en
(Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/
(Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
(e) https://support.apple.com/kb/PH21411
(Safari);
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge); and
(g) https://policies.google.com/technologies/ads?gl=uk
(Android)
12.2 Blocking all cookies will have a negative impact
upon the usability of many websites.
12.3 If you block cookies, you will not be able to use
all the features on our website.
13. Our details
13.1 This app or website is owned and operated by Innovemind Pvt Ltd.
13.2 We are registered in Sri Lanka under registration
number PV103418, and our registered office is at 29/1, Rathnapura
Road, Ingiriya.
13.3 Our principal place of business is at 29/1,
Rathnapura Road, Ingiriya. Sri Lanka.
13.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our app, website contact form;
(c) by telephone, on the contact number published on
our app, website from time to time; or
(d) by email, using the email address published on our
app, website from time to time.
14. Data protection officer
14.1 Our data protection officer’s contact details are: innovemind@gmail.com.
