Privacy Policy

 

PRIVACY NOTICE

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Effective Date: 25.02.2023

INTRODUCTION 

This Privacy Notice explains how Headstart (Pvt) Ltd (“Headstart,” “we,” “our,” or “us”) processes your personal data in accordance with applicable data protection laws. Headstart (Pvt) Ltd is a subsidiary of Dialog Axiata PLC and is committed to respecting your privacy and protecting your personal data. 

HOW WE USE YOUR PERSONAL DATA 

Your personal data may be used or processed for the following purposes: 

For Customers 

1. Providing products and/or services you have contracted for. 

1. Notifying you about benefits and changes to our products and services. 

1. Informing you of our latest offers, campaigns, and promotions (where you have subscribed to such updates). 

1. Sending service messages regarding your subscription or account registration. 

1. Compliance with legal, contractual, or regulatory obligations and protecting or exercising our rights and remedies. 

1. Sending you information via digital channels (telephone, text, email, etc.) or social media about products and services offered by Headstart, our group of companies, and selected third parties (with an option to unsubscribe). 

1. Responding to complaints or inquiries. 

1. Administering debt recoveries. 

1. Verifying your identity when necessary. 

1. Conducting market and product analysis based on your usage. 

1. Enhancing and improving our products and services. 

1. Other legitimate purposes. 

 

For Shareholders 

1. Verifying identity and executing shareholder requests. 

1. Compliance with legal, contractual, and regulatory obligations. 

1. Communicating updates related to shares and dividends. 

1. Other legitimate purposes. 

 

For Business Partners and Suppliers 

1. Business execution and management. 

1. Ensuring health, safety, and security. 

1. Compliance with obligations, including protecting assets and interests. 

1. Other legitimate purposes. 

 

For Visitors 

1. Ensuring health, safety, and security. 

1. Compliance with legal or regulatory obligations. 

1. Other legitimate purposes. 

 

For Employment Candidates 

1. Identifying and evaluating potential employment candidates. 

1. Record-keeping for recruitment. 

1. Conducting background checks. 

1. Compliance with legal or regulatory obligations. 

1. Emergency contact purposes. 

1. Other legitimate purposes. 

 

For Employees 

In addition to the purposes outlined for employment candidates: 

1. Career development and administration of benefits. 

1. Managing performance and conducting corporate exercises. 

1. Financial reporting, security monitoring, and audit purposes. 

1. Compliance with the employment contract and legal requirements. 

1. Other legitimate purposes. 

 

DISCLOSURE OF PERSONAL DATA 

We may disclose your personal data as follows: 

1. To our group of companies, subsidiaries, and affiliates, including Dialog Axiata PLC. 

1. To service providers, field engineers, and contractors for work performed on our behalf. 

1. For legal, regulatory, or fiscal compliance, and protecting our rights or investigating fraud. 

1. To third parties for market research, product analysis, and development. 

1. To payment processors and other financial intermediaries, as required. 

1. If involved in a business transaction (e.g., merger or acquisition), to relevant third parties. 

1. To third parties for purposes set out in “How We Use Your Personal Data.” 

 

DATA TRANSFERS AND SECURITY 

We may transfer your data across geographical borders. We apply reasonable protection measures to ensure your data’s security in accordance with applicable laws and industry standards. 

 

DATA RETENTION 

Personal data is retained only as long as needed for its intended purpose, with secure disposal after the retention period or when no longer legally required. 

 

YOUR RIGHTS 

You may request updates or corrections to your personal data by contacting us. Certain rights, such as stopping non-essential communications, are also available. Mandatory service communications will continue unless you cancel your subscription. 

 

CONSEQUENCES OF NOT PROVIDING PERSONAL DATA 

Failure to provide certain data may impact our ability to offer products or respond to your requests. 

 

CONTACT US 

For questions or complaints about this Privacy Notice, please contact us at: 

Headstart (Pvt) Ltd
Address: 475, Union Place, Colombo 02
Telephone: (+94) 76 544 7744
Email: admin@headstart.lk 

UPDATES TO THIS PRIVACY NOTICE 

We may amend this Privacy Notice periodically. The latest version will prevail, so please check this Notice from time to time. 

This draft refers directly to Headstart (Pvt) Ltd to satisfy the Google Play requirement that the privacy policy names the developer. You can host this on your website as a dedicated page, which should meet Google Play Console review standards. 

 

 

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