SLT Privacy Policy for SLT Lynked Product

Sri Lanka Telecom PLC (herein after referred to as SLT) has a firm commitment to safeguard privacy of users accessing SLT Lynked product/platform. This Privacy Policy for SLT Lynked product and the video conferencing platform (hereinafter referred to as the ‘Policy’) sets out SLT’s commitment to privacy of the users of the product/platform.

This Policy is applicable for the parties who access SLT Lynked video conferencing platform product as an account holder or an profile holder coming under the account holder (hereinafter referred to as the ‘Users’) for online meetings and educational purposes (hereinafter referred to as the ‘Platform’)

The Users understand that the user’s personal data shall be entered in to the Platform by the Users. As such Users shall be solely responsible for any submission or entry of inaccurate or incomplete data

Users, having read and having satisfied themselves of the Policy hereinafter recited continues to use or access the Platform and such continued access shall mean User’s consent to collect, use, store and process the User’s data (hereinafter referred to as Personal Data) by SLT as elaborated hereunder. 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, User shall immediately discontinue the use of the Platform and inform SLT via bizsolutions@slt.com.lk of User’s withdrawal of consent.

1. Collection of Personal Data

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

   • Account Information:

     Information associated with User that may access the Platform and use the SLT Lynked product as an account holder registered with SLT, which may include administrator name, contact information, account ID, billing information, and account plan information.

   • Profile and Participant Information:

     Information associated with the SLT Lynked profile of a user coming under an account holder who uses SLT Lynked Products under a licensed account or that is provided by an unregistered participant joining a meeting, which may include name, display name, picture, email address, phone number, job information and other information provided by the user or their account owner.

   • Contacts and Calendar Integrations:

     Contact information added by account holders or their user profiles to create contact lists on SLT Lynked Platform/products, which may include contact information a user integrates from a third-party app. Users can also integrate their calendars from other services with their SLT Lynked profile or account.

   • Contacts and Calendar Integrations:

     Contact information added by account holders or their user profiles to create contact lists on SLT Lynked Platform/products, which may include contact information a user integrates from a third-party app. Users can also integrate their calendars from other services with their SLT Lynked profile or account.

   • Settings:

     Information associated with the preferences and settings on a SLT Lynked account or user profile, which may include audio and video settings, screen-sharing settings, recording file location and other settings and configuration information.

   • Device Information:

     Information about the equipment including computers, phones, and other devices that may be used by the User when interacting with SLT Lynked Products, which may contain information on the speakers, microphone, camera, OS version, hard disk ID, PC name, MAC address, IP address, device attributes (like operating system version and battery level), signal strength information, and other device information (like Bluetooth signals).

   • Registration Information:

     Information people provide when registering for a SLT Lynked meeting, webinar or recording, which may include name and contact information, responses to registration questions, and other registration information requested by the host.

   • Meeting, Webinar, and Messaging Content and Context:

     Content generated in meetings, webinars, or messages that are hosted on SLT Lynked Platform, which may include audio, video, chat messaging content, in-meeting messages, transcriptions, written feedback, responses to polls and Q&A, and files, as well as related context, such as meeting or chat name, invitation details or meeting agenda. Content may contain voice and image of the User, available based on the settings adopted by the User when using SLT Lynked Platform.

   • Platform, SLT Lynked Product and Website Usage:

     Information of Users and their devices interact with SLT Lynked Platform, such as: when participants join and leave a meeting; i messaging options used by the Users; performance data; movements of the curser, clicks, keystrokes or actions (such as mute/unmute or video on/off), and other user inputs that help SLT Lynked Platform to understand the usage of available features, improve the design of the SLT Lynked product and the platform, and suggest features; which third-party apps users add to a meeting or other Product and what information and actions the app is authorized to access and perform; use of third-party apps and the SLT Lynked Platform Marketplace; features used (such as screen sharing, emojis, or filters); and other usage information and metrics. This also includes information about when and how people visit and interact with SLT Lynked Platform and SLT’s websites, including what pages they accessed, their interaction with the website features, and whether or not they signed up for a SLT Lynked Platform.

   • Communications with SLT Lynked Platform:

     Information about your communications with SLT Lynked, including relating to support questions, your account, and other inquiries.

   • Information from Partners:

     SLT Lynked Platform obtains information about Users from third-party companies, such as market data enrichment services, including information on the company size or industry, contact information, or activity of certain enterprise domains of the Users. SLT Lynked may also obtain information from third-party advertising partners who deliver ads displayed on SLT Lynked Platform, such as whether the User clicked on an ad they have published on the Platform.

2. Using of Personal Data

   • [A] Users understand that it is essential for SLT to collect Personal Data for the purpose of provisioning the service to the Users via this Platform. SLT will utilize Personal Data to process orders and to provide the Users with the services and/or information on the product offered through this Platform as elaborated below; which shall be the Primary Purpose. Provide SLT Lynked Products and Services:

     To provide products, features, and services to Users and those they invite to join meetings and webinars hosted on their accounts through the Platform. SLT also uses Personal Data to route invitations and messages to recipients sent by the Users . This may also include using Personal Data for customer support, which may include accessing audio, video, files, and messages, at the direction of the account owner or their users. We also use personal data to manage our relationship and contracts with account owners, including billing, compliance with contractual obligations, and related administration.

   • Product Research and Development:

     To develop, test, and improve the Platform, SLT Lynked Products, including, for example, content-related features (such as background filters), and to troubleshoot products and features.

   • Authentication, Integrity, Security, and Safety:

     To authenticate accounts and activity of the Users, detect, investigate, and prevent malicious conduct or unsafe experiences, address security threats, protect public safety, and secure the Platform and SLT Lynked products.

   • Communicate with Users:

     We use Personal Data (including contact information) to communicate with and to respond to you when you contact us.

   • Legal Reasons:

     To comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, and to enforce or investigate potential violations of our Agreements or policies.

     SLT Lynked uses advanced tools to automatically scan content such as virtual backgrounds, profile images, and files uploaded or exchanged through chat, for the purpose of detecting and preventing violations of our terms or policies and illegal or other harmful activity, and its employees may investigate such content where required for legal, safety, or security reasons.

     Users understand that using 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.

   • [B] SLT may send useful information to the Users, provided that Users have marked “I Agree to Receive Messages” Tick box displayed on this Platform 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 features and facilities offered through this Platform or by SLT in general for the purposes of marketing, advertising and promoting of SLT Lynked product and/or other products and services of SLT (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 through the Contact Information under Clause 7.

3. Information and Personal Data Shared with third parties

   Users understand that, in general, the third-party providers on the Platform engaged by SLT 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 on-line payments for the Platform use.

   Further, subjected to a non-disclosure agreement, SLT may share Personal Data to third parties for the purpose of maintaining of the Platform, system integrations, development, trouble shooting of a User account relating to the achieving of the Primary Purpose.

   Unless the same is required for achieving of the Primary Purpose, by Law or Change of Control (as detailed below), SLT shall NOT sell or disclose Personal Data to third parties without obtaining prior consent of the User.

   As required by Law:

   SLT Lynked may share Personal Data as needed to:

   (1) Comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies

   (2) Enforce or investigate potential violations of agreements or policies of SLT

   (3) Detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public

   (4) Meet our corporate and social responsibility commitments as required by Law

   (5) Protect SLT and its customers’ rights and property

   (6) Resolve disputes and enforce agreements.

   Change of Control:

   SLT may share Personal Data for the purpose of actual or prospective sale, merger, acquisition, restructuring, or change in control involving all or a portion of SLT Lynked’s business or assets, including in connection with bankruptcy or similar proceedings.

   Who Can See and Share My Personal Data When I Use SLT Lynked?

   When you send messages or join meetings and webinars on SLT Lynked, other people and organizations, including third parties outside the meeting, webinar, or message, may be able to see content and information that you share:

4. SLT Contract Information

   To exercise your rights, please click here. If you have any privacy-related questions or comments related to this Privacy Statement, please send an email to bizsolutions@slt.com.lk

5. Retention of Personal Data

   Users shall understand that SLT shall retain the 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 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.

6. 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 the Platform. 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.

7. 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 Services under the Website.

   SLT may refuse to collect additional data, which are not required for purpose of delivering of services 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.

8. Changes to this 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 Platform. User can check the latest update by checking the “last updated date and time” displayed at the bottom of this Privacy Policy.