Privacy Policy

The Site and App are owned and operated by SPAR Super Market (Pvt) Ltd (PV123456) of No11/2, Pannipitiya Road, Thalangama South, Battaramulla. Since we handle personal data from the end users on their behalf, we act in the capacity of both a Data Controller and a Data Processor, as defined under the EU Data Protection Directive and the General Data Protection Regulation (GDPR) and also under Personal Data Protection Act, No. 9 of 2022 (PDPA).

The Site or App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates or to websites shared by other users. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

1. Information We Process About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect and process personal information so we can provide our service to you. It's important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Please note that we do not collect any Special Categories of personal data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, political opinions, trade union membership, information about your health and genetic and biometric data), and we do not collect any information about criminal convictions and offences.

1.1 Information You Give Us

You provide information to us when you fill in forms on our Site or App, register to use our Site or App, subscribe to our service or marketing database, post material, search for a product or service, scan the QR code in a merchant's store or premises using our mobile app, place an order on a website that utilises SPARRewards, request further services, enter a competition or promotion, report a problem with our Site or App, complete a survey, or correspond with us (by phone, email or otherwise).

The information you give us includes your name, email address or login details, phone number, payment information (such as bank information or credit card information), purchase history and details of transactions carried out through our Site or App and our merchants, spatial data, and photograph(s) (if you choose to use this feature on our mobile application).

We ask for your explicit consent to use and process the data described above. However, some of this data is necessary for the provision of our services and the fulfilment of our contractual obligations to you, and we may rely on this as a legal basis for using the data described above if necessary.

1.2 Information We Automatically Collect

Each time you visit or use our Site or App, we automatically collect the following information:

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, network data, browser plug-in types and versions, languages, operating system and platform.
• Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site or App (including date and time), pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

We use this information as statistical data about our users' browsing actions and patterns, for system administration, and to report information to third parties. Because we collect, use, and share this information in the aggregate, it does not identify any individual.

2. Legitimate Bases

We will ensure that your personal data is processed lawfully, fairly, and transparently and that it will only be processed if at least one of the following bases applies:

• You have given your clear consent to the processing of your personal data for a specific purpose.
• Processing is necessary for the performance of a contract to which you are a party (or for us to take steps at your request prior to entering into a contract with you).
• Processing is necessary for our compliance with the law.
• Processing is necessary to protect someone's life.
• Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law.
• Processing is necessary for our legitimate interests or the legitimate interests of a third party (except where there is a good reason to protect your personal data which overrides those legitimate interests), such as: allowing us to effectively and efficiently manage and administer the operation of our business; maintaining compliance with internal policies and procedures; monitoring the use of our copyrighted materials; obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.

3. Cookies

A cookie is a small file of letters and numbers that we store on your browser. Cookies contain information that is transferred to your computer's hard drive (or the hard drive of another relevant device). We use cookies to distinguish you from other users on the Site and App, to help us provide you with a good experience when you browse by remembering your user preferences, and to help us improve the Site and App.

Before any non-essential cookies are placed on your device, you will be shown a pop-up message requesting your consent to setting those cookies. By default, most internet browsers accept cookies, but you can choose to enable or disable some or all cookies via the settings on your internet browser.

We use the following types of cookies:

• Strictly necessary cookies. These cookies are required to save your session and to carry out other activities that are strictly necessary for the operation of the Site or App.
• Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around the Site or App when they're using it.
• Functionality cookies. These cookies are used to recognise you when you return to the Site or App. They enable us to personalise our content for you, greet you by name and remember your preferences.
• Targeting cookies. These cookies record your visit to the Site or App, the pages you visit, and the links you follow.
• Social Media cookies. These cookies work together with social media plug-ins. Please note that we do not control cookies placed by third parties.

4. Storage and Security

4.1 Our Storage and Security

All of your personal information is stored on our secure servers and we have put in place appropriate physical, electronic, and management procedures to safeguard and secure the data we collect. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal data is gathered, processed or stored is limited to authorised employees. Any payment transactions will be encrypted using SSL technology.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site or App; any transmission is at your own risk.

4.2 Third Parties With Whom You Choose to Share Your Data

You may choose to share any information, photographs or other content that you voluntarily submit to the Site or App. If you choose to connect to social media networks from our Site or App, personal information that you post may be viewed or used by other users of those networks. We have no control over such viewing and use and cannot prevent further use of such information by third parties.

5. Uses Made of the Information

We use information held about you in the following ways:

• To administer and manage your account, provide you with information, products or services you request from us, and to carry out any other obligations arising from any contracts entered into between you and us.
• To ensure that content from our Site and App is presented in the most effective manner for you and for your device.
• To allow you to participate in interactive features of our service, when you choose to do so.
• To respond to communications from you and to provide you with information about other products or services we offer that are similar to those you have already enquired about.
• To administer the Site and App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• As part of our efforts to keep the Site and App safe and secure.
• To notify you about changes to our service.

We will not send you any unsolicited marketing or spam, and we will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the Personal Data Protection Act, No. 9 of 2022 (PDPA).

6. How Long We Store Your Information

We only keep your personal information for as long as it's necessary for our original legitimate purpose for collecting the information, for as long as we have your permission to keep it and/or for any periods of time prescribed by law or regulation. If you are a consumer or end user, we will delete your personal information no later than 30 days after you delete your account or send a deletion request to info@sparrewards.lk. If you are a merchant, we will delete your personal information no later than 1 year after you terminate use of our Service.

7. Disclosure of Your Information

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We may share your personal data with:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• Any member of our group, which means any subsidiaries or any ultimate holding company and its subsidiaries.
• Prospective sellers or buyers in the event that we sell or buy any business or assets.
• Third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of SPARRewards, our customers, or others.

8. Your Rights

Under the PDPA, you have the right to:

• Withdraw your consent to the processing of your personal data at any time.
• Be informed of what data we hold and the purpose for processing the data.
• Be forgotten and, in some circumstances, have your data erased.
• Correct or supplement any information we hold about you that is incorrect or incomplete.
• Restrict processing of the information we hold about you.
• Object to the processing of your data.
• Obtain your data in a portable manner and reuse the information we hold about you.
• Complain to a supervisory authority if you think any of your rights have been infringed by us.

You will not have to pay a fee to access your personal data unless your request is clearly unfounded, repetitive or excessive. You can exercise your rights to prevent marketing processing by contacting us at the Company Address, via email, or by unsubscribing using the links in our marketing emails.

9. Changes to Our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. You will be deemed to have accepted the terms of the updated Privacy & Cookie Policy on your first use of the Site or App following the alterations. Please check back frequently to see any updates or changes to our Privacy Policy.

10. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our Company Address or to our email.