Privacy Policy

1. Introduction

We are dedicated to providing you with an incomparable customer experience where all your interactions with Finagle (the “Purpose”) is concerned. This is a commitment we make to all our customers. To provide such a service, however, we need to use the personal information that you provide. We therefore also commit ourselves to safeguarding the privacy of the personal information we gather in this process.

You, as a customer, or some other party with whom we conduct business activities, understand and agree to our collecting, using and disclosing your personal information in accordance with this Privacy Policy for customers (this "Policy").

2. Application of this Policy

This Policy applies to:

• All personal information that we gather in any form, whether oral, written or in electronic medium,relating to customers and other individuals or organisations with whom we conduct business, or gathered from those who visit us and,
• The use of such personal information by us.

If you are an associate of Finagle, please refer to the Privacy Policy for employees or, to your Employer’s Privacy Policy, as may be applicable. This policy will not apply to your personal information unless such information is collected in your capacity as a customer.

3. Types of Personal Information Collected by Us

In this Policy, information that identifies or is capable of identifying you as an individual, is what is referred to as “personal information.” The types of personal information (which can vary by jurisdiction based on applicable law) that we process, include:

• Your name, gender, personal and work contact details, business title, any contact numbers, addresses, and email addresses;
• Information relating to your purchases as a customer, credit/debit card data, details relating to your payment method, and your account details;
• Any feedback or content that you reveal that relates to your marketing preferences in surveys, sweepstakes, contests or promotional offers, or provided to our websites and apps or to third parties;
• Information collected at the time you access the Finagle website (explained in more detail is section 6 below);

Information that you, or someone acting on your behalf knowingly provide to us forms most of the personal information we process. We may, however, process personal information inferred about you based on other information you provide to us, or during our interactions with you, or personal information about you that we receive from a third party. Unless specifically covered by such third party’s privacy policy, this policy will also apply to the personal information we receive about you from a third party.

With your agreement to this Policy, you are granting your express and written consent to the processing of any personal information that you provide to Finagle that is considered to be Sensitive Personal Information or financial information, to the extent required under your local law. You are not obliged to provide Finagle with any of your Sensitive Personal Information, save to the extent required by law. Should you choose not to, this will not prevent you from purchasing any products or services from Finagle.

4. Our Use of Personal Information

We may collect, use, and disclose portions of your personal information, subject to applicable laws, in order to:

• provide you with and charge for goods and services purchased by you;
• provide you with a superior or more personalized level of service;
• fulfil our contractual obligations to you;
• conduct market research, customer satisfaction and quality assurance surveys, and direct marketing and sales promotions (for more information about how we conduct direct marketing, please see Section 7 below);
• provide for the safety and security of staff, Customers and other visitors;
  administer general record keeping;
• meet legal and regulatory requirements;
• test and evaluate new products and services;

Your personal information will be retained and used by Finagle for as long as is necessary to fulfil the purpose for which it is being processed, and in accordance with our legal and regulatory obligations and risk management guidelines.

5. Disclosures of your Personal Information

We may disclose your personal information from time to time, but always in accordance with applicable law. Depending on jurisdiction, laws relating to data privacy may require us to obtain your consent prior to our transferring your information from your originating country to other countries. By agreeing to this policy, to the extent required and permitted under your local law, you are granting your consent to the transfer of your personal information to such other countries for the Purpose and to the extent stated in this section and as described in Section 4 above.

In addition to those described in section 4 above, the circumstances where we might make such disclosure include:

5.1 Our Agents, Service Providers and Suppliers

We may, as necessary, outsource the processing of certain functions and/or information to third parties. When we do so outsource the processing of your personal information to third parties, or provide your personal information to third-party service providers, we oblige those third parties to protect your personal information with appropriate security measuresin accordance with the terms and conditions of this Policy

5.2 Consumer Insights

The personal information we hold about you may be disclosed to other companies that also hold information about you. Such companies may combine the information in order to better understand your preferences and interests, thus enabling both organisations to serve you better. If and when your personal information is used for direct marketing purposes, you have the right to object to such use by contacting us using the contact information provided in Section 10 below.Information on how we conduct direct marketing is available in Section 7 below.

5.3  Credit Authorization

Your personal information will be used and also disclosed to appropriate third parties in accordance with applicable laws, if and when you request credit. This is to determine whether to grant and maintain a credit line to you.

5.4 Transfer of Business

As time goes on and we continue to develop our business, we may sell parts or the entirety of our business. In such circumstances, the personal information collected about you, or control of such personal information, may be included as a business asset in any such transfer. Moreover, though an unlikely event, if we, or substantially all of our assets are acquired, personal information collected about you, or the control of such information, may be included as one of the assets so transferred.

5.5  Legal Requirements

We; reserve the following rights;

• The right to disclose personal information we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a government entity, or if we determine it is necessary or desirable to comply with the law or to protect and defend our rights or property in accordance with applicable laws.
• Retaining personal information collected and processing such personal information to comply with accounting and tax rules and regulations and any specific laws relating to record retention.

6.  Information we Collect during your online visits

All who access the Finagle website may desire to know the following

6.1 You can browse anonymously

You do not need to login or otherwise reveal who you are when visiting our website. 

6.2 Information about Usage

Information about how you use the website is collected at the time you visit our site. For example, any or all of the following may be included within the ambit of such information;

• the Internet Protocol address that is automatically assigned to your computer each time you browse the internet,
• the date and time of your visit, the pages you accessed and the amount of time spent on each page,
• the type of internet browser you use, your device’s operating system and the URL of any websites that you visited before and after visiting our website.
• Note that this information is not linked to you as an individual unless you create a user profile, but we may keep records of the type of device being used.

6.3 Cookies and other Similar Technology

Cookie technology is used in our websites as this allows us to evaluate and improve its functionality. Our cookies, by themselves cannot be used to reveal your identity to our servers as these identify your browser or device, but not you, at the time you visit our websites. Information about how Finagle uses cookies can be obtained by visiting finaglelanka.com.

If you so desire, you can block cookies by adjusting the browser internet settings. If you block them, however, you will not be able to use all of the features of our websites. For instance, you cannot use the customization features associated with creating a user profile.

Additional information about cookies and other similar technologies and how they work is available at allaboutcookies.org.

6.4 Social Media

Third party social media platforms containing plug-ins and other features may also integrated into our websites through plug-ins and other features contained within our website. They can be manually activated. If you do activate any of them, the operators of these third party platforms may be able to; identify you; they may be able to determine how you use this website; and they may also be able to store this information along with your social media profile. 

Please consult the data protection policies of these social media platforms to gain an understanding as to what they will be doing with your personal data. Note that activating these plug-ins and other features is at your own risk.

6.5 Links to Other Websites

At the time you visit our website, you may be seamlessly linked to websites maintained by third parties who are bound by contract to us to provide services. Please always look at the location bar within your browser to determine whether you have been linked to a different website whenever you click on a link found on our website.

We limit this policy and our responsibility to our own information collection practices. We neither can we always ensure, nor hold ourselves responsible for, the information collection practices or privacy policies of other websites maintained by third parties or our service providers where you submit your personal information directly to such websites. Moreover, even if accessible using a link from our websites, we cannot ensure the content of the websites maintained by these third parties or our service providers. Before providing any personal information while accessing those websites, we urge you to read the privacy and security policies of any such external websites prior to providing any personal information while accessing those them

6.6 Security

As the security of your personal information is important to us, we use Transport Layer Security (TLS) software to encrypt the personal information that you provide to us. The personal information that you transmit to us online is encrypted when using TLS. There are two ways in which you can verify whether your personal information is transmitted using TLS encryption by:

a.       the presence of the symbol of a closed lock or a solid key inside your browser address bar,

b.      the change of the prefix for the web address listed for that page from “http” to “https.” 

.You should not assume that the personal information that you are being asked to provide will be encrypted prior to transmission if you do not see the appropriate symbol and/or the “https” prefix.

A combination of physical and electronic access controls, firewall technology and other reasonable security measures protect our servers where the personal information collected online from you is stored by us and/or our service providers. Such security measures, however, cannot prevent all loss, misuse or alteration of personal information. We cannot, and will not, hold ourselves responsible for any damages or liabilities relating to such incidents to the fullest extent permitted by law. We will, however, notify you of any such loss, misuse or alteration of personal information that may affect you, as may be required under law. This is to ensure that you can take appropriate actions for the due protection of your rights.

6.7 Minor Children

If you are less than 18 years of age, (or a minor in the jurisdiction in which you are accessing our websites), you may use our websites only with the involvement of a parent or guardian.  We do not knowingly solicit or collect information from children. Nor do our websites sell products or services for purchase by children.

6.8 Targeted Advertising

Depending on our requirements, we may work with other companies to share advertisements or marketing initiatives that in our opinion, you may find relevant and useful, but only where permitted by law. Advertisements displayed on our own websites or apps or communications sent by us, or advertisements from us displayed on other companies' websites may be included within this ambit. Such advertisements that you see may be based on information collected by us or third parties. These may also be based on your activities on our websites or third-party websites.

7 Choice

The personal information (if any) that you wish to provide us with may always be chosen by you. Some of your experiences with us may be affected, however, if you choose not to provide certain details (for example, we cannot make a delivery without an address to deliver to).

 
The contact details ( e.g. telephone / fax number, email address, postal address) you provide us with, will allow us to inform you about the products, services, promotions and events that we offer, on the assumption that you may be interested in them. We may also share your personal information with carefully selected third parties who may communicate directly with you. Laws pertaining to data privacy may require us to obtain a separate consent before we do so, in some jurisdictions. Whether or not you are willing to be the recipient of any or all such communications can be chosen by you by contacting us as described in Section 10 below or, by following the “unsubscribe” instructions contained in the communications.    

Despite your agreeing to this Policy, data privacy laws that prevail in some jurisdictions may require us to obtain a separate consent to send you information that you have not specifically requested for. Your consent may be implied in certain circumstances (for example, where communications are required are needed to fulfil requests made by you and/or where you have voluntarily submitted information for our use). It may also be that, in accordance with applicable laws, we may seek your consent expressly in accordance with applicable laws (for instance, where, under local regulations, the information collected is considered to be Sensitive Personal Information).

If you expressly request us not to send you direct marketing materials, we will abide by such request. On receipt of such a request, your contact details will not be deleted, but “suppressed.” We thus ensure that your request is recorded and retained unless a later consent is provided to override it.

8 Updating or Accessing your Personal Information

You will have rights to access and update personal we hold about you, with some limited exceptions. You can inquire about any personal information we may have about you by sending us a written request by letter or email to the addresses set out in Section 10 below. Please ensure that your full name, address, and telephone number and a copy of the document evidencing your identity (such as an ID card or passport identity page). This will not only enable us to ascertain your identity and whether we have any personal information relating to you, but also in case we need to contact you to obtain any additional information we may require to make that determination. In the event you make more than a single request in quick succession, we may respond to your subsequent request by referring to our earlier response and identify only any items that have been subject material change.

By sending a letter or an email to the addresses set out in Section 10 below, you may request that we correct, delete, and/or stop or restrict processing, or use of the personal information that we hold relating to you. We will delete or correct the personal information if we agree that the personal information is incorrect, or that the processing should be stopped. If we do not agree that the personal information is incorrect, we will inform you of our disagreement and explain our refusal to you. We will also record the fact that you consider the relevant personal information to be incorrect, in the relevant file/s.

9 Changes to this Policy

Our business changes constantly, and as such this Policy may also change. For your assistance, this Policy has an effective date set out at the end of this document.

10 Request for Access to Personal Information/Questions or Complaints

Any questions that you may have about this Policy, or about the processing of the data described, or any concerns or complaints relating to the administration of this Policy, or if you wish to submit a request (as described in Section 8 above) to exercise your rights in in relation to the personal information that we maintain about you, please contact us by any of the following means:

• by calling or emailing the contacts located at the Contact Us page

Though this Policy alone does not create contractual rights, Finagle has created a set of binding standards and policies (known as binding corporate rules in some countries), approved by a number of national privacy regulators, to ensure compliance with some of its legal obligations in relation to personal information in some countries. As a result, you may be able to enforce your privacy rights using those standards and policies through that regulator or court, depending on your circumstances and location. If you wish to know more about these standards and policies, please contact Finagle at the above address.

Any and all requests for your personal information must be submitted in writing by letter or email. We may respond to your request by letter, email, telephone, or any other method deemed suitable.

Effective Date: August 2020

If there are any inconsistencies present between the English version of this Policy and any version of this Policy in any other language, the English version shall prevail.