PRIVACY POLICY

Last update on 16/12/2023


This Privacy Policy explains how Robocash LK services (Pvt) Ltd. (Robocash) treats your personal data and protect your privacy when you use our service through this website accessible at: https://robocashlk.loan (the “Website”) or by other means. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. By accessing or using the Website, you signify that you have read this Privacy Policy, and you expressly consent to our processing, collection, use, disclosure, storage and protection of your personal information as described in this Privacy Policy. This Privacy Policy is applicable to any User of the aforementioned Website, Mobile by any client of Robocash and Users are advised to review it periodically for updates that are implemented on a regular basis.


DEFINITION OF TERMS:


a. Personal Information refers to any information, whether recorded in material form, from which the identity of an individual is apparent or can be reasonably, directly and certainly identify as an individual. Personal Information together with Sensitive Personal Information is defined as personal Information herein after. Sensitive Personal Information refers to personal information about an individual's race, marital status, age, color, and religious, philosophical, or political beliefs; health, education, genetic information, sexual life or involvement of a person in a legal proceeding. It may also include, social security numbers, health records and licenses, pin codes and account numbers.


b. User – refers to an individual whose Personal information is processed.


c. Processing – refers to any operation or any set of operations performed upon personal information including but not limited to the collection, recording, organization, storage, updating or modification, consultation, use, consolidation, blocking, erasure or destruction of data. Processing may be performed through automated means, or manual processing if the personal data are contained or are intended to be contained in a filing system.


d. Personal Data – any information that can identify a natural person directly or indirectly, by reference to an identifier such as a name, an identification number, location data, or an online identifier; or one or more factors specific to the physical, physiological, genetic, psychological, economic, cultural, or social identity of that individual or natural person.


PERSONAL INFORMATION WE COLLECT - User Data:


a. Full name

b. E-mail address

c. Social Media account details

d. Gender

e. Birthday

f. Telephone/ mobile number

g. ID type and number

h. Politically Exposed Person Status Declaration

i. Residential Address

j. Employment Status and Position

k. Company / Business Name, Address and Contact Number

l. Monthly Income

m. Name of relatives and contact number

n. Name of co-workers and contact number

o. Bank Name

p. Bank Account number

q. Geolocation data

r. Device data and accesses (persistent device identifiers, device id and model, IMEI, list of installed applications, EXIF data, information about network connection, SMS messages, call logs, contacts, multimedia materials stored on the device, access to the contact lists, camera)


1. General terms


A. This Privacy Policy is valid in relation to all personal Data received by Robocash from the natural person holding such User Data at the time of using or attempting to use the services of Robocash.


B. The purpose of this Privacy Policy is to respect the Users' rights to the User Data in relation to the collection, usage and processing of such User Data by Robocash.


2. No Sale of Personal Information


Robocash will not rent or sell your personal information to third parties.


3. Information you provide when using our services and data processing purposes


When you use the Website or Mobile application we collect information about you through the registration process to uniquely identify you, perform the verification of the provided information and confirm it with statutory requirements.


User Data may be treated, collected, used and processed by Robocash among others for the following purposes:


a. Verify the User's identity;

b. Manage the provision of services being offered, such as processing of the application or rendering the decision, among others;

c. Evaluate the User's credit standing through external report providers and bureaus;

d. Contact the User;

e. Contact the User's indicated references in the event that the User cannot be contacted;

f. Perform transfers of funds;

g. Manage, collect and recover User's outstanding amounts either through Robocash, its affiliates or external collection agencies, lawyers or third party service providers;

h. Update the information regarding the loan granted;

i. Enhance the User's customer experience and improve, develop and determine customized products to meet customer preferences and needs;

j. Send commercial or marketing communications on the products and services;

k. Improve the service and contents of the service through statistical analysis and market research;

l. Abide by any safety, security, public service or legal requirements and processes;

m. Process information for statistical, analytical, and research purposes;

n. Any other purpose expressly provided in the Application Form and/or in the Terms and Conditions.


4. Authorization for Usage of Third Party Data


Notwithstanding anything to the contrary in this Privacy Policy or the Terms and Conditions of website, you acknowledge, consent and agree that:


  • Where you use this Website or services for and on behalf on any other person, whether being a member of your family, your friend or employee, you have their full and informed consent and authorization for such use;

  • Where you provide any information of any other person, such as your family, friends or employees, you have their full and informed consent and you are authorized by such person to provide such personal information when using the Website or services.


We assume with your permission that you have obtained proper authorization from the owner/s of such personal information and have informed the said person/s of the terms and conditions of this Privacy Policy or the Terms of Use. You hereby represent and warrant that such person, whether being a member of your family, your friend or employee, has also read and understands this Privacy Policy or Terms and Conditions of website.


You further acknowledge, confirm, represent, and warrant that such person (1) on whose behalf you are using this Website or services or (2) whose personal information you have provided to us have agreed to the use, processing, storage and/or disclosure of their personal information in accordance with this Privacy Policy or the Terms and Conditions of the website, and all applicable laws.


5. Information from cookies and web beacons


Cookies are small text files created by a website that store information on your computer, such as your preferences when visiting that website. Similar to many websites, if you have enabled cookies in your browser, Robocash, independently and through enabled third party tools and programs, collects certain technical information using cookies, such as the path of users to the Website, pages visited, originating IP address, browser type, browser language and the date and time of the user's visit. This information helps Robocash track trends and improve areas of the Website and Program, and are common analytics used by most websites. If you have disabled cookies, the Website may not work as it is intended because Robocash uses cookies when you sign in to keep track of your personal session.


Web beacons are tiny graphics with a unique identifier that are similar in function to cookies but, instead of being stored on your computer, are embedded invisibly on web pages. Web beacons are used to track the online movements of internet users. Robocash uses them to better understand user interaction and engagement with the Website (including without limitation, in electronic Communications), such as by learning whether certain users have accessed the Website via links from other websites. Robocash can use this information to tailor its audience for advertisements promoting Robocash. You may set your browser preferences to opt out of the collection and use of this tracking information for ad targeting purposes.


Robocash also uses cookies for remarketing, by placing a cookie in your browser to signal that you've visited the Website. This gives us the option to show you ads for Robocash when you visit other websites that host advertisements. Robocash supports the Do Not Track preference available on most internet browsers. The use of cookies by third parties on the Website is for the purpose of making the Website easier to use and to enable certain features of the Website and is not covered by this Privacy Policy. We do not have control over these cookies. Robocash informs the user that if you reject the download of cookies, some sections of our website will not work or the user will not be able to access them. If you reject or block cookies, you may not be able to use some of the services that require your identification as a user. It can also slow down the loading of some pages of this Website. The additional information about cookies on the Website can be found here - https://robocash.lk/en/about/cookies


6. Electronic communications


From time to time you will receive disclosures, notices, documents and information based on your current loan status ("Communications") from Robocash (for example, confirmations of Loans obtained by you, confirmation of email address or password changes, or customer service inquiries regarding the status of or activity). By creating an account with Robocash on the Website, you agree that all Communications from Robocash relating to your use of the Website and participation in the Program may be provided or made available to you electronically by mobile SMS, by e-mail or at the Website.


By registering on the Website, you acknowledge that you can access the electronic Communications, and you consent to having all Communications provided or made available to you in electronic form and to obtain loan utilizing the online service provided by Robocash.


7. Disclosure to affiliates, service providers, agents and representatives


We will disclose your personal information to third parties only in the ways that are described in this Privacy Policy. Robocash’s affiliates and service providers, agents and representatives of Robocash and its affiliates may be provided access to your personally identifiable information as part of, or incident to, their provision of services to Robocash. All such access shall be under appropriate confidentiality and/or Data Processing Agreements and limited to use to provide services to Robocash. Robocash ensures that every party entrusted with data processing on behalf of Robocash implements appropriate technical and organizational measures to ensure secure personal data processing.


8. Legal disclosures


Notwithstanding anything to the contrary in this Privacy Policy or Terms and Conditions of website, you acknowledge, consent and agree that Robocash may disclose information in order to: (a) comply with applicable law, regulation, legal process, or governmental request; (b) protect the rights, property and safety of Robocash, Users and others, including intellectual property rights; and (c) enforce or apply our agreements and policies.


9. Use of your information


In addition to the uses (including display and disclosure) of your information that we have described above in this Privacy Policy, Robocash uses your information that Robocash has collected as described above in this Privacy Policy in order to facilitate activities and transactions for the operation of the Website and Program, improve User experiences on the Website.


10. Links to other websites


If you follow any links which remove you from the Website (for example, the independently operated PayPal, Facebook, Twitter, Blogger, Wordpress, Salesforce and any other websites), this Privacy Policy no longer applies – i.e., the privacy policies and practices of other websites and other parties are governed by their respective terms of use and privacy policies.


11. Security of personal data processing


Robocash takes reasonable steps to maintain appropriate physical, technical such as encrypting transmission of information using SSL and administrative security to help prevent loss, misuse and unauthorized access, disclosure and modification of personal information.


Robocash prioritizes secure processing of its Users’ personal data by ensuring encryption, network security and the latest technologies on which the service operates. Access to User personal data within Robocash is segmented on a need-to-know basis and is only provided to employees that need it to perform their direct responsibilities.


12. Retention period


Robocash reserves the right to retain your personal information for a period of 3 years or more to satisfy legal requirements such as recordkeeping and tax and credit reporting requirements, as well as for purposes of fraud prevention, audit and data integrity. In addition, Robocash reserves the right to retain, as well as to use and disclose as permitted pursuant to this Privacy Policy, your personal information for such period of time as reasonably needed by Robocash to facilitate activities and transactions for the operation of the Website, improve User experiences on the Website. Robocash reserves the right to retain information that does not directly identify you, for example, aggregated or anonymized data.


13. Modifications; Interpretation


Robocash may update or modify this Privacy Policy from time to time. If any changes are made, Robocash will reflect the date on which any such changes are made and posted by updating the "last updated" date at the top of the page. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective. Please be sure to check this page periodically for changes.


14. Data Protection Officer


To ensure compliance with applicable data protection laws Robocash appoints the Data Protection Officer. If you have any questions regarding the Privacy Policy of Robocash or you would like to excecise the your rights as data subject, please submit your requests to dataprotection@robo.cash.


15. Data Subject Rights, Requests & Complaints


We recognize and take seriously our responsibility to protect the User Data you entrust to us from loss, misuse, or unauthorized access. Here is a summary of your data protection rights (to the extent possible):


a. Right to access your personal data

b. Right to rectification

c. Right to erasure

d. Right to object/opt-out

e. Right to data portability

f. Right to not to be subject to automated decision-making

g. Right to lodge a complaint


If you believe that any of your personal data may have been misused or abused or otherwise compromised, or if you wish to withdraw your consent for processing of your personal data, you may lodge your inquiries and complaints to the Robocash in accordance with the contact details as outlined below and discuss such matter, together with your contact details for reference. All such complaints will be resolved within 30 (Thirty) calendar days.


Filing such complaints shall not affect the lawfulness of any processing carried out before you withdraw your consent.


For Complaints please contact us: e-mail - support@robocashlk.loan.