Last updated: October 1st , 2021

This Privacy Policy (referred to as “Policy”) sets out and defines the privacy policies and procedures of the ‘Lighting Digital’ initiative of the Government of Sri Lanka on the processing, including but not limited to the collection, use and disclosure, of your personal data through the use of the Website, mobile devices, tablets, consumer electronic devices (also referred to as the “Lighting Digital Service” and/or “Service”).

This Policy further provides you with information regarding Your privacy and data protection rights available under the existing legal framework in Sri Lanka and shall be updated from time to time.

We use Your Personal data for the management of the device donation for students and required members in the education system of Sri Lanka. By using the Service, You agree to the Processing of Personal data in accordance with this Privacy Policy.

1. Interpretation and Definitions

1.1 Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions.

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

1.2 Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access the Service or parts of the Service.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country means the Democratic Socialist Republic of Sri Lanka
• Other Government Parties means relevant governmental ministries, departments and statutory bodies of the Democratic Socialist Republic of Sri Lanka including but not limited to, the Ministry of Education, State Ministry of Education Reforms, Open Universities and Distance Learning Promotion, Ministry of Higher Education  and Ministry of Skills Development and Vocational Training.
• Personal Data means personally identifiable information requested for or gathered under Registration Data.
• Policy means this Privacy Policy.
• Registration Data is any information that is required for the access and use of the Service which may also include Personal Data.
• Service (at times referred to as the “Lightning Digital Service”) means and alternatively refers to the community platform and related platform features available through the web at lightingdigital.gov.lk, on mobile devices and tablets, and through other electronic devices.
• Service Provider means any natural or legal person who processes the data on behalf of Lightning Digital. It refers to third-party companies or individuals duly employed by Lightning Digital to facilitate the Service, to provide the Service on behalf of Lightning Digital, to perform services related to the Service or to assist Lightning Digital in analyzing how the Service is used.
• Lightning Digital (at times referred to as “We”, “Us” or “Our” in this Agreement) is facilitated by ICTA (in collaboration with its stakeholders), on behalf of the Government of the Democratic Socialist Republic of Sri Lanka.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to https://lightingdigital.gov.lk
• You or Your means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

2. Collecting and Using Your Personal Data

2.1 Types of Data Collected

2.1.1 Personal Data

In order to use the Service, We may request from You to provide Us with certain personally identifiable information or Registration Data that can be used to contact or personally identify You at the point of registering for the Service or any time thereafter, depending on the services you wish to obtain from Lighting Digital Service. Personally identifiable information requested for or gathered under Registration Data may include, but is not limited to:

• Your name as per the National Identity Card or Passport
• Sri Lankan National Identity Card number or Passport number
• Email address
• Contact Mobile Telephone number

2.1.2 Location Data

We may also collect location information from courier services and places You used to access the Lighting Digital website.

2.1.2 Information We Receive or Collect from Third Parties

We may receive or collect information about You from third parties and combine and store it on Our servers with other information We may have already received or collected from You. These third parties include places and Government / Private sector organizations You used to access websites, including Ministries, Departments, Provincial or Local Authorities, Statutory Bodies, Corporations, Government owned entities or companies incorporated under the Companies Act of Sri Lanka and Courier services, partners who have partnered with us and will be partnering with us.

Lightning Digital is not responsible for, and will assume no liability, if a third party or other entity collects, uses, or shares any information about You in violation of its own privacy policy or any applicable laws, rules, or agreements.

2.1.3 SMS Notifications

We may send You SMS notifications from time to time in order to update You about potential risks affecting You. To ensure You receive proper notifications, We will need to collect certain information as may be specified from time to time.

2.1.4 Our Use of Cookies

Lighting Digital uses a technology that is commonly known as “Cookies.” A cookie is a file Our server writes to Your hard drive that contains an alphanumeric identifier. We use the identifier in a cookie to help Us manage and report on Your interaction with the Service. Through cookies, We are able to collect information that We use to improve the Service, keep count of return visits to Our portal, collect and report on aggregate statistical information, authenticate Your login credentials, or manage multiple instances of the Service in a single browser. We may also collect other data such as the page or site that referred You to the Service, the date and time You visited the Service, and Your current IP address. The cookies We place on Your hard drive are known as “first-party cookies.”

We use both session cookies and persistent cookies. A session cookie expires when You close your browser. A persistent cookie remains on Your hard drive for an extended period of time. You may be able to remove persistent cookies by following directions provided in Your browser’s “help” section. If You do not accept first-party cookies You may still use our Service, but Your ability to use some areas of Our website, and the ability to stay logged in, will be limited.

2.2 Use of Your Personal Data

The Lightning Digital Services may use Personal Data for the following purposes:

• For the Effective management of the device donation.
• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, provide updates or informative communications related to the functionalities, services, including security updates, when necessary or reasonable for their implementation.

We may also share Your personal information in the following situations:

• With Other Government entities: We may share Your information with Government Parties and other entities for the purpose of effectively managing the devices donations, in which case We will require such parties to comply with this Privacy Policy.

2.3 Retention of Your Personal Data

Lighting Digital will retain Your Personal Data for a period of sixty (60) days for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with legal obligations (for example, if We are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal obligations and policies.

2.4 Transfer of Your Personal Data

Your information, including Personal Data, is processed by Lightning Digital. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer and its use.

Lightning Digital will take all steps reasonably possible to ensure that Your data is treated securely and in accordance with this Privacy Policy.

2.5 Disclosure of Your Personal Data

For the effective management of device donation, Lightning Digital may be required to disclose Your Personal Data to other Government entities, including Education Authorities in order to attend, manage and respond to risks associated with device donation. Under certain circumstances, Lighting Digital may be required to disclose Your Personal Data under provisions of written law or in response to valid requests by public authorities, pursuant to obligations under written law.

2.6 Other legal requirements

Lightning Digital may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation in the interest of public safety or any other obligation imposed by written law.
• Protect and defend the rights or property of Lightning Digital.
• Prevent or investigate possible wrongdoing in connection with the Service.
• Protect the personal safety of Users of the Service or the public.
• Protect against legal liability.

2.7 Security of Your Personal Data

The security of Your Personal Data is paramount to Us. However, We wish to remind You that no method of transmission over the Internet, or method of electronic storage is 100% secure. We strive to adopt industrially acceptable means to protect Your Personal Data.

2.8 Children’s Privacy

Where We require Your consent as a legal basis for processing Your information for the purpose(s) mentioned in this Privacy Policy and in the event You are below the age of 18, We may require Your parent’s or legal guardian’s consent before We process Your information. For this purpose, You are required to provide Your Parent/ Guardian’s contact details.

3. Changes to this Privacy Policy

We may update this Policy from time to time. Such updates shall be posted on the Lightning Digital portal as and when this Policy is updated. We encourage you to review this Policy periodically for any changes.

After such updates are posted, use of Our Services will be understood as consent to the updates to the extent permitted by law.