Commercial Excellence collects information about you when you use our internal mobile app and other associated digital services (collectively, the “Services”) provided in connection with our business operations. The personal information we collect from you will be handled with utmost care, providing adequate protection and confidentiality, and will solely be used to facilitate internal operations, supplier communications, and other business-related services. This Privacy Statement applies to information collected and used by Commercial Excellence.
SCOPE AND APPLICATION
This Privacy Statement (“Statement") applies to authorised users of the Commercial Excellence mobile app including employees, agents, contractors, and approved third-party suppliers operating in Sri Lanka.
COLLECTION OF INFORMATION
We collect information you provide directly to us, such as when you:
(a) create or modify an account with us or
(b) contact customer support
(c) otherwise provide us with your personal data or
(d) use internal features or services connected to Commercial Excellence in the course of your duties or business interactions with the company
This information may include: name, email, phone number, postal address, profile picture, employee or supplier ID, payment method and other information you choose to provide.
When you access the Commercial Excellence mobile app, we will automatically collect your data, which may include:
(a) browser type
(b) IP address
(c) Language
(d) Operating system
(e) Cookies and the ID location of your device
(f) Demographic and geographic information
(g) Transaction information
(h) The pages/ videos you view
(i) Length of time spent on pages/videos
(j) The services you use and the manner in which you use such services
(k) The date and time of your visit
(l) Metadata, log files, error logs,
(m) Hardware and software information
(n) Usage and preference information
This data is collected for analysis and evaluation in order to improve Commercial Excellence, the services we provide and to enhance your experience by providing you relevant operational features and updates.
To the extent that such data is maintained in a manner that identifies your name or contact information, it will
be treated as personal data. Any other data will be treated as non-personal data.
IMPORTANT INFORMATION ABOUT PLATFORM PERMISSIONS
Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Commercial Excellence app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the Commercial Excellence app seeks before you first use the app, and your use of the app constitutes your consent. Sometimes these permissions require more explanation than the platforms themselves provide, and the permissions we request will change over time.
INFORMATION WE COLLECT FROM OTHER SOURCES
We may also receive information from company systems, HR records, or supplier databases and combine that with information we collect through our Services, such as if you choose to link, create, or log in to your Commercial Excellence account with a payment provider (e.g., Google Wallet) or social media service (e.g., Facebook), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.
USE OF INFORMATION
The information we collect from users helps us improve our app, Services, from user-friendliness of the site to customer service requests. This also includes directly contacting users regarding their inquiries. The information collected from users helps us better understand our audience and develop personalized user experience.
Depending on user permission and information, data collected may be used for:
i. Creating or maintaining any account or profile you may have with us;
ii. Tracking your activity on the Commercial Excellence mobile app;
iii. internal announcements, company updates, or relevant operational communications;
iv. Distributing relevant materials such as policies, safety notices, operational documentation or
training materials;
v. Carrying out research and analytics on our users demographics and behaviour;
vi. Personalise and enhance your user experience
vii. To personalise our communication we may send you information we think you may find useful or which you have requested from us or have expressed an interest in;
viii. Enforcing our terms of use;
ix. Communicating with you regarding your account and the latest developments in Commercial Excellence
x. Delivering any Products and/or Services or information requested by you;
xi. Responding to complaints or account enquiries;
xii. Any other related activity (such as news and updates).
However, users who do not wish to receive such information can unsubscribe from them.
How We Manage Your Data
Unless permitted by applicable laws and regulations, we will obtain consent from you if we wish to use your
Personal Identification Information for purposes other than those stated in this Privacy Policy.
"Personal Identification Information" means any personal Identification information provided by you including but not limited to Name, Contact Number, Email Address, National Identity Card/ Passport/ Driving License Number, Address, photographic image, and information obtained by us in the course of providing any Products and/or Services.
Your Personal Identification Information will be shared solely with Commercial Excellence, its managing and associate Companies and relevant persons providing essential functions to Commercial Excellence.
No Personal Identification Information obtained by us is sold or made available to third parties unless we are legally required to do so. We will not share non-public personal information with non-affiliated third parties without your prior consent.
If you have provided consent and wish to withdraw it or if you prefer not to receive marketing communications from us in any form, please inform us by writing to the address in the Contact section set out below. Any such request should clearly state details of the personal data in respect of which the request is being made.
SHARING OF INFORMATION
We may share the information we collect about you, including Personal Identification Information as described in this Statement or as described at the time of collection or sharing, including as follows:
We may share your information:
• With our managing and associate companies, companies that provide services or conduct data
processing on our behalf, or for data centralisation and / or logistics purposes;
• With service providers, consultants etc who need access to such information to carry out work on our behalf; All third-party service providers are contractually obligated to maintain confidentiality and data protection standards.
• In response to a request for information by a competent authority if we believe disclosure is in
accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
• If we otherwise notify you and you consent to the sharing; and
• In an aggregated and/or anonymised form which cannot reasonably be used to identify you.
DATA INTEGRITY
You are responsible for the accuracy and completeness of the Personal Identification Information provided to us. However subject to the extent you have made available to us, we will make reasonable measures to maintain complete, current, and accurate records of your Personal Identification Information. You are obliged to bring to our attention of any change or alteration to the said information for which shall be corrected within a reasonable time from the receipt of written notification by you of the same.
USE OF DEVICE IDENTIFIERS
We may use device identifiers, local storage, and analytics tools to understand usage patterns and enhance your experience. These technologies serve similar purposes to browser cookies.
EXTERNAL LINKS
If any part of our app contains links to other websites or are integrated with social sharing features or other related tool, which let you share actions you take on our app with other apps, sites, or media, those sites may not operate under this Privacy Policy. You are advised to check the privacy statements on those websites, apps and social sharing platforms to understand their policies on the collection, usage, transferal and disclosure of personal data.
BREACH OF INTERNET SECURITY
We together with our directors, officers, employees or affiliates’ will not be responsible if unauthorized persons breach our security control measures resulting in the app being hacked or presenting inaccurate information etc, despite our best efforts to maintain the integrity of our app.
CHANGES TO ACCOUNT INFORMATION
You may correct your account information at any time by logging into your account. If you wish to cancel your account, you may do so. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance if we believe you have committed fraud or violated our Terms, we may seek to resolve the issue before deleting your information.
ACCESS RIGHTS
Commercial Excellence will comply with individual’s requests regarding access, correction, and/or deletion of the personal data it stores in accordance with Sri Lankan data protection obligations and internal company policies.
CONTACT INFORMATION
We may also seek permission for our app’s collection and syncing of contact information from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, iOS users can later disable it by changing the contacts settings on your mobile device. The Android platform does not provide such a setting.
RIGHT TO CHANGE THE POLICY
We reserve the right to change this Privacy Policy as a whole or any part hereof from time to time at our sole discretion with or without notice to reflect changes in internal procedures, regulatory obligations, or technical enhancements. We encourage you to periodically review the Statement for the latest information on our privacy practices.