This policy explains when, why and how we collect personal information from the people who visit our website, sign up or purchase any of our services or request or contact us in any other manner. The policy also details the conditions under which we may disclose the information to others and how we keep it secure.
- We will never sell your data on.
- We will never share your data for marketing to by any third parties.
- We will always keep your personal data secure using strong encryption, abiding by data protection rules and by implementing good security practice.
- We will never send you direct email marketing without your consent, our newsletter requires you to explicitly opt-in, you can opt-out at any time using the unsubscribe link contained within the email or through your client area by selecting Communications > Manage E-mail Subscriptions
If you are ever concerned or have question about how your personal data is collected or used, please contact us at email@example.com.
2. About us
W3 DATA TECHNOLOGIES PVT LTD is registered at the following address:
00500, Sri Lanka
Company number: WA/100710
For the purpose of the Data Protection The Computer Crimes Act 2007 Sri Lanka (the Act) and GDPR (General Data Protection Regulation), the data controller is W3 DATA TECHNOLOGIES PVT LTD, a company Registered in Western Province of Sri Lanka under Companies registration number WA/100710. Our registered office address is W3 DATA TECHNOLOGIES PVT LTD, No 9, Park Gargens, Colombo 5, 00500 Our nominated representative for the purpose of the Act is Mr. Parinda Dissanayake.
3. When do we collect your personal data?
We may collect data about you in the following ways:
- By filling in forms on any of our websites, this includes information provided at the time of registering to use our websites, subscribing to any of our services, posting material or requesting further services. We may also ask you for information when you enter a competition or promotion sponsored by us or if you report a problem with our site.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of transactions you carry out through our site and of the fulfillment of your orders.
- Visiting our sites, including, but not limited to, traffic data, location data and other communication data required for our own security, diagnostic, authentication and billing.
4. What personal data do we collect
If you are simply viewing our website then we will collect the following information within our logs:
- IP Address (See cookies and IP addresses)
If you sign up to use our services we will then collect the following information:
- Email Address(s)
- Telephone number(s)
- IP address
- Payment details
While not actively collected we may store any other personal information that you may disclose during live chat, tickets or emails.
5. Cookies and IP Addresses
We collect IP address information for security (DDoS prevention, anti-hacking and fraud prevention), diagnostics and statistical analysis of traffic used for improvements to the performance and usability of our services, for GDPR purposes we collect this information under legitimate interest.
A cookie is a small file saved on your computer that is used to help store preferences and other information that is used by websites you may visit.
- Authentication of users when logging in or out of our services.
- Analysis of traffic to our website via Google Analytics (see Google Analytics).
- Tracking of website preferences.
- Third party services such live chat.
You can block cookies by activating the setting in your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies you may not be allowed access to all or parts of our site.
6. Where we store and process your personal data
The data that we collect from you is stored in the UK, EU, US and SG Data Centers but it may be processed by staff operating outside the EEA (European Economic Area) who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
Any customer have full right to decide which datacenter they are going to host their services and we will not move their Server or services to other datacenters.
By submitting your personal data, you agree to the processing of this data outside of the EEA.
7. How we protect your personal data
We treat all data with the utmost care and take appropriate steps in compliance with data protection regulation to ensure it is kept safe.
- All data we collect is done so over encrypted connections (https).
- All data is stored behind state of the art firewalls managed by our security team.
- All systems storing personal data have access logging.
- All passwords are encoded at rest.
- All systems are subject to regular penetration testing and are monitored for vulnerabilities and attacks.
8. Uses we make of personal data
We use information held about you in the following ways:
- To verify your identity.
- To provide you with the products and services you have purchased from us.
- To carry out our obligations arising from any contracts entered into between you and us.
- To ensure that content from our site is presented in the most effective manner for your device.
- To respond to queries.
- To provide you with information, products or services that you request from us where you have consented to be contacted.
- To notify you about changes to our services.
- To send you marketing emails where you have given explicit consent.
- To display personalised Ads from us.
- To prevent fraud.
- To detect, prevent and diagnose potential security breaches.
9. Legal basis for the collection and processing
Data protection law sets out the conditions under which personal data can be collected and which we use as the basis for collection and processing, these include:
When you purchase a service, we need to collect personal data to fulfill our legal contractual obligation, for example: so we can manage and invoice your account and contact you for technical support purposes.
The law requires we collect and process data for certain purposes such as for keeping financial records (i.e. invoicing) and that we can comply with law enforcement requests for data.
We collect data under legitimate interest in a way that is reasonably expected as part of the day to day running of our business.
For example, we collect and log IP addresses for fraud protection and security as well as analysis of our site usage.
In certain cases, we may collect and process your data with your consent, for example our newsletter and hot offers emails. Consent to receive these can be withdrawn at any time.
10. How long we keep personal data
Your data will be kept until it is no longer required for the purpose of its collection.
At the end of the retention period the data will either be deleted or anonymized so it can no longer be linked back to an individual.
Personal data linked to purchases or any other financial transaction are kept for a minimum of 5 years as required by Sri lanka law to retain financial data.
11. Who we share personal data with
Like many websites we use a number of third-party services for functionality such as email sign-up and payment processing. The following is a list of companies we share data with on a day to day basis. This list does not include services we share anonymous data with or that provide services on an ad-hoc basis such as IT contractors. All the suppliers below have been carefully selected to ensure they provide suitable protections under GDPR.
tawk.to inc provide our live chat service available on our website, if you contact us by live chat your conversation will be recorded and archived on tawk.to inc servers, these archives may include personal information that you may have disclosed during a conversation.
Please note: if your conversation requires further action, for example if it is a technical support query, then your live chat transcript maybe copied to our ticketing system for future reference.
Our newsletter and marketing email lists are managed through Mailchimp, these emails are opt-in, when you opt-in to our newsletter your name and email address will be added to our mailing list which is held securely on mailchimp’s servers, by opting in you agree to:
- Transfer your contact information to MailChimp
- Store your contact information in our MailChimp account
- To being sent marketing emails from our MailChimp account (These will be for our services only)
- To have tracked interactions for email marketing and ad placement purposes.
Emails are initiated and managed by ourselves.
Please see the section entitled “Newsletter and Marketing Emails” for information on how to opt out of these emails.
Stripe is used to provide secure credit and debit card processing services. If you choose to pay by this method then your card details, name, address and email will be transmitted to Stripe securely for the processing of payment and for fraud prevention.
If you choose to store your card details then this will be saved alongside your name, address and email on Stripe’s servers.
Maxmind is used for fraud prevention, if you make a purchase your IP address will be shared with Maxmind to determine the approximate location the order is being placed from and if the IP is a known source of fraud.
If you purchase an SSL certificate you will be required to provide your name, address and contact details which will be used by Globalsign to register the certificate and perform vetting. GlobalSign may contact you by email, phone or post as part of the vetting process.
Tucows (Enom & OpenSRS)
Tucows are a domain registrar and owners of Enom and OpenSRS, when you register a domain with us you are required to provide contact details that are used to register your domain against. It is important to note that these details will be visible within the publicly searchable database called “whois”, we strongly advise customers when making a GTLD (Generic top-level domain) purchase to choose the whois privacy option which anonymises the whois database entry.
(It should be noted that prior to the 25th of May 2018 all personal whois data will be anonymised by Tucows to comply with GDPR.)
Nominet are the registration authority for .uk and .co.uk domains, when you register a .UK domain you are required to provide contact details that are used to register your domain against. It is important to note that these details will be visible within the publicly searchable database called “whois”, if registering the domain as an individual you can opt out of having details listed in the whois database, you cannot opt-out if registering for commercial use.
(Important: prior to the 25th of May 2018 all personal whois data will be anonymised by Nominet to comply with GDPR.)
We use Microsoft Office 365 for document storage, email and collaboration, in some instances your personal data may be stored on office 365 servers, any data stored there is encrypted and controlled by us.
12. Ads and Remarketing
We use Google AdWords remarketing services on our blog and forum to display our ads on third party websites (including Google) to previous visitors of those pages, this is done in the form of a cookie that contains anonymous data regarding your visit.
If you have a google account you can opt-out of receiving these ads here http://www.google.com/settings/ads
Google are also a member of the NAI (Network Advertising Initiative), you can also use their site to opt out here http://www.networkadvertising.org/managing/opt_out.asp
13. Google Analytics
Like many websites we use Google Analytics to collect anonymous data about the users of our sites such as how often they visit, what pages they visit, what time they visit, how long the stay and what country they are visiting from.
This data is collected using cookies and from your IP address, the resulting statistics are used for the following purposes:
- Improving website usability
- Tracking the success of marketing campaigns
- Pattern analysis
You can prevent Google Analytics from collecting this information by installing the google opt-out browser addon: https://tools.google.com/dlpage/gaoptout
To learn how Google uses data collected from our own and partner sites please see the following link: https://policies.google.com/privacy/partners?hl=en-GB&gl=uk
14. Newsletter and Marketing Emails
All our marketing emails are opt-in, we will never sell on your details or pass them on to third parties for marketing purposes. If you have opted in to receive these then you can opt out at any time in one of three ways:
- If you have received an email, click on the unsubscribe link located in the email footer.
- Log into your client area and select: Communication > Manage E-mail Subscriptions
- By contacting our customer services department.
15. Disclosure of your personal information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in right to information act, no. 12 of 2016.
We may disclose your personal information to third parties:
If W3IN1WEB.COM or substantially all of its assets are acquired by a third party, in which case personal data held by it (W3IN1WEB.COM) about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply Terms and Conditions and other agreements; or to protect the rights, property, or safety of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
16. External links
Our site may, from time to time, contain links to and from the websites of our partners. 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.
17. Your rights under GDPR
Under GDPR (General Data Protection regulation) you have a number of rights relating to your personal data, these will come into force on the 25th May 2018, for further information please see https://ico.org.uk
Right to Restrict Processing
You have the right to request we restrict processing of your personal data where there is no legitimate interest for us to do so:
- Where the accuracy of the personal data is contested, to restrict the processing until such time as the accuracy has been sufficiently verified.
- Where you object to the processing (See Right to Object), and where we are considering whether there are legitimate grounds to override the request.
- When processing is unlawful and you oppose erasure and request restriction instead.
- If we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.
You can exercise the right at any time by contacting our team (see Contacting Us).
Right of Access (Access to Information)
The GDPR Act gives you the right to access information held about you.
You can exercise this right by contacting us (see Contacting Us).
We are required to verify your identify before processing any right to access request, once verified the data shall be provided within 28 days.
The data shall be provided free of charge however an admin fee may be applied where a request is manifestly unfounded or excessive, particularly if it is repetitive.
Right to Erasure (Also known as the right to be forgotten)
As an individual you have the right to request the erasure of any data we hold on you, this is not an absolute right, for example it does not override our requirement under Sri lanka law to keep financial data such as invoice information.
You can make a request where your personal data is no longer necessary in relation to the purpose for which it was originally collected/processed, for example if you cancel all services you have with us.
To make a right to erasure request please contact our customer services team (see Contacting Us).
Right to Rectification
The GDPR provides the right to have any personal data rectified that may be incorrect or incomplete.
Customers can update their own personal details via the client area however if this is not sufficient please contact our customer services team (See contacting Us).
Right to Object
You have the right to object to the processing of your personal data where there is no legitimate or lawful reason to do so.
To make a right to object request please contact our customer services team (see Contacting Us).
19. Contacting us
- Existing customers can contact us by creating a ticket through their client area.
- Email us at firstname.lastname@example.org