Website Privacy Policy

Introduction

C.W. Mackie PLC (“C.W. Mackie PLC”, “we”, “us” or “our”) is committed to safeguarding your personal data and ensuring your privacy. C.W. Mackie PLC processes personal data in compliance with the Personal Data Protection Act, No. 22 of 2025 (Sri Lanka), and other applicable laws.

This Privacy Policy explains what information we collect about you, how we use that information, with whom we share it, the circumstances under which we share it, and the steps we take to keep it private and secure.

1. Are You Subject to This Policy?

This Privacy Policy applies to you if you are:

A retail partner or distributor of C.W. Mackie PLC, meaning any legal entity that has acquired or uses our products or services, entered into a contract with us, or maintains a business relationship with C.W. Mackie PLC.

A person interested in our products, services or content who interacts directly or indirectly with us, for example, through our premises, customer service channels, website contact forms, social networks, websites or events.

A candidate interested in job opportunities published by C.W. Mackie PLC, including those subscribing to job alerts by email.

A journalist in contact with our press teams.

A social network user who posts or interacts with publications related to C.W. Mackie PLC.

When you provide us with personal data relating to other people, please ensure that you inform them about the disclosure of their personal data and invite them to read this Privacy Policy. We will also make reasonable efforts to do so whenever possible, for example, when we have their contact details.

2. What Types of Personal Data Do We Collect?

We may collect the following types of personal data to serve you better.

A. Retail Partners, Distributors and Suppliers

Depending on the nature of the products or services provided to or by retail partners, distributors and suppliers, we may collect:

Identification Information: Full name, NIC or passport information, nationality, place and date of birth, gender and professional photographs.

Professional Contact Information: Postal address, email address, telephone number and other contact details.

Presence on Our Premises: Vehicle registration numbers.

Image Recordings: CCTV footage and photographs.

We do not generally request sensitive personal data relating to racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data or information concerning children unless required by a legal obligation or requested by you.

B. Employment Candidates and Employees

In addition to the information listed above, we may collect:

Identification Information: Name, gender, date of birth, nationality, photographs, signature, EPF/ETF details and pension number.

Official Identification Information: National identity card number, passport number, tax identification number and driving licence number.

Contact Information: Residential address, email address and mobile or landline telephone number.

Education and Employment Data: Educational qualifications, employment history and employer details.

Behavioural Data: Information describing behavioural characteristics, such as pre-employment screening test results.

Personal Relationship Data: Information about relationships or associations with other C.W. Mackie PLC employees, such as whether family members work for the company.

We may sometimes need to collect special categories of personal data where necessary, with your consent or where permitted by law. This may include:

Health Information: Information relating to your health.

Criminal Convictions and Related Information: Information about criminal convictions, proceedings, allegations or offences.

Your personal data are collected directly from you. However, where necessary, we may also obtain personal data from other sources, including:

Businesses and Other Organisations: Your employer or the company, business or organisation you represent, relevant law enforcement authorities, and social networking sites such as LinkedIn, Facebook and Instagram.

Publicly Available Resources: Online directories, career platforms, publications, public social media posts and other publicly available information.

3. Personal Data We Collect from Other Sources

Our presence on social networks may result in the processing of some of your personal data.

As part of our legitimate interests relating to communication, crisis management and customer relationship management, we may collect:

Your interactions with our social media pages and posts, including claims and complaints.

Information contained in social media pages and posts that you have made publicly available.

We may process this information for social listening and customer relationship management, including:

Crisis Prevention: Monitoring and analysing social networks and the web using keywords to assess C.W. Mackie PLC’s reputation and understand discussions about relevant topics.

Crisis Management: Analysing issues relating to publications, responding to comments, detecting and reporting fake accounts or publications, and investigating serious allegations or claims.

4. Why and on Which Legal Basis Do We Use Your Personal Data?

We process personal data for the purposes described below, subject to applicable laws.

A. Legal and Regulatory Obligations

We process personal data when necessary to comply with legal and regulatory obligations, including responding to official requests from duly authorised public or judicial authorities.

B. Contractual Obligations and Pre-Contractual Measures

We may process personal data when necessary to enter into or perform a contract with you or to take pre-contractual measures at your request. This may include:

Providing information about our products and services.

Enabling access to our digital services.

Assisting with your enquiries and requests to improve customer experience.

Where information is mandatory, failure to provide it may prevent us from offering the relevant product or service. Optional information will be identified where applicable, and choosing not to provide it will not affect your access to our services.

C. Legitimate Interests

We may process personal data to pursue our legitimate interests or those of a third party, provided that these interests are balanced against your rights and freedoms.

These purposes may include:

Keeping our premises and people safe through identity verification, building-access security checks and CCTV monitoring to prevent and detect fraud, theft and other crimes, and to support health and safety compliance.

Managing IT infrastructure, business continuity and information security.

Responding to suspected breaches of IT security rules.

Securing our IT systems and preventing fraud.

Preparing aggregated statistics and conducting tests, such as A/B testing, to improve existing products and services or develop new ones.

Communicating and interacting with you through channels such as email and our websites.

Managing our activities and presence on social networks.

Analysing habits and preferences across communication channels, including email, website visits and social networks.

Administering contests, giveaways, competitions, promotional campaigns and events.

Managing and delivering prizes won through competitions.

Communicating company news and information about our activities.

Responding to enquiries.

Improving and personalising your experience on our websites and applications.

Retaining and producing records where necessary to exercise or defend our legal rights or comply with laws, regulations or legal proceedings.

For more information about the legitimate interests pursued, please contact us using the details in Section 11.

D. Recruitment and Employment Applications

We may also process personal data for recruitment purposes, including:

Reviewing job applications and assessing skills, qualifications and suitability.

Conducting pre-employment checks, background checks and reference checks.

Communicating with applicants about their applications and potential career opportunities.

Improving recruitment and applicant screening procedures.

Performing related administrative, auditing and risk management activities.

E. Consent

For certain processing activities, we will provide specific information and request your consent where required. You may withdraw your consent at any time, subject to applicable laws.

Your data may also be aggregated into anonymised statistics and shared with partners or service providers where necessary. Recipients of genuinely anonymised information will not be able to identify you from that information.

5. Who Do We Share Your Personal Data With and Why?

We may share your personal data within the C.W. Mackie PLC group, with consultants, service providers, business partners and other third parties for the purposes described in Section 4, or where required by law or requested by an authorised authority.

We limit how and with whom we share personal data and take appropriate steps to maintain confidentiality and protection. Sharing will take place in accordance with applicable laws and the relevant legal basis.

Recipients may include:

Companies within the C.W. Mackie PLC group.

Our advisers and consultants.

Our service partners and suppliers.

Third-party business partners.

Government and law enforcement authorities.Courts, tribunals and other relevant forums for legal recovery or the establishment, exercise or defence of legal rights.

6. How Do We Store Your Personal Data?

We may collect and store personal data electronically or physically, depending on the requirements.

We may store, share and transfer personal data within C.W. Mackie PLC and with third parties to support our processes, business operations and legal or regulatory obligations. This may include cloud storage and cross-border transfers to jurisdictions with different data protection laws, subject to applicable data protection requirements.

7. How Long Do We Keep Your Personal Data?

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected and in accordance with applicable laws and regulations.

Retention periods may vary depending on the type of data and legal or statutory requirements. As a general guideline:

Data collected for legal and regulatory compliance are retained in accordance with applicable legal requirements and industry standards.

Information used for customer communication purposes is retained until you withdraw your consent or request erasure, subject to applicable laws.

We regularly review our data retention practices. Once the applicable retention period expires, personal data will be securely deleted or anonymised in accordance with applicable requirements.

8. How Do We Protect Your Personal Data?

We implement appropriate technical, physical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration or destruction.

We train our staff to maintain privacy and security standards. We also require third parties carrying out work on our behalf to comply with appropriate standards, protect personal information and apply suitable measures when using or transferring information.

9. How Can You Control the Processing of Your Personal Data?

Subject to applicable law, you may have the following rights regarding your personal data:

Right of Access: Request access to your personal data and information about how it is processed.

Right to Correction: Request correction or completion of inaccurate or incomplete personal data. Supporting documentation may be required in some cases.

Right to Deletion: Request deletion of your personal data to the extent permitted by law.

Right to Object: Object to processing based on legitimate interests on grounds relating to your particular situation. We will cease processing unless compelling legitimate grounds exist or processing is necessary for legal claims.

Right to Review Automated Decisions: Request a review of decisions based solely on automated processing or profiling that have legal effects or significantly affect you. You may challenge the decision, express your views and request review by a competent person.

Right to Withdraw Consent: Withdraw consent where processing is based on your consent.

Right to Complain: Submit a complaint or appeal to the Data Protection Authority regarding a decision relating to your data protection rights, where applicable.

To exercise these rights, please contact our customer service hotline or contact our Data Protection Officer using the details in Section 11.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal and regulatory reasons.

The latest version of this Privacy Policy will be available on our website. Please visit this page periodically to review any updates.

11. Contact Us

If you require further information or have questions or concerns about this Privacy Policy or your personal data, please contact our Data Protection Officer:

Data Protection Officer
C.W. Mackie PLC
36, D.R. Wijewardena Mawatha, Colombo 10
Email: info@cwmackie.com