Daskalos.lk, located in Ja-Ela, Sri Lanka, respects User’s rights regarding their privacy and information, taking great care with any personally identifying information. As a Sri Lanka-domiciled entity, the Daskalos.lk platform is subject to the laws of Sri Lanka and regulations in Asia. The Personal Data Protection Act No. 9 of 2022 ('PDPA') was passed in the Parliament of Sri Lanka ('the Parliament') and was certified by the Speaker on March 19, 2022. Section 1 of the PDPA provides for the mechanism and specific periods by and on which the PDPA would gradually come into force as follows. This act applies to the safeguarding and processing of personal data that could be used to identify any citizens of Sri Lanka. Daskalos.lk is committed to complying with its legal obligations in this regard, not just to data subjects (Users) in Sri Lanka but to extend the same courtesy to all Daskalos.lk Users worldwide.
This policy is based on obligations created through the PDPA in Sri Lanka and other equivalent legislation worldwide such as the California Consumer Privacy Act in the US.
The Daskalos.lk platform may collect and process personal data relating to past and present users and learners in the course of business. Daskalos.lk collects data directly from the User input but also in automated ways such as through system logs, cookies, web beacons, and integration with third-party service providers. Processing of data includes collecting; recording; storing; altering; disclosing; destroying; and blocking. This policy governs Daskalos.lk’s approach to data and does not apply to any third-party organizations which may have integrated their systems to the Daskalos.lk platform.
Personally, Identifying Information (PII) may be required to uniquely identify a User upon Registration (e.g., a personal email address) and other information may be required to complete purchases and receive certification if requested. You may also be invited to create a personal profile and resume (including date of birth, existing education, work experience, and career ambitions) and to generate or supply other personal information (such as completing personality, psychometric, and workplace assessments) to build out your profile to determine your suitability for different careers, job opportunities, and to establish your own tailored learning pathway. You will have the option to share or unshare some or all of this information in your own public profile.
Personal data is stored within your User account on the platform and access is completely restricted via encrypted networks and access permissions in order to ensure the highest levels of confidentiality and protection. No personal data is available to download or remove from the platform by employees or third parties, and Daskalos.lk ensures that only authorized personnel have online access to a User’s account data.
Users may decide to post comments on the Daskalos.lk Blog or interact with other Users in a way which is public or widely available to Daskalos.lk Users through postings, sharing, course reviews, direct communications, giving testimonials, uploading photos, or commenting on different parts of the Daskalos.lk platform (“Shared Content” or “Public Posting”). Daskalos.lk will collect and store Public Postings and Shared Content which will become publicly available or viewable by others. When you share content or make a public posting you are consenting to granting Daskalos.lk a non-exclusive right and license to reproduce, distribute, publicly perform, offer, market, and otherwise use and exploit the Public Postings and Shared Content. However, Daskalos.lk is not responsible for how other Users may use such publicly available information or otherwise accessible to others who have access to the Services. Users are expected to use their discretion when making such posts. In the event that a User is selected as "Learner of the Day" or "Learner of the Month", the User agrees to allow Daskalos.lk to publish their Registration Information (except for your email address), Profile Information, and Course Information as well as your response to the accolade for marketing purposes and/or via Daskalos.lk Services.
After registration, a User can enroll in a course offered by Daskalos.lk or its affiliated Publishers. Aggregated data on age, gender (where available), and country of origin is shared with affiliated Publishers relating to the Users enrolled in the courses they teach and is subject to a legal agreement between Daskalos.lk and each individual Publisher. There is no way for a Publisher to access or derive User-level information from this aggregated information.
Daskalos.lk processes certain data relevant to the publication and playback of course content by publishers and learners. Certain data is collected to ensure Users, publishers, and learner progress are uniquely identified and accurate records are maintained in order to deliver the Daskalos.lk learning service and to comply with relevant legal obligations. This will include regular emails to keep Users informed of their progress and make various suggestions and recommendations. Patterns of usage behavior and course content evaluation are also collected and stored as metadata to help Daskalos.lk and Publishers improve the services and offer the most appropriate content and courses to registered Users.
All User personal data is stored securely on third-party cloud-based electronic storage and safeguarded. User purchases of physical goods require a home delivery address to process orders. Daskalos.lk uses payment processing and fulfillment partners who will receive sensitive PII to enable payment collection and, when necessary, physical fulfillment. Highly sensitive data, such as credit card information and passwords, are never received by Daskalos.lk (e.g., when you allow third-party authentication via your social media sign-on, or by choosing third-party payment providers such as PayPal or Stripe, that isolate Daskalos.lk from your payment details). Recurring payment details are stored by a third-party payment provider that you choose and not by Daskalos.lk. Although Daskalos.lk allows Users to register with their social media single sign-on (such as Facebook, Google, LinkedIn, etc.), the information available on these third-party platforms is governed by their terms and information sharing practices. Daskalos.lk only takes necessary information from these social platforms (i.e., your name, email address, and country for legitimate purposes) and does NOT take any other personal or social information on your friends and contacts from these platforms.
Daskalos.lk tests and operates a number of analytical tags, scripts, and tracking pixels (also known as web beacons) from third-party providers such as Google, Facebook, Bing, and Hotjar to enable browser and mobile analytics that measure page views and sessions. This helps Daskalos.lk understand User behaviors as they visit, navigate, and leave the Daskalos.lk platform.
Daskalos.lk provides free learning supported through advertising services managed by third parties. Daskalos.lk both buys online ads and sells online ads through third-party providers (e.g., Google AdWords, Bing, Facebook Ads, and Google AdSense). Cookies and tracking pixels are used by advertising service providers as independent third-party data controllers to enable personalized advertising to the User based on intent, search history, and demographics built up by advertising service providers over time. Daskalos.lk has no access to these third-party cookies or tracking technology nor any control over how third- party advertising service providers use the data they collect.
As an internet-based service, Daskalos.lk collects and monitors web server log files for usage and behavior patterns over time. User device information and IP addresses are also gathered to understand platform traffic flows, how each User interacts with Daskalos.lk Services, and to ensure the right balance of technical support, customer service resources, and device expertise is available to Users.
Daskalos.lk also stores and uses cookie information (a piece of text saved on each User’s device) to help track unique user sessions and to personalize Daskalos.lk Services for the User. Daskalos.lk stores Preference, Security, Functional, and Session cookies to tailor the usage experience, securely automate User login, and enable purchase transactions. Daskalos.lk uses web beacons to help monitor email communications with our registered Users to understand which messages are successfully delivered and read.
By using Daskalos.lk Services and directly inputting your information on the platform, you, the User, are consenting to the collection and use of your data by Daskalos.lk. You have full access to your information through your user account, and are responsible for ensuring that you keep your personal details up to date through the platform. You have the power to modify your personal data and the power to deactivate your account and request the removal of your personally identifiable information when you delete your account. You may modify your email client, browser settings, or use browser add-ons to control how cookies, beacons, and other third-party services work. Privacy settings are also provided on your mobile device operating system to give you more control over your data. Reducing the level of data shared and advertising options may reduce the quality of, or disable, some or all Daskalos.lk services.
To understand and control how the digital advertising industry uses your data please visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link. These help you to opt out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Opting out means that your personal data is not used to personalize ads. Opting out does not mean you will not receive ads. Daskalos.lk has no affiliation nor control over these industry initiatives and how you use these tools is your own responsibility.
Daskalos.lk recognizes the privacy interests of children. Parents and guardians need to take an active role in their children's online activities and interests. Digital consent is generally not legally recognized for children under the age of 13, or under the age of 16 where such children reside in Asia. Parents and legal guardians should not allow their children defined as such to register, enroll and learn on the Daskalos.lk platform without full-time supervision. Daskalos.lk reserves the right to delete any User account that we discover was created by a child unable to give digital consent. If a parent or guardian discovers that Daskalos.lk has unlawfully collected personal information from a child, please contact our data protection officers who will take all reasonable steps to delete such information promptly.
Daskalos.lk is under a legal obligation to keep certain data for a specified period of time. Furthermore, Daskalos.lk aggregates data and anonymizes User accounts that are deleted so that it is no longer reasonably associated with an identified or identifiable natural person. Such Other Information is used by Daskalos.lk for other relevant business purposes for as long as necessary. This may include keeping Other Information after the User has deleted their account for whatever period of time needed for Daskalos.lk to pursue its legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce commercial agreements.
Daskalos.lk takes all reasonable steps to ensure that appropriate security measures are in place to protect the confidentiality of electronically stored data. The platform is large and public and subject to regular attack by hackers. The platform has been hardened extensively over time; however, no online system is perfect or immune from breach. Daskalos.lk has appropriate security measures in place to protect against unauthorized access. Safeguards are applied to the processing and retention of data. These include:
The platform databases are not accessible directly by employees or software developers other than authorized DevOps administrators. Multi-factor authentication is required for all authorized DevOps administrators to ensure access to sensitive data is restricted to the maximum possible. Security measures will be reviewed from time to time, having regard to the technology available, the cost, and the risk of unauthorized access. Customer Support employees will have access to a certain amount of personal data relating to users and other third parties. Employees must not disclose User’s personal data, except where necessary in the course of their employment or in accordance with law. They must not remove or destroy personal data except for lawful reasons and with the permission of the organization. Any breach of the data protection principles is a serious matter and may lead to disciplinary action up to and including dismissal. All Daskalos.lk employees must adhere to the following data protection principles:
Users have an obligation to keep their User account credentials sufficiently strong, protected for safe-keeping, and private to themselves to prevent unauthorized access. Users must monitor and control all activity on their account. If you suspect a breach of your account, please change your password immediately and contact Daskalos.lk customer support so that the impact can be minimized. Were a data breach to occur and if such a breach puts individuals’ personal rights and freedoms at risk and Daskalos.lk is unable to contain those risks, all affected individuals will be notified expeditiously. Furthermore, Daskalos.lk’s data protection officers will inform the relevant data protection authority in Sri Lanka so that they are aware and can monitor the response.
The directors of the company are ultimately responsible for your data and have nominated a named Data Protection Officer for Daskalos.lk (“DPO”). The DPO is responsible for assisting the organization in monitoring and maintaining compliance with data protection legislation.
Users across the world may have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete, or correct this Information. Your Daskalos.lk User Account provides the settings and self-service tools needed for these requests. Please contact Daskalos.lk Customer Services if you wish to get a complete copy of all your electronic data held about you as a User. If a User opts to delete their User account, Daskalos.lk will delete all PII, Profile and Resume data, and will irreversibly anonymize their learner record.
There is no charge to use Daskalos.lk’s User account self-service tools. However, the company reserves the right to charge a fee to process any further Subject Access Request. The organization will, in most circumstances, provide this data within one month. In some cases, due to the complexity of the request or the number of requests being handled by the organization, the organization may require a further two months to provide this data. Users are only entitled to access data about themselves and will not be provided with data relating to other users or third parties. However, some user data may have been disclosed publicly on Daskalos.lk forums, for example. It may be possible to block out User data relating to a third party or conceal the User’s identity, and where this is possible the organization will endeavor to do so. A user who is dissatisfied with the outcome of an access request has the option of referring a complaint to the relevant data protection authority in Sri Lanka.
Users may have the right to object to data processing that is causing them distress and/or to make corrections to personal data which is inaccurate. Where such objection is justified, Daskalos.lk will cease processing the data unless it has a legitimate interest that prevents this. Daskalos.lk will make every effort to alleviate the distress caused to the individual. An objection should be made in writing to the Data Protection Officer, outlining the data in question and the harm being caused.
Based in Sri Lanka, Daskalos.lk operates on a global basis, and it may be necessary in the course of business to collect or transfer User personal data across state boundaries, to share data with other group companies in countries outside Asia, and to share information with third-party service providers. The transfer of such data is deemed necessary for the management and administration of your User Account and delivery of Daskalos.lk Services. Some states do not have comparable data protection laws to Sri Lanka or Asia. When data transfer is necessary, Daskalos.lk will take steps to ensure that the data has an equal level of protection as it would in Sri Lanka or as expected within other leading international jurisdictions. Furthermore, Daskalos.lk will only transmit data to companies that agree to guarantee the same level of protection. For more information, please contact Daskalos.lk’s Data Protection Officers.
Daskalos.lk has completed a Data Protection Impact Assessment and put the necessary policy and procedures in place to minimize risks to users' data privacy and maximize data protection. This policy will be reviewed from time to time to take into account changes in the law and the experience of the policy in practice. Updates will be posted to the website when available. Material updates will be circulated to each User via the registered User email on the User Account. Continued usage of the Daskalos.lk Service is deemed to be User acceptance of this policy as permitted by applicable law.