Introduction
Welcome to the Privacy Policy of SriLankan Airlines Limited (SriLankan).
SriLankan is a company registered in Sri Lanka with the company registration number
PB 67 and the registered office is at “Airline Centre”, Bandaranaike International
Airport, Katunayake, Sri Lanka.
Your privacy is important to us and we want to assure you that that the Personal
Data we collect about you will be treated with care. This Privacy Policy will inform
you about how we look after your Personal Data when you avail the services of SriLankan
through various means such as visiting our website, purchasing a ticket through
our website or the Global Contact Centre, from one of our offices or agents, and
tell you about your privacy rights and how the law protects you.
This Privacy Policy is provided in a layered format so you can click through to
the specific areas set out below. Alternatively you can download a pdf version of
the policy here. By continuing to avail SLA’s services, you agree that you have
read, understood and agreed to this Privacy Policy.
Definitions
This Privacy Policy uses a number of definitions which are set out below:
Comply with a legal or regulatory obligation: processing your personal
data where it is necessary for compliance with a legal or regulatory obligation
that we are subject to.
Legitimate Interest the interest of our business in conducting
and managing our business to enable us to give you the best service/product and
the best and most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process your
personal data for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you (unless we have
your consent or are otherwise required or permitted to by law).
Performance of Contract: processing your data where it is necessary
for the performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.
Personal Data: any information which identifies an individual
or information relating to an individual who can be identified (directly or indirectly)
from that data alone or in combination with other identifiers we possess or can
reasonably access. Personal Data does not include anonymous data or data that has
had the identity of an individual permanently removed.
Processing or Process: any activity that involves the use
of Personal Data. It includes obtaining, recording or holding the data, or carrying
out any operation or set of operations on the data including organising, amending,
retrieving, using, disclosing, erasing or destroying it. Processing also includes
transmitting or transferring Personal Data to third parties.
Special Categories of Personal Data: any data which reveals details
about sensitive issues such as an individual’s race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union membership,
information about health or genetic and biometric data.
Important Information And Who We Are
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how we collect and process your
Personal Data through your use of this website, global contact centre, purchasing
air tickets, including any data you may provide through this website when you make
or amend a flight booking, join our Frequent Flyer Programme of ours and participating
in the frequent flyer programme of any member of oneworld Alliance,
purchasing any holiday package from us, obtaining any other value added services
from us, participating any survey, or sign up to our newsletter.
This website is not intended for children and we do not knowingly collect data relating
to children unless provided by the parents or guardians.
It is important that you read this Privacy Policy together with any other privacy
notice or fair processing notice we may provide on specific occasions when we are
collecting or processing Personal Data about you so that you are fully aware of
how and why we are using your data. This Privacy Policy supplements the other notices
and is not intended to override them.
Data Controller
SriLankan is the Data Controller of all Personal Data relating to our passengers,
employees and third party individual contact, as well as any other Personal Data
used in our business for our own commercial purposes. This means that SriLankan
is responsible for determining when, why and how to Process Personal Data and for
establishing practices and policies in line with applicable data protection law.
SriLankan is part of the SriLankan Airlines’ Group, including SriLankan Catering
Limited, which, together with SriLankan itself, are collectively referred to as
the Group
For the purpose of the General Data Protection Regulation (“GDPR”), SriLankan has
appointed the UK Information Commissioner’s Office (ICO) as its
Supervisory Authority. Our office in London is the representative in the EU for
the purposes of GDPR and it is located at 7th Floor One Lampton Road Hounslow Middlesex
TW3 1JB United Kingdom.
This Privacy Policy is issued on behalf of the Group so when we mention “SriLankan”,
"we", "us" or "our" in this Privacy Policy, we are referring to the relevant company
in the Group responsible for processing your data. We will let you know which entity
will be the controller for your data when you purchase a service with us. SriLankan
is the controller and responsible for this website.
Data Protection Officer
SriLankan has appointed a Data Protection Officer (DPO) who is responsible for overseeing
questions in relation to this Privacy Policy. If you have any questions about this
Privacy Policy, including any requests to exercise your legal rights, please contact
the DPO using the details set out below:
Contact details
- Full name of legal entity: SriLankan Airlines Limited
- Name or title of DPO: Data Protection Officer
- Email address: privacy.office@srilankan.com
- Postal address: “Airline Centre”, Bandaranaike International Centre, Katunayake
11450, Sri Lanka.
- Telephone number: (0094) 19733 4488
- Fax number: (0094) 19733 5588
Your duty to inform us of changes
It is important that the Personal Data we hold about you is accurate and current.
It is your obligation as well to keep us informed if your Personal Data changes
during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications
which are not maintained or controlled by SriLankan. Clicking on those links or
enabling those connections may allow third parties to collect or share data about
you. We do not control these third-party websites and are not responsible for their
privacy statements. When you leave this website, we encourage you to read the Privacy
Policy of every website you visit.
The Data We Collect About You
Personal Data
We may collect, use, store and transfer different kinds of Personal Data about you
which we have grouped together follows:
-
Identity Data includes first name, middle name, last name,
maiden name, username or similar identifier, marital status, title, date of birth,
gender, emails from your passport or other identification documents, and Frequent
Flyer Programme membership number.
-
Booking Data includes travel details, flight numbers, itinerary,
seat and meal preferences, any reservations made for value-added services, and information
about your travel companions.
-
Contact Data includes e-mail address, telephone, mobile number,
postal address and fax number.
-
Financial Data includes credit and debit card information,
including your card number, expiry date, cardholder’s name, billing address, and
other billing information.
-
Transaction Data includes details about payments from you
other details of services you have purchased from us.
-
Technical Data includes internet protocol (IP)
address, your login data, browser type and version, time zone setting and location,
browser plug-in types and versions, operating system and platform and other technology
on the devices you use to access this website.
-
Profile Data includes your username and password, Frequent
Flyer Programme membership number, bookings made by you, your interests, service
preferences, places of visit, feedback and survey responses.
-
Usage Data includes information about how you use this website
and services.
-
Marketing and Communications Data includes your preferences
in receiving marketing from us and our third parties and your communication preferences.
Aggregated Data
When you visit this website or use any SriLankan mobile applications, we may also
collect, use, store and share aggregated, anonymised statistical or demographic
data (Aggregated Data). Aggregated Data may be derived from your
Personal Data but is not considered Personal Data in law as it cannot directly or
indirectly reveal your identity.
Aggregated Data may include the time and length of your visit to this website, the
pages you have visited on this website, as well as details of the website you visited
immediately prior to visiting this website. We may also record the name of your
internet service provider. We use this information only to measure site activity
and to develop ideas for improving our services.
For example, we may aggregate your Usage Data to calculate the percentage of users
accessing a specific website feature. However, if we combine or connect Aggregated
Data with your Personal Data so that it can directly or indirectly identify you,
we treat the combined data as Personal Data which will be used in accordance with
this Privacy Policy.
Special Categories of Personal Data
It is a necessary part of our business to collect certain types of Special Categories
of Personal Data about you. For example, we need to collect data about your state
of health if you inform us about that you are pregnant, have a medical condition
which requires special equipment, or when you make a request for mobility assistance.
Making certain meal choices will also involve the collection of data about your
religious beliefs or state of health, for example if you inform us that you require
a Halal or diabetic meal.
We treat our obligations to protect Special Categories of Personal Data very seriously
and we will always ask your express consent to collect, process or transfer such
data for specified purposes each time you provide it to us.
Personal Data relating to minor passengers
In certain circumstances, we may need to collect, process or transfer Personal Data
relating to minor passengers (i.e. children under the age of 16), for example where
a flight booking is made in respect of a minor passenger. This is necessary for
us to pursue our legitimate interest in running our business and to perform the
contract of carriage.
We will only use Personal Data relating to minor passengers for the specified purposes
set out in paragraph 6 and with the express consent of the person who has parental
responsibility for the minor passenger. Minor passengers have the same rights as
any other passenger regarding their Personal Data which are set out in paragraph
11.
If you fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract
we have with you, or we are required that information mandatorily to provide the
services your are looking for and you fail to provide that data when requested,
we may not be able to perform the contract we have or are trying to enter into with
you. In these circumstances, we have the right to cancel or refuse to accept the
services you are looking for, but we will notify you if this is the case at the
time.
How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
-
Direct interactions. You (or an agent acting on
your behalf) may give us your Personal Data by filling in online forms or by corresponding
with us by post, phone, email or otherwise. This includes Personal Data you provide
to us when you:
-
book a flight or arrange any other service with us;
-
create an account on this website;
-
join our Frequent Flyer Programme;
-
purchasing holiday packages from us;
-
subscribe to our newsletter;
-
enter a competition, promotion or survey; or
-
give us some feedback;
-
making complaints on our services.
-
This website. As you interact with this website, we may automatically
collect Technical Data about your equipment, browsing actions and patterns. We collect
this Personal Data by using cookies, server logs and other similar technologies.
We may also receive Technical Data about you if you visit other websites employing
our cookies. Please see paragraph 6 below and our
Cookie Policy for further details.
-
Our mobile website and mobile applications. Our mobile website
and mobile applications have the ability to access mobile device information to
better serve passengers in the service that is used. We may use location data for
our mobile website and mobile applications to enable us to provide the most helpful
format and content (for example pre-populating your departure airport based on current
location) providing that you have agreed to the use of your location data. If you
would like to restrict our collection of your location data, please adjust the settings
on your device.
-
Third parties or publicly available sources. We may receive Personal
Data about you from various third parties and public sources such as set out below:
-
analytics providers such as Google based outside the EU;
-
advertising networks based within and/or outside the EU;
-
search information providers within or outside EU;
-
contact, Financial and Transaction Data from providers of technical or payment
services within or outside the EU; or
-
identity and Contact Data from data brokers or aggregators within or outside
the EU.
How We Use Your Personal Data
We will only use your Personal Data in the manners permitted by law. Most commonly,
we will rely on the following types of lawful basis to process your Personal Data:
-
Legitimate Interests: the interests of SriLankan in conducting
and managing our business in order to give you the highest standard of service and
the best and most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process your
Personal Data for our legitimate interests.
We do not use your Personal Data for activities where our interests are overridden
by the impact on you (unless we have your express consent or are otherwise required
or permitted to by law). You can obtain further information about how we assess
our legitimate interests against any potential impact on you in respect of specific
activities by contacting us.
- Performance of Contract: processing your data is necessary for
the performance of the contract of carriage to which you are a party or to take
steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation: processing your Personal
Data may be necessary for compliance with a legal or regulatory obligation to which
we are subject.
- Consent: in certain circumstances, we may ask for your express
consent to collect, process or transfer your Personal Data, for example in relation
to opting in to our newsletter and other direct marketing. You have the right to
withdraw your consent at any time simply by contacting us.
Purposes for which we will use your Personal Data
We have set out below, in a table format, a description of primary ways we will
use your Personal Data, and which types of legal basis we rely on to do so. However,
it is may not be an exhaustive list and we will be able to provide additional information
you may require in that regard upon request. We have also identified what our legitimate
interests are where appropriate. We may process your Personal Data for more than
one lawful basis depending on the specific purpose for which we are using your data.
Purpose/Activity
|
Type of data
|
Lawful basis for processing
(including our legitimate interest to give you the best service/product and the best and most secure experience.)
|
If you as a user face difficulty in completing a booking through our official website or mobile app we will send you service emails, such as reminders when you have not checked out your purchases. This is to assist you if you have faced difficulty in completing the booking due to any issues that you may encounter during the process.
|
-
Booking reference
-
Email address
-
Passenger name
-
Time of booking
-
Origin and Destination
-
Travel dates
|
These messages are sent to ensure that we provide proactive support for any of our customers who have faced technical issues in making an online booking with us.
|
To register you as a new account holder or Frequent Flyer Programme
|
-
Identity
-
Contact
|
Necessary for our legitimate interests (for running our business)
|
To process and administer flight reservations and any other requests that you make
in connection with our services including:
-
Manage payments, fees and charges
-
Collect and recover money owed to us
|
-
Identity
-
Contact
-
Financial
-
Transaction
-
Marketing and Communications
|
-
Performance of a contract with you
-
Necessary for our legitimate interests (to recover debts due to us)
|
To process and administer reservations for our cargo services
|
-
Identity
-
Contact
-
Financial
-
Transaction
-
Marketing and Communications
|
-
Performance of a contract with you
-
Necessary for our legitimate interests (to recover debts due to us)
|
To arrange any special assistance you require or make arrangements for special medical
equipment, which may necessitate providing the data to our third party suppliers
|
-
Identity
-
Special Categories
|
-
Performance of a contract with you
-
Necessary for our legitimate interests (to enable us to assist you in boarding your
flight and travelling safely)
-
Express consent requested during the booking process
|
To arrange meal choices which may identify your religious beliefs or state of health,
which may necessitate providing the data to our third party suppliers
|
-
Identity
-
Special Categories
|
-
Necessary for our legitimate interests (to enable us to provide you with a meal
which fits your religious beliefs or to ensure medical safety)
-
Express consent requested during the booking process
|
To manage our relationship with you which will include:
-
Notifying you about changes to our conditions of carriage, Privacy Policy or any
other terms and conditions
-
Asking you to leave a review or take a survey
-
personalising your customer experience
-
improving our customer service
|
-
Identity
-
Contact
-
Profile
-
Marketing and Communications
|
-
Performance of a contract with you
-
Necessary to comply with a legal obligation
-
Necessary for our legitimate interests (to keep our records updated and to study
how passengers use our services)
-
Necessary for our legitimate interests to present you with the right kinds of products
and services
-
Necessary for our legitimate interest in improving our customer service
|
To enable you to partake in a prize draw, competition or complete a survey
|
-
Identity
-
Contact
-
Profile
-
Usage
-
Marketing and Communications
|
-
Performance of a contract with you
-
Necessary for our legitimate interests (to study how passengers use our services,
to develop them and grow our business)
|
To administer and protect our business and this website (including troubleshooting,
data analysis, testing, system maintenance, support, reporting and hosting of data)
|
-
Identity
-
Contact
-
Technical
|
-
Necessary for our legitimate interests (for running our business, provision of administration
and IT services, network security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise)
-
Necessary to comply with a legal obligation
|
To deliver relevant website content and advertisements to you and measure or understand
the effectiveness of the advertising we serve to you
|
-
Identity
-
Contact
-
Profile
-
Usage
-
Marketing and Communications
-
Technical
|
Necessary for our legitimate interests (to study how passengers use our services,
to develop them, to grow our business and to inform our marketing strategy)
|
To improve the security and safety of our services
|
-
Identity
-
Contact
-
Financial
-
Transaction
-
Profile
|
Necessary for our legitimate interests to operate a safe and lawful business or
where we have a legal obligation to do so
|
To use data analytics to improve this website, services, marketing, passenger relationships
and experiences
|
-
Technical
-
Usage
|
Necessary for our legitimate interests (to define types of passengers for our services,
to keep this website updated and relevant, to develop our business and to inform
our marketing strategy)
|
To make suggestions and recommendations to you about services that may be of interest
to you
|
-
Identity
-
Contact
-
Technical
-
Usage
-
Profile
|
Necessary for our legitimate interests (to develop our services and grow our business)
|
To process your job applications
|
- Identity
- Contact
- Job Application
|
Necessary for our legitimate interest to recruit new employees or contractors
|
Cookies
This website makes use of cookies to measure site activity and to enhance your experience
in searching our services. Cookies are alphanumeric identifiers that are sent to
your computer when you visit websites and online services. If your web browser’s
preferences are set to accept it, the cookie is stored on your computer’s hard drive.
Cookies enable our and other websites to recognize your preferences and to tailor
content to you.
You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please note
that some parts of this website may become inaccessible or not function properly.
For more information about the cookies we use, please see our
Cookie Policy.
Change of purpose
We will only use your Personal Data for the purposes for which we collected it,
unless we reasonably consider that we need to use it for another reason and that
reason is compatible with the original purpose. If you wish to get an explanation
as to how the processing for the new purpose is compatible with the original purpose,
please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you
and we will explain the legal basis which allows us to do so.
Marketing
We strive to provide you with choices regarding certain Personal Data uses, particularly
around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view
on what we think you may want or need, or what may be of interest to you. This is
how we decide which services and offers may be relevant for you (we call this marketing).
The “soft opt-in”
You will continue to receive marketing communications from us if you have previously
booked flights or purchased other services from in the past, or if you have requested
information from us in connection with a potential booking or purchase, unless you
have opted out of receiving future marketing communications.
Third-party marketing
We will request your express consent before we share your Personal Data with any
company outside the Group for marketing purposes.
Opting out
You may withdraw your consent to receive promotional emails at any time either by
unsubscribing through the link provided in such an email or by changing the settings
in your personal account with us.
Please note that we may process your Personal Data without your knowledge or consent,
in compliance with the above rules, where this is required or permitted by law.
Disclosures Of Your Personal Data
We may have to share your Personal Data with the parties set out below for the purposes
set out in paragraphs 5 and 6 above
Internal Third Parties
Other companies in the Group, outstations, branches and offices based in Sri Lanka
and other countries who are acting as joint controllers or processors.
External Third Parties
-
Service providers, contractors, and agents acting as processors based who provide
providing services such as hotels, insurance packages, duty free items on board,
call centres, data processing and analytics, marketing and research, limousine services,
distribution, revenue optimization, payment, and other services to SriLankan in
connection with the operations of the business of SriLankan Airlines’ Group.
-
Business partners of SriLankan such as code-share partners, sea and land transport
service providers, and members of any airline alliance in which SriLankan is a member.
-
With partners of the Frequent Flyer Programme of SriLankan.
-
With the frequent flyer programmes of operators of other partner airlines.
-
Professional advisers acting as processors or joint controllers including lawyers,
bankers, auditors and insurers who provide consultancy, banking, legal, insurance
and accounting services.
-
With Internet payment gateway service providers, banks, credit/debit card companies,
and other financial services providers.
-
With any law enforcement authority or governmental institution for security, customs,
immigration, or any other investigative purpose.
-
Regulators and other authorities acting as processors or joint controllers who require
reporting of processing activities in certain circumstances.
-
Third parties to whom we may choose to sell, transfer, or merge parts of our business
or our assets. Alternatively, we may seek to acquire other businesses or merge with
them. If a change happens to our business, then the new owners may use your Personal
Data in the same way as set out in this Privacy Policy.
We require all third parties to respect the security of your Personal Data and to
treat it in accordance with the law. We do not allow our third-party service providers
to use your Personal Data for their own purposes and only permit them to process
your Personal Data for specified purposes and in accordance with our instructions.
International Transfers
Internal Transfers
SriLankan is an international commercial airline operating in many different jurisdictions
and, accordingly, it will be necessary to transfer your data outside of the European
Economic Area (EEA).
External Transfers
Many of our external third parties are based outside the EEA so their processing
of your Personal Data will involve a transfer of data outside the EEA.
Whenever we transfer your Personal Data to third parties which are based outside
the EEA, we ensure a similar degree of protection is afforded to the data by ensuring
at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used
by us when transferring your Personal Data out of the EEA.
Data Security
We have put in place appropriate security measures to prevent your Personal Data
from being accidentally lost, used or accessed in an unauthorised way, altered or
disclosed. In addition, we limit access to your Personal Data to those employees,
agents, contractors and other third parties who have a business need to know. They
will only process your Personal Data on our instructions and they are subject to
a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach
and will notify you and any applicable regulator of a breach where we are legally
required to do so.
Data Retention
How long will you use my Personal Data for?
We will only retain your Personal Data for as long as necessary to fulfil the purposes
we collected it for, including for the purposes of satisfying any legal, accounting,
or reporting requirements. In order comply with applicable laws locally, we may
store your data up to a period of 12 years from the time of receiving.
To determine the appropriate retention period for Personal Data, we consider the
amount, nature, and sensitivity of the Personal Data, the potential risk of harm
from unauthorised use or disclosure of your Personal Data, the purposes for which
we process your Personal Data and whether we can achieve those purposes through
other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure at
paragraph 11 below for further information.
In some circumstances we may anonymise your Personal Data (so that it can no longer
be associated with you and you can no longer be identified by it) for research or
statistical purposes in which case we may use this information indefinitely without
further notice to you.
Your Legal Rights
Under certain circumstances, you have the following rights under data protection
laws in relation to your Personal Data:
-
Request access to your Personal Data (commonly known as a "data
subject access request"). This enables you to receive a copy of the Personal Data
we hold about you and to check that we are lawfully processing it.
-
Request correction of the Personal Data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected,
though we may need to verify the accuracy of the new data you provide to us.
-
Request erasure of your Personal Data. This enables you to ask
us to delete or remove Personal Data where there is no good reason for us continuing
to process it. You also have the right to ask us to delete or remove your Personal
Data where you have successfully exercised your right to object to processing (see
below), where we may have processed your information unlawfully or where we are
required to erase your Personal Data to comply with local law. Note, however, that
we may not always be able to comply with your request of erasure for specific legal
reasons which will be notified to you, if applicable, at the time of your request.
-
Object to processing of your Personal Data where we are relying
on a legitimate interest (or those of a third party) and there is something about
your particular situation which makes you want to object to processing on this ground
as you feel it impacts on your fundamental rights and freedoms. You also have the
right to object where we are processing your Personal Data for direct marketing
purposes. In some cases, we may demonstrate that we have compelling legitimate grounds
to process your information which override your rights and freedoms.
-
Request restriction of processing of your Personal Data. This enables
you to ask us to suspend the processing of your Personal Data in the following scenarios:
(a) if you want us to establish the data's accuracy; (b) where our use of the data
is unlawful but you do not want us to erase it; (c) where you need us to hold the
data even if we no longer require it as you need it to establish, exercise or defend
legal claims; or (d) you have objected to our use of your data but we need to verify
whether we have overriding legitimate grounds to use it.
-
Request the transfer of your Personal Data to you or to a third
party. We will provide to you, or a third party you have chosen, your Personal Data
in a structured, commonly used, machine-readable format. Note that this right only
applies to automated information which you initially provided consent for us to
use or where we used the information to perform a contract with you.
-
Withdraw consent at any time where we are relying on consent to
process your Personal Data. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent. If you withdraw your consent,
we may not be able to provide certain services to you. We will advise you if this
is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any
of the other rights). However, we may charge a reasonable fee if your request is
clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply
with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity
and ensure your right to access your Personal Data (or to exercise any of your other
rights). This is a security measure to ensure that Personal Data is not disclosed
to any person who has no right to receive it. We may also contact you to ask you
for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may
take us longer than a month if your request is particularly complex or you have
made a number of requests. In this case, we will notify you and keep you updated.
Changes To This Privacy Policy
SriLankan will amend this Privacy Policy from time to time in accordance with applicable
laws and regulations, and the updated version will be posted on this website. We
request that you revisit this website from time to time for updates on the Privacy
Policy. Historic versions of this Privacy Policy can be obtained by contacting us.
The Privacy Policy may be translated into different languages, and in the event
of any inconsistency among the versions, the English version shall prevail.
Complaints
If you have any comments, questions or concerns about the contents of this Privacy
Policy or the way in which we use your information, we encourage you to contact
us to see if we can help resolve the issue in the first instance.