Effective Date: 1st of March 2025

1. Introduction

This Privacy Policy outlines how the OnDemand App ("the App") collects, uses, shares, and protects your personal data. Our commitment is to ensure your data is handled securely and transparently, in compliance with the Personal Data Protection Act No. 9 of 2022 of Sri Lanka. By accessing or using the App, you agree to the practices described in this policy.

2. Who We Are

The App is operated by 3D'S Entertainment (Pvt) Ltd, a company registered in Sri Lanka. As the data controller, we determine how and why your personal data is processed. For inquiries regarding this policy, please contact us at 21plusondemand@gmail.com.

3. What Data We Collect

The App collects personal data necessary to provide and improve our services. The types of data we collect include:

• Identity Information: Name, date of birth, and National Identity Card (NIC) image to verify age and identity, ensuring compliance with the National Authority on Tobacco and Alcohol Act No. 27 of 2006, which restricts the sale of certain products to individuals below the age of 21.
• Contact Information: Email address, phone number, and delivery address to facilitate communication and order fulfillment.
• Account Information: Username, password, and account activity details.
• Transaction Information: Records of orders placed, payments made, and delivery history.
• Device Information: IP address, device type, operating system, and App usage patterns for analytics and security purposes.

4. How We Use Your Data

We process your personal data for the following purposes:

1. Age and Identity Verification: To ensure users meet the legal age requirement of 21+, as mandated by Sri Lankan law.
2. Service Provision: To manage user accounts, process orders, and facilitate deliveries.
3. Customer Support: To respond to inquiries and provide assistance.
4. Improvement of Services: To analyze usage patterns and enhance App performance and user experience.
5. Legal Compliance: To fulfill legal and regulatory requirements, including the prevention of fraudulent or unauthorized use of the App.
6. Promotional Communications: To send updates, offers, and promotions, subject to your consent.

5. Legal Basis for Processing

Our legal grounds for processing your personal data include:

• Consent: When you agree to provide specific information (e.g., during registration).
• Contractual Obligations: To fulfill our service agreements with you.
• Legal Obligations: To comply with applicable laws, such as verifying age restrictions under the National Authority on Tobacco and Alcohol Act No. 27 of 2006.
• Legitimate Interests: To improve and secure our App and services.

6. Sharing Your Data

We may share your data with:

• Service Providers: Such as payment gateways and delivery personnel, strictly for fulfilling orders.
• Regulatory Authorities: Where required by law or legal processes.
• Third-Party Partners: For analytics and operational support, under strict data protection agreements.

We do not sell or rent your personal data to third parties for marketing purposes.

7. Data Retention

Your personal data is retained only for as long as necessary to fulfill the purposes outlined in this policy. For example:

• NIC Images: Retained for [90 Days] to verify age compliance.
• Transactional Records: Retained as required by Sri Lankan tax and legal regulations.

Once the retention period expires, data is securely deleted or anonymized.

8. Your Rights

Under the Personal Data Protection Act No. 9 of 2022, you have the following rights:

• Access: Request a copy of the data we hold about you.
• Correction: Rectify inaccurate or incomplete data.
• Erasure: Request deletion of your data, where legally permissible.
• Restriction: Limit the processing of your data under certain conditions.
• Objection: Object to processing based on legitimate interests.
• Data Portability: Request transfer of your data to another service provider.

To exercise these rights, contact us at 21plusondemand@gmail.com.

9. Protecting Your Data

We employ industry-standard measures to safeguard your data, including:

• Encryption of sensitive data, such as NIC images.
• Access controls to restrict unauthorized access.
• Regular security audits and updates to protect against breaches.

While we strive to ensure data security, users are advised to maintain the confidentiality of their account credentials.

10. Cookies and Tracking Technologies

The App uses cookies and similar technologies to:

• Enhance user experience.
• Analyze usage patterns for service improvements.
• Ensure security and fraud prevention.

You can manage cookie preferences through your device or browser settings.

11. International Data Transfers

If your data is transferred outside Sri Lanka, we ensure it is protected by appropriate safeguards, such as data protection agreements or compliance with international standards.

12. Changes to This Privacy Policy

We may update this policy from time to time to reflect changes in laws or services. Significant updates will be communicated through the App or via email. The effective date at the top of this policy will indicate the latest revision.

13. Contact Us

For questions, concerns, or to exercise your rights, contact us at:

Data Protection Officer
3D'S Entertainment (Pvt) Ltd.
No:3A, 3rd Lane, Ratmalana, Sri Lanka
21plusondemand@gmail.com
+94 77 310 1560

By using the 21+ OnDemand App, you confirm that you have read, understood, and agree to this Privacy Policy.