Privacy Policy

1. Introduction

Padak Pvt Ltd ("Padak", "we", "us", "our"), based in Batticaloa, Sri Lanka, operates the Padak Loyalty App (the "App"). The App lets you earn rewards by sharing lead details or referring warm leads to Padak, discover our services, and talk with other members in a community.

This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and the choices you have. By creating an account or using the App, you agree to this Policy. If you do not agree, please do not use the App.

We handle personal data in line with applicable Sri Lankan law, including the Personal Data Protection Act, No. 9 of 2022.

2. Information We Collect

We only collect the information needed to run the App and the rewards programme.

3. How We Use Your Information

• Create and manage your account and verify your identity.
• Record, review, and follow up on the leads and referrals you submit.
• Calculate, credit, and pay rewards and process withdrawal requests.
• Operate and moderate the community, and enforce our community rules.
• Send service messages such as referral status updates, reward credits, and security alerts.
• Show you information about Padak's services and, where you agree, offers and news.
• Prevent fraud, duplicate or fake referrals, and abuse of the rewards programme.
• Improve the App, fix bugs, and analyse usage.
• Comply with legal, tax, and accounting obligations.

4. Rewards & Withdrawals

You earn a reward when a warm lead that you refer results in a project that is closed with Padak. Rewards are credited to the person who made the referral, after Padak confirms the project.

To process a withdrawal we need your payout details and may need to confirm your identity. We keep payout and transaction records for accounting and audit purposes. Rewards have no cash value outside the terms of the programme, and we may withhold or reverse rewards that result from fraud, duplicate submissions, or false information.

5. Leads & Referrals You Submit

When you submit details about another person or business, you are sharing their personal data with us. Please only submit information if:

• you have a genuine relationship with the person or business, and
• you have their permission, or a lawful reason, to pass on their contact details to Padak.

We use lead details only to contact the referred party about our services, to assess whether a project can be agreed, and to credit the correct referrer. Referred parties may ask us to correct or delete their data, or to stop contacting them, by writing to us at the address in Section 15.

6. Community & User Handles

The App includes a community where members can talk with each other. To protect your privacy, the community uses handles instead of real identities.

• Other members see only your handle and what you post. Your internal user ID, name, phone number, and email are not shown to other members.
• Choose a handle that does not reveal your real name or contact details.
• Anything you post is visible to other members. Do not share personal, financial, or confidential information in the community.
• Padak staff and moderators can access account details where necessary to moderate content, investigate abuse, or respond to legal requests.
• We may remove content or suspend accounts that breach community rules.

Handles reduce, but cannot fully remove, the risk that someone may work out who you are from what you write, so please post with care.

7. Our Services

The App lists the services offered by Padak Pvt Ltd so you know what you can refer. These include:

• Web development
• Android app development
• Digital marketing
• SEO (search engine optimisation)
• Other software and digital services we may add from time to time

If you or a lead shows interest in a service, we use the details provided to follow up, prepare proposals, and manage the resulting project.

8. Sharing & Disclosure

We do not sell your personal data. We share it only in these cases:

• Service providers: hosting, SMS or email delivery, analytics, and payment or bank partners who process data on our behalf under confidentiality obligations.
• Padak team: staff who need the data to review leads, handle support, and process rewards.
• Legal and safety: where required by law, court order, or a lawful request from authorities, or to protect rights, safety, and prevent fraud.
• Business changes: if Padak is involved in a merger, sale, or restructure, subject to this Policy continuing to protect your data.
• With your consent: for any other purpose we tell you about at the time.

Some of our providers may store data on servers outside Sri Lanka. Where this happens we take steps to keep your data protected.

9. Data Retention

We keep personal data only as long as needed for the purposes in this Policy:

• Account data: while your account is active and for a reasonable period afterwards.
• Lead and referral records: until the lead is closed or declined, plus the period needed to settle rewards and resolve disputes.
• Reward and payout records: as long as required for accounting, tax, and audit purposes.
• Community posts: until you delete them or your account is closed, unless we need to keep them for moderation or legal reasons.

When data is no longer needed, we delete it or anonymise it.

10. Data Security

We use reasonable technical and organisational measures to protect your data, including encrypted connections (HTTPS), hashed passwords, access controls, and activity logging. No system is completely secure, so please keep your password private and tell us straight away if you suspect unauthorised access to your account.

11. Your Rights & Choices

Subject to applicable law, you may:

• Ask for access to the personal data we hold about you.
• Ask us to correct inaccurate or incomplete data.
• Ask us to delete your data or close your account.
• Withdraw consent for marketing messages at any time.
• Object to or ask us to restrict certain processing.
• Complain to us, or to the relevant data protection authority in Sri Lanka.

To use these rights, contact us using the details in Section 15. We may ask you to verify your identity first. Some data may need to be kept after a deletion request where the law requires it, or to settle unpaid rewards and disputes. Closing your account may forfeit any unredeemed rewards.

12. Age Restriction

The App is intended for people aged 18 or over. We do not knowingly collect data from anyone under 18. If you believe a child has given us personal data, please contact us and we will delete it.

13. Cookies & Device Data

The App and any related web pages may use cookies, local storage, and similar technologies to keep you signed in, remember settings, protect against fraud, and understand how the App is used. You can control cookies in your browser or device settings, but some features may not work without them.

14. Changes to This Policy

We may update this Policy from time to time. When we make important changes, we will notify you in the App or by other suitable means and update the "Last updated" date above. Continued use of the App after changes means you accept the updated Policy.

15. Contact Us

If you have questions about this Policy or how we handle your data, contact: