Privacy Policy
1. Purpose
This Privacy Policy explains OLAK policies and practices
regarding the use
and disclosure of personal information by OLAK. OLAK reviews and
updates
this Privacy Policy from time to time as needed without notice.
2. Personal Information
However,
there are instances where OLAK must have Customer personal
information in
order for OLAK to grant Customer access to OLAK protected and
secured sites.
Personal information refers to information that is related to
Customer, and
may include things such as registration data (name, address,
email address,
phone number, title, etc.), information request data and
response data. When
a Customer receives confirmation email or when receive any email
from the
list server, Customer will be given instructions on how to
remove from the
list. In addition to the information that OLAK collect from
Customer
directly, OLAK may also receive information about individuals
from other
sources, including from OLAK customers, third parties, or
publicly available
sources. OLAK may also collect personal information that is
necessary for
OLAK legitimate interests, which will be disclosed to the person
at the time
of collection. OLAK will use this information for the purposes
of which it
was collected.
3. Use of Personal Information
OLAK
intend to use such information for purposes of supporting
Customer
relationship with OLAK by designing content that is suitable to
customer
needs and alerting customer to new product and service offerings
as they
become available. This personal information may be retained by
OLAK to
verify compliance with the agreement between OLAK and customer
employer, to
create a user profile to better serve customer, or to simply
contact
customer either electronically or otherwise. If customer decide
that OLAK
should not use customer personal information to contact him, and
OLAK will
not use that information for such purpose. OLAK may also use
personal
information for various purposes, including without limitation
to help
diagnose problems with OLAK site, to administer OLAK site, and
to enhance
OLAK site for optimal user experience; to monitor the usage and
performance
of OLAK site, and to determine aggregate information about OLAK
users and
usage pattern; to identify customer when customer access and use
OLAK
services; to facilitate transactions and process payments; to
provide
maintenance, support, and customer service for OLAK site;
subject to user
consent; and to fulfil other legitimate purposes permitted by
applicable
law.
4. Disclosure of Personal Information
OLAK
may
share personal information with companies that are affiliated
with us (that
is, that control, are controlled by, or are under common control
with OLAK).
If OLAK sells all or part of its business or makes a sale or
transfer of
assets or is otherwise involved in a merger or business
transfer, OLAK may
transfer customer personal information to a third party as part
of that
transaction. OLAK disclose personal information if: OLAK have
customer
consent; OLAK need to share it in order to provide customer with
the
products and/or services customer requested; OLAK respond to a
court order
or in order to comply with the law, or customer violate OLAK
Terms of Use.
OLAK may share customer personal information with service
providers that
perform services for OLAK, such as providing hosting services,
marketing
assistance, analyzing user data, processing payment card
information, and
for other legitimate purposes permitted by applicable law. If
customer agree
to provide such information to these service providers directly,
then
customer personal information will be subject to their privacy
policies and
terms of use.
5. Public Forum and Messaging
OLAK
may
offer public discussion forums and bulletin boards. Please note
that
information that customer discloses in these public forums
become public.
Use caution in disclosing any personal information. The site may
also allow
customer to exchange messages with other users. OLAK may store
these
messages in order to deliver them and allow customer to manage
them.
6. Accuracy and Security
The
accuracy and security of the personal information is important
to OLAK. If
customer contact OLAK to correct customer personal information,
OLAK will
attempt to correct such inaccuracies in a timely manner. OLAK is
concerned
with the security of customer personal information and is
committed to
taking reasonable steps to protect it from unauthorized access
and use of
that personal information. To that end, OLAK put in place the
appropriate
policies and procedures to secure customer personal information.
While there
is no such thing as “perfect security” on the Internet, OLAK
will take
reasonable steps to ensure the safety of customer personal
information.
7. Access and Choice
OLAK has implemented the following procedure that customer may use to access, correct, or delete customer personal information, or choose how customer information is used:
- If customer would like correct any inaccurate personal information that OLAK maintains from users of the site, please email OLAK at the addresses listed below under the Section titled “Communication.”
- Customer may also have a right, in accordance with applicable laws, to access, update, and delete in some cases requests deletion of the personal information that OLAK hold about customer. When updating customer personal information, OLAK may ask customer to verify customer identity before OLAK can act on customer request. Any access request will be subject to the relevant fee, if any, to meet OLAK costs in providing customer with details of the information OLAK hold about customer. OLAK will comply with customer request as soon as reasonably practicable and in accordance with applicable laws. OLAK may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations, or to complete any transactions that customer began prior to requesting such change or access.
- If customer wish to stop receiving email marketing communications from OLAK, please contact OLAK at the address listed below or clicking the “Unsubscribe” in any marketing communications. If customer opt out, OLAK may still send customer non-promotional communications, such as those about customer account or to facilitate services that customer has made or accepted.
- Some web browsers and devices permit customer to broadcast a preference that customer not be “tracked” online. At this time OLAK does not modify customer experience based upon whether such a signal is broadcast.
8. Retention of Personal Information
OLAK
retains customer personal information for so long as customer
account is
active or as needed to provide customer with services or to
fulfil OLAK
contractual obligations; as necessary to comply with OLAK legal
obligations,
resolve disputes, and enforce OLAK agreements; and for so long
as is
necessary for the purposes for which OLAK collected such
personal
information.
In accordance with applicable data protection laws, customer may
have the
right to request: access to, rectification, and erasure of
customer personal
information; restriction of processing of personal information;
objecting to
certain processing of personal information; and the right to
data
portability. Where any processing of personal information is
solely
dependent upon customer consent, customer have the right to
withdraw such
consent at any time (For example, OLAK suggest by using the any
unsubscribe
link contained in an applicable marketing message, or, emailing
us at the
“Communications” details below).
Where customer believe that OLAK has not processed customer
personal
information in accordance with applicable data protection laws,
customer may
lodge a complaint with the respective supervisory authority or
data
protection regulator. The provision of personal information by
customer will
be for contractual, marketing, or analytical purposes as
referred to in this
Privacy Policy. To exercise customer rights under these
provisions, please
contact OLAK at the “Communications” details below. When OLAK
receive
customer requests, OLAK may ask customer to verify customer
identity before
OLAK can act on customer request. OLAK may withhold information
where the
search for that information would require disproportionate
effort or have a
disproportionate effect to, for example, the cost of providing
the
information, the time it would take to retrieve the data, or how
difficult
it may be to obtain the information requested.
9. International Operations
OLAK
Technologies is based in the Sri Lanka. If customer is from a
country
outside of Sri Lanka with laws governing data collection, use,
and
disclosure that may differ from Sri Lanka law and customer
provide personal
information to OLAK, please note that any personal information
that customer
provide to OLAK may be transferred to the Sri Lanka. By
providing customer
personal information, customer hereby specifically and expressly
consent to
such transfer and processing and the collection, use, and
disclosure set
forth herein or in any terms and conditions related to the use
of and access
to the OLAK site. Where OLAK transfer customer personal
information from
OLAK do so on the basis of standard contractual clauses.
Customer may
request a copy of the relevant standard contractual clauses by
emailing OLAK
at the “Communications” details below.
10. Cookies
OLAK
uses
"cookies". The use of cookies is an industry standard, and
customer will
find cookies at most major websites. A cookie is a small data
file that a
website can transfer to a visitor's hard drive to keep records
of the visits
to such site. A cookie contains information, such as customer
User
Information, that helps OLAK to recognize the pages where
customer has
visited and improve future visits, but the only personal
information a
cookie can contain is the information that customer has
provided. A cookie
cannot read data off customer hard drive or read cookie files
created by
other sites. If customer prefer not to accept a cookie, customer
can set
customer’s Web browser to refuse all cookies or to warn customer
before
accepting a cookie. Customer can still access most of the
features on OLAK
websites even without accepting a cookie.
11. External Links
OLAK’s
website provides links to other third-party websites. Even if
the third
party is affiliated with OLAK through a business partnership or
otherwise,
OLAK is not responsible for the privacy policies or practices or
the content
of such external links. These links are provided to customer for
convenience
purposes only and customer access them at customer own risk.
12. Terms of Use
Please
also see OLAK Terms of Use, which describes the restrictions,
disclaimers,
indemnification and limitation of liability governing the use of
the entire
OLAK website.
13. Communications
If
customer have questions regarding OLAK Privacy Policy, please
contact OLAK
at info@olak.org or go to OLAK Contact Us page. If OLAK needs,
or is
required, to contact customer concerning any event that involves
information
about customer, OLAK may do so by email, telephone, or mail.
- End of 19: Privacy Policy –
IT Quality Policy
1. Purpose
- IT quality policy states the basic beliefs that OLAK to deliver quality in developing software systems and related support services.
- It acts like a company constitution informing Staff actions when there is no specific procedure to guide them.
- The quality policies identify OLAK priorities separating the critical few from the important many. This policy also summarises measures of success too.
- This document describes the how quality principles applied in the genera business process of Software Development and Support services.
2. General
- Management of OLAK is committed to delivering quality software and quality services to our customers.
- OLAK recognise that consistent satisfaction of customer needs is essential to business survival.
- OLAK value customer references more than anything else in order to expand our business.
- All software projects maximise user engagement in requirements specification and system design
- OLAK is published quality policies, establishes clear and unambiguous quality goals and demonstrates by their actions that policies are to be followed and makes sure that staff have the knowledge and tools to do their jobs.
- OLAK shall provide an environment where staff is given everyone can contribute to quality and identifies people who need help and initiates training and support.
- A separate Software Development Standard Manual describes steps to be followed in each step in the Software Development process at OLAK Technologies.
- OLAK Management reviews the effectiveness of a quality management system on a regular basis.
3. Planning
- A Project Management Plan is created for all projects and planning the deliverables and strictly adhere to the plan is the key rule.
- A responsible project manager is assigned to each project whether it is a software development or infrastructure support project or consultancy project.
4. Monitoring and Controlling
- Project managers shall produce project performance reports for each project at intervals agreed with the project sponsor.
- Project progress meetings is conducted with stakeholders. In addition, PMO (Project Management Officer) Dashboard is updated on daily basis which track each and every project.
5. Documenting requirements
- All projects shall prepare a Software Requirements Specification describing the functions, performance and the interface requirements of the software product.
- A formal document is shared with the business owner as well as technical team explaining the requirement of each project.
- The Business Analyst is heavily involved in this stage.
6. Architectural Design
- All projects shall conduct a Design Input Review to establish that design inputs such as Software Requirements Specifications are unambiguous, complete and correct and possess sufficient quality to support the development of a design solution.
- System model diagram & System Architecture diagram including interfaces is a mandatory caption in the requirement understanding document for any project.
- The Business Analyst is heavily involved in this stage.
7. Coding
- Software Projects shall develop in compliance with predefined coding standards mentioned in the Software Development Standard Manual.
- Coding standards shall be updated to reflect any project specific practices.
8. Testing & Quality Assurance (QA)
- All projects shall describe the approach to testing in a Software Test Plan (STP).
- The STP shall describe the project's approach to unit, integration and acceptance testing methodologies and test cases.
- All projects shall plan and perform the software quality management activities required to ensure that the customer's stated and implied needs are met and that the software product is developed in compliance with recognized best practice
- Software will not be released to live environment without the User Acceptance Test (UAT) report signed by Business User.
- Stress Testing is required based on the software functionality
9. Software or patch deployment
- Software is released to live environment after UAT sign off is given with the Software Release Note (SRN)
- Tested codes are deployed in the production environment by the System Engineers or Database Administrators based on the instructions provided in the SRN.
- No software is released to live environment without an authorized SRN
- Software patch is reversed immediately in case any issue is found in the production environment due to newly deployed software patch.
10. Software Maintenance
- Live environment Issues are reported to OLAK maintenance & support team using an electronic system provided
- Issue is assigned to the Support Engineer automatically and he or she will be attended to it bases on the severity of the issue
- Issues are transfer to the Issue Tracker and which maintains summary of all issues and it is shared with all stakeholders
- Normally Annual Maintenance Contract (AMC) is singed by the Customer
- End of 20 : IT Quality Policy –
Anti-Bribery & Corruption Policy
1. Policy Statement
- OLAK Technologies Private Limited (“OLAK”) supports the national anti-bribery and anti-corruption effort by establishing and upholding good corporate governance and continuously inculcating good ethical business practices among its directors, employees, service provider and other business partners.
- In line with this commitment, OLAK has developed its Anti-Bribery & Anti-Corruption Policy.
- All members of the Board of Directors, staff and related parties must uphold the highest standard of integrity and accountability in discharging their duties and to ensure that all activities, offer, or services are conducted in compliance with this Policy and all other applicable legal and regulatory requirement on anti-bribery and anti-corruption.
- Normally Annual Maintenance Contract (AMC) is singed by the Customer
2. Definitions
- The following definitions are included in this Policy.
- Bribery: Bribery is defined as any action which would be considered as an offence of giving or receiving ‘gratification’. In practice, this means offering, giving, receiving, or soliciting something of value to illicitly influence the decisions or actions of a person, in a position of trust within an organisation.
-
Gratification: Means
-
(a) money, donation, gift, loan, fee, reward, valuable
security, property or interest in property being property of
any description whether movable or immovable, financial
benefit, or any other similar advantage;
-
(b) any office, dignity, employment, contract of
employment or services, and agreement to give employment or
render services in any capacity;
-
(c) any payment, release, discharge or liquidation of any
loan, obligation or other liability, whether in whole or in
part;
-
(d) any valuable consideration of any kind, any discount,
commission, rebate, bonus, deduction or percentage;
-
(e) any forbearance to demand any money or money’s worth or
valuable thing;
-
(f) any other service or favour of any description,
including protection from any penalty or disability incurred
or apprehended or from any action or proceedings of a
disciplinary, civil or criminal nature, whether or not
already instituted, and including the exercise or the
forbearance from the exercise of any right or any official
power or duty; and
-
(g) any offer, undertaking or promise, whether conditional
or unconditional, of any gratification within the meaning of
any of the preceding paragraphs (a) to (f).
- Board: Board Means the Board of directors of the Company and which shall include all independent and non- independent directors, executive and non-executive directors of OLAK.
- The areas covered under this Policy are as follows:
3. Conflict of interest
- OLAK conducts its business according to the principle that it must manage conflicts of interest fairly.
- OLAK may face actual and potential conflicts of interest from time to time.
- OLAK policy is to take all reasonable steps to maintain and operate effective organizational and administrative arrangements to identify and manage relevant conflicts.
- It is stated in the OLAK Employee Agreement that employees should exercise caution in their personal relationships with customers, suppliers, competitors, or businesses introduced or affiliated with a customer or supplier.
- This is to ensure there is no involvement of obligations that may prejudice or influence the business relationship or result in any conflict with their duties.
- If a conflict of interest arises between employees and a third party, the employees or the relevant department head should be made aware of the conflict, where appropriate, and inform the Senior Management.
- Should a conflict of interest arise, it must be managed promptly and fairly
-
OLAK has in place arrangements and/or procedures designed to ensure
that:
- There is control of the flow of information where, otherwise, the risk of a conflict may harm the interests of a customer.
- There is prevention of trading activities that harm the interests of a customer.
- Appropriate and adequate disclosures to customers to enable the customer to make an informed decision.
- Staff declares the gifts and entertainment received, their external engagements and appointments.
- Where necessary, exclusion of certain persons from working on a specific transaction, business activity or participating in the management of a potential conflict of interest.
4. Gifts and Entertainment
- Care should be exercised in the giving and receiving of business-related gifts/entertainment from customers, business partners and third-party suppliers.
- The act of giving or receiving these gifts must not carry any intention or obligation or expectation of favors
- The Company’s aim is to deter givers of gifts from seeking or receiving special favors from OLAK employees.
- Accepting any gift of more than nominal value or entertainment that is more than a routine social amenity can appear to be an attempt to influence the recipient into favoring a particular customer or vendor. Gift
- The acceptance of gifts under inappropriate circumstances may also amount to Bribery and/or a criminal act. Accepting gifts shall be guilty of an offence if he corruptly receives or gives a Gratification (whether in the form of cash, employment, business opportunities, favours or otherwise) as an inducement or reward to a person to do or not to do any act.
-
To avoid the reality, the appearance that business judgement may
be improperly influenced or compromised and to protect the staff
from any perception of improper conduct or conflicts of interest,
employees should observe the following guidelines when deciding
whether to accept gifts.
- Where circumstances make it impossible, difficult, or impractical to reject gift or where the rejection of the gift may affect the relationship with the customers or business associates (other than cash or cash equivalent) or rejecting them is deemed as offensive given the local custom, you may accept the gift(s). If accepted, it is deemed to have been accepted on behalf of the Company and become the property of the Company. The use of the gift is to be determined by the OLAK Management team.
- Consumables like food gifts and hampers at nominal value will not need to be declared but instead be shared within the company staff.
- The employee should obtain approval from his or her supervisor for business entertainment extended to the employee. As a guide, business meals are acceptable.
- The following need not be declared:
- Annual dinner/ gala dinner/ cocktail events which are also attended by employees or other companies / organizations.
- Working lunches and other meals including those following / preceding official meetings
- Invitations to official opening ceremonies / seminars
- Business entertainment that might compromise the employee’s ability to or appear to hinder his or her duties in a professional manner should not be accepted. The following deemed inappropriate
- Overseas trips in the form of paid holidays or holiday incentives.
- Accepting invites or tickets by the employee when the prospective host will not be present at the event with the employee.
- If there are doubts as to whether business entertainment might create the appearance of any conflict or impropriety, these situations can be referred to Senior Management or Chief Executive Officer (CEO)
5. Donations and Sponsorships
-
OLAK is permitted to provide donation or sponsorship provided it
comply with following:
- Ensure such contribution is allowed by applicable laws.
- Obtain all necessary authorization (where required)
- Be made to well established entities having an adequate organizational structure to guarantee proper administration of the funds;
- Not to be used to cover up an illegal payment or bribery.
- OLAK ensure that such contribution is recorded in the Company’s books and/or records properly.
- OLAK shall not make political contribution from the Company’s resources to any political party, political candidate, or political campaign.
6. Facilitation Payments
- OLAK adopts a strict stance that disallows facilitation payments or other provision made personally to an individual in control or a process or decision.
- Employees are expected to notify their immediate superior when encountered with any requests for a facilitation payment.
- In addition, if a payment has been made and employees are unsure of the nature, their immediate superior must be immediately notified and consulted.
- They must also ensure that the payment has been recorded transparently.
7. Financial Controls
- OLAK has established proper approval process to disburse any payment to any party.
- The Company’s internal operational manual illustrated clear responsibilities and approval matrix of authorised officer in the Company to approve its purchase or payment or other expenditure.
8. Non-financial Controls
- Due diligence shall be undertaken with regards to any service provider intending to act on OLAK behalf/ act for OLAK.
- The extent of the due diligence will be risk-based and shall include a bribery risk assessment.
- Due diligence may include a search through relevant databases, checking for relationships with public officials, and documenting the reasons for choosing one service provider over another.
- OLAK expects all service providers acting on behalf of the Company to contractually agree to refrain from bribery and corruption practices, and to adhere to the Policy.
- Due diligence, and background checks during staff recruitment and on an ongoing basis, to be satisfied that they are fit and proper persons who have the necessary
9. Record Keeping
- OLAK shall maintain documentation related to the adequate procedure for 7 years
- As a measure to satisfy the requirement of document retention, any disposal of relevant documents will require consent and approval from OLAK Chief Executive Officer CEO.
- Each department should inform CEO and obtain his prior approval for any disposal of relevant documents.
10. Awareness and Training
- OLAK will conduct a training session for all new staff within the first month of their employment.
- For all existing staff, refresher training on anti-Bribery and anti-corruption measures will be held once a year.
11. Whistleblowing policy and Reporting Channel
- OLAK is committed to a high standard of compliance with accounting, financial reporting, internal controls, corporate governance and auditing requirements and any legislation relating thereto.
- Whistleblowing Policy is created to encourage employees to raise concerns, in confidence about possible irregularities while being protected from reprisals or victimization for whistleblowing in good faith.
-
The key objectives of the Whistleblowing Policy are to:
- Discourage wrongdoing and to promote standards of good corporate practices.
- Provide proper avenues for employees to raise concerns about actual or suspected improprieties in matters of financial reporting or other matters and receive feedback on any action taken.
- Give employees the assurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.
- A whistle blower may also report on any suspected and/or real corruption incidents or inadequacies to CEO via secured reporting channels: email or SMS or WhatsApp or voice call
- Each Employee has a responsibility to ensure that suspected bribery and corruption incidents are reported promptly.
- Reports made in good faith, either anonymously or otherwise, shall be addressed in a timely manner and without incurring fear of reprisal or victimization regardless of the outcome of any investigation.
12. Disciplinary action for non-compliance
- Cases of misconduct or gross misconduct will be dealt with according to internal procedure.
- The procedure is designed to ensure that all staff are dealt with fairly.
- It does not form part of the contract of employment or otherwise have contractual effect.
- OLAK regards bribery and corruption as a serious matter. Non-compliance may lead to disciplinary action, up to and including termination of employment depending on the seriousness of the situation, the Company may decide at its sole discretion.
- OLAK shall notify the relevant regulatory authority if any identified bribery or corruption incidents have been proven beyond reasonable doubt.
- Further legal action may also be taken if the OLAK’s interests have been harmed because of non-compliance.
- OLAK is committed to continually improving its Policy and to develop further integrity measures and enhance its anti-Bribery and anti-corruption procedures.
- Any deviation or waiver from this Policy must be approved by the Board.
- OLAK shall make this Policy available to both internal and relevant external parties.
- End of 21: Anti-Bribery & Anti-Corruption Policy –
1. General
- OLAK is committed to the prevention of pollution and the protection of the environment and recognizes that this is in the best interests of the organization, it’s employees and stakeholders, and that it contributes to a better quality of life, now and for future generations including helping our customers use information technology to meet environmental challenges.
- OLAK activities, even though within the professional services industry, have an environmental impact at local, national and global levels, so it acknowledges that even small contributions to the preservation of the environment are important to pursue. It endeavours to conduct all business activities and operations in line with best environmental practice and seeks continual improvement in all activities.
- Taking account of our business needs, customer requirements and the desire to minimize adverse impacts on the environment, we maintain our products, run our business operations and develop products in a responsible manner.
- OLAK’s primary environmental impacts relate to: the company’s own energy consumption as well as the energy consumption of its hardware products; the disposition of its hardware products at the end of their useful life; vendor and supply chain management; business travel; and the consumption of natural resources through its own activities and its procurement processes.
- Striving to reduce business travel and promote alternatives wherever practicable;
- Committing to comply with applicable environmental laws and regulations, as well as other standards
- Educating OLAK employees about the steps OLAK is taking to help protect the environment and providing channels for employees to contribute to our efforts;
- Requesting that employees report any instances of noncompliance with applicable environmental laws and regulations and conducting appropriate follow-up.
2. The Process to achieve goals
-
Save Energy - Our aim to be efficient in our use of energy
and
natural resources and to reduce consumption within our offices.
- Advising staff to switch off lights and appliances when not in use.
- Phase out energy inefficient Air conditions and replace with energy-efficient versions
- Shutdown the Software Development servers and move to Cloud
- Minimise Travels - We have a policy to use video and telephone conferencing as an alternative to travel where this is feasible, to reduce carbon dioxide emissions.
- Minimize printing -Our policy to minimize the printing or using hard copies and always use digital copies. Even the contracts use digital signature so it minimizes the printing papers, printer cartridges etc.
- E-waste policy - Our recognition of our responsibility to manage redundant and obsolete equipment properly, by disposing of such to third party organizations wherever possible
- Reuse paper - Our encouragement of the use of previously used paper within the internal operation and reuse envelops tool.
- Digital documentation - Generate employee letters digitally. Even project proposals, invoices etc are submitted digitally with digital signature.
- Digital payments - Encourage supplier payments using digital channels instead of physical cheques. Encourages customers to make payments using bank transfers instead of issuing of cheques.
- Scanned documents - Reduce paper movements and use scanned copies of documents and transfer them using workflows or email.
- Digital marketing - Not use any printed marketing materials and use eFlyers and social media. All the promotional campaign done using social medial to reduce paper usage.
- End of 22 : Environment Policy –