Privacy Policy

1. Absolute Confidentiality

1.1 Luhn is totally committed to protecting your privacy and ensuring the security of any personal information received from you ("User"). We strictly adhere to the requirements of data protection and this Privacy Policy is published in accordance with:

• i. Digital Documentation of COVID-19 Certificates: Vaccination Status — Technical Specifications and Implementation Guidance, 27 August 2021. Geneva: World Health Organization; 2021
• ii. Sri Lanka Telecommunications Act, No. 25 of 1991

1.2 The purpose of this privacy policy statement is to explain to you what personal information We collect from your use of the App, and how We protect the information that you provide to us when you use our App. You can be assured that Luhn will use such information sensibly and carefully, and only in accordance with this privacy statement. We maintain compliance with the highest standards of privacy.

2. Your Consent

2.1 By accessing this App and whenever you submit any information to Luhn, or use services offered by our App, you agree to be bound by the terms of this Privacy Policy. Please read below carefully the entire Privacy Policy before using the Luhn App.

2.2 As part of providing our Services to you, We may need to send routine communications to you, such as confirmation text messages and other administrative messages through your phone or email and notifications posted on the App or through other means available, including text and other forms of messaging.

2.3 You must ensure to provide us with the correct or up-to-date Personal Information. This will allow us to contact you for further correspondences with respect to the digital documentation of your COVID-19 vaccination certificate. We are not responsible for any inaccurate information you provide to us.

2.4 If, at any time, you want to access, update, modify or eliminate any of your account information at Luhn, you may do so by clicking "Your Account", and then review/change your sensitive personal information as you want it to be.

2.5 Luhn may, in future, request other optional information from you in order to customise the App to deliver personalised service to our Users.

3. What Information We Collect About You

3.1 We do not automatically collect your personally identifiable information. However, when first using the App, you will be required to provide us with your personal and demographic information - including your name, gender, date of birth, image of national identity card, address (MOH area, district, country), phone number, email address and your COVID-19 vaccination history.

3.2 During your use of the App, We may automatically receive technical information about your device, including your IP address, your operating system, time-zone, browser type and browser plug-in details, due to the communication protocol settings on the Internet.

4. What Information We Collect About You

4.1 We will collect and retain your personally identifiable information only to the extent that it is necessary to fulfil our services to you. Any Personal information submitted by you to the App or collected by us will be used ONLY for the purposes mentioned below:

• i. to carry out our obligations arising from your requests for our services;
• ii. to improve our App's functionality, and to customise your experience with us;
• iii. to make sure that our App content is presented in the manner that is most effective for you;
• iv. to communicate with you about any changes to our services;
• v. to verify your identity and perform checks to prevent fraud.

5. With Whom We Share Your Information

5.1 We do not sell, rent or exchange your any personally identifiable information that you provide to us through this App with any third party for commercial reasons.

5.2 As with any business, it is possible that as our business develops, we might sell or buy other businesses or assets. In such transactions, User/Customer information is typically one of the transferred business assets. Accordingly, in the event that Luhn, or substantially all of our assets, is acquired by a third party, such information may be one of the assets that is transferred or acquired by a third party. Under such circumstances, Luhn would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy. You acknowledge that such transfers may occur, and that any acquirer of Luhn may continue to process your personal information as set forth in this Privacy Policy.

6. Who Has Access to Your Information

6.1 Your personally identifiable information can be accessed only on a need-to-know basis by certain Luhn employees who are designated to carry out your requested activity, and all such employees are bound to strict confidentiality obligations.

6.2 A copy of your COVID-19 vaccination data is transferred to the Ministry of Health, Sri Lanka (“MOH”) to enable you to access your vaccination certificate. Your COVID-19 vaccination data includes your NIC number, your name, your date of birth, your gender, MOH area and the dates of your COVID-19 vaccinations as well as technical information about the type of vaccine you had. This information will be processed by the MOH to produce the digital documentation of your COVID-19 vaccination certificate.

7. How We Use Cookies

7.1 "Cookies" are small pieces of information placed by a website onto your computer's hard drive. Cookies do not collect any sensitive personal information from you. We use cookies to analyse data about our web page traffic, which helps us save your preferences for your future visits. This allows us to customise our website according to your interests, which will enable us to deliver a more personalised service to our Users. You may choose to accept or decline cookies. Please be aware that by declining cookies you may be unable to use our website to its fullest capability.

8. Security Policy

8.1 We guarantee that all your personal information with us is secure. Luhn takes careful precaution to protect our Users’ personal information from unauthorised access, improper use or disclosure or unauthorised modification. To prevent unauthorised access, we have put in place the latest industry-standard security technology and procedures to safeguard the information we collect online. Your personal information is encrypted and is protected with 256-bit Secure Sockets Layer (SSL) software, which encrypts all information you input. We store your personally identifiable information on the computer servers placed in a secure environment. Even though we have taken significant steps to protect your personally identifiable information, no company, including our App, can fully eliminate security risks associated with Personal Information.

9. Maintain Confidentiality of Your VACCINATION STATUS

9.1 We understand the confidential nature of the vaccination history you provide us to create your digital documentation and we treat your vaccination history as protected information.

10. Changes to Our Privacy Policy

10.1 We may revise this Privacy Policy from time to time by updating this page, and so we urge you to review it periodically to ensure that you agree with any such changes that we make. We will make best efforts to inform you of any important amendments by e-mail, message on the App or notification in Your Account. However, it is your responsibility to check the Policy regularly to ensure that you agree with it and your continued use of the App will be deemed to be your acceptance of any changes that we make.

Last updated Date: 23/09/2021

11. Contact Information

11.1 Please contact us for any questions or comments regarding these Terms and Conditions.

Telephone Number:+94 71 234 2940

E-mail Address: contact@luhn.io