Privacy Policy
SL Mobility (Pvt.) Limited [hereinafter referred to as ‘SL Mobility’, including references to“we”, “our” or “us”, where the context so means] is committed to providing convenient and eco-friendly transport solution services, using the latest technology in connectivity and sustainability.
When you use our products and services, you trust us with your personal data. SL Mobility is committed to safeguarding that trust. We ask that you read and familiarise yourself with this Privacy Policy, as it contains important information on how we use your personal data to offer you a better service while protecting your privacy.
This Privacy Policy describes how SL Mobility, and its affiliates, collect, process, and protect the personal data and information of:
- visitors and users of the Lencar website;
- users of the EZR App;
- people who do business with us and/or register for our services;
- people who purchase and use Lencar vehicles;
- people who use the battery charging/swapping facilities linked to the EZR App;
- people who make/send payments to us or our affiliates;
- any person who discloses their personal information via the Lencar website, the EZR App, or via email or in physical form (e.g.: by filling out a form during our promotional campaigns).
1. DATA CONTROLLERS
SL Mobility (Pvt.) Limited of No 115/5-115/15, Moragasmulla Road Rajagiriya, Sri Lanka (PV No. 108147) and EZR Power Hubs (Pvt.) Limited of No, 29, Grenier Road Borella Colombo 08, Sri Lanka (PV No. 00279226) are the data controllers for the data collected in connection with the use of the products and services we provide.
2. THE DATA WE COLLECT
We are in the business of providing technologically advanced transport solutions, products, and related services.
When you purchase or subscribe to our products and/or receive our services and/or engage with us electronically or physically, we collect all or some of the data about you that falls within the following categories of data [hereinafter referred as ‘data categories’]:
- Data provided by you:
This category includes the information you directly provide when you: i) buy any Lencar products or services; ii) submit any form on the Lencar website; iii) subscribe to the EZR App; or, iv) submit any physical form provided by SL Mobility or our affiliates that discloses details about you or describing yourself and your identity.
Data collected under this category are:
- Name,
- Age,
- Gender,
- Postal Addresses,
- Email Addresses,
- Mobile Phone Numbers, Residential Phone Numbers, Official Phone Numbers,
- National Identity Card Numbers, Passport Numbers, or Driving License Numbers,
- Bank account number and details.
Please note that all the information listed above may not be collected at the same time.
- Data you create while using our products and services;
We collect other information you provide when you are using our products and/or
services. This information can be collected through the Lencar website, the EZR App,
physical documents, or Vehicle Software (either by direct connection, or through the
EZR App).
Information collected under this category are:
- Electronic images and videos you provide through the EZR App or Vehicle
Software, - Physical images you provide with any physical form you have submitted,
- You usage data (how you interact with our products/services; your preferences),
- Vehicle type(s) and details of vehicle(s) you use,
- Charging Centre(s) and Battery Swapping Storage Facilities you use,
- Your location information,
- Your vehicle usage (distances you have travelled; trip information),
- Your transaction information,
- Your bank account and payment card details, including card numbers and expiry
dates, and - Details of other EZR App users you share your vehicle with.
- Electronic images and videos you provide through the EZR App or Vehicle
Please note that all information listed above may not be collected at the same time.
- Data about you that is automatically collected;
The Lencar website, the EZR App, and Vehicle Software (either by direct connection,
or through the EZR App) automatically collect data about users and their usage of our
products/services.
Data collected under this category are:
- Images and videos collected through the Vehicle Software while you are using
the vehicle, - Vehicle location and vehicle details at a point in time,
- Vehicle performance details, including the distances travelled, battery condition,
engine condition, brake condition, and system diagnostic details, - Duration of your use of the vehicle or the EZR App,
- Information provided through Cookies on our website.
- Images and videos collected through the Vehicle Software while you are using
Please note that all information listed above may not be collected at the same time.
- Data Collection through T-Box & Processing
Scope of Data Collected
The T-Box includes a SIM card that enables SL Mobility to collect real-time data
related to:
- Vehicle location & ride patterns
- Battery charge cycles & usage
- System diagnostics & maintenance status
- Speed, acceleration, and braking patterns
Legal Basis for Data Processing
Data processing is conducted in compliance with the Personal Data Protection Act
(PDPA) of Sri Lanka and is based on:
- Contractual necessity (i.e., providing mobility services).
- Legitimate interest (i.e., fleet optimization and safety).
- Legal and regulatory compliance.
How Data is Used
- To ensure seamless operation and safety of the e-scooter services.
- To provide real-time diagnostics, updates, and customer support.
- To analyze service performance and improve the user experience.
Data Sharing & Disclosure
SL Mobility may share T-Box data with:
- EZR Power Hub for battery performance analytics.
- Regulatory authorities where required by law.
- Third-party service providers, strictly for operational purposes.
No personal data will be sold, rented, or disclosed to third parties for marketing without explicit consent.
User Rights Data Retention
Users have the right to:
- Request access to collected data.
- Request data correction or deletion, subject to legal obligations.
Data will be retained for as long as necessary to provide services and meet legal
requirements.
Security Measures
- SL Mobility implements industry-standard encryption and security to protect user data from unauthorized access, disclosure, or misuse.
- Battery Rental & Usage Monitoring
As batteries are rented and remain the property of SL Mobility or its affiliates, we monitor:
- Charging and swapping history.
- Battery health and usage behavior (e.g., overcharging, unauthorized handling).
We may use this data to:
- Detect improper use, unauthorized modifications, or unsafe handling.
- Enforce penalties or take action against non-compliance.
- Improve battery performance and customer experience.
- Leasing Arrangements & Ownership Compliance
If your e-bike is purchased through a leasing company, SL Mobility may share necessary data with the leasing provider, including:
- Vehicle registration details and ownership status.
- Service and maintenance history.
- Any violations, non-compliance, or penalties imposed on the vehicle.
SL Mobility will comply with leasing company instructions regarding service eligibility, ownership records, and operational requirements.
- Enforcement of Terms & Penalties
We may collect, store, and process customer data related to:
- Service violations (e.g., battery misuse, tampering, or non-payment).
- Penalties and outstanding charges.
- Legal and compliance actions taken against a user.
This data may be retained for legal compliance, dispute resolution, and service enforcement.
- Data we collect about you from Third Parties:
In the course of business, we may receive data about you from other sources (such as, credit reference agencies, insurance or financial service providers, or public officials), which we will be added to the data that we already hold about you in order to help us improve the products and services we offer to you
3. HOW YOUR DATA IS USED
We process your personal data and information in compliance with the Personal Data Protection Act No. 9 of 2022.
The data that we gather is used to enable us to continue offering you eco-friendly transport services and solutions that are convenient and reliable. The data we gather about you is also used:
- to facilitate your subscription to our products/services (this involves using your data to verify your identity and register you and your vehicle(s) on our database);
- to carry out payments (this involves using your data to process transactions related to the use of our products/services and for authorising the payment and settlement of such transactions;
- to process any requests you make, and for customer support (this involves recording your requests and concerns and using your data to address such requests and concerns in a satisfactory manner);
- to provide you with real-time updates on charging/swapping facilities (this involves using your data to identify the charging/swapping stations within your proximity, and providing you information on the facilities available at such charging/swapping stations);
- to provide you with real-time updates on your vehicle (this involves using your data to provide you information on the condition of various components of your vehicle and the status of the battery of your vehicle);
- to personalise your experience (this involves using your data to know your personal preferences and to customise our platforms and products/services based on such preferences);
- for marketing and promoting (this involves using your data to market and advertise our latest products/services and any new features or updates to our existing products/services, and to promote new or expanded charging/swapping stations);
- to send non-market communications to users of our products/services (this involves using your data to send you communications that do not relate to marketing or advertising of products, such as, software & security updates, and surveys etc.);
- for research and development (this involves using your data to test, evaluate, and assess new products/services, and to analyse and review market conditions, which help us improve the products and services offered to you);
The following table depicts the data categories that are relevant to our uses of your data.
| Why your data is used | Relevant data categories |
| To facilitate your subscription to our products/services |
|
| To carry out payments |
|
| To process any requests you make, and for customer support |
|
| To provide you with real-time updates on charging/swapping facilities |
|
| To provide you with real-time updates on your vehicle |
|
| To personalise your experience |
|
| For marketing and promoting |
|
| To send non-market communications to users of our products/services |
|
| For research and development |
|
We may also use aggregate data and statistics (data that does not include information or identifiers that can be used to identify you) for the purposes of monitoring and improving the usage and performance of the Lencar website, the EZR App, or any of our products/services. We may also provide such aggregate data to third party market researchers, business analysts, and investors.
4. COOKIES AND OTHER INFORMATION-GATHERING TECHNOLOGIES
Our websites use cookies. Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. The information is used to track visitor use of the website and to compile statistical reports on website activity. For further information about cookies visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser to reject cookies, and the above websites describe how you can remove cookies from your browser. However, certain features of our website may not function if you remove cookies from your browser.
We may also allow third parties to provide audience measurement and analytics for us, to serve advertisements on our behalf, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.
5. HOW YOUR DATA IS PROTECTED
The security and integrity of your data is important to us. Therefore, we have put in place the following security procedures and technical and organisational measures to safeguard your personal data:
- Encryption in transit and at rest of the personal data under the ‘Your account information’ and ‘Data you create while using our products and services’ categories.
- Obtaining browser certificates and SSL certificates for our websites and platforms.
- Creating awareness among our employees, advisors, and representatives to create a work environment that values and is conscious of data protection and privacy.
- Having employment related protocols regarding the processing, handling, and storing of personal data and information.
In addition to these specific measures, we will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason, we cannot guarantee the security or integrity of any personal information that is transferred from you, or to you, via the Internet. If there is any data breach from our end, we will immediately take the necessary steps to remedy the breach and notify the relevant parties in compliance with the applicable legal requirements.
6. HOW YOUR DATA IS SHARED AND DISCLOSED
Some of the features of our products and services necessitate the sharing of data with our affiliates and business partners. Therefore, data may be shared with and disclosed to:
A). EZR Power Hubs (Pvt.) Limited (the developer of the EZR App; an affiliate of SL Mobility)
The data shared includes:
- the name, age, gender, postal and email addresses, contact information and numbers, National Identity Card/Passport/Driving License numbers of purchasers/users of Lencar products and services;
- the details (including, the manufacturer and model, license plate number, and vehicle photo), condition, and battery status of your vehicle(s);
- Electronic images and videos you provide through the Lencar website or the Vehicle Software, as well as physical images you have submitted to SL Mobility;
- Vehicle performance details, including the distances travelled, battery condition, engine condition, brake condition, and system diagnostic details;
- Vehicle location and vehicle details at a point in time;
- Charging Centre(s) and Battery Storage Facilities you use.
b. Vendors of battery charging/swapping stations:
The data shared includes:
- the name, contact details, and location of a user of a purchaser/user of Lencar products/services;
- the details (including, the manufacturer and model, license plate number, and vehicle photo), condition, and battery status of the vehicle of a purchaser/user of Lencar products/services and the EZR App.
c. SL Mobility’s business partners and service providers:
These include:
- Marketing platform providers, including social media advertising services and advertising networks;
- Insurance and financial service providers;
- Research partners, including market researchers and survey service providers;
- Payment processors;
- Cloud storage providers;
- Identity verification services providers;
- Our consultants, legal advisors, accountants and other professional service providers.
d. Persons that a user has requested data to be shared with:
This may include situations where a user of our services requests data (such as vehicle performance details, vehicle location in a point in time, or images and videos provided through the Lencar website or the Vehicle software) to be shared with another party, such as, a prospective buyer of a vehicle or a technician.
This may also include requests for data to be shared in respect of third-party promotions that are offered in partnership with SL Mobility.
e. Any law enforcement or government authority, for the purposes of legal action:
SL Mobility may be required to disclose data to law enforcement or government authorities if such a disclosure if required by application of law, regulation, or a judicial process, or if such a disclosure is warranted for security and safety concerns.
In the event of a dispute, SL Mobility may be required to disclose data with law enforcement officials, public officials, government authorities, or other third parties, as may be necessary to comply with any judicial or administrative proceedings, or to enforce our Terms of Service, agreements, and policies.
f.Leasing companies for ownership verification and compliance.
7. RETENTION OF YOUR DATA
As the functionality of our products/services depends on processing data, we retain your data for as long as it is necessary for the uses and purposes described in this Policy. We determine the duration to retain your data based on the category that the falls into, the type of user to whom the data relates, and use for which the data was collected. For example, we may retain personal or transactional data for longer periods in order to comply with legal or regulatory requirements, to prevent frauds, or in the event of likely or ongoing disputes and outstanding payments.
You may, at any time, request us to disclose some or all your data that has been retained, by submitting a formal request to info@lencar.lk. You may even submit a formal request by Page 11 of 2post, which is addressed to Head of Operations, 29, Grenier Road, Colombo 08, Sri Lanka. Please note that disclosing the retained data may be subject to a processing fee.
If any data that we have disclosed to you is incorrect or requires revision (for example, if your contact details must be updated, or your bank details are incorrectly recorded), please provide us with the information necessary to correct and revise your data. You may provide such corrected and revised information, or request us to delete any incorrect information, by sending an email to info@lencar.lk or a letter addressed to Head of Operations, 29, Grenier Road, Colombo 08, Sri Lanka.
You may, at any time, request us to delete an account/profile, or cancel any subscription, that you have created or signed up for to use or products/services. Upon receiving such a deletion/cancellation request, we will delete your account/profile/subscription and your data. However, we may continue to retain some your data even after a deletion/cancellation request due to legal and regulatory reasons, and for the other purposes stated in this Policy.
You may also, at any time, ask us to delete the data we have retained, expect such data that we are required to retained due to legal and regulatory reasons by sending an email to info@lencar.lk or a letter addressed to Head of Operations, 29, Grenier Road, Colombo 08, Sri Lanka. However, your ability to access and use any or all of our products and services may be affected by the deletion of you data.
8. YOUR DATA CONTENTS AND PREFERENCES
We value your agency over how your data is used. Therefore, you can review your consents and adjust your data preferences at any time by:
- accessing and reviewing Privacy and Cookies setting on the Lencar website and the EZR App;
- accessing and reviewing the Device Permissions on the device(s) you use to access our products/services;
- making requests to access and review your data.
9. CHANGES TO THE PRIVACY POLICY
Our Privacy Policy is regularly reviewed to ensure your information is safeguarded. If any changes are made to our Privacy Policy, we will post notices of the changes on the Lencarwebsite and/or update the EZR App, so that you may consent to and familiarise yourself on how your information is collected and how we use it.
Your failure or refusal to consent to any amendments to the Privacy Policy, shall constitute an immediate termination of any agreement(s) between you and SL Mobility.
10. HOW TO CONTACT US
We welcome your views about our products and services, the Lencar website, the EZR App, and our Privacy Policy. If you would like to contact us, make any inquiries, or provide any feedback, please send an email to info@lencar.lk , or a letter addressed to Head of Operations, 29, Grenier Road, Colombo 08, Sri Lanka.
11. LINKS TO OTHER WEBSITES
The Lencar website the EZR App contain links to other websites. This Privacy Policy only applies to our products and services. Thus, when you link to other websites you should familiarise yourself with the policies of those websites.
12. EFFECTIVE DATES AND AMENDMENTS
This Privacy Policy is effective from 18th February 2025
Due to reasons such as implementation of updates for the Lencar website and the EZR App, including functionality changes, addition of new features, complying with legal requirements, and other necessary matters, we may, from time to time, amend this Privacy Policy. Such amendments will be made at our sole discretion. Any such amendment will be effective from the date set out in such amendment. Any such amendments will be notified to you, and you have the option of agreeing or disagreeing with the amendments.
In order to use the license to use the App and receive Services, you must agree and comply with the terms of the Privacy Policy appliable at the date of making the request for the relevant product/service.