Privacy Policy

Company: Horton Group

Effective Date: June 2025

Last Updated: June 2025

This Privacy Policy explains how Horton Group (“we,” “us,” or “our”) collects, uses, discloses, and safeguards your personal information when you visit our website or engage with our services. By accessing our website or providing us with your information, you agree to the terms of this Privacy Policy.

1. Information We Collect

1.1 Information You Provide Directly

When you submit an enquiry through our Contact Us page, we collect the following information:

  • First Name and Last Name
  • Email Address
  • Contact Number
  • Organisation Name
  • Correspondence records including any messages or follow-up communications you send to us.
  • Business information shared during partnership or financing discussions.

1.2 Information Collected Automatically

  • IP addresses, browser type, operating system, and referring URLs.
  • Pages visited, time spent on pages and click-through patterns.
  • Cookies and similar tracking technologies (see our Cookie Policy for details).

1.3 Information from Third Parties

  • Publicly available business information from government registries, financial databases, and news sources relevant to investment due diligence.
  • Referral information from business partners or intermediaries.

2. How We Use Your Information

We use the information we collect for the following purposes:

  • To respond to your enquiries and communications submitted via our Contact Us page.
  • To send you future promotional communications, including updates on our portfolio companies, sector insights, events, and business announcements, where you have submitted your details through our Contact Us page. You may opt out of such communications at any time by contacting us at info@horton.lk or by using the unsubscribe link included in any marketing email.
  • To evaluate potential investment opportunities and business partnerships.
  • To conduct due diligence and compliance checks as required by Sri Lankan law.
  • To improve and maintain our website and digital services.
  • To comply with applicable legal obligations, including regulatory reporting.

3. Legal Basis for Processing

We process your personal information under the following legal bases:

  • Consent: By submitting the Contact Us form, you agree that the information provided may be used to contact you with future promotional communications from Horton Group. This consent is voluntary and may be withdrawn at any time.
  • Legitimate Interests: For business development, investor relations, and website analytics, where such interests are not overridden by your data protection rights.
  • Legal Obligation: Where processing is required to comply with Sri Lankan laws and regulations, including the Companies Act No. 7 of 2007 and applicable data protection legislation.

4. Sharing of Information

We do not sell or rent your personal information. We may share your information with:

  • Professional advisors including attorneys, accountants, and auditors engaged under confidentiality obligations.
  • Regulatory authorities, courts, or government bodies where required by law.
  • Technology service providers (e.g., website hosting, email platforms) acting on our behalf under data processing agreements.
  • Affiliated entities within the Horton Group for legitimate business purposes.

5. Data Retention

We retain personal information for as long as necessary to fulfil the purposes outlined in this Policy, or as required by applicable law. Business correspondence and investor records may be retained for up to seven (7) years in accordance with financial record-keeping obligations.

6. Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. However, no method of transmission over the internet is entirely secure, and we cannot guarantee absolute security.

7. Your Rights

Depending on applicable law, you may have the right to:

  • Access and obtain a copy of your personal information held by us.
  • Request correction of inaccurate or incomplete data.
  • Request deletion of your personal information where no longer necessary.
  • Withdraw consent at any time where processing is based on consent.
  • Lodge a complaint with the relevant data protection authority.

To exercise any of these rights, please contact us at info@horton.lk.

8. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites. We encourage you to review their privacy policies independently.

9. Children’s Privacy

Our website and services are not directed at individuals under the age of 18. We do not knowingly collect personal information from minors.

10. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. Changes will be posted on this page with a revised effective date. Continued use of our website following any changes constitutes acceptance of the updated Policy.

11. Contact Us

For questions or concerns regarding this Privacy Policy, please contact:

Company: Horton Group

Address: No. 2 Arunachalam Avenue, Horton Place, Colombo 07, Sri Lanka

Phone: +94 11 289 898

Email: info@horton.lk