Privacy Policy

1. Who We Are

Sentered Media (Private) Limited is a company operating in Sri Lanka.

For the personal information described in this Privacy Policy, Sentered Media generally acts as the organisation responsible for determining why and how that information is processed.

2. Information We Collect

When you apply for a position or respond to one of our recruitment advertisements, we may collect:

• your name; and
• your telephone number.

During the recruitment process, we may also create internal notes or assessments relating to your application, such as whether you appear suitable for a role based on the information provided during the recruitment process.

We do not intentionally collect personal information from individuals under 18 through our recruitment lead forms.

We do not intentionally request sensitive personal information such as health information, biometric information, religious beliefs, political opinions, financial information or national identity card numbers through these recruitment forms.

3. How We Collect Your Information

We may collect personal information directly from you through:

• Meta or Facebook/Instagram Instant Forms;
• telephone conversations;
• WhatsApp communications; and
• our website or other recruitment communications.

When you submit a recruitment form through Meta, Meta may also process information in accordance with its own privacy policies and platform terms.

4. Why We Use Your Information

We use recruitment information for purposes including:

• receiving and reviewing your application;
• assessing whether you may be suitable for a position at Sentered Media;
• qualifying and organising recruitment candidates;
• contacting you about your application;
• conducting recruitment-related telephone or WhatsApp conversations;
• arranging interviews or further stages of our recruitment process;
• maintaining appropriate recruitment records; and
• protecting our legitimate business, security and legal interests where necessary.

We will not use recruitment information collected through these forms to place you on an unrelated ongoing marketing list.

5. Basis for Processing

Where applicable, we process your personal information because you have voluntarily submitted an application or requested to participate in our recruitment process.

Processing may also be necessary in order to take steps at your request before entering into an employment or contractual relationship with you and, where permitted by applicable law, for legitimate recruitment and business administration purposes.

Where processing relies specifically on your consent, you may withdraw that consent by contacting us at sharon@senteredmedia.com.

Withdrawal of consent does not affect processing that was lawfully carried out before the withdrawal.

6. Contacting Applicants

By submitting an application for a position advertised by Sentered Media, you understand that Sentered Media or an authorised member of our recruitment team may contact you in connection with that application.

We may contact you using:

• telephone calls; or
• WhatsApp.

These communications are for recruitment and application-related purposes and are not intended to enrol you in unrelated ongoing advertising or promotional communications.

7. How We Assess Applications

Our recruiters may manually assess or categorise applicants based on information relevant to the position.

For example, we may consider information discussed during the recruitment process when determining whether an applicant should proceed to another recruitment stage.

We do not currently use artificial intelligence or solely automated systems to make final recruitment decisions based on information collected through our Meta lead forms.

8. Who Can Access Your Information

Access to recruitment information is limited to people who reasonably require it for recruitment or administration purposes, such as authorised Sentered Media recruiters.

We do not sell recruitment applicant information to third parties.

We do not provide recruitment leads to clients or other businesses for their own marketing purposes.

9. Service Providers

We use third-party technology providers to operate parts of our business.

These may include:

• Meta Platforms, for advertising and Meta Instant Forms;
• Google, including Google Drive and Google Sheets, for storing and managing recruitment information; and
• website analytics, advertising and tracking technology providers used on senteredmedia.com.

These providers may process information on our behalf or as separate organisations under their own terms and privacy policies.

We take reasonable steps to limit access to information to what is appropriate for the services being provided.

10. International Processing

Some technology providers we use, including Meta and Google, operate internationally and may process or store information using systems or infrastructure located outside Sri Lanka.

As a result, personal information may be processed outside Sri Lanka.

Where applicable, we will take reasonable steps and use appropriate arrangements required under applicable data-protection law for international processing or transfers of personal information.

11. How Long We Keep Recruitment Information

We do not intend to keep unsuccessful recruitment leads indefinitely.

Personal information collected through recruitment lead campaigns will ordinarily be retained for no longer than 60 days after the relevant recruitment process or campaign has concluded, unless:

• the applicant progresses to employment or another working relationship with Sentered Media;
• the applicant expressly agrees to be considered for future opportunities;
• retention for a longer period is reasonably required to handle a dispute, complaint or legal matter; or
• applicable law requires us to retain the information.

After the applicable retention period, information that is no longer reasonably required will be deleted or otherwise securely disposed of.

If an applicant becomes an employee or contractor, information necessary for that relationship may subsequently be maintained as part of the appropriate employment or contractor records and may be subject to different retention requirements.

12. Security

We take reasonable technical and organisational measures to protect personal information against unauthorised access, misuse, loss, alteration or disclosure.

Recruitment information may be maintained through secured Google accounts and Google Sheets.

Access is restricted to authorised personnel who require the information for their work. We use account security measures such as passwords and access controls, and access should be removed when a person no longer requires it or leaves the company.

No electronic storage or communication system can be guaranteed to be completely secure.

13. Your Privacy Rights

Subject to applicable Sri Lankan law, you may have rights regarding your personal information, including the ability to request that we:

• confirm whether we hold personal information about you;
• provide access to relevant personal information;
• correct inaccurate or incomplete information;
• erase personal information where applicable;
• stop certain further processing;
• respond to an objection to certain processing; or
• give effect to a withdrawal of consent where processing is based on consent.

To make a privacy request, contact:

sharon@senteredmedia.com

Please provide enough information for us to reasonably identify your application. We may request additional information where reasonably necessary to verify your identity before providing, changing or deleting personal information.

We will respond within the period required by applicable law.

14. Withdrawal From the Recruitment Process

You may tell us at any time that you no longer wish to continue with a recruitment application.

You can do this during a telephone or WhatsApp conversation with our recruitment team or by emailing sharon@senteredmedia.com.

Where appropriate, we will stop using your information for the recruitment process and delete it in accordance with applicable law and our retention requirements.

15. Website Cookies and Tracking Technologies

Our website may use cookies and similar technologies.

These technologies may be provided by services such as Google Analytics and other analytics, advertising or website measurement providers.

They may collect information such as browser or device information, interaction with website pages, approximate location derived from technical information, and information relating to how visitors interact with our website.

We use these technologies for purposes such as:

• understanding website usage;
• measuring website performance;
• diagnosing technical issues;
• measuring advertising effectiveness; and
• improving our website and services.

Where legally required, we will provide appropriate choices or consent mechanisms relating to non-essential cookies or similar technologies.

16. Meta Lead Forms

When you submit information through a Facebook or Instagram lead form, some processing occurs through Meta's services.

Meta may collect or otherwise process information independently under its own terms and privacy policies.

The information submitted to Sentered Media through the recruitment form will be used by us for the recruitment purposes described in this Privacy Policy.

17. Children

Our recruitment lead forms are intended for people aged 18 or older.

We do not knowingly use these recruitment forms to collect personal information from children under 18.

If we become aware that such information has been submitted, we may delete it unless there is an appropriate lawful reason to retain it.

18. Data Breaches and Incidents

If we become aware of unauthorised access, disclosure, loss or misuse of personal information, we will investigate the incident and take reasonable steps to contain and address it.

Where applicable law requires notification to affected individuals or a competent authority, we will take the required steps.

19. Complaints

If you have a concern about the way Sentered Media handles your personal information, please first contact us at:

sharon@senteredmedia.com

We will review your concern and respond in accordance with applicable requirements.

Where applicable, you may also have the right to submit a complaint to the Data Protection Authority of Sri Lanka in accordance with the Personal Data Protection Act and applicable regulations.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our business, technology, recruitment practices or legal obligations.

The latest version will be published with an updated “Last Updated” date.

21. Contact Us

For questions, requests or concerns concerning this Privacy Policy or your personal information, contact:

Email: sharon@senteredmedia.com

Website: senteredmedia.com