SL Mobility (Pvt.) Limited (“SL Mobility”, “we”, “our”, or “us”) is committed to providing convenient and eco-friendly transport solutions, using the latest technology in connectivity and sustainability.
When you use our products and services, you trust us with your personal data. We ask that you read and familiarise yourself with this Privacy Policy, as it explains 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 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).
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.
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 following categories of data. Please note that not all information listed below is collected at the same time.
- Name, age, gender
- Postal and email addresses
- Mobile, residential, and official phone numbers
- National Identity Card, passport, or driving license numbers
- Bank account number and details
- Electronic images and videos via the EZR App or vehicle software
- Physical images submitted with any physical form
- Usage data and preferences
- Vehicle type(s) and details
- Charging centre(s) and battery swapping facilities used
- Location information, trip distances, and transaction information
- Bank account and payment card details
- Details of other EZR App users you share your vehicle with
- Images and videos collected through the vehicle software
- Vehicle location and details at a point in time
- Vehicle performance: distance travelled, battery, engine, and brake condition, system diagnostics
- Duration of your use of the vehicle or the EZR App
- Information provided through cookies on our website
- Credit reference agencies
- Insurance or financial service providers
- Public officials
- Used to help us improve the products and services we offer you
Data Collection Through T-Box & Processing
The T-Box includes a SIM card that enables SL Mobility to collect real-time data related to vehicle location and ride patterns, battery charge cycles and usage, system diagnostics and maintenance status, and speed, acceleration, and braking patterns.
This processing is conducted in compliance with the Personal Data Protection Act (PDPA) of Sri Lanka, and is based on contractual necessity (providing mobility services), legitimate interest (fleet optimisation and safety), and legal and regulatory compliance. It is used to ensure seamless operation and safety of our e-scooter services, to provide real-time diagnostics and customer support, and to analyse and improve service performance.
T-Box data may be shared with EZR Power Hub for battery performance analytics, with regulatory authorities where required by law, and with third-party service providers strictly for operational purposes. No personal data will be sold, rented, or disclosed to third parties for marketing without your explicit consent.
You have the right to request access to your collected data, and to request correction or deletion, subject to our legal obligations. Data is retained for as long as necessary to provide our services and meet legal requirements, and is protected with industry-standard encryption and security measures.
Battery Rental & Usage Monitoring
As batteries are rented and remain the property of SL Mobility or its affiliates, we monitor charging and swapping history, and battery health and usage behaviour (e.g. overcharging, unauthorised handling), to detect improper use, enforce penalties where needed, and improve battery performance.
Leasing Arrangements & Compliance
If your e-bike is purchased through a leasing company, we may share vehicle registration and ownership status, service and maintenance history, and any violations or penalties with the leasing provider, and will comply with their instructions on service eligibility and operational requirements.
Enforcement of Terms & Penalties
We may collect, store, and process data related to service violations (e.g. battery misuse, tampering, or non-payment), penalties and outstanding charges, and legal or compliance actions taken against a user. This data may be retained for legal compliance, dispute resolution, and service enforcement.
How Your Data Is Used
We process your personal data in compliance with the Personal Data Protection Act No. 9 of 2022. The data we gather is used to continue offering you eco-friendly transport services that are convenient and reliable, including to facilitate your subscription, carry out payments, process requests and provide customer support, share real-time updates on charging/swapping facilities and vehicle condition, personalise your experience, market and promote our products, send non-marketing communications, and support research and development.
We may also use aggregate, de-identified data and statistics to monitor and improve the Lencar website, the EZR App, and our products and services, and may share such aggregate data with third-party market researchers, business analysts, and investors.
| 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 |
|
How Your Data Is Protected
The security and integrity of your data is important to us. We have put in place the following measures to safeguard your personal data:
- Encryption in transit and at rest of personal data under the ‘account information’ and ‘data you create while using our services’ categories.
- Browser certificates and SSL certificates for our websites and platforms.
- Ongoing awareness training for our employees, advisors, and representatives on data protection and privacy.
- Employment protocols governing the processing, handling, and storing of personal data.
We use all reasonable efforts to safeguard your personal information; however, use of the internet is not entirely secure, and we cannot guarantee the security or integrity of information transferred via the internet. If a data breach occurs on our end, we will immediately take the necessary steps to remedy it and notify the relevant parties in compliance with applicable legal requirements.
Retention of Your Data
As our products and services depend on processing data, we retain your data for as long as necessary for the purposes described in this policy. Retention periods are based on the category of data, the type of user, and the purpose for which it was collected — for example, we may retain transactional data longer to comply with legal or regulatory requirements, prevent fraud, or address ongoing disputes and outstanding payments.
You may request disclosure of retained data, or corrections to inaccurate data, by emailing info@lencar.lk or by post to the Head of Operations, 29 Grenier Road, Colombo 08, Sri Lanka. Disclosure requests may be subject to a processing fee.
You may also request deletion of an account, profile, or subscription at any time. On receiving a deletion request, we will delete your account, profile, and subscription data — though we may continue to retain some data where required by law or for the other purposes described in this policy. Note that deleting data may affect your ability to access or use our products and services.
Your Data Rights & Preferences
We value your agency over how your data is used. You can review your consents and adjust your data preferences at any time by:
- Accessing and reviewing Privacy and Cookies settings on the Lencar website and the EZR App.
- Accessing and reviewing Device Permissions on the device(s) you use to access our products/services.
- Making a request to access and review your data.
Changes to the Privacy Policy
This Privacy Policy is regularly reviewed to ensure your information is safeguarded. If we make changes, we will post notice of the changes on the Lencar website and/or update the EZR App, so you can review how your information is collected and used.
Your failure or refusal to consent to any amendments to this Privacy Policy will constitute immediate termination of any agreement(s) between you and SL Mobility.
How to Contact Us
We welcome your views on our products and services, the Lencar website, the EZR App, and this Privacy Policy.
Postal Address
Head of Operations, 29 Grenier Road, Colombo 08, Sri Lanka
Links to Other Websites
The Lencar website and the EZR App contain links to other websites. This Privacy Policy only applies to our products and services — when you link to other websites, you should familiarise yourself with their own privacy policies.
Effective Dates & Amendments
This Privacy Policy is effective from 18th February 2025.
We may, from time to time, amend this Privacy Policy — for reasons such as updates to the Lencar website and the EZR App, functionality changes, new features, or compliance with legal requirements. Amendments are made at our sole discretion and take effect from the date set out in the amendment. You will be notified of any amendments and have the option to agree or disagree with them.
To use the license to access the App and receive our services, you must agree to and comply with the terms of the Privacy Policy applicable at the date you request the relevant product or service.
