DATA DELETION & RETENTION POLICY: MACKVOLT
Effective Date: December 24, 2024 Last Revised: December 24, 2024
1. Overview
Macksons Power and Energy (Pvt) Ltd (“the Company”) is committed to the principle of data minimization. We believe that personal data should not be kept longer than is necessary for the purpose for which it was collected. This policy outlines how and when data is deleted, and the legal grounds upon which we may retain certain information.
2. Your Right to Erasure
In accordance with Section 16 of the Sri Lanka PDPA, every user of the Mackvolt App has the right to request the deletion of their personal data. You may exercise this right if:
The data is no longer necessary for the charging services provided.
You withdraw your consent for processing.
You believe the data is being processed unlawfully.
3. How to Initiate Deletion
To ensure the security of your account, all deletion requests must be verified.
In-App Feature: Navigate to Settings > Account > Delete Account. This will trigger an OTP to your registered Sri Lankan mobile number.
Written Request: Send an email to privacy@mackvolt.lk from your registered email address.
Physical Request: Visit the Macksons Holdings head office with your National Identity Card (NIC) for manual verification.
4. Retention Schedule (Sri Lanka Compliance)
While we aim to delete data immediately upon request, certain Sri Lankan laws require us to “freeze” and archive specific records for a set period.
| Data Category | Retention Period | Legal Basis |
| Personal Profile (Name, Email, NIC) | Deleted within 30 days of request. | PDPA Right to Erasure |
| Payment & Invoices (LKR transactions) | 6 Years | Financial Transactions Reporting Act No. 6 of 2006 |
| Charging Session Logs (Energy usage) | 2 Years (Anonymized thereafter) | PUCSL Operational Requirements |
| CCTV Footage (At charging stations) | 180 Days | FIU/CBSL Safety Guidelines |
| Customer Support Chats | 1 Year after ticket closure | Legitimate Interest (Quality Assurance) |
5. The Deletion Process
Once a deletion request is verified, Mackvolt follows a structured “Hard Delete” vs “Soft Delete” protocol:
Phase 1: Immediate Deactivation (Soft Delete): Your account is locked. You can no longer log in, and your profile is hidden from all active Mackvolt systems.
Phase 2: Database Scrubbing: Within 30 days, your PII (Personally Identifiable Information) is overwritten or cryptographically shredded in our primary databases.
Phase 3: Backups: Residual data in secure off-site backups will be overwritten according to our standard 90-day backup rotation cycle.
Phase 4: Anonymization: Your charging history (kWh used, station location) is stripped of all identifiers and turned into “Statistical Data” to help Macksons Power and Energy improve the national grid infrastructure.
6. Exceptions to Deletion
We may deny or delay a deletion request if the data is required for:
Debt Recovery: If there is an outstanding balance on your Mackvolt wallet or a failed session payment.
Legal Proceedings: If the data is subject to a “Legal Hold” issued by a Sri Lankan court or law enforcement agency.
Safety Investigations: If your account was involved in an incident involving damage to a charging station or electrical infrastructure.
7. Contact Information
For any concerns regarding how your data is handled during the deletion process, please contact:
Data Protection Officer Macksons Power and Energy (Pvt) Ltd , No 443, 5th floor, Galle Road, Colombo 03, Sri Lanka Email: dpo@mackvolt.lk Phone: 070 1977 100