Privacy Policy

Last Updated: May 2026

1. Introduction

Welcome to Kiwi Grow. Kiwi Grow is a product of Havik Labs (Pvt) Ltd (“we,” “us,” or “our”). We are committed to protecting your personal data and your privacy. This Privacy Policy explains how we collect, use, process, and share your information when you use our website or join our waitlist (collectively, the “Platform”).

Kiwi Grow is currently in a pre-launch phase. The data we collect today is used to shape the product and notify you when it launches.

By using the Platform, you agree to the collection and use of information in accordance with this policy and the Sri Lanka Personal Data Protection Act (PDPA), No. 9 of 2022.

2. Information We Collect

We collect the following types of information to shape our product and improve our service to you:

• Identity & Contact Data: Your name and phone number, collected when you join the waitlist.
• Survey Data: Your monthly salary range, whether you invest in unit trusts, which fund providers you use, where your savings currently go, how much you save per month, and your top savings priority.
• Technical & Usage Data: IP address, browser type, device information, pages viewed, scroll depth, and interaction data collected via analytics tools (Hotjar, Mixpanel) to understand how visitors use the website.

3. How We Use Your Data

We use the information we collect to:

• Understand the needs and preferences of potential users to shape the Kiwi Grow product.
• Contact you about the Kiwi Grow launch and related updates.
• Analyse website usage patterns to improve the user experience.

We do not currently share your personal data with third parties. In the future, when Kiwi Grow launches, your data may be shared with SEC-regulated partner fund managers to facilitate investment services and comply with Know-Your-Customer (KYC) and Anti-Money Laundering (AML) regulations. We will update this policy and notify you before any such sharing occurs.

We will never sell your data to third-party advertisers.

4. Data Security and Retention

We implement industry-standard security measures to protect your personal information from unauthorized access, alteration, or disclosure. We retain your data only for as long as necessary to fulfill the purposes outlined in this policy or to comply with statutory legal requirements.

5. Your Rights Under the PDPA

Under the Sri Lanka Personal Data Protection Act, you have the right to access, correct, or request the deletion of your personal data held by us. To exercise these rights, contact us at support@kiwi-money.com.