PERSONAL DATA PRIVACY POLICY

 

Purpose

As a part of LTRIA’s commitment to act with integrity and respect individual privacy, we protect the personal data of our stakeholders, including employees, customers, shareholders, partners, suppliers and other individuals who trust us with information.

“Personal data” includes any information, which identifies or locates an individual, or is capable of doing so.

To be a trusted business partner, LTRIA continually strives to protect personal data in accordance with applicable laws and regulations and industry standards including PDPA, HIPAA and Safe Harbour Privacy. To that end, this policy guides how LTRIA collects, uses, stores, transfers and secures personal data.

Policy

LTRIA obtains personal data only for business-related purposes, which may include, but are not limited to, designing, developing, selling and deploying of health benefits and wellness products and providing related support and other services, providing employee benefits, acquiring information as legally required and providing consultancy or advisory services to operators and other customers within the employee benefits and wellness umbrellas.

We work to ensure that personal data is accurate, complete and reliable for its intended use. Individuals have the right to review, request updates to, withhold or limit transfer of personal data, as necessary and reasonable.

LTRIA protects personal data from loss, misuse, or unauthorized access, disclosure, alteration or destruction. We store personal data, regardless of its form, with security procedures appropriate to the sensitivity of the data. Records which may contain personal data are retained and destroyed by LTRIA in accordance with the company’s Record Retention Policy.

A separate privacy policy guides LTRIA treatment of information, correspondence and software exchanged through LTRIA websites. A copy of the LTRIA Privacy Policy is available at www.LTRIA.com.

Disclosure to Third Parties

LTRIA does not sell, rent or lease personal data, or disclose it to third parties unless there is a legally valid reason for doing so. In order to meet the needs of our stakeholders, we may share information with third-party business partners. When we do so, the companies are required to protect personal data. LTRIA will adhere to all applicable laws and requires our third-party partners to do the same.

LTRIA may provide personal data without express written permission, if allowed under applicable laws, in circumstances that include, but are not limited to:
Requests from governmental agencies, subpoenas, court orders or other legal requirements. In these circumstances, LTRIA will make every effort to limit the nature of the disclosure.
Limited employment status data (including dates of employment and positions held) in the course of an employment-related inquiry.
Emergency situations as necessary to ensure health and safety.

Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data

If you:
have any questions or feedback relating to your Personal Data or our Privacy Policy;
would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or
would like to obtain access and make corrections to your Personal Data records, please contact us as follows:

Email: hello@ltria.com

Please note that if your personal data has been provided to us by a third party (e.g. your employer), you should contact that party to make such queries, complaints, and access and correction requests to LTRIA on your behalf.

If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, LTRIA may not be in a position to continue to provide its products or services to you, or administer any contractual relationship in place. It may also result in the termination of any agreements with LTRIA, and your being in breach of your contractual obligations or undertakings, and LTRIA’s legal rights and remedies in such event are expressly reserved.

Responsibilities

MANAGEMENT: Management is responsible for enforcing data privacy rules. The Corporate Privacy Officer, Information Technology and Human Resources Departments have additional responsibilities for helping to protect personal data.

EMPLOYEES: Employees are responsible for following data privacy laws and complying with this policy. Employees must report any violations of this policy to the Corporate Privacy Officer as soon as they are aware.