LTRT Privacy Policy

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Overview 

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you interact with LTRT. It is further to and supported by LTRT’s IT Security Policy and Procedures for Managing a Privacy Breach. Combined, these policies document and procedures how we comply with the Personal Information Protection and Electronic Documents Act (PIPEDA). 

We invite members of the public to share personal information with us for the purpose of consultation and provision of feedback to our clients to improve their services and products. We also collect some personal data from our employees, contractors, and our clients for the purpose of conducting our day-to-day activities. If you choose to share your personal data with us, then you are agreeing to the terms and services of this Privacy Policy.  

Interpretation and Definitions 

Interpretation 

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. 

Definitions 

For the purposes of this Privacy Policy: 

• Company (referred to as either "the Company", "We", "Us" or "Our") refers to Left Turn Right Turn Ltd. 
• Country refers to: Canada 
• Personal Data is any information that relates to an identified or identifiable individual. 
• Service refers to activities related to consultation. 
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. 

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). 

Website refers to Left Turn Right Turn’s online site, accessible from www.ltrt.ca. 

You is the person whose information we are or might be collecting. 

Privacy Officer 

LTRT’s Privacy and Security Officer is our Chief Executive Officer, Yuval Grinspun. He may be reached at privacy@ltrt.ca.  

Collecting and Using Your Personal Data 

Types of Data Collected 

When working with clients, we often collect personal information for the purpose of conducting consultations on behalf of our clients. The reason we collect this data is so that our clients can get feedback about their programs, services, or future plans, to make improvements, and be responsive to their customers/clients and stakeholders. The types of information we typically collect include: 

• Email address 
• First name and last name 
• Location  
• Whether the individual belongs to an equity-deserving group (e.g., woman, person with a disability, member of an Indigenous community, racialized persons,  etc.) 
• Experiences or stories you have about interacting with our clients, or other similar experiences 
• Thoughts and feedback about certain initiatives, either before or after they have been launched 

We recognize that some information may be disclosed to LTRT that could identify who the person is. This Privacy Policy covers the steps we take to limit the disclosure of personally identifying information, and how we handle personally identifying information when it is received.  

We also collect information from our employees and suppliers to fulfil our legal and contractual obligations. This includes: 

• First name and last name 
• Personal email addresses 
• Mailing address and phone number 
• Dates of birth 
• Social Insurance Numbers 
• Banking information 

Purpose of Data Collection and Limiting Collection 

We use the data we collect to support our clients with improving their products and services, particularly as it relates to accessibility. Typically, a client is working on an initiative or project and wants to find out what their customers/clients/employees think about that initiative. We support our clients by administering surveys, running focus groups, community engagement, and conducting interviews with the client’s target audience.  

We collect data about our employees and suppliers to comply with our legal and contractual obligations and facilitate payment. 

We only collect the information that we need for the stated purposes. We do not collect additional information. 

Consent 

We only collect information with Your consent. We commit to sharing with You the purpose and use of that information so that you can make a decision about whether to share that information. 

Use of Your Personal Data 

We take care to ensure that your personal data is protected. All information that you provide to us, either through surveys, or through participation in interviews and focus groups, is kept confidential. We store your data in Canada and we do not share any identifying information about you (such as your name, location, e-mail address, occupation etc.) with our clients.  

The information that is shared with LTRT is aggregated (which means it is combined together) and anonymized (which means we remove any identifying information, such as your name) before we share it with our clients. We will tell our clients how many people filled out the survey and may share statistical information about how many people answered a question in a certain way. We will also share the feedback that you provided with our clients in a way that does not identify who you are.  

There are also some unique situations where a person’s identity might be revealed due to the nature of the group that we are collecting feedback from. We will take steps to ensure that confidentiality of our participants is always protected by removing identifiable details or not sharing the information.  For each client that we work with, we consider whether a unique situation, such as the one below, is present. For example, if we are surveying a client’s workforce which has only 3% French language speakers, then the language in which the feedback is received could be an identifying factor. In this case, we would translate the feedback into English to preserve anonymity.   

Retention of Your Personal Data 

We retain raw data collected through surveys, interviews or focus groups for a period of 6 months after the conclusion of the project (6 months starting from the end date of the contract). This includes personally identifying information (such as name and e-mail address). 

Documents that include aggregated and anonymized data (such as reports and memos) are kept for a period of 7 years. We have chosen the period of 7 years because it aligns with document retention requirements in the Accessible Canada Act.  

Some exceptions to the above timelines may apply.  

Transfer of Your Personal Data 

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. 

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. 

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information. 

Deleting Your Personal Data 

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. 

We can delete raw data, such as your name and the feedback you have provided. We cannot delete information that has been aggregated.  

If you have shared information with LTRT and you would like that data deleted, please contact us at:  

privacy@ltrt.ca 

Disclosure of Your Personal Data 

Business Transactions 

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred.  

Law enforcement 

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). 

Other legal requirements 

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: 

• Comply with a legal obligation 
• Prevent or investigate possible wrongdoing  
• Protect the personal safety of the public 
• Protect against legal liability 

Security of Your Personal Data 

The security of Your Personal Data is important to Us. We follow our IT Security Policy to maintain security. But remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. 

Breaches of Privacy 

Privacy breaches are managed pursuant to our Procedures for Managing a Privacy Breach. 

Changes to this Privacy Policy 

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. 

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. 

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. 

Contact Us 

If you have any questions about this Privacy Policy, You can contact our Privacy Officer, Yuval Grinspun at: 

• By email: privacy@ltrt.ca