Lyra International Global Privacy Policy

Last Updated: 05/05/25

Introduction

Lyra Health International Ltd and its subsidiary companies and branches (referred to as Lyra International going forward) is a wholly owned subsidiary of Lyra Health, Inc. Lyra International supports organisations through the promotion of the health and wellbeing of their employees, while at the same time improving productivity and reducing absence. We have been an Employee Assistance Programme (“EAP”) provider since 1987 and today, we are one of the major global players in the sector. We are committed to ensuring your privacy and Personal Information is protected.

What is Data Protection Law?

Data Protection law gives individuals certain rights about the way in which their Personal Information is processed. If organisations do not comply with data protection law, they may be subject to penalties imposed by the data protection authorities and the courts. When Lyra International processes Personal Information, this activity and the Personal Information in question are covered and regulated by applicable data protection law, specifically the UK Data Protection Act 2018 and the UK GDPR – as the principal regulations in the Policy – and the EU’s General Data Protection Regulation (GDPR) which covers all EU countries plus Norway, Iceland, and Liechtenstein. For countries outside these regions where we – or our subsidiaries – gather and process data, additional conditions may apply, where this is the case, you will find these in our ‘Jurisdictional Clauses’ at the bottom of this Policy.

Data Privacy Policy

This Data Privacy Policy (Global) (“Policy”) establishes Lyra International’s approach to global compliance and the lawful processing of Personal Information. As a UK company, the UK Data Protection Act 2018, the UK e-Privacy Regulations (‘PECR’), and the UK-adopted version of the EU GDPR (‘UK GDPR’) apply directly to all our UK processing, as such, for the purposes of this Policy, we use ‘GDPR’ to refer to both the UK and EU versions due to their similarities, except when we refer to International Data Transfers for example.

We always seek to comply with the applicable data protection laws relevant to our processing of Personal Information, as such where local laws and regulations mandate additional restrictions on the collection, use and disclosure of Personal Information that exceed those contained in this Policy, the local laws and regulations will prevail. These Addendums can be found at the bottom of this Policy under the ‘Jurisdiction Specific Terms’ tab.

This Policy describes how Personal Information must be processed to meet Lyra International’s data protection standards and to comply with privacy laws and regulations. Additional instructions and/or guidelines regarding Personal Information processing activities at Lyra International are provided to employees in internal policies.

What does this mean for Lyra International?

Lyra International must take proper steps to ensure that it processes Personal Information on an international basis in a safe and lawful manner. Lyra International has therefore developed policies and procedures to ensure appropriate governance and compliance with such data privacy laws. This framework will apply to all Personal Information processing activities conducted by Lyra International globally subject to our jurisdictional legal requirements.

Data Protection Principles

Below is the summary of basic data protection principles that Lyra International must observe when it processes Personal Information.

Principle 1 – lawfulness of processing, fairness and transparency

Lyra International will ensure that all processing is carried out in accordance with applicable laws.
Lyra International will inform and explain to individuals, at the time when their Personal Information is collected, how their Personal Information will be processed.

Principle 2 – purpose limitation

Lyra International will only obtain and process Personal Information for those purposes which are known to the individual or which are within their expectations and are relevant to Lyra International.
Lyra International will only process your data for the express purposes for which it was given, for example out of contractual obligation, because you’ve given your express consent, or where there is a legal basis for doing so. Where we consider ‘Legitimate Interest’ a legal basis, we will balance this against the potential risks to the rights and freedoms of the individual — for example, limiting what we keep, who we send your data to, how long we keep it for, what we do with it and the technical measures we use to protect your information.

How do we collect your personal information?

We collect Personal Information directly from you:

when you use our Employee Assistance Program (EAP) services generally and which may be by phone, via e-mail through the web, mobile or web applications, any other internet-based application or in person;
when you contract with Lyra International to provide services on our behalf or where we agree to provide services on your behalf.
via cookies. You can find out more about this in our Cookie Policy;
through feedback forms;
via our telephone calls with you, which may be recorded;
when you provide your details to us either online or offline;
when you respond to any job advertisement or are employed by Lyra International;

We also collect your Personal Information from many different sources including third parties such as:

your employer
medical professionals.

Principle 3 – data minimisation

Lyra International will ensure that data collected and processed is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

What personal information do we collect?

As the Data Controller and/or joint Data Controller Lyra International may collect and process the following information about you:

Personal information
- gender, contact details such as name, email address, postal address and telephone number;
- factors specific to physical, physiological, economic, cultural or social identity;
- call recordings;
- information obtained through our use of cookies. You can find out more about this in our Cookie Policy.
Sensitive Personal Information
- details of your current or former physical or mental health;
- details regarding criminal offences, including alleged offences, criminal proceedings, court judgments, outcomes and sentences;
- marital status
- details concerning sexual life or sexual orientation.

Principle 4 –accuracy

Lyra International will only keep Personal Information for as long as is necessary for the purposes for which it is collected, and to comply with our legal and regulatory obligations. The time we retain your Personal Information for, will differ depending on the nature of the Personal Information and what we do with it. In some cases, such as if there is a dispute or a legal action, we may keep Personal Information for longer.
Lyra International will retain call recordings for a period of 6 months after your last interaction with us or as required for operational needs. However, please note that certain local or national laws may require us to keep your data for a longer period. In such cases, we will hold your information in accordance with those legal requirements.
Your personal information will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information are processed; personal information may be stored for longer periods insofar as the personal information will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by data protection law in order to safeguard the rights and freedoms of individuals.
Your personal information will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information are processed; personal information may be stored for longer periods insofar as the personal information will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by data protection law in order to safeguard the rights and freedoms of individuals.
We may retain anonymised or aggregated data to help evaluate and improve our services. This data cannot be used to identify any individual.

Principle 5 – limited retention of personal data

Lyra International will only keep personal data for as long as is necessary for the purposes for which it is collected and further processed and to comply with our legal and regulatory obligations. The time we retain your personal information for, will differ depending on the nature of the personal information and what we do with it. In some cases, such as if there is a dispute or a legal action, we may keep personal information for longer.
Where we retain call recordings for a period of 6 months after your last interaction with us or as required for operational needs. However, please note that certain local or national laws may require us to keep your data for a longer period. In such cases, we will hold your information in accordance with those legal requirements. Rest assured, all data is kept secure and will only be used for the purposes for which it was collected and will be deleted when it is no longer necessary for those purposes or as otherwise required by applicable laws.
Your personal data will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by data protection law in order to safeguard the rights and freedoms of individuals.

Principle 6 – integrity and confidentiality (security)

Lyra International has a dedicated security team who maintain stringent controls over the Personal Information we collect, maintaining it in firewalled and secured systems and databases with strictly limited and controlled access rights, to ensure it is secure. If you would like to know more about how we secure your data you can contact us by emailing globalprivacy@lyrahealth.com.

Where processing is necessary for us to provide you with the services you require, such as assessing your needs, setting you up as a user, communicating with you, and assisting you with technical support, for example on our LYRA Hub App, your data will be processed and stored within the EU. Please be aware that if you reside outside of the EEA, your data may also be processed at one of our regional servers, depending on the technical and operational requirements of the service provided. All processing will be in line with the relevant data protection regulations, details of which can be found in Principle 8 (below), as well as in the Jurisdiction Specific Terms at the bottom of this Policy.
Lyra International will implement appropriate technical and organisational measures to ensure a level of security of Personal Information that is appropriate to the risk for the rights and freedoms of the individuals.
Lyra International will ensure that providers of services to us also adopt appropriate and equivalent security measures.
Lyra International will comply with data security breach notification requirements as required under applicable law.
Lyra International will ensure that information is processed in a manner that ensures appropriate security of the Personal Information, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

How do we use your personal information?

We use your Personal Information to provide you with the services you require based on your situation. So, if you have a problem, we make sure the right network of providers and specialists are in place. However, there are other reasons why we use your Personal Information.

Under UK and EU data protection laws we need a reason to use and process your Personal Information and this is called a legal basis. Generally speaking, most countries we operate in require a legal basis for us to process user data, where this is the case, you can view our Jurisdictionally specific sections at the bottom of this Policy however as the GDPR sets such a high bar, we refer to this as a reliable benchmark.

We have set out below the main reasons why we process your Personal Information and the applicable circumstances when we will do so. When the Personal Information we process about you is classed as sensitive Personal Information (such as details about your health, sexual orientation, or criminal offences) we must have an additional legal ground for such processing. Legal grounds are as follows.

Processing is necessary for us to provide you with the services you require, such as assessing your needs and setting you up as a user of the services and communicating with you.
We have a legal or regulatory obligation to use such Personal Information, for example, when the relevant data protection regulator requires us to maintain certain records of any dealings with you.
We need to use your Personal Information to establish, exercise or defend our legal rights, for example when we are faced with any legal claims or where we want to pursue any legal claims ourselves.
We need to use your Personal Information for reasons of substantial public interest, such as investigating fraudulent or criminal activities.
In certain instances, you may elect to use our EAP services anonymously. However, where necessary we will ask for your consent in relation to processing your sensitive Personal Information (such as health data) such as where you are in a safety-critical role. This will be made clear when you provide your Personal Information. We will ask for your consent and explain why it is necessary. Without your consent in these circumstances, we may not be able to provide you with some of our services.
Where you provide sensitive Personal Information about a third party, we will ask you to confirm that the third party has provided his or her consent.
We have appropriate legitimate business need to use your Personal Information (such as call recordings if applicable) to maintain our business records, developing and improving our products and services (when expressly permitted), to train our staff and complaints handling all while ensuring that such business need does not interfere with your rights and freedoms and does not cause you any harm.
We need to use your sensitive Personal Information such as health data because it is necessary for your vital interests, this being a life-or-death matter, or where there is a risk to others.

Principle 7 – rights of individuals

Lyra International will adhere to the data subject rights procedure under the GDPR, and where we operate in a country outside of the EU, UK or the broader EEA, your rights will be based on our obligations in that country, as such, we will respond to any requests from individuals to access their Personal Information in accordance with applicable law.
Lyra International will also deal with requests to rectify or erase inaccurate or incomplete Personal Information, or to cease processing Personal Information in accordance with the data subject rights procedure. Please see below the contact details for each of our regional offices where you can exercise these rights.

The right to access your personal information

Lyra International will adhere to the data subject rights procedure under the GDPR, and where we operate in a country outside of the EU, UK or the broader European Economic Area (EEA), your rights will be based on our obligations in that country, as such, we will respond to any requests from individuals to access their Personal Information in accordance with applicable law.

Lyra International will also deal with requests to rectify or erase inaccurate or incomplete Personal Information, or to cease processing Personal Information in accordance with the data subject rights procedure. Please see below the contact details for each of our regional offices where you can exercise these rights.

The right to rectification

We take reasonable steps to ensure that the Personal Information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us and you can ask us to update or amend it.

The right to erasure

In certain circumstances, you have the right to ask us to erase your Personal Information, for example where the Personal Information we collected is no longer necessary for the original purpose or where you withdraw your consent. However, this will need to be balanced against other factors, for example according to the type of Personal Information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request. Please note that if you withdraw your consent, we may not be able to provide you with the services you have requested.

Right to restriction of processing

In certain circumstances, you are entitled to ask us to stop using your Personal Information, for example where you think that the Personal Information we hold about you may be inaccurate or where you think that we no longer need to process your Personal Information.

Right to data portability

In certain circumstances, you have the right to ask that we transfer any Personal Information that you have provided to us to another third party of your choice. Once transferred, the other party will be responsible for looking after your Personal Information.

Right to object to direct marketing

You can ask us to stop sending you marketing messages at any time.

The right to withdraw consent

For certain uses of your personal information, we will ask for your consent, as the legal basis for processing. Where we do this, you have the right to withdraw your consent to further use of your Personal Information. However, please note that withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal, and we may continue to process your Personal Information where we have another lawful basis to do so. In some cases we may not be able to deliver the services you require if you withdraw your consent.

The right to make a complaint

You have a right to complain to the relevant regulator at any time if you object to the way in which we use your Personal Information. More information can be found below on the appropriate regulator for the regions covered.

Principle 8 – ensuring adequate protection for crossborder transfers

Lyra International is a global business. To offer our services, we may need to transfer your Personal Information to companies within the Lyra Group of companies and with third parties in other countries.
Lyra International will not transfer Personal Information that is subject to the GDPR to parties outside the UK or the EEA without ensuring adequate protection.
With the exception of those countries that benefit from an adequacy decision under the GDPR, where data is transferred outside the United Kingdom, EEA or Switzerland – for example to the US where the parent company, Lyra Health, Inc. is registered – the EU Standard Contractual Clauses, and the associated UK and Swiss Addendums will apply to Personal Information that is transferred. This will also apply where Personal Information is either directly, or via onward transfer, transferred to any country or recipient outside the UK, EEA or Switzerland, that is not recognised by the European Commission (or, in the case of transfers from Switzerland, the competent authority for Switzerland).
When we send your Personal Information from the EEA, UK, or Switzerland to the United States, Lyra International also uses trusted processes to keep your information safe. We follow the EU-US Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework when the US recipient receiving your data is approved under these programs. These frameworks meet strict EEA, UK, and Swiss data protection rules to ensure your data is handled securely.
We use “cookies” and other web technologies to collect information and to support certain features of our websites, this will include the transfer of identifiable cookie data to countries outside the UK, EEA and Switzerland that have different privacy laws and requirements, and some provide less legal protection for your Personal Information than others. For more information see our Cookie Policy.

Who do we share your personal information with?

We might share your Personal Information with two types of organisations – companies within the Lyra Health, Inc. group of companies, i.e. group companies, subsidiary and affiliated (sister companies) (“Group”), and other third parties outside the Group – for example our broad independent counsellor network.

We will not share any of your Personal Information other than for the purposes described in this Privacy Policy and if we share anything outside the Group, it will be subject to strict confidentiality obligations, and will only be used for specific reasons that we have communicated to you agreed in advance, where required.

Principle 9 – safeguarding the use of sensitive personal information

Owing to the services that we offer, Lyra International sometimes needs to process sensitive Personal Information (known as special category data) about you, in order to fulfil our contractual requirements – referred to as a ‘Legal Basis’. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so based on your jurisdiction.
Where we rely on your consent for processing special category data, we will obtain your informed and explicit consent. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.
Additional security measures and safeguards will be implemented to ensure that this sensitive Personal Information remains confidential.

Principle 10 – accountability

Lyra International takes responsibility for compliance with the other data protection principles.
Lyra International implements appropriate technical and organisational measures, including record keeping, in order to be able to demonstrate compliance.

Legally Binding Effect of This Policy

Lyra International and its employees (including new hires, individual contractors, and temporary staff) that process Personal Information worldwide must comply with, and respect, this Policy when processing Personal Information, irrespective of the country in which they are located.
Lyra International reserves the right to change, modify or update this Policy, including changes to the Jurisdictional specific sections below at any time. Please review it frequently for any updates.

Contact Details and Your Rights to Complain

If you have any questions regarding the provisions of this Policy, your rights under this Policy or any other data protection issues, you can contact the Lyra International Data Privacy Officer at the address below who will either deal with the matter or forward it to the appropriate person or department.

Our Data Protection Officer is available to facilitate requests for access or correction to users own Personal Information and to describe how you can file a complaint with the applicable regulator regarding our handling of your Personal Information where required by law:

To log a data subject access request or exercise any other rights under applicable data privacy law, please e-mail globalprivacy@lyrahealth.com.

If you wish to comment, or make a complaint about the way we process your data or to find out more about your rights, you can contact our Data Protection Officer using the details below:

Attention: The Data Protection Officer

Email: globalprivacy@lyrahealth.com

Address: Lyra Health International Ltd, 85 Gresham Street, London, EC2V 7NQ

Please note that in some cases we may not be able to comply with a request relating to your rights under this Policy for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make within one month or whatever the requirement is under your regional legislation and if we are unable to comply with your request, we will tell you why. In some circumstances exercising some of these rights (including the right to erasure, the right to restriction of processing and the right to withdraw consent) will mean we are unable to continue providing you the services you have selected and may therefore result in the cancellation thereof.

Regional enquiries

Lyra International operates in over 150 territories worldwide, and some business operations are independent ‘non-Lyra’ subsidiaries which will process, maintain, and store service user data locally, and as such, will be solely responsible, and wholly accountable, under applicable law in their own countries laws for how they manage this data. Where this is not the case, and where data is potentially processed outside of its borders by Lyra International or its parent company, we provide a non-exhaustive list of regional offices below who you can contact for data related queries. If you do not see your country listed below, please contact globalprivacy@lyrahealth.com.

Group Entity

Jurisdictions covered

LYRA HEALTH contact for data related enquires, including Access Requests

The regulatory authority

ICAS Belgium BV

Belgium

globalprivacy@lyrahealth.com

Data Protection Authority

Lyra Canada

Canada

globalprivacy@lyrahealth.com

Office of the Privacy Commissioner of Canada (‘PIPEDA’)‎
Office of the Information and Privacy Commissioner of Alberta (‘PIPA Alberta’)‎
Office of the Information and Privacy Commissioner for British Columbia (‘PIPA ‎BC’), and
Commission d’accès à l’information du Québec (the “CAI”) (‘Quebec Privacy Act’)

Lyra Health Hungary Kft

Hungary

globalprivacy@lyrahealth.com

National Authority for Data Protection and Freedom of Information

Turning Point

Malaysia

consult@turningpoint.org.my

Department of Protection of Personal information

ICAS MENA (Dubai office)

Algeria
Bahrain
Egypt
Iraq
Jordan
Kuwait
Lebanon
Libya
Mauritania
Morocco
Oman
Pakistan
Palestine
Qatar
Saudi Arabia
Senegal
Tunisia
UAE
Yemen

globalprivacy@lyrahealth.com

The Commissioner of Data Protection, Dubai International Financial Centre Authority

Lyra Netherlands BV

Netherlands

globalprivacy@lyrahealth.com

Dutch Data Protection Authority

Lyra Health Singapore Pte Ltd

Singapore

globalprivacy@lyrahealth.com

Personal Data Protection Commission

Lyra Health Spain SLU

Spain

globalprivacy@lyrahealth.com

Agencia Española de Protección de Datos (“AEPD”)

Lyra Southern Africa Pty Ltd

South Africa

paia@icas.co.za

The Information Regulator

Lyra Schweiz GmBH

Switzerland

dpo.eu@lyrahealth.com

Federal Data Protection and Information Commissioner (“FDPIC”)

Lyra France SASU

France

dpo.eu@lyrahealth.com

Commission Nationale de l’Informatique et des Libertés (“C`NIL”)

Lyra Deutschland GmbH

Germany

dpo.eu@lyrahealth.com

Bundesbeauftragter für Datenschutz und Informationsfreiheit (“BfDI”)

Lyra Italy SRL

Italy

dpo.eu@lyrahealth.com

Garante per la protezione dei dati personali (“Garante”)

Lyra International Luxembourg SARL

Luxembourg

dpo.eu@lyrahealth.com

Commission Nationale pour la Protection des Données (“CNPD”)

ICAS Austria GmBH

Austria

dpo.eu@lyrahealth.com

Österreichische Datenschutzbehörde

Lyra UK & Ireland Ltd

United Kingdom
Ireland

globalprivacy@lyrahealth.com

Information Commissioners Office (“ICO”)

ADDENDUM

Jurisdictional Terms

Additional terms may apply to you based upon the country you reside in or the services you use. Please click the region or state that applies to you to learn more about additional terms and rights that may apply to you.

Canada

Applicable Law and Jurisdiction

This Canadian Jurisdictional Addendum (“Addendum”) is incorporated into and forms an integral part of the Privacy Policy of Lyra International and is applicable to all Personal Information collected or processed by us from Data Subjects located in Canada pursuant to the Personal Information Protection and Electronic Documents Act (‘PIPEDA’). If there is any conflict between this Addendum and the rest of the Privacy Policy, the provisions of this Addendum will prevail for the protection of Personal Information of Data Subjects residing in Canada.

Definitions:

“Data Protection Law” (as defined in this Privacy Policy) includes the Canadian Federal Personal Information Protection and Electronic Documents Act (“PIPEDA”).
“Applicable Data Protection Law” (as defined in this Privacy Policy) includes the Federal Personal Information Protection and Electronic Documents Act (PIPEDA)
“Processor” (as defined in this DPA) includes a “Third Party Organisation” as defined under the PIPEDA.
“Personal information” (as defined in this DPA) includes “Personal Information” as defined under the PIPEDA.
“Personal information Breach” (as defined in this DPA) includes a “Breach of Security Safeguards” as defined under the PIPEDA.

Principal 2 – Purpose Limitation

Subject to Section 6 of the Quebec Privacy Act, information held and processed by Lyra Canada will be done so on the basis of Consent from the Data Subject except:
- if there is a serious and legitimate reason to not obtain Consent and either of the following conditions are fulfilled:
  - the information is collected in the interest of the person concerned and cannot be collected from that person in due time;
  - collection from a third person is necessary to ensure the accuracy of the information, or
- if the collection is otherwise authorised by law.

Principal 8 – Ensuring adequate protection for trans-border transfers.

With limited exceptions, the Ontario Personal Health Protection Act requires Lyra Canada to obtain Consent before Personal Health Information is transferred outside of Ontario. More broadly, where this is the case, and this involves transferring Personal Information of Canadians outside the province in which it was collected, it may be accessed by the courts, law enforcement and national security authorities of that jurisdiction.
We take measures to ensure that recipients of your Personal Information in other jurisdictions (i) provide an adequate level of protection; (ii) will not use your Personal Information for purposes other than those described in this Privacy Policy

Principal 9 – Safeguarding the use of sensitive Personal Information.

In respect of Personal Information obtained from Quebec residents, where Personal Information is transferred to third party service providers, Lyra Canada will use safeguards to ensure that such third party service providers will take necessary security measures with respect to the protection of Personal Information that are reasonable given the sensitivity of the information, the purposes for which it is to be used, the quantity and distribution of the information and the medium on which it is stored.
Lyra Canada’s sub-processors (subsidiaries), as set forth in Principle 8 of this Policy, are third parties under Applicable Data Protection Law, with whom Lyra Canada has entered into a written contract that includes terms substantially similar to this Policy. Lyra Canada has conducted appropriate due diligence on its sub-processors.
Lyra Canada will ensure that the appropriate technical and organizational measures as set forth in Principle 6, clause 2 (Security) of this Policy are adhered to.

Consent to the Collection, Use, and Disclosure of Personal Information.

By using the services, you are representing to Lyra Canada that you have reached the age of majority in the Canadian province in which you reside, such that you can lawfully enter into agreements with Lyra Canada and provide your informed and express Consent with respect to Lyra Canada’s collection, use, and disclosure of your Personal Information and Personal Health Information. If you have not reached the age of majority in the Canadian province in your province of residence, you may not use or access our services or otherwise share your Personal Information or Personal Health Information with us, unless your parent or another person lawfully entitled to give or refuse Consent in the place of your parent has provided us with express Consent on your behalf.

The parties have expressly requested and required that this Privacy Policy and all other related documents be drawn up in the English language. Les parties conviennent et exigent expressément que cette politique ainsi que tous les documents qui s’y rapportent soient rédigés en anglais.

Complaints and Exercising Your Rights:

Malaysia (Turning Point)

This Malaysian Jurisdictional Addendum (“Addendum”) is incorporated into and forms an integral part of the Privacy Policy of Lyra International and is applicable to all Personal Information collected or processed by us from Data Subjects located in Malaysia pursuant to the Personal information Protection Act 2010 (PDPA). If there is any conflict between this Addendum and the rest of the Privacy Policy, the provisions of this Addendum will prevail for the protection of Personal Information of Data Subjects residing in Malaysia.

If there is any conflict between this Addendum and the rest of the Privacy Policy, the provisions of this Addendum will prevail for the protection of Personal Information of Data Subjects residing in Malaysia.

Definitions:

“PDPA” refers to the Personal information Protection Act 2010 of Malaysia and any subsequent amendments.
“Data Subject” refers to an individual who is the subject of Personal Information as defined under the PDPA.

Data Controller and Data Processor

Turning Point, Malaysia will be deemed the Data Controller for Personal Information collected from individuals residing in Malaysia.

Turning Point may engage third-party service providers as Data Processors to process Personal Information on its behalf. Such engagement will comply with the PDPA and be governed by a written agreement.

Principle 1 – lawfulness of processing, fairness and transparency

Where Turning Point collect Personal Information, Turning Point will collect, use, disclose, and process Personal Information of individuals in Malaysia only in accordance with the PDPA.

Turning Point will obtain explicit Consent from Data Subjects before collecting or processing their Personal Information, unless exempted under the PDPA.

Turning Point will inform Data Subjects of the purpose of data collection and obtain separate Consent if Personal Information will be used for any purpose beyond the original Consent obtained.

Principle 7 – rights of individuals

Service Users have the right to access, correct, update, or delete their Personal Information as set out under the PDPA. Turning Point will respond to such requests within the timelines prescribed by the PDPA.

Service Users have the right to withdraw their Consent for the processing of their Personal Information. Turning Point will respect such requests, except where retention is necessary by law or for legitimate business purposes.

Principle 6 – integrity and confidentiality (security)

Turning Point will implement reasonable technical and organisational measures to protect Personal Information from unauthorised access, disclosure, alteration, or destruction, as required by the PDPA.

In the event of a Personal Information breach, Turning Point will notify affected Service Users and the relevant regulatory authority in accordance with the PDPA.

Principle 8 – ensuring adequate protection for trans-border transfers

Turning Point may transfer Personal Information of individuals in Malaysia to other countries, subject to compliance with the PDPA’s requirements for cross-border data transfers.

Turning Point will ensure appropriate safeguards, such as obtaining Consent or implementing contractual arrangements, to protect Personal Information during cross-border transfers.

Complaints and Inquiries

Our Data Protection Officer is available to facilitate requests for access or correction to Users own Personal Information and to describe how you can file a complaint with the applicable regulator regarding our handling of your Personal Information where required by law. Please see contact details for both the Data Protection team, and applicable regulator in the table above.

MENA (Dubai Office)

Applicable Law and Jurisdiction

This Dubai Jurisdictional Addendum (“Addendum”) is incorporated into and forms an integral part of the Privacy Policy of Lyra International and is applicable to all Personal Information collected or processed by us from Data Subjects located in Dubai, United Arab Emirates (UAE) pursuant to the Personal Data Protection Law (“PDPL”). If there is any conflict between this Addendum and the rest of the Privacy Policy, the provisions of this Addendum will prevail for the protection of Personal Information of Data Subjects residing in Dubai.

Definition of Terms

For the purpose of this Addendum, the terms “Personal Information,” “Data Subject,” “Controller,” “Processor,” and “Processing” shall have the same meaning as provided under the General Data Protection Regulation (GDPR).

Local Legal Framework

Although the European Union’s GDPR provides a unified approach to data protection for individuals within the EU, Dubai has its specific legal framework concerning data protection. While this Addendum considers local regulations, it primarily serves to bridge any gaps or clarify any overlaps between the GDPR and local laws in Dubai.

Data Protection Authority

The relevant authority overseeing and enforcing data privacy and protection in Dubai is the Dubai Data Protection Department. Any concerns or questions related to the Processing of Personal Information in Dubai should be directed to this authority.

Principle 7 – rights of individuals

Access: You have the right to request access to the Personal Information we hold about you, consistent with local laws and regulations.
Correction: If the Personal Information we hold about you is inaccurate or incomplete, you can request that we correct it.
Deletion: In specific circumstances, you can request the deletion of your Personal Information, unless there are compelling reasons for its retention.
Objection: You have the right to object to the Processing of your Personal Information in some circumstances.

Principle 8 – ensuring adequate protection for trans-board transfers

Given Dubai’s role as a global business hub, Personal Information may be transferred internationally. Any data transferred out of Dubai will be in line with local regulations and will only occur with jurisdictions that provide an adequate level of data protection as judged by Dubai’s standards.

Data Breach Notification

In case of a data breach that poses a risk to the rights and freedoms of individuals, we are obliged to notify the Dubai Data Protection Department and the affected individuals without undue delay.

Complaints and Exercising Your Rights

Singapore (SACAC)

Applicable Law and Jurisdiction

This Singapore Jurisdictional Addendum (“Addendum”) is incorporated into and forms an integral part of the Privacy Policy of Lyra International and is applicable to all Personal Information collected or processed by the us from Data Subjects located in Singapore. If there is any conflict between this Addendum and the rest of the Privacy Policy, the provisions of this Addendum will prevail for the protection of Personal Information of Data Subjects residing in Singapore.

Definition of Terms

Principle 1 – lawfulness of processing, fairness and transparency

SACAC shall ensure that any processing of Personal Information within Singapore complies with the legal bases for processing as set forth in the GDPR.

SACAC shall obtain explicit and informed Consent from individuals located within Singapore when processing their Personal Information unless another lawful basis for processing under the GDPR is applicable.

Principle 8 – ensuring adequate protection for trans-board transfers

SACAC may transfer Personal Information of individuals located within Singapore to recipients located outside Singapore, subject to compliance with the requirements under the GDPR for international data transfers. SACAC shall ensure that appropriate safeguards, such as Standard Contractual Clauses, are in place when transferring Personal Information to recipients outside Singapore, unless an exception under the GDPR for such transfers applies.

Principle 7 – rights of individuals

Individuals located within Singapore shall have the same rights as outlined in the Privacy Policy and as granted under the GDPR, including but not limited to the right to access, rectification, erasure, restriction of processing, and data portability.

SACAC shall respond to any requests made by individuals located within Singapore exercising their Data Subject rights within the timeframes specified by the GDPR.

Principle 5 – limited retention of personal data

SACAC shall retain Personal Information of individuals located within Singapore only for as long as necessary to fulfil the purposes for which it was collected unless a longer retention period is required or permitted by law.

Cross-Border Data Transfer Assessments

If SACAC engages in regular and systematic monitoring of individuals located within Singapore or carries out large-scale processing of special categories of Personal Information, it shall conduct a data protection impact assessment (DPIA) in accordance with the requirements of the GDPR.

Data Breach Notification

In the event of a Personal Information breach affecting individuals located within Singapore, SACAC shall promptly notify the relevant Singaporean authorities and affected individuals, as required by the GDPR.

Complaints and Inquiries

South Africa

Applicable Law and Jurisdiction

This South African Jurisdictional Addendum (“Addendum”) is incorporated into and forms an integral part of the Privacy Policy of Lyra International and is applicable to all Personal Information collected or processed by us from Data Subjects located in South Africa pursuant to the Protection of Personal Information Act 4 of 2012 (“POPIA”). If there is any conflict between this Addendum and the rest of the Privacy Policy, the provisions of this Addendum will prevail for the protection of Personal Information of Data Subjects residing in South Africa.

Definitions

“Controller” (as defined in this DPA) includes a “Responsible Party” as defined in the POPIA.
“Data Protection Law” (as defined in this DPA) includes the South African Protection of Personal Information Act 4 of 2012 (“POPIA”).
“Personal information” (as defined in this DPA) includes “Personal Information” as defined in the POPIA.
“Processor” (as defined in this DPA) includes an “Operator” as defined in the POPIA.
“Restricted Transfer of SA Personal information” means any transfer of Customer Personal information subject to the POPIA which is undergoing Processing or is intended for Processing after transfer to a SA Third Country or an international organisation in a SA Third Country, including data storage on foreign servers.
“SA Third Country” means a country outside of the Republic of South Africa.

Principle 1 – lawfulness of processing, fairness and transparency

The Personal Information collected by Lyra Southern Africa is consistent with the collection limitations set out by POPIA, which allows for the collection of Personal Information for a specifically defined, lawful purpose related to a function or activity of the Responsible Party. We ensure that Data Subjects are made aware that their Personal Information is being collected and the purpose for which it is being collected.

Personal information will only be processed with the explicit Consent of the Data Subject unless processing is necessary for compliance with applicable laws. Lyra Southern Africa will ensure that adequate security measures are in place to protect the integrity and confidentiality of the Personal Information.

Principle 6 - integrity and confidentiality (security)

Lyra Southern Africa will implement reasonable technical and organisational measures to protect Personal Information from unauthorised access, disclosure, alteration, or destruction, as required by POPIA.

In the event of a Personal Information breach, Lyra Southern Africa will notify affected Service Users and the relevant regulatory authority in accordance with POPIA.

Principle 7 – rights of individuals

Under POPIA, Data Subjects have the right to:

Be notified that their Personal Information is being collected.

Access and correct their Personal Information.

Object to the processing of their Personal Information in certain circumstances.

Lodge a complaint with the Information Regulator.

Principle 8 – ensuring adequate protection for trans-board transfers

With regards to any Restricted Transfer of Personal information from South African service users to Lyra International within the scope of this Data Processing Addendum and the Principal Policy, the following mechanisms, in the order of precedence, will apply:

Data Protection Law to which Lyra International is subject, that effectively upholds the principles for reasonable processing of Personal information that are substantially similar to the conditions for the lawful processing of Personal information relating to a Data Subject, and which includes provisions substantially similar to Section 72 of the POPIA, relating to any further onward transfer of Personal information (for the purposes of this Section 4.2.1 of this Policy, the Parties agree that transfers to Lyra entities within the EEA, which are subject to the GDPR and Lyra entities within the UK, which are subject to UK Data Protection Law, comply with this mechanism);

The terms of this DPA, as a binding agreement between the Parties to effectively uphold the principles for reasonable processing of Personal information that are substantially similar to the conditions for the lawful processing of Personal information relating to a Data Subject, and which includes provisions substantially similar to Section 72 of the POPIA, relating to any further onward transfer of Personal information; or

Any other lawful data transfer mechanism, as provided for in the POPIA.

Complaints and Inquiries

Switzerland

Applicable Law and Jurisdiction

This Swiss Jurisdictional Addendum (“Addendum”) is incorporated into and forms an integral part of the Privacy Policy of Lyra International and is applicable to all Personal Information collected or processed by us from Data Subjects located in Switzerland pursuant to the Federal Act on Data Protection of 25 September 2020 (FADP). If there is any conflict between this Addendum and the rest of the Privacy Policy, the provisions of this Addendum will prevail for the protection of Personal Information of Data Subjects residing in Switzerland.

Definition of Terms

For the purpose of this Addendum, the terms “Personal Information,” “Data Subject,” “Controller,” “processor,” and “processing” shall have the same meaning as provided under the General Data Protection Regulation (GDPR).

Principle 1 – lawfulness of processing, fairness and transparency

The Company shall process Personal Information of Data Subjects located in Switzerland only on a lawful basis as provided under the FADP. The legal basis for processing may include the Data Subject’s Consent, the necessity of processing for the performance of a contract with the Data Subject, compliance with a legal obligation, protection of vital interests, the performance of a task carried out in the public interest or in the exercise of official authority, or the legitimate interests pursued by the Company or a third party.

Principle 7 – rights of individuals

Data subjects located in Switzerland have the following rights regarding their Personal Information:

Right to Information: Data subjects have the right to obtain information about the processing of their Personal Information, including the purposes, categories of Personal Information processed, recipients or categories of recipients to whom the Personal Information is disclosed, and the retention period for the Personal Information.

Right of Access: Data subjects have the right to access their Personal Information held by the Company and receive a copy thereof.

Right to Rectification: Data subjects have the right to request the rectification of inaccurate Personal Information concerning them and the completion of incomplete Personal Information.

Right to Erasure: Data subjects have the right to request the erasure of their Personal Information under certain circumstances, such as when the Personal Information is no longer necessary for the purposes for which it was collected or processed.

Right to Restriction of Processing: Data subjects have the right to request the restriction of the processing of their Personal Information under certain circumstances, such as when the accuracy of the Personal Information is contested, or the processing is unlawful.

Right to Data Portability: Data subjects have the right to receive their Personal Information in a structured, commonly used, and machine-readable format, and have the right to transmit such data to another Controller without obstruction.

Right to Object: Data subjects have the right to object to the processing of their Personal Information, including for direct marketing purposes or when the processing is based on the legitimate interests pursued by the Company.

Right to Withdraw Consent: Where Consent has been given to the processing of data, and where no other legal basis has been established for the processing of data, Data subjects have the right to withdraw their Consent at any time.

Automated decision making: We are committed to protecting your data privacy and ensuring compliance with data protection regulations, including the Federal Act on Data Protection (FADP). In accordance with our data processing practices, we want to inform you that we do not engage in any automated decision-making processes in relation to your Personal Information.

Automated decision-making refers to processes that use algorithms, artificial intelligence, or machine learning to make decisions about individuals without human intervention. These decisions can have significant effects on your rights and interests. However, we want to assure you that any decisions made regarding your data, if necessary, are subject to human review and consideration to ensure fairness, transparency, and compliance with FADP.

Principle 8 – ensuring adequate protection for trans-board transfers

Lyra Schweiz only transfers anonymised data from Switzerland to locations inside the European Economic Area (EEA), as such, under Swiss law, this falls outside of the scope of what is considered Personal Information.

Swiss law allows the transfer of Personal Information to countries with adequate data protection, therefore, where the data of a service user is not processed in Switzerland, for example when using the online chat feature outside of working hours, Lyra Schweiz will only transfer Personal Information from Switzerland to a country inside the European Economic Area (EEA). This compliance ensures that Personal Information is protected according to Switzerland’s robust data protection standards.

Complaints and Inquiries

“Lyra” includes but is not limited to Lyra Health International Holdings, Lyra Spain SLU, Lyra Southern Africa Pty Ltd, Lyra Health Hungary Kft, Lyra Netherlands BV, Lyra Belgium BV, Lyra Schweiz (Group), Lyra Malaysia Sdn Bhd, Lyra Singapore Pte Ltd and designated third parties (“Group Members”).
“Processing” means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Personal information” / “Personal information” means any information relating to an identified or identifiable natural person (“Data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Sensitive Personal Information” means “special categories of Personal Information” as set out in the GDPR as well as Article 6 in the UK GDPR, which must be treated with extra security. These categories include health information and also genetic data and biometric data where processed to uniquely identify an individual. Personal information relating to criminal convictions and offences are not included, but similar extra safeguards apply to its processing.
For the purpose of this Policy, reference to Europe means the EEA which incorporates Norway, Iceland, Lichtenstein as well as Switzerland.