Privacy Policy – Tropicoir Lanka(PVT) Ltd.

TEG PRIVACY NOTICE

This Privacy Statement describes the personal data that is collected by Tropicoir Lanka (Private) Limited, Growrite Substrates (Private) Limited and Euro Substrates (Private) Limited (hereinafter collectively referred to as ‘TEG’ or the ‘Company’) which is collected, organized, structured, stored and used to provide the services offered by ‘TEG’ in a more efficient manner.

As a Company we are committed to protecting the data of our customers,employees, suppliers, visitors and investors and to such effect we have taken stringent measures to ensure that the data that is collected is protected, kept confidential and is lawfully obtained in terms of prevailing laws including but not limited to the Personal Data Protection Act No 09 of 2022.

When processing data at all times the company has taken stringent steps to ensure that;

Data is obtained in a lawful manner;
Data is processed for a specified explicit and legitimate purpose;
Data obtained and processed is adequate relevant and proportionate to the purpose for which such data is collected;
Reasonable steps will be taken to erase or rectify inaccurate or outdated personal data;
Data is retained only for such period as is necessary;
The integrity and confidentiality of the data is maintained at all times;
Data is processed in a transparent manner;
The rights of data subjects in terms of prevailing laws are maintained and protected;

DATA PRIVACY OFFICER

Our Data Privacy Officer is responsible for overseeing questions in relation to
this privacy notice. If you have any questions about this Privacy Notice, including
any requests to exercise any of your legal rights, please contact the Data Privacy
Officer using the details set out below.

CONTACT DETAILS

TEG Holdings (Private) Limited
Address :104, Pagoda Road, Pitakotte, Nugegoda, 10100
Contact name : Privacy Officer
Email address : privacy@trowide.lk

WHAT PERSONAL DATA DO WE COLLECT?

In order to legitimately pursue the business of the Company the Company collects the following types of data.

Customer Information

Contact information such as name, address, e-mail address, and telephone number.
Information on orders and order preferences.
Information regarding order quantities.
Financial information such as bill payment and banking transactions.
Identification information such as national identity card number or passport number or driver’s license and date of birth.
Business information such as name of organization, name of employer, job title, and department.

Supplier Information

Contact information such as name, address, e-mail address, and telephone number.
Information on orders and order preferences.
Information regarding order quantities.
Financial information such as bill payment and banking transactions.
Bank details such as Bank name, branch, account number.
Identification information such as national identity card number or passport number or driver’s license and date of birth.
Business information such as name of organization, name of employer, job title, and department.

Employee information and potential employee information

Contact information such as name, address, e-mail address, and telephone number.
Identification information such as national identity card number or passport number or driver’s license number and date of birth.
Bank details such as Bank name, branch, account number.
Academic and professional qualifications.
Employment history as provided in the curriculum vitae.
Biometric data.
Gender, race, nationality.
Age.
Emergency contact number and name of contact person.
Marital status.
Account details for remittance of salary.
Previous salary information.
Photographs.
Footage as captured by our CCTV security system.
Any criminal records or history.

Visitor Information

Contact information such as name, address, e-mail address, and telephone number.
Identification information such as national identity card number or passport number or driver’s license number and date of birth.
Business information such as name of organization, name of employer, job title, and department of organization.
Nationality.
Any footage captured by the CCTV security system.

Shareholder information

1. Contact information such as name, address, e-mail address and
telephone number.
2. Shares held by shareholder’s and percentage.
3. Employment details.

HOW DO WE USE YOUR PERSONAL DATA?

As discussed below, and where technically feasible, the Company uses Personal Data in the following manner.

The data belonging to our customers:

Providing products and Services: The Company may collect and use personal data to provide the products or services that customers have requested. This could include processing transactions, delivering goods and services, or offering customer support.
Personalization: The Company may use customer data to personalize user experiences. For example, they might use preferences, purchase history, and behavior data to tailor marketing messages, recommendations, or website content to individual users.
Marketing and Advertising: The Company may use personal data of its customers for marketing and advertising. This can involve sending promotional materials, displaying personalized ads, and conducting market research.
Improving Services: The Company may use Personal Data such as purchase history to personalize its services to meet the requirements of the Customer better.
Analytics: The Company may use personal data for internal analytics to gain insights into customer behavior, optimize operations, and make informed business decisions.
Compliance: Some data processing is necessary for legal and regulatory compliance. This includes activities such as verifying customer identity, preventing fraud, and meeting tax, customs or financial reporting requirements.
Customer Communication: The Company may use personal data to communicate with customers, send updates, and provide information related to their products or services.

The Data belonging to our suppliers:

Supplier Relationship Management: The company uses supplier data to manage relationships with its suppliers effectively. This includes maintaining contact information, assessing supplier performance, and ensuring compliance with contractual agreements.
Procurement and Sourcing: Supplier data is crucial for the procurement process. It helps the Company identify its suppliers, evaluate their capabilities, negotiate contracts, and make informed decisions about sourcing goods and services.
Order Processing and Fulfillment: The Company uses supplier data to process orders efficiently. This involves tracking inventory levels, managing order fulfillment, and coordinating deliveries with suppliers.
Payment and Invoicing: Supplier data is used in financial transactions, including processing invoices and making payments.
Quality Control and Compliance: The Company uses supplier data to monitor and ensure the quality of products and services provided by their suppliers.
Risk Management: Supplier data is utilized to assess and manage risks associated with the supply chain.
Collaboration and Communication: The Company uses supplier data to facilitate collaboration, share information, and address any issues or changes in requirements.
Performance Analytics: Supplier data is analyzed to assess supplier performance and identify areas for improvement.

The data belonging to employees and potential employees

Payroll and Benefits Administration: Employee information is used for processing payroll, including salary payments, tax withholdings, and benefits administration.
Human Resources Management: Employee data is essential for various HR functions, such as recruitment, onboarding, training, performance management, and career development.
Employee Communication: The Company uses employee information to facilitate internal communication. This includes sending important updates, announcements, and other relevant information to employees.
Workforce Planning: Employee data is analyzed to assess the current workforce and plan for future staffing needs.
Compliance with Employment Laws: The Company uses employee information to comply with labor laws and regulations.
Security and Access Control: Employee information is used to manage access to physical and digital resources within the company.
Health and Safety: Employee data is used to ensure the health and safety of employees in the workplace.
Employee Surveys and Feedback: The Company uses employee information to conduct surveys and gather feedback to assess employee satisfaction, engagement, and well-being.

HOW WE SHARE YOUR PERSONAL DATA?

As a responsible corporate citizen, we have taken great care to ensure that no outside parties have access to personal data belonging to our customers, suppliers and employees. However, in order for there to be greater efficiency, information is shared with the following systems and organizations.

Customer data and supplier information is stored on ERP systems whereby data is stored on servers both locally and overseas.

Employee data is stored on a Human Resources Management System, which is primarily stored on cloud servers equipped with the latest security controls.

Shareholder information is shared with our auditors and secretaries.

We may also share your Personal Data with state institutions such as the Inland Revenue Department, Customs, Board of Investment Sri Lanka, or the Sri Lankan Police if required to do so by law or in the event such information is required to be produced before a court of law. Upon such an event we will only disclose the minimum amount of information necessary. We will also inform the data subject concern of any such disclosure unless we are prohibited from doing so by law or by an order of Court.
TEG PRIVACY NOTICE 6
We require all third parties to respect the security of your Personal Data and to treat it in accordance with applicable laws. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to Process your Personal Data for specified purposes and in accordance with our instructions.

WHAT ARE YOUR RIGHTS?

At ‘TEG’ we take all necessary steps to protect the data rights and privacy of our clients, employees, shareholders, visitors and suppliers. In this regard we have taken steps to ensure that all data maintained is accurate and up to date. As a customer, supplier, employee or potential employee, shareholder or visitor of the Company you have the following rights with regards to protecting your privacy and data.

You have the right to access your personal data by writing to our Data Protection Officer and have the right to be provided with a confirmation as to whether such personal data has been processed.
You have the right to request from us in writing to rectify or complete your personal data relating to either data that is inaccurate or incomplete.
You have the right to make a written request to have your personal data erased in the event processing of personal data is carried out in contravention of the obligations more fully set out in the personal Data Protection Act or you wish to withdraw your consent if your consent has been granted in terms of Schedule 1(a) of the personal Data Protection Act of Sri Lanka.
You may further requests from us to stop sending you communications or promotional material by writing to the address below or sending us an e-mail to the address set out at the bottom of this document.
You also have the right to complain to the Data Protection Authority of Sri Lanka in the event you are of the belief that the Company has acted in contravention of your rights contained in the Personal Data Protection Act No 09 of 2002.

HOW DO WE STORE AND PROTECT YOUR PERSONAL DATA?

As a company we place great value on your data and have taken several measures to keep your data confidential and maintain the highest integrity with regards to your data at all times. In this regard we take all necessary steps wherever practicable to process your personal data in a safe and confidential manner by preventing any unauthorized persons and parties having access to your data.

We further use a range of physical and electronic security measures to protect the confidentiality and integrity of the personal information we hold about you.

When we collect data through the Site, we collect your personal details on a secure server. We use firewalls on our servers. Furthermore, we aim to only keep your information for as long as we need it. When we no longer need information, we take reasonable steps to destroy or deidentify it. Further, your information will be kept up to date, and we will take every reasonable step to erase or rectify any inaccurate or outdated personal data, without undue delay.

Changes to This Privacy Statement

We may update this Privacy Statement periodically to account for changes in our collection and/or processing of personal data, and will post the updated Privacy Notice on our website, with a “Last Updated” date at the top. If we make material changes to this Privacy Statement, we will notify you and provide you an opportunity to review before you choose to continue using our products and services.