New Life Solution, Inc. Privacy Policy
Last Updated: October 5th, 2016
Your privacy and the security of your Personal Information (defined below) are very important to us at New Life Solution, Inc. (“NLS”, “we”, “us”, “our”). This Privacy Policy explains what Personal Information and other data we collect, how we use and share that information, and the choices you have concerning our policies regarding the collection, use and sharing of such information. This Privacy Policy applies to all Personal Information and other data collected by NLS from users of and/or visitors to the NLS website (the “Website”), and users of the products, services (including the NLS’s meQuilibrium service described below), websites and mobile applications we may offer on behalf of ourselves or others (collectively, the “Services”). Other capitalized terms used and not otherwise defined in this Privacy Policy have the meanings assigned to them in NLS’s Terms and Conditions located at https://www.mequilibrium.com/terms-and-conditions.
Please read this Privacy Policy carefully and contact us if you have any questions or concerns. By accessing or using our Website or the Services, you are indicating that you have read, understood and agree to be bound by the terms of this Privacy Policy. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, YOU DO NOT HAVE PERMISSION TO ACCESS OR USE THE WEBSITE OR THE SERVICES.
Changes to the Privacy Policy. We may change this Privacy Policy from time to time. We will post any changes to this Privacy Policy on this page and update the Privacy Policy modification date. If the changes are significant, we will, in our sole discretion, post a more prominent notice on the homepage of the Website or notify you by email at the address we have on file for your Account (as defined below) and provide you with an opportunity to opt-out of your continued use of our Services. You agree that your continued access or use of the Website or any Services after posting of the changes to the Privacy Policy or your receipt of notice of a change to the Privacy Policy will constitute your affirmative acceptance of any such change and your agreement to its terms.
Personal Information. In this Privacy Policy, “Personal Information” is information about an identified or identifiable individual, such as your name, email address or telephone number. “Non-personal Information” is information that does not identify you personally. The definition of Personal Information depends on your physical location and may include other types of information as well, such as your IP address. Only the definition of Personal Information that applies to your physical location will apply to you under this Privacy Policy.
What We Do. NLS’s meQuilibrium product is an integrated set of online tools that allow individuals to assess their level of resilience, create an action plan to increase resilience, and monitor their progress increasing their resilience over time. meQuilibrium is offered directly to end users as well as being offered as an adjunct to corporate benefits programs through employers. In order to provide this service, it is necessary for NLS to collect and process data about the individuals using this service.
What Information does NLS collect?
We may collect the following types of information:
Information you provide. We collect Personal Information through the Website and the Services when you opt-in to provide us with such information. You can opt-in by signing up for or using the Services through the Website, which requires you to create an account and collects your name, email address, and telephone number. We receive and store the information you voluntarily enter on the Website during the registration or subscription process or that you provide us any other way (e.g., by mail, email, or phone). For example, you may provide us with your name, gender, birthday, geographic location, job title, job description and related information, department, email, payment method, and billing information. To the extent that you provide us with information on third parties, for example your family members, you represent and warrant that you have permission from such third parties to share this information with us so that we may provide the Services.
If you are accessing the Website or the Services through your employer’s employee benefits program, your employer’s service administrator may provide this information on your behalf. We also collect your company name and assign you an account name based on your company name.
We also collect your email address when you email us for information or sign up for our newsletters and email updates.
If you do not opt-in and provide us with the Personal Information that is required to register for and use the Services, you will not have access to the Services and we will have no way of contacting you to send you updates or respond to your inquiries.
Information Provided by your Employer. In some implementations, your account will be pre-provisioned with information sent by your employer or health provider. Common examples include: Gender, Name, Employer Name, Employee Division, Employee ID. The specific data of Personal Information provided by your employer or health provider will be based upon employer or health provider request, as applicable.
Device Information. We collect device-specific information from users in order to provide the Services (such as a user’s hardware model, operating system and web browser versions, unique device identifiers and mobile network information, including phone number). We may need to associate your user’s device-specific information with your Personal Information on a periodic basis in order to confirm you as a user and to check the security on your device.
Information from cookies. Like many other websites, the Website gathers and stores certain information automatically. When you visit our Website or click on a banner advertisement we may send one or more “cookies” to your computer or other device to provide us with information relating to the sources of our site traffic. Cookies are small pieces of information that some websites store on your computer’s hard drive when you visit them. Most web browsers automatically accept cookies but allow you to modify security settings so that you can approve or reject cookies on a case-by-case basis. Our Website requires that both cookies and JavaScript be enabled. If you reject cookies from our Website, some parts of the Website or of the Services may not work properly for you.
Log and other information. When you access our Website, our Services, email, or other content served by or on behalf of us on other websites or mobile applications, our servers may automatically record information that your browser sends whenever you visit a website. These server logs typically include your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or Account(s) to us. During some visits to our websites we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Surveys and Contests. From time to time we may provide you the opportunity to participate in contests or surveys. If you participate, we will request certain Personal Information from you at the time of the survey. Participation in these surveys or contests is completely voluntary and you have a choice whether or not to disclose this information. The requested information typically includes contact information, such as email or phone number. We use this information to improve our service to send our customers update on how we are improving the service based on their feedback.
Information from other sources. We may receive information about you from other sources. For example, information we may receive from other sources may include updated delivery and address information from third parties, which we use to correct our records and deliver you communications, and demographic information from data collection companies and others.
How does NLS use your information?
To manage your Account and provide Services. We use the information we collect to manage your Account(s) and provide the Services and customer service support, as well as to support our aggregate reporting as part of the Services.
To contact you. We may use the contact information we receive from you or third parties to contact you directly or through third parties via email, direct mail, telephone or other channels such as text messaging, and third party integrated services, in each case provided we are permitted by law to send such communications to you and you have not otherwise opted-out of receiving them. We may also use your contact information to provide you administrative communications from time to time.
Email communications that you send to us via the email links on our Website may be shared with a customer service representative, employee, expert or agent that is most able to address your inquiry. We make every effort to respond in a timely fashion once communications are received. Internet email is inherently insecure, as any given email may be sent via multiple third party computers, some of which can make a copy of the contents with no detection possible. Because of this lack of security, it is possible that your email communication may be accessed or viewed by another Internet user while in transit to NLS. If you wish to keep your communication completely private, do not correspond with NLS via email. You may decide at some point that you no longer wish to receive communications, such as newsletters and updates, from our Website. To stop receiving such communications, click “Unsubscribe” at the bottom of such communication, or send an email message to optout@mequilibrium.com or send a regular mail to the following postal address:
Security and Privacy Officer
New Life Solution, Inc.
260 Franklin Street
Boston, MA 02110
To develop, evaluate, improve and deliver the Website’s products and services and the Services. We use the information we collect to develop, evaluate, improve and deliver the Website and its services and the Services. For example, if we learn from the information we collect that certain common events are producing stress in the lives of Registered Users (defined below), we may use that information to develop skill exercises designed to enable Registered Users to respond productively to such events. A “Registered User” is a person who completes the enrollment process.
To protect the rights or property of NLS, Registered Users, and others. We also may use the information we collect to the extent we believe it is necessary or appropriate to enforce or apply our rights under our agreements with Registered Users, and/or to protect the rights, property or safety of NLS, our Registered Users and others.
How does NLS share your information?
Employer Data Sharing (For corporate subscribers only). If you are using the Website or the Services as part of a work-place initiative paid for by your employer, NLS will deliver to your employer reports containing de-identified aggregate information. NLS may, upon request, deliver to your employer a list of user accounts that are active. NLS may also allow your employer to access certain information regarding your participation with the Services including, without limitation, your specific score information and other account data that includes Personal Information. Additional details regarding the scope of data sharing with your particular employer, if applicable, is available in NLS’s Terms and Conditions located at https://www.mequilibrium.com/terms-and-conditions. If you have any questions about your employer’s access to and use of information regarding your interaction with the Services, we recommend that you contact your employer directly to discuss such questions.
Agents and service providers. We engage third party intermediaries and partners to perform certain services and functions on our behalf and under our instructions. For example, we may engage third parties to help us develop the products and services offered on our Website, send email and postal mail, analyze data, provide marketing services, process applications, provide search results and links, host the Website, and provide customer service. For Personal Information transferred to us from European Union member countries under the EU-US Privacy Shield, we will remain liable under the Privacy Shield Principles if our agents or service providers process such Personal Information in a manner inconsistent with the Privacy Shield Principles, unless we will prove that we are not responsible. (Please see, “For our Registered Users in the European Union (EU) and the European Economic Area (EEA)” below.)
Information we share with nonaffiliated third parties as permitted by law. We may disclose Personal Information to the extent permitted by applicable law as follows:
In business transfers. If there is a change of control in NLS’s business (whether by merger, sale, or otherwise), NLS may assign or transfer this Privacy Policy and your Account and related Personal Information to any person or entity that acquires or is merged with NLS. As part of any such assignment or transfer, the transferee will be subject to applicable laws regarding the collection, use, protection and disclosure of Personal Information. We will notify you by email at the last address shown on our records in the event of any such assignment or transfer.
To fulfill legal and regulatory requirements. We may disclose your Personal Information, in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other lawful requests by public authorities, including to meet national security or law enforcement requirements, or to establish or exercise our legal rights or defend against legal claims. We may also disclose your Personal Information in special circumstances when we have reason to believe that disclosing this information is necessary in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or the safety and security of our users, our Website, the Services or the general public, violations our Terms and Conditions or our Subscription Agreement, or as otherwise required by law.
With your consent. In addition to the above, we may share Personal Information about you with others to the extent you consent to such sharing.
Non-personal Information. We may provide aggregated Non-personal Information about our users, to strategic partners for research, statistics, product marketing, analysis. For example, your information (e.g., scores and personality types) may be aggregated with the information of other Registered Users and shared with third parties to enable them to develop products and research. We may also provide aggregated Non-personal Information about you to third party service providers and, to employers for analysis if you participate in an employer program. For example, your information may be aggregated with information of other employees and analyzed to evaluate the effectiveness of our Website, our Services, and the results of that analysis may be shared with third party service providers to help NLS improve the Website and our Services, or with employers to allow them to evaluate the success of the NLS program.
Security of your Personal Information. NLS has implemented reasonable and appropriate measures designed to safeguard your information from loss, misuse, unauthorized access, disclosure alteration and destruction in accordance with this Privacy Policy. Only NLS employees and service providers who need to use it as part of their jobs are authorized to have access to your Personal Information. Notwithstanding our commitment to take reasonable and appropriate measures to protect your information (including Personal Information), you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart or hack our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security and privacy of any information you transmit to us, and you do so at your own risk.
Please remember that you also play a valuable part in data security. You should never share your password, if applicable, with anyone. If you feel your password has been compromised, you should change it immediately. After you have finished using our Website, you should log out of your Account and exit your browser so that no unauthorized persons can use our Website under your name or Account.
Links to other sites. Through our various online offerings, we may provide links to third-party websites. Except for those portions of the websites that are hosted by us, each of these websites may have separate privacy and different data-collection practices from NLS, and we are not responsible for the actions or practices of these third parties, nor for the content on these sites. We encourage you to review the privacy policies of these third-party websites. This Privacy Policy applies only to information collected by our Website and the Services.
Online forums. Please note that information you voluntarily reveal or post in bulletin boards, chat rooms, online forums and other public areas of the Website (collectively, “Community Areas”), we may offer may be viewed and used by anyone with access to those forums. To request removal of your Personal Information from the Community Areas, contact us at privacy@mequilibrium.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
Retention of your information. We will retain your Personal Information for as long as needed to provide you the Website’s products and services and the Services or as otherwise permitted by law.
Collection of information from children. None of our products or services is intended for use or purchase by children. Accordingly, NLS does not knowingly collect, either online or offline, information from children under the age of 13. If you believe that we might have any information from a child under age 13, please contact us.
California Do Not Track disclosures and other disclosures under CalOppa. NLS currently respond to Do Not Track signals that may be sent by some browsers or other client software. Personal Information collected by us as described in this Privacy Policy is not maintained in personally identifiable form in combination with any identifier collected by cookies, web beacons, or other technologies.
Choice and consent. Each time you email us, sign up for or use our Website or the Services, you are giving your express consent to the collection, use, retention, transfer and disclosure, including cross-border disclosure, of your information as described in this Privacy Policy. You have the right to object to the disclosure of your information to third parties as described in this Privacy Policy, except for disclosures made to agents and service providers, as well as to the use of your information for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized by you. If you wish to opt out and withdraw your consent, you may do so at any time by writing to privacy@mequilibrium.com. If you opt out and withdraw your consent you will no longer be able to use the Website or the Services or receive updates or other communications, and we will not have any means by which to respond to your inquiries.
For users located outside of the United States. Given that the Internet operates in a global environment and that transfer of your data is necessary to process your registration and use of the Website and the Services, to provide updates, and to respond to your inquiries, using the Internet to collect and process Personal Information necessarily involves the transmission of data on an international, or cross-border, basis. By signing up for or using the Website or the Services, and/or by communicating with us by email, you acknowledge and expressly consent to our processing and disclosure of your Personal Information in this way except in the case of data transfers from the EU or the EEA and Switzerland, which are covered under the EU-US Privacy Shield Framework and the US-Swiss Safe Harbor Framework. (Please see “For our Registered Users in the European Union (EU) and the European Economic Area (EEA)” and “For our Registered Users in Switzerland”, below.) The Personal Information of users who are located outside the United States will be transferred outside of each eligible country to the United States where our servers are located and where it will be processed and stored on servers owned and operated by Amazon Web Services (“AWS”). You may view the AWS privacy policy at http://aws.amazon.com/privacy.
For our Registered Users in the European Union (EU) and the European Economic Area (EEA).
NLS complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the processing of personal information from European Union member countries. NLS has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
NLS is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and of other relevant US statutory bodies authorized to verify and ensure compliance with the Privacy Shield Principles.
For our Registered Users in Switzerland.
NLS complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use and retention of Personal Information from Switzerland. NLS has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. If there is any conflict between the policies in this Privacy Policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the Safe Harbor principles and to see a list of frequently asked questions regarding it, please visit http://www.export.gov/safeharbor. NLS understands that the decision of the European Court of Justice of October 6, 2015, which invalidated the US-EU Safe Harbor Framework, does not apply to the US-Swiss Safe Harbor Framework, which the US Department of Commerce will continue to administer. However, should this change, we will provide an update in this Privacy Policy.
For our Registered Users in Australia: NLS complies with the 13 Australian Privacy Principles (APPs) set forth in the Privacy Amendment (Enhancing Privacy Protection) Act 2012 to the Privacy Act 1988, which include open and transparent management, anonymity, collection of solicited Personal Information, dealing with unsolicited Personal Information, notification of the collection of Personal Information, use and disclosure, direct marketing, cross-border disclosure. adoption, use and disclosure of government related identifies, quality, security, access and correction.
For our Registered Users in Canada: NLS complies with the fair information principles defined in the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA). NLS conforms to the 10 principles defined in PIPEDA, which include accountability, identifying purposes, consent, limiting collection, limiting use, disclosure and retention, accuracy, safeguards, openness, individual access and provision of recourse.
For our Registered Users in Singapore: NLS complies with the nine key obligations set forth in the Personal Data Protection Act 2012 (PDPA) regarding the collection, use and disclosure of Personal Information, which include consent, purpose, notification, access and correction, accuracy, protection, retention, transfer and openness.
What information can you access? You can access and update your account information by accessing the account settings area on the Website. Personal Information entered actively by a user during the use of the Website, such as answers to assessment questions, journal entries, self-reported stress-level, etc., is not deleted or modified and may remain on servers for as long as needed to provide you the Website’s products and services and the Services or as otherwise permitted by law. However, should you wish to have your Personal Information deleted please contact privacy@mequilibrium.com to request us to do so.
As soon as practically possible after your request is received, NLS will disclose to you all of your Personal Information that it keeps.
Promptly after receiving your request, all Personal Information stored in databases we actively use and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as reasonably practicable.
Contact us about questions, comments, complaints, notices or disputes. If you have a question, comment, complaint or a problem, or if you believe your privacy rights have been violated, you may email us at privacy@mequilibrium.com. Please indicate the following reason for contacting us: “l want to provide feedback about your site.” Our Customer Service department will forward your question, comment, complaint or notice to the appropriate NLS department for response or resolution.
In compliance with the EU-US Privacy Shield and US-Swiss Safe Harbor Principles, NLS is committed to resolving complaints about your privacy and our collection or use of your Personal Information. European Union individuals or Swiss residents with inquiries or complaints regarding this Privacy Policy should first contact us by email at privacy@mequilibrium.com. If you don’t receive adequate resolution of a privacy-related problem, you may write to NLS’s Security and Privacy Officer at:
Security and Privacy Officer
New Life Solution, Inc.
260 Franklin Street, Suite # 930, Boston, MA 02110
If a complaint cannot be resolved through NLS’s internal process, NLS has further committed to refer such complaints:
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- For European Union individuals, under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
- For Swiss residents, under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
If a complaint cannot be resolved by any of the mechanisms described above, you also have a right, under certain conditions, to invoke binding arbitration under the Privacy Shield Panel in compliance with the EU-US Privacy Shield. If you want to initiate this arbitration procedure, you are required to first formally notify us of your intention to do so by writing to privacy@mequilibrium.com. Please remember to include a summary of the steps you have already taken to resolve your complaint and a description of the alleged violation.
Terms and Conditions. When you access and use the Website or our Services, you are expressly agreeing to comply with NLS’s Terms and Conditions, available for review at https://www.mequilibrium.com/terms-and-conditions. The Website and the Services are owned and operated by New Life Solution, Inc., 260 Franklin Street, Suite 930 Boston, MA 02110.