New Life Solution, Inc. is committed to protecting your privacy.
Last Updated: January 23, 2020
|Category of Personal Information Collected|
|Source||Purpose for Collection|
|Categories of Recipients|
|Contact information: such as name and email address||From you when you register for or enroll in any Services; or from, as applicable, a family member participant in, or sponsor (e.g., your employer) or administrator of, your benefits or wellness program||To provide, manage, support, improve and personalize the Services and any related transactions, and to communicate with and respond to you about the Services, including to validate your identity or to meet legal obligations||Our affiliates, agents and successors; to the extent relevant, select marketing, technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, a sponsor or administrator of your benefits or wellness program|
|Personalized assessment information:||From you when you engage with the Services and answer questions related to your preferences or personality; or from, as applicable, a family member participant in, or sponsor or administrator of, your benefits or wellness program||To provide, manage, support, improve and personalize the Services||Our affiliates, agents and successors; to the extent relevant, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, relevant data (like application progress but not journal entries or user-input free text answers) with a sponsor or administrator of your benefits or wellness program|
|Payment information: such as name, card issuer and card type, credit or debit card number, expiration date, CVV code, and billing address||From you or your payment card issuers||Authorizing of credit card and other financial transactions with respect to your subscription or other payment obligations, as applicable, related to the Services||Our service providers who process payments for us—they are prohibited from using personal information for any other purposes and are contractually required to comply with all applicable laws and requirements, which includes the Payment Card Industry Data Security standards|
|Legal process-related information: such as details of your identity, or suspected or alleged criminal, dangerous, impermissible, unlawful or other relevant behavior||From crime and fraud prevention agencies, you, witnesses or law enforcement agencies||To protect customers, the public and our business against risks and crime||Law enforcement and other governmental authorities in accordance with applicable law, our technical and other service providers, and our professional advisors|
How we protect personal data: We take reasonable and appropriate measures designed to safeguard personal data, but there is always some risk involved in transmitting data over the Internet or storing data electronically. Please note that data you voluntarily reveal on any community or public areas of our service may be viewed by others with access to such areas. Learn more.
How long we retain personal data: We will not retain personal data for longer than necessary for the fulfilment of the purposes for which it was collected, unless otherwise required or authorized by law. Learn more.
Your choices regarding personal data: You can access, update or delete your personal data through the functionality of our service. You can choose whether or not to receive promotional communications, but please note that we may still contact you with important information about your account. Learn more.
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 or other wellness programs (each, a “Program”) through employers, health plans or providers, or other Program sponsors or administrators, or their respective designees (each, a “Sponsor”). NLS collects and processes data about the individuals using the Services as part of the Services.
We may collect the following types of information:
Information you provide. We collect Personal Information that you provide or make available through or in connection with the Website or the Services, including when you register, which requires you to create an account and provide contact information such as your name, email address, and telephone number, when you sign up for our electronic newsletters or updates and provide your email address, or when you provide relevant identifying, contact, demographic, employment or billing information. To the extent that you provide us with information about 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 or in connection with a Program, your Sponsor may provide this information on your behalf. We may collect your company name and assign you an account name based on your company name.
If you do not provide us with the Personal Information that is required to register for and use the Services, you may not access the Services, and we will have difficulty contacting you to send you updates or respond to your inquiries.
Information Provided by your Sponsor. In some implementations, your account will be supplemented with information sent by your Sponsor. Common examples include: Gender, Name, Employer Name, Employee Division, and Employee ID. The specific Personal Information provided by your Sponsor will be based upon the specifications and features of the applicable Program. Contact your Sponsor for more information about the information that it shares with us.
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 associate your 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.
Surveys and Contests. From time to time we may provide you the opportunity to participate in contests or surveys. If you participate in a survey or contest, we may request certain relevant Personal Information. 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 address or phone number.
Information from other sources. We may receive information about you from other sources, including updated, demographic and delivery and address information from third parties.
To manage your Account and provide Services. We use the information we collect to manage your Account(s), process your transaction(s), and provide the Services and customer service support, as well as to support our aggregate reporting as part of the Services. We may use Personal Information to verify or validate the identify of a user.
To contact you. We may, subject to applicable law, 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. For example, we may communicate with you in connection with your participation in surveys or contests, as discussed above, to educate you regarding use of or updates to the Services, to promote other products or services that may be of interest to you, or for other marketing or quality control purposes. 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 the Website may be shared with a customer service representative, employee, expert or agent that is most able to address your inquiry. We make reasonable efforts 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 the Website. To stop receiving such communications, click “Unsubscribe” at the bottom of such communication, or send an email message to email@example.com or send a regular mail to the following postal address:
Security and Privacy Officer New Life Solution, Inc. 260 Franklin Street Suite 1010 Boston, MA 02110
To develop, evaluate, improve and deliver the Website and the Services. We use the information we collect to develop, evaluate, monitor, document, improve and deliver the Website 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 for the Website. We may work with Sponsors to tailor and promote Programs and relevant Services.
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.
Sponsors. If you are using the Website or the Services as part of a Program, NLS may provide or make available the following information, which may include your Personal Information, to your Sponsor:
- Information, other than journal entries or user-input free text answers entered as part of the Services, regarding your account activity or participation with the Services, which may include log-in times, application progress, your specific meQ, Resilience Factor or other score or personality type information, survey results, or derivative information or analysis. Our automated algorithms may derive insights and recommendations from this information, offering suggestions regarding helpful resources related to the Services.
- Information generated or stored by the Services in connection with application integration. Integration between the Services and your Program portal allows you to, for example, view your meQuilibrium status and scores on the portal without needing to separately log in to the Services.
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 the 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. We may share your Personal Information with our agents and service providers, to the extent relevant to the services they perform on our behalf and subject to contractual agreements with respect to the confidentiality of such information. 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 prove that we are not responsible. (Please see, “For our Registered Users in the European Union (EU) and the European Economic Area (EEA)” below.) For Personal Information transferred to us from Switzerland under the Swiss-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 prove that we are not responsible. (Please see, “For our Registered Users in Switzerland” below.)
Nonaffiliated Third Parties. We may disclose Personal Information to the extent permitted by applicable law as follows:
To fulfill legal and regulatory requirements. We may disclose your Personal Information as we reasonably deem necessary 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 in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose your Personal Information, in accordance with or as authorized by law, to our accountants, auditors, agents, service providers, lawyers and other advisors 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, the Website, the Services or the general public, or violations of the Terms and Conditions or our Subscription Agreement.
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. In some jurisdictions, individuals may have the right to withdraw consent from certain uses. Withdrawal of consent is discussed below.
Non-personal Information. We may provide Non-personal Information about our users to strategic partners for research, statistics, marketing or 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 Non-personal Information to third party service providers in relation to the services they provide. We may provide Non-personal Information to Sponsors in relation to a Program. For example, your information may be aggregated with information of other employees and analyzed to evaluate the effectiveness of the Website and the Services, and the results of that analysis may be shared with third party service providers to help NLS improve the Website and the Services, or with Sponsors to allow them to evaluate the success of the Services.
Security of your Personal Information. NLS has implemented reasonable and appropriate measures designed to safeguard your Personal Information from loss, misuse, destruction and unauthorized access, disclosure and alteration. Notwithstanding our commitment to take reasonable and appropriate measures to protect your 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, we cannot ensure or warrant the security and privacy of any information you transmit to us, and you do so at your own risk. We will notify you, via email, posting or other commercially reasonable method, of any loss of data or breach of our security measures that has resulted in the loss or unauthorized access, disclosure, use or acquisition of your Personal Information (including hard copy records) or otherwise presents a potential threat to such information, as required by law.
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 the Website, you should log out of your Account and exit your browser so that no unauthorized persons can use the Website under your name or Account.
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, including the possibility that such information may be copied or further disclosed. To request removal of your Personal Information from the Community Areas, you may contact us via email 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 Personal Information. We will not retain your Personal Information for longer than necessary for the fulfilment of the purposes for which it was collected, unless otherwise required or authorized by law. Personal Information that is no longer required to fulfil the identified purposes, such as providing the Services to you, will be destroyed, erased or made de-identified. You may exercise your rights, subject to applicable law, to request that we delete or restrict access to your Personal Information. We may need to retain such information for legally permitted purposes, which will be explained to you if necessary.
What choices do you have regarding your Personal Information?
If you prefer that we do not contact you by mail or phone to promote other products or services that may be of interest to you, or for other marketing or quality control purposes, you may advise us via email at privacy@meQuilibrium.com that you are opting out of such communications.
To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still contact you with important information about your account.
If you wish to prevent the data sharing described herein, you may close your account upon request via email at privacy@meQuilibrium.com. If you close your account, you will no longer be able to use the Website or the Services or receive updates or other communications, and we will not be able to respond to your inquiries.
Updates. We respect your right to access and correct your Personal Information. If you need assistance correcting or updating your Personal Information, you may contact us via email at privacy@meQuilibrium.com. Sponsors are responsible for any requests made to them by Program participants regarding access to and rectification of participants’ respective Personal Information that is transferred to us.
Collection of information from children. None of our products or services are directed to children and NLS does not knowingly collect, either online or offline, Personal Information from children under the age of 13 without verifiable parent or guardian consent. If you believe that we have any Personal Information from a child under age 13, please contact us via email at privacy@meQuilibrium.com.
California Privacy Rights.
California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once per calendar year, information about the user information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of user information and the names and addresses of those businesses with which we shared user information for the immediately prior calendar year (e.g. a request made in 2020 will receive information regarding 2019 sharing activities).
To obtain this information from us, please send an email at privacy@meQuilibrium.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Not all information sharing is covered by these requirements, and only information on covered sharing will be included in our response.
If you are a California resident, California law also provides you with the following rights with respect to your Personal Information:
- The right to know what Personal Information we have collected, used, disclosed and sold about you. To submit a request to know, you may email us at privacy@meQuilibrium.com. Please include "California Privacy Rights Request" in the first line of the description and your California mailing or street address. You also may designate an authorized agent to make a request for access on your behalf.
- The right to request that we delete any Personal Information we have collected about you. To submit a request for deletion, you may email us at privacy@meQuilibrium.com. You also may designate an authorized agent to make a request for deletion on your behalf.
When you exercise these rights and submit a request to us, we may verify your identity. We also may use a third party verification provider to verify your identity. Your exercise of these rights will have no adverse effect on the price and quality of the Services.
How may your Personal Information be transferred to different locations?
For our Registered Users in the European Union (EU) and the European Economic Area (EEA).
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. In addition, NLS will cooperate with EU Data Protection Authorities (DPAs) and will comply with their guidance regarding human resources (HR) data transferred to NLS in the context of an employment relationship.
For our Registered Users in Switzerland.
NLS commits to cooperate with the Swiss Federal Data Protection and Information Commissioner (FDPIC) and to comply with the advice given by such authorities with regard to human resources data transferred from Switzerland in the context of the employment relationship.
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? NLS acknowledges the individual’s right to access their personal data. 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.
VeraSafe has been appointed as NLS's representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to firstname.lastname@example.org, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative/.
Alternatively, VeraSafe may be contacted at:
|VeraSafe Czech Republic s.r.o|
Prague 1, 11002
|VeraSafe Ireland Ltd|
Unit 3D North Point House
North Point Business Park
New Mallow Road
Security and Privacy Officer New Life Solution, Inc. 260 Franklin Street
Suite 1010 Boston, MA 02110
If a complaint cannot be resolved through NLS’s internal process, NLS has further committed to refer such complaints:
For European Union and Swiss individuals, under the 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 EU and Swiss Individuals: 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 and US-Swiss Privacy Shield programs. 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.
How can you communicate with us?
The Website and the Services are owned and operated by New Life Solution, Inc., 260 Franklin Street, Suite 1010, Boston, MA 02110. You may contact us via email at privacy@meQuilibrium.com.