Privacy

How we protect personal data: We take reasonable and appropriate measures designed to safeguard personal data where we have control over it, 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. If you have any concerns, you should not post any personal or identifying information on these public areas. Learn more.

How long we retain personal data: We will not retain personal data for longer than necessary for the fulfillment of the purposes for which it was collected, unless otherwise required or authorized by law. We retain your data for the duration of our commercial relationship and for a period of [seven] years afterwards unless such retention is restricted by applicable laws or you request that it is deleted sooner. Learn more.

Your choices regarding personal data: You can access, update, correct, object to or delete your personal data, withdraw your consent, cancel your account and obtain a duplicate of your personal data through the functionality of our service. You can choose whether or not to receive promotional communications by opting out if you have subscribed or where we send you communications we consider are relevant to you, but please note that we may still contact you with important information about your account. In addition, you may request that we restrict the processing of your personal data or request that a copy of certain of your data is provided to you or a third-party provider where applicable in certain jurisdictions such as Europe. All of these rights are subject to legal exemptions and limitations. We will respond within 15 working days of your request unless we have grounds, as permitted by applicable laws, to extend the period and respond within three months (or such required maximum period under applicable laws) instead. We may need to ask you to provide identity information before we can process any of these requests. Learn more.

Other important privacy information: Our Privacy Policy includes additional privacy information that you may find important, including with respect to data involving kids or California or other international residents and including data transfers to different geographic locations. Learn more.

Background. The privacy and the security of your Personal Information (defined below) are very important to us at New Life Solution, Inc. d/b/a meQuilibrium (“NLS”, “meQuilibrium”, “we”, “us”, or “our”). This Privacy Policy explains what Personal Information and other data we collect through or in connection with the Website or the Services (each, as defined below), 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 or about users of and/or visitors to the NLS website (the “Website”), and users of the associated products, services (including 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 (the “Terms and Conditions”).

Please read this Privacy Policy carefully and contact us if you have any questions or concerns. By accessing or using the Website or the Services, you are indicating that you have read, understood and agree to be bound by the terms of this Privacy Policy and the Terms and Conditions. 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, including as reasonably required to keep current with rules and regulations, technology and security standards, and our offerings and protocols. 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). 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 such updated terms.

The significant changes to this Policy include but are not limited to:

1. Major changes in our service mode, e.g. the purpose of processing personal information, the type of processed personal information, and how personal information is used;

2. Major changes in our ownership structure, organizational structure, e.g. the change of control due to business adjustments, bankruptcy, merger and acquisition;

3. Changes of the main recipients which personal information is publicly disclosed to, shared with, or transferred to;

4. Changes in your rights involved in personal information processing and in how you exercise such rights;

5. Changes of our responsible department, contacts and complaint channels for personal information protection;

6. When a personal information impact assessment report indicates high risks.

Personal Information. In this Privacy Policy, “Personal Information” is information relating to an identified or identifiable individual, such as your name, email address or telephone number, provided to or collected by us through or in connection with the Website or the Services. “Non-personal Information” is information that is de-identified, aggregated or cannot reasonably be associated with an identifiable individual.

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.

What information does NLS collect?

1. Information Collected and Used for Essential Business Functions

In order to provide you with our Services, we must collect and use certain Personal Information for our business. Below we list the necessary Personal Information that we collect and use about you to fulfill such essential and additional business functions:

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 received consent 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.

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. Where required under applicable laws, we seek your consent before enabling cookies that collect this information.

If you do not provide us with the necessary Personal Information above that is required to register for and use the basic business function, you may not access the basic business function, and we will have difficulty contacting you to send you updates or respond to your inquiries.

2. Information Collected and Used for Additional Business Functions

We also collect and use Personal Information about you to fulfill our expanded business functions. If you do not provide such Personal Information, you cannot use the additional business functions, but you can still use the essential business functions listed in item 1 above.

(1) Sign up for our electronic newsletters

When you sign up for our electronic newsletters or updates, you should provide your email address.

Information from cookies. Like many other websites, the Website gathers and stores certain information automatically or, where required under applicable laws, with your consent. Unless you are in a jurisdiction requiring active consent to the use of certain cookies, the cookies will be placed automatically and when you visit the 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. The Website requires that both cookies and JavaScript be enabled. If you reject or do not actively consent to the use of non-essential cookies from the Website, some parts of the Website or of the Services may not work properly for you.

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.

Log and other information. When you access the Website or the Services, or other content served by or on behalf of us on other websites or mobile applications, our servers may automatically or, where required under applicable laws, with your consent, 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 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 notify you that we may receive information about you from other sources, including updated, demographic and delivery and address information from third parties.

Sensitive Personal Information Collected and Used

We may collect or receive the following types of sensitive personal information about you, including but not limited to, your name, e-mail address, or other information you may enter into the Service for the purposes of providing you the Services, including validating your eligibility to use the Service. Therefore, you need to carefully consider before using the Services we provide you. You agree that this sensitive personal information will be processed in accordance with the purposes and methods stated in this Privacy Policy.

How does NLS use your information?

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 identity 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. Where required under applicable laws, we will seek your consent before sending any such communications to you.

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 optout@mequilibrium.com or send a regular mail to the following postal address:

Security and Privacy Officer
New Life Solution, Inc.
68 Harrison Ave, Ste 605
PMB 25958
Boston, MA 02111-1929

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.

How does NLS share your information?

Sponsors. If you are using the Website or the Services as part of a Program, you expressly consent that NLS may provide or make available the following information, which may include your Personal Information, to your Sponsor or their delegate:

• 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.

With respect to Personal Information that we collect from you and share with your Sponsor, as described in this Privacy Policy, your Sponsor is responsible for limiting its use of such information as reasonably necessary in connection with the Program, in each case solely to the extent needed to develop, implement, manage, or improve the Program and in accordance with all applicable notices and consents and this Privacy Policy. Your Sponsor is also responsible for any notification or consent that may be required beyond this Privacy Policy. Your Sponsor is responsible for maintaining reasonable and appropriate confidentiality and security of Personal Information shared with it under the Program. Sponsors are responsible for ensuring that any commercial emails, text messages, or telephone calls to their Program participants comply with applicable law, including any consent requirements. If we are instructed by Sponsors to transmit communications on their behalf, Sponsors remain responsible for ensuring that recipients have consented to receiving such communications and that the information contained in the communications are accurate and complete. Subject to applicable law, we assume no responsibility for validating that appropriate consent has been obtained or that information contained in communications we send on behalf of Sponsors are accurate and complete. If you have any questions or concerns, we recommend that you contact your Sponsor for more information about how your Personal Information is shared and used in connection with the applicable Program in relation 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. You expressly consent to us sharing or, if permitted under applicable laws, you acknowledge that 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-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), we will remain liable under these frameworks 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 below for additional information.) For a list of current service providers (subprocessors), please contact compliance@mequlibrium.com

Nonaffiliated Third Parties. You expressly consent to us instructing third parties to process your Personal Information to the extent required or permitted by applicable law or you are otherwise informed that we may instruct third parties to process your Personal Information 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 provide your Personal Information to third parties 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 provide 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 providing 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.

How does NLS protect your information?

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.

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 policies 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 us through or specifically with respect to the Website or 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, 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.

How long does NLS retain your Personal Information?

Retention of your Personal Information. We will not retain your Personal Information for longer than necessary for the fulfillment of the purposes for which it was collected, unless otherwise required or authorized by law. Personal Information that is no longer required to fulfill the identified purposes, such as providing the Services to you, will be destroyed after a period of seven years, or erased or made de-identified within the terms established by applicable law. When deleting Personal Information, we will take commercially reasonable and technically feasible measures to make the Personal Information irrecoverable or irreproducible. In case any Personal Information is required to be retained for a period beyond the period of retention and use as prescribed by applicable laws, such information will be stored or maintained separately from other items of Personal Information to the extent technically possible. 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?

Choice and consent. Each time you email us, sign up for or use the Website or the Services, you are giving your express consent to the collection, use, retention, transfer and sharing, including cross-border transfer, of your information as described in this Privacy Policy. You may access, correct, delete, withdraw your consent, cancel your account, obtain a duplicate of your Personal Information as follows:

If you wish to withdraw your consent so 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 withdrawing your consent to receive 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.

How does NLS handle requests regarding kids, Do Not Track signals or other special circumstances?

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 (or such higher age if required by applicable laws) without verifiable parent or guardian consent. If you believe that we have any Personal Information from a child under age 13 (or such higher age if required by applicable laws), please contact us via email at privacy@meQuilibrium.com.

Do Not Track Signals. NLS does not 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.

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.

For the 12-month period prior to the date of this Privacy Policy, we have not sold any Personal Information about our clients; nor do we have any plans to do so in the future.

How may your Personal Information be transferred to different locations?

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, in some cases Personal Information that we manage may be transferred, processed and stored outside of your country of residence, including the United States, where data protection laws may be of a lower standard compared to the country from which the data was sent and where the data may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions. 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, subject to the terms set forth below regarding specific jurisdictions, such as the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). 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), the European Economic Area (EEA), the United Kingdom (UK) and Switzerland.

NLS complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. NLS has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. NLS has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. NLS commits to cooperate with relevant EU, EEA, UK, and/or Swiss data protection authorities and to comply with the advice given by such authorities with regard to human resources data transferred from EU, EEA, UK, and/or Swiss in the context of the employment relationship.

Users in this territory have certain rights relating to their personal information under the applicable European/UK/Swiss data privacy laws. This section only applies to such users. Under applicable European/UK/Swiss data privacy laws, NLS is the data controller.

(a) Rights to Control Your Personal Information

Applicable data privacy laws gives certain users the right to access their personal information. Your right of access can be exercised in accordance with the data privacy laws. If you would like to request a copy of your personal information being held by us, or request that it is deleted or to update and/or correct your personal information or request that we provide a copy to another data controller of your personal information that you have provided to us, please contact us. We will need enough information to ascertain your identity as well as the nature of your request. We will aim to respond to your request within one calendar month of receipt of the request. Where we were unable to do so within the calendar month, we will notify you of the soonest practicable time within which we can respond to your request (and within three months from the date of your request). There are certain exemptions and restrictions of these rights under the data privacy laws that enable personal information to be retained, processed or withheld from access and we will inform you of these if applicable.

(b) We use your Personal Information for the following key purposes:

• to contact you: subject to applicable law, we or our third-party service and business providers may send you communications; especially if you have subscribed to one of our services. Such communications are designed to make your experience of our Website more efficient and may include, but are not limited to: communications about our organization and other notifications including important news that could affect your relationship with us. Where required under applicable data privacy laws, we will not send you marketing communications without your prior consent;
• for legal purposes: we may use and share personal information for legal purposes, including financial, regulatory, tax and other legal obligations and to respond to governmental or regulatory requests or subpoenas or for litigation purposes;
• for our legitimate interests and those of a third party: we may use your personal information to manage our legal, regulatory, financial and business requirements, including obtaining legal advice, in the course of disputes and litigation, internal and/or regulatory investigations and other legitimate interests; we also use your personal data for our legitimate marketing purposes and we may share your data with third parties, such as our sponsors, where we consider this meets our legitimate interests or those of our sponsors, whilst respecting users’ data privacy rights;
• for our business purposes: we may use your personal information to help us manage the objectives of our organization;
• for other purposes: subject to applicable law, we may use your personal information for additional purposes in connection with the Website or our organization, where you have provided your prior consent.

(c) International Transfers

Your personal information will be processed in the US (which may have less stringent data privacy laws compared to those in your country of residence) and we also transfer your personal information to the recipients described in this Privacy Policy including those recipients located in countries which may also have a less stringent standard of data privacy laws compared to those in your country of residence. Where this occurs, you acknowledge and where required, consent to such transfer in accordance with 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.

For our Registered Users in Russia: NLS will provide recording, systematization, accumulation, storage, adjustment (update, modification), and extraction of your Personal Information with the use of databases located in the territory of the Russian Federation. NLS may transfer your personal data to another country and subsequently store your personal data on additional databases. NLS may also transfer your personal data to a country that, under the applicable data protection laws, does not provide for the adequate level of protection of data subject’s rights. You hereby expressly consent to such transfer for the purposes of performing NLS obligations under this Privacy Policy.

For our Registered Users in Mexico: NLS complies with the fair information principles defined in the Federal Law for the Protection of Personal Data in the Possession of Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares) and its regulation (Mexican Privacy Laws). NLS conforms to the principles defined in the Mexican Privacy Laws, which include legality, consent, transparency, quality, purpose, loyalty, proportionality and responsibility. Further, NLS has put in place and maintains administrative, technical and physical measures that (i) allow it to protect your data against damage, loss, alteration, destruction or its unauthorized treatment or use, and (ii) provide you with the means for exercising rights of access, rectification, cancellation or objection (ARCO rights) in accordance with the provisions of the Mexican Privacy Laws.

For our Registered Users in South Korea: NLS delegates the processing of personal information as described herein, and the delegatees may process personal information according to the purpose of the delegation.

Please contact privacy@meQuilibrium.com for a list of delegatees.