Privacy policy

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Apr 2, 2024

About this Privacy Policy and Our Commitment to Your Privacy

This Privacy Policy (this "Policy" or these “Terms” ) sets forth the terms upon which New Resilience LLC, a Wyoming limited liability company (or “New Resilience”, “we”, “us”, or “our”) offers you, our third party end-users (each, an "End-User", “Member”, “user”, “client”, “patient” , you” or “your”), access to our mobile application (the "App") or website located at www.newresilience.ai (including any successor site) (the “Website” or “Site”). This Policy also describes the choices available to you regarding our use of your information, and how you can manage and update this information. By accessing the Website, by clicking “I Agree”, by accessing the New Resilience App, which (i) brings therapists and clients, both existing as well as prospective, closer together, (ii) provides therapy resources so that therapists can focus on providing quality care to their clients while offloading the administrative items around billing, insurance, scheduling and compliance, and (iii) may facilitate confidential communication of certain health information (“Member Information”) between client and therapist (the “Service”), or by using the New Resilience App in any way, you agree to be bound by these Terms. Any terms used in this Privacy Policy not defined herein are as defined in the Terms of Service.



Your Consent to this Privacy Policy by Using the Site

As described in this Privacy Policy, we may use and disclose your information to provide you with products and services and to improve your experience using those products and Services. By using the Site, or any other website, online service or mobile application where this Privacy Policy is posted, you agree to our collection, use, disclosure, and storage of information as described in this Privacy Policy.



Third-Party Advertising on Our Site

We do not allow third parties to advertise to End-Users on our Site, unless you provide consent, which is not requested in this Privacy Policy.



How to Contact Us with Questions about this Privacy Policy

Please read this Privacy Policy carefully. If you have questions or complaints regarding our Privacy Policy or privacy practices, please contact us at: Attn: Privacy Concerns, New Resilience LLC, 30 N Gould St. STE R, Sheridan, WY 82801 or support@newresilience.ai.



Information Addressed by this Privacy Policy

We want you to have a clear understanding of the information addressed by this Privacy Policy. We will collect information about you (“Information”) in a variety of ways, including directly from you, through automatic means, or from third parties. The Patient Information that is collected depends on how you use the Site.



Personal Information and Privacy

When you use our Service, you may be creating and maintaining a personal, private area of the application for yourself and/or one or more therapists or patients (an “Account”). By their very nature, these Accounts contain a great deal of personal information about you or others, and our goal is to support our End-Users’ desire for privacy. All End-Users are responsible for maintaining the confidentiality of the Account, including not sharing passwords.   



Information You Provide Directly to New Resilience

When you use the Site, you may provide certain information directly to us. For example, without limitation, when you choose to register an Account, you will be required to provide, among other things, your e-mail address, name, and phone number. When you create an account, we may collect identifying information about users to suggest contact information about available and potentially synergistic therapists or other resources available through our platform that may be of assistance to the user. 



Certain Information in the Services is Visible to Other End-Users

Information regarding patient, actions taken, therapy conversation, and AI Service conversations are not shared or visible to other End-Users unless a patient willfully makes this information available to such End-User. You can clear your chat at any time in the settings by making a request at support@newresilience.ai.



Cookies and Tokens

Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of local storage (such as browser-based or plugin-based local storage, or application-based local storage on a mobile device). You may be able to restrict or disable certain cookies. Please note, however, that without cookies, you may not be able to use all of the features of our Site.

Our cookies, tokens and similar technologies (collectively, “Tracking Technologies”) also are used for administering the Site, including without limitation, for authentication, to remember End-Users’ settings, to customize the content and layout of the Site for End-Users, to contact you about the Site, and to improve our internal operations, the content of our Site and our services. End-Users may be able to control the use of, or reject or disable, some Tracking Technologies at the individual browser level. If you reject or disable Tracking Technologies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. We use Tracking Technologies to identify your device and keep track of your Internet session with our Site. Using these Tracking Technologies, we may automatically end your session on our Site after a period of inactivity (as determined by us in our sole discretion). We also use Tracking Technologies that allow us to recognize your device when you return to the Site within a certain period of time (as determined by us in our sole discretion) and automatically log you back into your account with us. UNLESS YOU AFFIRMATIVELY LOG OUT of your account PRIOR TO YOUR SESSION ENDING (whether by you or by us), YOU WILL BE AUTOMATICALLY LOGGED BACK IN THE NEXT TIME YOU OR ANY END-USER OF YOUR DEVICE VISITS OUR APP within the period of time determined by us. If you do not wish to be automatically logged back in when you (or someone using your device) next initiate a session with our App(using the same device that is being used for your current session), you should log out of your account (i) prior to ending your session, or (ii) if you will be inactive on our App for more than a few minutes.



Web Logs

In conjunction with the gathering of data through cookies, Web servers may log records such as your device type, operating system type, device advertising identifier, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The Web server logs also may record the address of the Web page that referred you to our Site, the IP address (and associated city and state or province for the IP address) of the device you use to connect to the Internet, and data about your interaction with our Site, such as which pages you visit.



Online Analytics

We may use third-party web analytics services on our Site, such as those of Google Analytics. These service providers use the sort of technology described in this “Information that is Automatically Collected” section to help us analyze how End-Users use the Site, including by noting the third-party Web site from which End-Users arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Site.



Mobile Application Technologies

Our mobile applications may also collect information specific to use of your mobile device, such as unique device identifier and, with your consent, precise geolocation information, motion coprocessor data (e.g. recording information such as steps, distance, and elevation), accelerometer data (showing whether you’re stationary or moving), and gyroscope data. We may also use third-party analytics, such as those of Google Analytics.



Collection of Information Across Personal Devices and Applications

Sometimes, we (or our service providers) may use the information we collect—for instance, log-in credentials, IP addresses, hashed email addresses, and unique mobile device identifiers—to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this, in order to better tailor content, features, and advertising (for New Resilience on other sites), and provide you with a seamless experience across the devices you use to access our services.‍



Our Use of Information

‍Use and Storage of Information to Provide You with the Site and Related Services

New Resilience, and any third party vendors acting on New Resilience’s behalf, may use and store your Information to perform activities associated with providing you with the Site and related services such as: (i) registering you to use the Site and otherwise logging you into the Site, including the authentication of your identity, where applicable, and otherwise enabling your access to the Site; (ii) resolving disputes and/or troubleshooting problems including logging into your account to troubleshoot problems or otherwise help you navigate the Site; (iii) verifying your compliance with your obligations in our Terms of Service or other New Resilience policies; (iv) improving the quality of the Site, (v) fulfilling any request you make; (vi) communicating with you; (vii) connecting you with and providing you with information about services, providers of services, resources or programs to which you may have access; (viii) providing you with Site content, including, without limitation, generating recommendations (such as recommended Site activities or services), providing therapist navigation services, creating action plans for therapists, helping therapists anticipate the needs of the patient, and processing your preferences and requests; (ix) analyzing, customizing, and personalizing the Site, including through the delivery of tailored content and communications; and (x) otherwise as directed by you or provided for herein. Except where prohibited by law, and only to the extent permitted by New Resilience’s agreements with applicable therapists, we may also use your Information in connection with any other services we make available to you.



Additional Information Regarding Use of Information for Communications with You

New Resilience may use your Information to communicate with you (including, without limitation, via email and/or mobile push notifications) about the Site and/or our products and services (and related features and functionality) or those of any therapists that are providing services to you. Our communications to you will include, without limitation, contacting you by SMS text message or at the email address(es) that you use to register for our Site to communicate with you regarding the Site and actions that you take in connection with the Site.



Your Choices Regarding Our Communications with You

In accordance with applicable law, we will offer you the opportunity to opt out of certain communications, such as, for example, communications that deal with any of our products or services you are not using but that we think might be of interest to you. Where applicable, you can opt out by emailing us at support@newresilience.ai. However, even if you opt out of such communications, you may continue to receive other transactional, relationship, and/or administrative communications from or through New Resilience that are important or related to your New Resilience account or the products and services you are using (such as, for example, a notice that there has been a change in one of your services or a change to this Privacy Policy). Please also note that you, not New Resilience, have control over certain settings for how communications such as emails and push notifications are displayed on your devices, and the settings you select will affect how New Resilience’s communications are displayed.



Creation and Use of Combined Data, De-Identified Data, and Aggregated Data

As permitted by law, we may aggregate and/or de-identify your Information and/or combine your Information with other information maintained or available to New Resilience and use or disclose such information as follows: 

We may use aggregated or combined data to communicate with you about the Site and/or our products and services and disclose such aggregated or combined data to New Resilience service partners in connection with providing the Site.

We may also use and disclose de-identified data, de-identified aggregated data, and/or de-identified combined data for any business purpose, which may include, without limitation, improving our products and services, conducting analytics such as evaluating our Site and developing additional benefits, programs, and services, and disclosing to New Resilience service partners for analytics purposes.



Disclosure of Information. We may share your Information in the following circumstances:

Disclosures to Service Providers and New Resilience Service Partners

With the limited exceptions discussed below, we do not share your information with third parties, unless you tell us to. We will not share your personal information under any circumstance with any third parties for the purpose of allowing them to conduct direct marketing to you. In this section, we describe the potential uses of your information in greater detail

With Third Parties That Provide Requested Benefits: As stated above, we primarily share your information, including your personal information, with third parties for the purpose of providing certain benefits that you request. Specifically, at your direction, we will submit your information to the appropriate third parties for purposes of filling your third-party service requests. For example, if you are interested a therapist’s services, then we will share your information, at your direction, with third parties that work with New Resilience to provide such services, which may fit your particular needs. The third party, not New Resilience, will evaluate your eligibility to obtain service from its program. The third party’s use of your personal information will be governed by the third party’s own terms of service and privacy policy, not New Resilience’s; New Resilience does not have any control over your information once it is submitted to a third party for receipt of benefits. While we work with reputable third-party service providers, we cannot represent how any of them will use your personal information in connection with their services, and recommend that you review their terms of use and privacy policies before requesting their services. 

To Perform Services on Our Behalf: We may hire vendor companies to provide limited services on our behalf, such as payment processing, sending postal and electronic mail, providing technical support, and to assist us in providing the products and services that you request from us. We only provide those service providers with the information necessary to perform the requested service.



Additional Disclosures with Your Consent

With your consent outside of this Privacy Policy, we may share your Information with third parties or allow them to collect information from the Site in some ways not specifically described in this Privacy Policy.



Safety, Security and Compliance with Law

Your Information and the contents of your communications through the Site may be disclosed to third parties as required by law, such as to comply with a subpoena or similar legal process, or when we reasonably believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, report improper or unlawful activity, or respond to a government request. ‍



Subsidiaries and Affiliated Companies

Except where prohibited by law or precluded by contract, we may share your Information with any subsidiaries or other affiliated companies under the control of, or under common control with, New Resilience for the purposes set out in this Privacy Policy.



Sale, Merger or Similar Transaction

We may share your Information in connection with any proposed or actual merger, reorganization, a sale of some or all our assets, a financing or acquisition of all or a portion of our business by another company, or to a receiver, trustee or successor in interest in bankruptcy, in which case such company may continue to process your Information as set forth in this Privacy Policy (except where prohibited by law) or otherwise with your consent.



We Do Not Control the Privacy Policies of Third Parties

Our Site may contain links that enable you to visit or use other third-party websites, resources or programs. However, we do not have control over the other websites, resources, or programs that you choose to visit, so this Privacy Policy does not apply to information collected or that you provide while visiting such other websites, resources, or programs. You should refer to the privacy policies, if any, applicable to the other websites, resources, or programs.



Data Security and Integrity

The security of your Information is important to us. We follow security standards to protect the Information submitted to us from loss, interference, misuse, unauthorized access, disclosure, alteration or destruction, both during transmission and once we receive it. These safeguards vary based on the sensitivity of the Information that we collect, process and store and the current state of technology. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. We also maintain procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current. If you have any questions about data security and integrity on our Site, you can contact us at support@newresilience.ai.



Managing and Updating Information

To access, review, update and/or delete certain Information, you may contact us at support@newresilience.ai, and you may update and/or delete certain Information by logging into the Site and updating your account. We will respond to your request within a reasonable and lawful timeframe under the circumstances of your request. Please remember, however, if we have already disclosed some of this Information to third parties, we cannot access that Information any longer and cannot force the deletion or modification of any such Information by the parties to whom we have made those disclosures. Additionally, if you modify certain Information on our Site that we received from a third party, we reserve the right, but are not obligated, to share the updated information back to that third party. As a result, you will need to provide updated information to those third parties if you want to be sure they have your updates.

Certain Information is necessary in order for us to provide the Site and our related Services; therefore, if you delete such necessary Information you will not be able to use the Site or receive our Services. If you wish to have your account deactivated, you may contact us at support@newresilience.ai. After we receive your request, within a reasonable timeframe under the circumstances of your request, we will deactivate your account; provided, however, that: 1) New Resilience (and our third-party vendors acting on our behalf), our New Resilience service partners, and any other applicable third parties may continue to use and share for any purpose de-identified data and aggregated or combined data developed using your Information that has been de-identified and 2) New Resilience may continue to use Information in your deactivated account for compliance with applicable regulations. Also, please note that even though you may deactivate your account or request the deletion of your Information, we may be required (by law or otherwise, such as to prevent fraud, resolve disputes, or troubleshoot problems) to retain this information, in which case we will comply with your deletion request only after we have fulfilled such requirements. We may also keep a copy of your Information to protect our legal rights, such as in connection with your use of the Site or your agreement to our Terms of Service, as permitted or required by applicable law.



California Do-Not-Track Disclosure Requirements (for California End-Users)

We are committed to providing you with meaningful choices about the information collected on our Site for third-party purposes. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.



Your California Privacy Rights (for California End-Users)

California law permits customers of New Resilience who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write us:

New Resilience LLC

30 N Gould St. STE R

Sheridan, WY 82801 

email: support@newresilience.ai.

We will provide a list of the categories of personal information, if any, disclosed to third parties during the immediately preceding calendar year for third-party direct marketing purposes, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or postal address specified above. You should put “California Privacy Rights” in the subject line and in your request. You must provide us with specific information regarding yourself so that we can accurately respond to the request.



Children; Special California Notice

The Site and Services are not directed to children under the age of 18, and children under the age of 18 years of age are not eligible to use them. Protecting the privacy of children is very important to us. Through the Site and Services, we do not collect Information from people we actually know are under 18 years of age, and no part of the Site or Services is designed to attract people under 18 years of age. If we later learn that an individual has provided us with their information through the Site or Services and they are under 18 years of age, we will take steps to remove that End-User’s Information from our databases and to prevent the End-User from utilizing the Site or Services. 

If you are a California resident under the age of 18 and are a registered End-User of our Site, you may request that we remove from our Site any content you post to our Site that can be accessed by any other End-User (whether registered or not). Please note that any content that is removed from our Site may still remain on our servers and in our systems. To request removal of content under this provision, please send an email to info@newresilience.ai and provide us with a description of the content and the location of the content on our Site, and any other information we may require in order to consider your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the Site by you.‍



Uses and Disclosures as Required or Permitted by Law, Including Research, Health Care Operations, and Public Health

To the extent not prohibited by law or precluded by New Resilience’s agreements with the applicable therapists, and any third party vendors acting on New Resilience’s behalf, may use and disclose your Information: (a) as required or permitted by law, including, where applicable, the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), which may include disclosures to the applicable therapists; (b) for Research purposes; (c) for purposes of Health Care Operations of the applicable therapists; and (d) for Public Health, as each is defined and in accordance with HIPAA.‍ . For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html



Retention of Personal Data

Personal data will be retained only for so long as reasonably necessary for the purposes set out in this Privacy Policy, considering criteria such as applicable rules on statute of limitations and at least the duration of your use of our Site and Services. Information may persist in copies made for backup and business continuity purposes for additional time.



Our Responsibilities

We are required by law to maintain the privacy and security of your protected health information. We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information. We must follow the duties and privacy practices described in this notice and give you a copy of it. We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind. 

For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.



Modifications to this Privacy Policy

From time to time, we may update this Privacy Policy to reflect changes to our information practices. If we make changes to this Privacy Policy, they will be reflected in an updated Privacy Policy that will be posted on the Site, and all changes will be effective upon such posting or upon any later date specified by us in writing. We encourage you to periodically review this page for the latest information on our privacy practices. You can determine when this Privacy Policy was last revised by referring to the “Effective Date” legend at the top of this Privacy Policy. By continuing to use the Site or any services following the effective date of any updated Privacy Policy, you are agreeing to be bound by the terms and conditions of such updated Privacy Policy.