LIFELENZ United States Privacy Policy
Welcome to LIFELENZ, a versatile all-in-one people management platform that simplifies HR tasks and streamlines workflows(“Services”). People are at the core of our Services and we are committed to protecting the personal information of individuals that we work with globally.
To make this Privacy Statement easier to understand, we have provided a summary to the of each section. We also encourage you to contact us (see “How to Contact Us “below) if you have any questions or concerns.
Last Updated: October 10th, 2024
SCOPE OF THIS PRIVACY STATEMENT
This Privacy Statement applies toindividuals who interact with us or use LIFELENZ products and Services.
This Privacy Statement(“Statement”) sets out how LIFELENZ uses the information that we collect aboutyou when you interact with us on our website (“Site”) or when using ourServices. This Statement also explains the choices that you can make about theway that we use your information and applies to all individuals who interactwith us globally as customers or their employees, our partners and vendors,visitors to our Site, or our own prospective employees or employees. This Siteis owned and operated by Positive Circularity Inc.
Our Statement details the information we collect about you and how we use it, outlines the steps we take to protect the information you entrust to us, and describes your choices with respect to your information. By registering on this Site, submitting any information to LIFELENZ on our Site or by otherwise accessing or using any of our systems or Services, you agree to the terms of this Statement and consent to the policies and practices described here.
YOUR RIGHTS AND PREFERENCES
LIFELENZ allows you to exercise your privacy rights and manage how we use your information.
Privacy and data protection laws in different geographic regions give individuals certain rights in relation to their personal information. We conduct our privacy practices according to thisPrivacy Statement and the relevant laws of the geographic regions in which we interact with you.
LIFELENZ encourages you to become familiar with our privacy practices and to contact us to learn more about your privacy rights and how we collect and use your personal information. Unless we specifically disclose otherwise, you understand that we may use any of your collected personal information for any of the purposes described in this Statement (as permitted by applicable law).
INFORMATION WE COLLECT
We collect information that relates to you and your interactions with LIFELENZ.
When used in this Statement,“personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual (“data subject”), and includes “personal data” or “personal information” as defined in applicable data protection laws. Data that cannot be associated with you, such as aggregated, de-identified, or anonymized information (“Anonymous Information”),is not personal information. LIFELENZ commits to keep Anonymous Information inits de-identified state and will make no efforts to re-identify such data.
A. Information Directly from You.
LIFELENZ collects certain information from you in order to conduct business globally, including providing you with access to our Services, improving your experience, communicating with you in connection with or regarding our Services, and to enhance and improve our Site and operations based on insights we are able to obtain from your information, such as whether a given Site layout is convenient and accessible.
LIFELENZ also collects personal information directly from you during the recruitment process and in the context as an employer. If you choose not to provide certain personal information, we may not be able to provide you with requested Services, or information.
B. Information Collected in the Course of Using Our Services.
Your use of our Services may cause us to generate or collect certain information in order to facilitate providing those Services and enabling them to be useful, including:
• Scheduling and timekeeping information, Site work schedules and shifts, work offer and shift swap requests and responses, hours worked, estimated earnings and time records
• Work tasks, forms, notices, documents, locations, stations, and notifications, and messages
• Union membership
• Conversations between employees or between employer and employee
• Transactional, usage, and preference information, Site your subscription status, pages visited, types of Services accessed, data volumes transferred, shifts offered, response times, number of notifications, advertisements and coupons viewed, and settings chosen
• Other information about actions you perform through our Services and that you upload or provide during your use of our Services
C. Information from Third Parties.
We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application or site, such as an app store or a social networking site, we may collect information about you from that third-party site that you have made public via your privacy settings. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business and Services. We may also collect details of your interactions with other users of our Services.
D. Automatically CollectedInformation.
LIFELENZ may automatically collect some usage information when you interact with us. We use cookies and other tracking technologies to automatically collect technical information, such as URL, cookie data, IP address, device type, unique device IDs, device attributes, network connection type (e.g., Wi-Fi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, operating system, and Services information.
E. Derived Information.
LIFELENZ may use information wehave about you to draw inferences, and we may then use those inferences to gaina more complete understanding of your preferences. We use preference data inorder to offer you potential choices, make recommendations, or to alert you toproducts or services that may be of interest to you.
F. Children’s Information.
LIFELENZ Services are notintended for children under 13 years of age. If you are aware that we haveunintentionally collected information from someone who is underage, pleasenotify us immediately by sending an email to privacy@LIFELENZ.com. By continuingto use our products and Services, you confirm that you are at least 18 years ofage and are fully able and competent to enter into and accept the terms setforth in this Statement or that you have had a responsible parent or guardiando so on your behalf.
LIFELENZ does process children’sinformation in the employment context for the purpose of providing employeebenefits.
G. Personal InformationCollection and Disclosure Chart.
The following applies to the personal information of data subjects that interact with LIFELENZ and ourServices:
HOW WE USE YOUR INFORMATION
We use your personal information to develop and provide our Services, to personalize, improve and promote our interactions with you, to operate our business and to communicate with you.
A. Delivering Services,including:
• Sending you an invitation to use our Services (for example, when your employer or potential employer invites you to use our Services, we may send you an invitation)
• To provide you with customer or technical support (e.g., by contacting you via email address)
• To facilitate social interactions between you and other users of our Services (such as employers)
• To notify you of future changes and improvements to our Services
• To provide you with access to the functionality and features of our Services (e.g., in order for you to create or update your CV, to request shifts, to find employers or employees)
• To manage our relationship with you and to manage the payment and recovery of amounts payable to us by you
B. Business and Internal Operations Purposes, Including:
• To analyze data to ensure appropriate service levels are being achieved
• To enable us to operate, maintain and improve the functionality and features of our Services
• If you have opted-in to receive advertising or coupons through the LIFELENZ app, to enable third parties to provide you with advertising or coupons in relation to offers for goods or services
• To provide you with other direct marketing communications regarding offers of goods or services which maybe relevant to you
• To enable us to conduct our business generally, such as notifying our insurers, quality assurance, internal teaching and data processing and handling and in connection with any potential sale of our business and for other purposes which are reasonably necessary in connection with our normal functions and activities
• For our internal management purposes as a business and as an employer
C. Our Employment/ContractApplication Process, Including:
• To assess and determine youreligibility or suitability for a job or contract with us
• To, with your permission, contact professional or other reference(s) you have provided in connection with a job application to discuss your experience/employment
HOW WE SHARE YOUR INFORMATION
We will only share your personal information as we have described in this Privacy Statement.
A. Affiliated Companies.
We may share your information with our affiliated companies to fulfill the purposes described in this Statement, including for data processing, marketing, and administrative purposes.
B. Vendors and Other Third Parties.
We may authorize vendors and other third-party companies to provide certain services. We provide these companies with only the information they need to perform their services and work closely with them to ensure that your privacy is respected and protected. These companies are prohibited by contract from using this information for their own marketing purposes or from sharing this information with anyone other than us. The services provided include:
1. Information TechnologyProviders
• Hosting and operation of the Site and other platforms
• Processing transactions and payments
• Digital marketing and advertising
2. Marketing, Advertising and Customer Service
• Marketing or promotional assistance
• Advertising, such as:
o Sending you advertisements and promotions through the LIFELENZ app if you have opted-in to receiving these
o Participating in or administering our promotions or surveys
o Teaming to provide products, services, or promotions
o Providing customer service
o Third parties who may wish to contact you regarding offers of goods or services which you may be interested in, unless you have opted-out of receiving such marketing communications
C. In Connection With Your Job Application or in Connection with a Job or Contract With Us
• Disclosure to any professional or personal references you provide in connection with your job or contract application to the extent necessary for us to consider your application
• Disclosure to vendors that assist with employment processes such as payroll providers, benefits providers and IT service providers
D. Social Sharing, Including:
• Logging into, linking with or connecting your LIFELENZ account with your social media account
• Using your social media account to authorize or verify your LIFELENZ account
• Connecting your LIFELENZ account to your social media account where you have authorized us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy
E. Following the Law and Protecting LIFELENZ
We may share your information with courts, law enforcement or regulatory agencies, or other government bodies when we have a good faith belief we are required or permitted to do so by applicable law, regulation, or legal process. We may also disclose your information if we believe it is appropriate to protect the rights, property or safety of LIFELENZ, our Services, our people, or to protect or assist others as required by law or contract.
F. Credit Reporting.
We may share information about your creditworthiness with credit bureaus, consumer reporting agencies, and card associations. Late payments, missed payments, or other defaults on your account may be reflected in your credit report and consumer report. We may also share your personal information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, or debt collection.
G. Sale of Our Business.
If we sell, merge, or transfer any part of our business, information about you may be shared, sold or transferred as part of that transaction. We may also share your information with current or future corporate parents, to our subsidiaries, between our brands ,or with our affiliates.
H. De-identified or AggregatedData.
We may de-identify or aggregate your information, alone or in combination with information from other individuals. Such de-identified or aggregated information will not contain personal information and may be shared freely by LIFELENZ.
I. With your Consent.
Other than as set out above, we may also share your personal information and your other information for additional purposes with your consent or at your direction.
DATA TRANSFERS
LIFELENZ uses appropriate data transfer mechanisms and protection measures. The personal information (or "personal data") we collect from you will be stored in the US and in the European Economic Area ("EEA"), and it may be transferred to a destination outside the EEA or the UK, namely to theUS. You acknowledge the transfer to, and storing or processing outside of theEEA or UK of your personal information as set out in this Privacy Policy.
LIFELENZ complies with theEU-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. LIFELENZ 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 and the United Kingdom in reliance on theEU-U.S. DPF and the UK Extension to the EU-U.S. DPF. LIFELENZ has also 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 theSwiss-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, thePrinciples shall govern. For more information about the Data Privacy Framework(DPF) Program and to view our certification, please visit https://www.dataprivacyframework.gov/.
In compliance with the EU-U.S.DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, LIFELENZ commits to resolving DPF Principles-related complaints about our collection and use of personal data. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on theEU-U.S. DPF, the UK Extension to the EU-U.S. DPF, or the Swiss-U.S. DPF should first contact LIFELENZ at: privacy@lifelenz.com. If you do not receive timely acknowledgment of your inquiry or complaint, or if we have not addressed your inquiry or complaint, please contact your local data protection authority(DPA), the UK Information Commissioner's Office (UK ICO), or the Swiss FederalData Protection and Information Commissioner (FDPIC). We will work with them to resolve the concerns. In certain circumstances, the EU-U.S. DPF Principles provide the right to invoke binding arbitration to resolve complaints not resolved by other means.
In compliance with the EU-U.S.DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, LIFELENZ commits to cooperating and complying respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK InformationCommissioner's Office (ICO), and the Swiss Federal Data Protection andInformation Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S.DPF, the UK Extension to the EU-U.S. DPF, or the Swiss-U.S. DPF.
LIFELENZ is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf. LIFELENZ complies with the EU-U.S. DPFPrinciples for onward transfers of personal data, including the onward transfer liability provisions.
The Federal Trade Commission has jurisdiction over LIFELENZ's compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, LIFELENZ maybe required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Cookies and Similar Tracking Technologies
We and our service providers use cookies and other related technologies to receive and store certain types of information whenever you interact with us or use our Services through your computer or mobile device.
A. Cookies.
We may use and allow others to use cookies, web beacons, pixels, local shared objects, device identifiers, and other similar technologies ("Cookies”) to collect information about you. We use this information to improve your experiences when you interact with us.You have control over some of the data we collect from Cookies and how we use it. You may learn more about Cookies and how to manage them athttps://www.allaboutcookies.org/
Please note that even if you elect not to enable Cookies or interest-based advertising and marketing, you may still receive advertisements, they just won't be tailored to your interests. Also, if you elect to receive Cookies and later delete them, use a different browser, update your systems, or use a different device, you may need to renew your choices.
B. Do Not Track.
Like most other companies, LIFELENZ is not currently configured to respond to browser "Do NotTrack" signals because, at this time, no formal "Do Not Track"standard has been adopted.
C. Social Media Features.
LIFELENZ or our authorized third parties may use social media features to gather certain information about you.These features may collect your IP address, log which pages you are visiting, and may set a Cookie to enable features to function properly. Your interactions with these social media features are governed by the privacy policies and practices of the providing company and not by LIFELENZ.
SECURITY OF YOUR INFORMATION
We provide reasonable andappropriate security measures in connection with securing your personalinformation.
Keeping your personal informationsafe is important to us. We have implemented measures designed to secure yourpersonal information from accidental loss and from unauthorized access, use,alteration and disclosure. At LIFELENZ, we:
• Work to review and update oursecurity practices and implement accepted methods to protect your personalinformation.
• Store personal information onour secure servers behind firewalls and securely transmit such.
• Transmit, store, protect, andaccess all cardholder information in compliance with the Payment CardIndustry's Data Security Standards (PCIDSS). Payment transactions are encryptedusing SSL or other encryption technology, or will use our third-party paymentprocessors, who will use appropriate security procedures.
• Comply with applicable laws andsecurity standards.
• Train applicable employees andcontractors on data privacy and require them to safeguard your data.
Your communications containingpersonal information may be unlawfully intercepted or accessed by third partiesand our Site may be subject to network attacks or malfunctions. We cannot anddo not guarantee the security of any information transmitted over the Internet.Once we receive your personal information, we take steps that we believe arereasonable to limit access to your personal information to only those employeesand service providers whom we determine need access to the personal informationto provide the requested Services, offers or opportunities that may be ofinterest to you or that you have ordered, or that we may otherwise disclose.However, even after we receive your personal information, we cannot and do notguarantee that your personal information will not be accessed, disclosed,altered, or destroyed as a result of a breach of our security efforts or as aresult of any other event beyond our reasonable control. Accordingly, we cannotand do not guarantee that your personal information or any other information iscompletely secure and safe from any risk.
The safety and security of yourinformation also depends on you. Where we have given you (or where you havechosen) a password for access to certain of our Services (such as our Sites oryour customer account), you are responsible for keeping this passwordconfidential. You should not share your password with anyone. We urge you to becareful about giving out information in public areas, like message boards orsocial media.
Unfortunately, the transmissionof information via the internet is not completely secure. Although we do ourbest to protect your personal information, we cannot guarantee its securityduring transmission to us. Any transmission of your information to us is atyour own risk. LIFELENZ is not responsible for circumvention by a third partyof any privacy settings or security measures.
YOUR DATA ACCESS RIGHTS
You may have the right toexercise certain data protection rights regarding your personal information.
LIFELENZ will not discriminateagainst you for exercising your privacy rights.
A. Responses from LIFELENZ.
We respond to all requests fromindividuals regarding the exercise of their data protection rights inaccordance with applicable data protection laws. While your data protectionrights may vary depending on your location, they generally include:
● Accessing, correcting,updating, or requesting deletion of your information,
● Objecting to or asking us torestrict the processing of your information,
● Requesting the portability ofyour information and providing the same in a timely manner and at no charge;
● Electing whether or not toreceive marketing communications from us, and
● Withdrawing your consent at anytime for us to collect, process, store, or share your information (noting thatsuch withdrawal will not affect the lawfulness of any processing that weconducted prior to your withdrawal, nor will it affect otherwise lawfulprocessing or storage).
Please see Section 10 foradditional regional and country considerations.
B. Data Controller.
LIFELENZ is considered to be a“controller” of your information under certain data privacy regulations. It ispossible that other entities may also act as controllers of your information,and you should contact them if you have any questions about how they use yourinformation.
ADDITIONAL REGIONAL/ COUNTRY PRIVACY CONSIDERATIONS
We operate in many differentcountries and regions. Our Statement sets out the privacy principles andprocedures we adhere to globally, but specific laws may apply to you based onthe country or region in which you are located.
LIFELENZ has adopted a globalapproach on privacy with the intent of providing individuals with strongprivacy protections regardless of where they reside. We recognize and implementhigh standards for privacy rights compliance on a global scale. Listed below,you can find additional privacy provisions that may be relevant to yourspecific country or region.
If you have any questions orconcerns regarding the privacy provisions relevant to you, or you wish toexercise any of these rights, please contact our Privacy Officer by using thecontact information provided in Section 12 “How to Contact Us.”
A. Australia:
Controlling law: AustraliaPrivacy Act of 1988
Australia Privacy Rights: If youare located in Australia, you have the following rights with respect to yourpersonal information:
• right to know why personalinformation is being collected, how it will be used and who it will bedisclosed to,
• right to not identify oneself,or use a pseudonym in certain circumstances,
• right to access personalinformation,
• right to stop receiving directmarketing,
• right to correct personalinformation, and
• right to make a complaintagainst a subject entity that mishandled your personal information.
B. Canada:
Controlling law: PersonalInformation Protection and Electronic Documents Act (PIPEDA)
Canada Privacy Rights: You canexercise your rights of access and rectification by contacting us. Depending onyour province, you may have additional rights, including the right to controlthe dissemination of your personal information, the right to data portability,the right to be informed of and submit observations regarding automateddecision-making, and the right to request information about data processing.
You also have the right to file acomplaint with the Office of the Privacy Commissioner of Canada or your localprivacy commissioner.
C. European Union (EU), UnitedKingdom (UK), Switzerland (CH) and European Economic Area (EEA):
Controlling laws: The GeneralData Protection Regulation (Regulation (EU) 2016/679) (GDPR), UK The DataProtection Act 2018 (UK GDPR), Swiss Federal Act on Data Protection.
Legal Bases for Processing EU, UKCH, EEA personal data: Applicable law and policies require LIFELENZ to have a“legal basis” for the processing of your personal data. The applicablelegal basis often depends on the types of data and the specific context inwhich it is processed. Where the GDPR and similar laws apply, we typically relyon performance of a contract, our legitimate business interests, or yourconsent as our primary legal bases to process your personal data.
EU, UK, CH, EEA Privacy Rights:If you are located in these regions listed, you have the following rights withrespect to your personal data. You may contact us if you wish to exercise anyof these rights:
• The right to access yourpersonal data;
• The right to update yourpersonal data by emailing us or, where appropriate, amending the personaldetails contained in your registered account with us. If practically possible,we will make corrections (where appropriate) based on your updated information;
• The right to withdraw yourconsent with respect to data that is collected on the basis of your consent;
• The right to request erasure ofyour data or object to its processing;
• The right to data portability;and
• The right to lodge a complaintwith us or with a supervisory authority.
D. United States (US):
Controlling Law: There are manyUS state-specific privacy laws with new ones coming into effect every year. Asa company with operations based in California and because California’s privacyprotections are viewed by many to be the most comprehensive in the US, we referUS-based individuals to the California Consumer Privacy Act of 2018 (“CCPA”),and as of January 1, 2023, the California Privacy Rights Act of 2020 (“CPRA”),for personal information protection.
Our Processing of US PersonalInformation: LIFELENZ collects and has collected in the last 12 monthsall of the information described in Section 3 of our Privacy Statement from andabout US residents. You should refer to that section for more detail, but thisinformation generally falls into the categories listed in the chart in Section3 to the extent it is personally identifiable. The chart also indicates thedata subjects whose personal information we collect, the purposes ofprocessing, and the categories of third parties to whom we recently disclosedthe data leading up to the effective date of this Statement.
LIFELENZ does not receive anymonetary compensation for data it shares with vendors or service providers.LIFELENZ shares or “sold” (as that term is defined under applicable US privacy regulations)“identifiers” (like IP addresses), “internet or other electronic networkactivity information” (like information regarding an individual’s browsinginteractions on a website), and “commercial information” (like the fact that abrowser visited our webpage,) to third parties that assist us, such asmarketing or analytics providers.
US Privacy Rights: Underapplicable US law, you have the right to:
• Request access to your personalinformation as it is processed and stored by us;
• Correct or delete your personalinformation that we hold unless LIFELENZ is legally required to retain it;
• Restrict or object to ourprocessing of your personal information;
• Lodge a complaint; and
• Opt out of “sale” of yourpersonal information.
Marketing opt-out: Use the “YourPrivacy Choices” link in the footer of LIFELENZ Sites, click on the “opt-out”option to opt out of sharing and sales of your personal information, whichincludes any sharing of your information for targeted advertising. As analternative to using the link referenced above, you may call +1 8559555885 tosubmit your request.
Cookies and online trackeropt-out: If you would like to opt-out of CPRA “sales or sharing” that happenthrough Cookies and related technologies, follow the steps below on eachLIFELENZ Site you use:
Click the cookie icon in thebottom left corner of the Site and select the “Reject All” option.
Please note, you must repeat thisprocess for each device and browser that you use to access LIFELENZ Sites.
Contact: Please contact us formore information or to exercise a request regarding your US privacy rights. If you are concerned about LIFELENZ’s compliance with US laws relating tothe privacy of your personal information, you may contact your AttorneyGeneral’s Office.
CHANGES TO OUR PRIVACY STATEMENT
We may make changes to ourPrivacy Statement or our supporting privacy procedures at any time.
From time to time, we may changeor update this Privacy Statement. We reserve the right to make changes orupdates at any time and without prior notice to you.
If we make material changes tothe way we process your personal information, we will provide you notice byposting the most current version of this Statement on our Sites and we may alsoadvise you of changes via our Services information, or by other communicationchannels, such as by email, newsletters or community post. Please review anychanges carefully.
If you object to any changes andno longer wish to use our Services, you may close your accounts and cease useof our Services. All changes to our Statement are effective immediately upon posting and your continued interaction with us or your use of our Services after a posting of an updated Statement constitutes your consent to all changes.
HOW TO CONTACT US
If you have questions or commentsabout this Statement, you may contact us by email, direct mail or phone.
A. Email privacy@LIFELENZ.com is thefastest and most-preferred way to reach us with your data management orprivacy-related questions and concerns.
B. Via Direct Mail:
LIFELENZ
Attn: Privacy Officer
Level 7, 200 Massachusetts Ave,NW Washington, DC 20001
C. Via Phone: +1 8559555885