EU-U.S. AND SWISS-U.S. PRIVACY SHIELDS
This Privacy Shield Policy (this “Policy”) applies to personal information transferred to New Frontier Group, Inc. (New Frontier Group) in the United States from organizations subject to data protection law in the European Economic Area (EEA) (which includes the member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland. This Policy sets out our practices for collecting, using, maintaining, protecting and disclosing that personal information.
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, New Frontier Group or to which New Frontier Group discloses personal information for use on New Frontier Group’s behalf.
“New Frontier Group” means New Frontier Group, Inc. and any of its predecessors and successors in the United States.
“Personal information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal information does not include information that is anonymized or aggregated.
“Sensitive information” means any personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information that concerns health or sex life, and information about criminal or administrative proceedings and sanctions.
EU-U.S. AND SWISS-U.S. PRIVACY SHIELD PRINCIPLES
New Frontier Group participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from organizations subject to data protection law in the EEA and Switzerland to the United States, respectively. New Frontier Group has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms of this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view New Frontier Group’s certification, visit https://www.privacyshield.gov/.
New Frontier Group receives data from its customers, international insurers and assistance teams, healthcare providers and its customers’ policyholders. Some of this data includes personal information about individuals in the EEA and Switzerland, which may include basic contact information like name, address and phone number, date of birth, billing information, and medical information. New Frontier Group uses this information to provide case management services for critical injuries, urgent care clinic solutions, pharmacy concierge services, claim resolution services, and customer service to its customers in the travel industry’s global healthcare management services and policyholders.
New Frontier Group will subject all personal information received via the Privacy Shield to the EU-U.S. and Swiss-U.S. Privacy Shield Principles. New Frontier Group is subject to the investigative and enforcement authority of the Federal Trade Commission (FTC). New Frontier Group may be required to disclose personal information in response to lawful requests by public authorities. New Frontier Group has potential liability for onward transfers to third parties. Additionally, an individual may be allowed to invoke binding arbitration to resolve disputes under certain limited conditions.
New Frontier Group will offer EEA and Swiss individuals whose personal information has been transferred to us the opportunity to choose whether the personal information it has received is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal information by contacting us at the address given below.
New Frontier Group will not use sensitive personal information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless New Frontier Group has received the individual’s affirmative and explicit consent (opt-in).
Data Integrity and Purpose Limitation
New Frontier Group will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. New Frontier Group will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.
Transfers to Agents
New Frontier Group may disclose personal information to Agents, including but not limited to, providers of analytical, hosting, payment processing and other support services. Agents may have access to personal information if needed to perform their functions for New Frontier Group. New Frontier Group does not transfer personal information to non-Agent third parties.
New Frontier Group will require its Agents to safeguard personal information consistent with this Policy by contract obligating the agent to provide at least the same level of protection as is required by the EU-U.S. and Swiss-U.S. Privacy Shield Principles. Under certain circumstances, New Frontier Group may bear liability for onward transfers of personal information from the EEA where its Agent processes personal information inconsistent with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, unless New Frontier Group proves that it is not responsible for the event giving rise to the damages.
Access and Correction
New Frontier Group will grant individuals reasonable access to personal information it received pursuant to these Principles. In addition, New Frontier Group will take reasonable steps to permit individuals to correct, amend, or delete such information that is demonstrated to be inaccurate or incomplete. An individual may request to access his or her information, or otherwise correct, amend, or delete his or her information pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield Principles by contacting us at the address given below.
New Frontier Group will take reasonable and appropriate precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
New Frontier Group will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that New Frontier Group determines is in violation of this policy will be subject to disciplinary action.
Dispute Resolution – Privacy Shield
In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, New Frontier Group commits to resolve complaints about your privacy and our collection or use of your personal information. EEA or Swiss individuals with inquiries or complaints regarding this Policy should first contact New Frontier Group at the address given below. New Frontier Group will investigate and attempt to resolve complaints regarding use and disclosure of personal information by reference to the principles contained in this Policy.
New Frontier Group has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, JAMS Privacy Shield Program, operated by JAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shieldfor more information and to file a complaint.
Under certain limited conditions, an individual may be able to invoke binding arbitration as provided under the Privacy Shield to address an otherwise unresolved complaint.
Questions regarding this Policy should be submitted to New Frontier Group:
ATTN: Chief Operating Officer
27442 Portola Pkwy Suite 350,
Foothill Ranch, CA 92610
LIMITATIONS & CHANGES
Adherence by New Frontier Group to the EU-U.S. and Swiss-U.S. Privacy Shield Principles may be limited (a) by the exception for personal information that is gathered for publication, broadcast, or other forms of public communication of journalistic material as well as information found in previously published material disseminated from media archives; (b) to the extent required to respond to a legal obligation; (c) to the extent necessary to respond to requests by authorities; and (d) to the extent expressly permitted by an applicable law, rule or regulation.
This Policy may be amended from time to time, consistent with the requirements of the EU-U.S. and Swiss-U.S. Privacy Shield Principles. The amended Policy will be made publicly available via New Frontier Group’s website.