Outsourcing Privacy Notice
THIS NOTICE DESCRIBES HOW PERSONAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN CONTACT US. PLEASE REVIEW IT CAREFULLY.
WHO WE ARE
Willis Towers Watson, our affiliated entities, and successors in interest ("Willis Towers Watson," "we," "our," or "us") provide benefits enrollment, benefits administration, and pension administration services, including the creation and hosting of websites (collectively, the "Services"), on behalf of employers who offer healthcare, retirement, or similar employee benefit plans. Andersen Corporation, as your employer and the Plan Sponsor for the benefits you are eligible for (collectively, the “Plan Sponsor”), has hired Willis Towers Watson to provide this website and other benefits administration services. Willis Towers Watson cares about your privacy and wants you to be familiar with how we collect, use, and disclose information. We use Personal Information to determine your benefit eligibility and validate any election information that is submitted through the application.
This Privacy Notice describes our practices in connection with information that we collect through this website; telephone service center; employer data import files; other third-party import files approved by the Plan Sponsor; mobile devices; and HTML-formatted email messages that may be sent to you. By providing Personal Information to us, you agree to us using that information in accordance with this Privacy Notice.
SCOPE AND PURPOSE OF THIS NOTICE
Willis Towers Watson is committed to privacy and transparency in our information practices. This Privacy Notice describes how we receive, collect, process, and share your personal information when providing the Services, which include, but are not limited to, this website, our telephone service centers, data import files that we receive from the Plan Sponsor, other third-party import files approved by the Plan Sponsor, and electronic communications such as HTML-formatted email messages that may be sent to you.
This Privacy Notice describes our overall privacy and data protection practices related to the Services. Our exact practices will depend on and will always be limited by the terms of our contract with the Plan Sponsor.
OUR ROLEWhen providing the Services, Willis Towers Watson acts as a “data processor” or “service provider” under applicable privacy and data protection laws. This means that we will only process the Personal Information we collect about you through the Services on behalf of and subject to the limitations and instructions that we receive from the Plan Sponsor. If our contract with our client is more restrictive than the terms of this Privacy Notice, the more restrictive contract terms will apply, including to your Personal Information.
The Plan Sponsor is the responsible "controller" or "business" under applicable privacy laws with respect to your Personal Information. Except as set forth herein, the Plan Sponsor’s privacy notices (and not this one) will apply to and control the processing of Personal Information. Please contact the Plan Sponsor for more information regarding its data protection practices and/or review their privacy notice for more information.
"HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION "Personal Information" is information that identifies you as an individual or relates to an identifiable person, including, but not limited to:
The information we collect is provided by the Plan Sponsor to confirm whether you, your spouse/domestic partner, and your dependents are eligible for benefits. You may be asked to provide additional information about yourself, your spouse/domestic partner, your dependents, and beneficiary designations. You may also be asked to update or correct information about yourself, your spouse/domestic partner, or your dependents. As between you and us, you own your identifiable Personal Information and any identifiable Personal Information of your dependents and your spouse/domestic partner, although you agree that we may de-identify and aggregate it as provided elsewhere in this Privacy Notice.
To the extent you submit Personal Information relating to other people to us in connection with the Services, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Notice and applicable laws.
How We May Collect Personal Information
We and our service providers may collect Personal Information in a variety of ways, including:
HOW WE MAY USE PERSONAL INFORMATION
In general, we use personal information that we collect about you to provide the Services (for example, to determine your benefit eligibility, validate election information, and otherwise facilitate your enrollment) and to comply with legal obligations. In addition, to the extent permitted by our agreement with the Plan Sponsor, we may use Personal Information:
Any references in this Privacy Notice to an agreement with the Plan Sponsor or similar language refers to the Group Marketplace Master Program Agreement between us and Plan Sponsor dated March 11, 2019, as it may be amended from time-to-time, including the Business Associate Agreement referenced therein. We will use Personal Information consistent with our obligations in the agreement with the Plan Sponsor and consistent with additional protections that we have or may agree upon in writing, from time to time, with the Plan Sponsor.
HOW PERSONAL INFORMATION MAY BE DISCLOSED
To the extent permitted by our agreement with the Plan Sponsor, we may disclose your Personal Information:
Our website may use first-party and third-party cookies and similar technology to gather device and usage information when users visit the website. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the website, and to recognize your computer to assist your use of the website. We also gather statistical information about use of the website to improve design and functionality and understand how the website is used. We do not use advertising cookies on the website.
There are different types of cookies, for example:
Strictly Necessary Cookies. Strictly necessary cookies enable you to navigate the website and to use their services and features. Without these necessary cookies, the website will not function properly and we may not be able to provide the website or certain services or features.
Functional Cookies. Functional cookies enable the website to provide enhanced functionality and personalization. They allow us to see the overall patterns of usage on the website. We use the information to analyze traffic on and improve the website. They may be set by us or by third party providers whose services we have added to our pages. Without these cookies, some or all of these services may not function properly.
Performance Cookies. Performance cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. Without these cookies, we will not know when users have visited our site and will not be able to monitor its performance.
We may use the following cookies for our site:
|Description or Purpose
|Persistent or Session
|1st or 3rd Party Cookie
|Session Cookie - Typical naming pattern: [SystemName]Ess
|Unique Identifier, identifying user's session
|Authorization Cookie - Typical naming pattern: AuthId
|Unique Identifier, identifying user's session
|Verification Token - Typical naming pattern: __RequestVerificationToken_[UniqueIdentifier]
|Unique Identifier, identifying user's session
|Network Load Balancing Cookie - Typical naming pattern: F5-cookie
|Identifier used to route user traffic to specific resource
|Culture Code - Typical naming pattern: [SystemName]_CultureCode
|User mobile or full site selection
|Google Captcha - various naming patterns
|Persistent with expiration
|Third-party initiated Single Sign On
|Application performance monitoring
|Application trend and usage monitoring
You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. Information about the procedure to follow to enable or disable cookies can be found on your Internet browser provider's website via your help screen.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org, www.allaboutcookies.org, or www.youronlinechoices.eu.
We may include links in the Services to websites for third parties, such as government agencies, carriers, and health and wellness providers. When you access these links, you will be leaving the Services and your usage of those third-party sites will be governed by the privacy policies of such third parties, not by this Privacy Notice. This Privacy Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or service to which the Services may link. The inclusion of a link on the Services does not imply endorsement of the linked site or service, by us or by our affiliates.
We have implemented industry standard organizational, technical, and administrative measures to protect Personal Information we collect or receive. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the "Contacting Us" section below.
YOUR DATA PRIVACY RIGHTS
You may have a legal right to review, correct, update, or delete personal information pursuant to applicable privacy and data protection laws. As indicated above, Willis Towers Watson acts as a “data processor” or “service provider” under applicable privacy and data protection laws. For this reason, the Plan Sponsor, not Willis Towers Watson, may be legally responsible for fulfilling any legal rights requests you might have. Regardless, if we receive a rights request, we will pass it on to the Plan Sponsor and follow the instructions of the Plan Sponsor related to your rights request.
Data may be accessed and, in some cases, corrected through our self-service website. You may also be able to access data and make data corrections through a toll-free telephone number established for the purpose of administering your benefits. If you do not want to, or you are unable to, self-serve through our website or the toll-free telephone number (if any) established for the purpose of administering benefits, you may exercise your rights by contacting the Plan Sponsor subject to applicable law.
If you reside in Canada, you have the right to request access to any additional information that we hold about you subject to limited exceptions under applicable law. If you believe that any information that is held about you is inaccurate, you may also request a correction.
If you are a resident of California, under 18, and a registered user of the Services or are otherwise permitted by applicable law, you may ask us to, and to the extent that we are required, we will remove content or information that you have posted to the Services in accordance with the "Contacting Us" section below. Please note that your request does not ensure complete or comprehensive removal of the content or information; for example, some of your content may have been reposted by another user.
Applicable privacy and data protection law may limit the fulfillment of a rights request. For example, the Plan Sponsor may limit a rights request so that it can retain certain information for recordkeeping purposes and/or to complete any transactions that began prior to the request for a change or deletion.
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required by law or permitted by our agreement with the Plan Sponsor. All Personal Information will be deleted at the time specified and in accordance with our agreement with the Plan Sponsor.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of sixteen (16), and we request that individuals under age 16 not provide personal information through the Services.
Because of the nature of our business, we do not solicit or intentionally receive information from children under the age of 16, except that we do collect information regarding dependent children that pertains to their benefits coverage and to beneficiary designations.
We are a global provider of services and have operations across the world. As such, for other customers, we generally may store and process Personal Information in any country where we have facilities or in which we engage service providers. Currently, however, our agreement with the Plan Sponsor only allows us to store your Personal Information in the United States, and to access your Personal Information in both the United States and the Philippines. We will comply with those restrictions unless our agreement with the Plan Sponsor changes to allow processing of Personal Information in other countries. Because our agreement with the Plan Sponsor may change in the future, by using the Services after an update to this Privacy Notice reflecting such additional country(ies) as provided in “Updates to this Privacy Notice” below and providing us with your Personal Information, you consent to the transfer of your Personal Information to countries outside of the United States, which may have data protection laws different from those of your country, but only to the extent permitted by our agreement with the Plan Sponsor.
We ask that you not send us, and you not disclose, any Personal Information we do not request (for example, information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
UPDATES TO THIS PRIVACY NOTICE
We may change this Privacy Notice to the extent reasonably necessary: (1) to reflect our business or process changes that are consistent with our agreement with the Plan Sponsor; (2) to provide different or additional services to you and/or the Plan Sponsor, consistent with our standard practices, that are agreed in writing with the Plan Sponsor and consistent with our agreement(s) with the Plan Sponsor; (3) to reflect changes that are otherwise agreed in writing with Plan Sponsor and consistent with our agreement(s) with the Plan Sponsor; or (4) to comply with applicable law. The "Last Updated" legend at the top of this page indicates when this Privacy Notice was last revised. Any changes consistent with this paragraph will become effective when we post the revised Privacy Notice.
INFORMATION FOR CALIFORNIA RESIDENTS
In providing the Services, we do not “sell” any personal information under the California Consumer Privacy Act (CCPA).
If you wish to submit a consumer rights request under the CCPA, please do so through the Plan Sponsor. We will cooperate with and facilitate these requests to the extent required by law or requested by Plan Sponsor.
If you have any questions about this Privacy Notice, how your Personal Information may be used or disclosed, or are directed to contact us as noted elsewhere in this Privacy Notice, please contact us at email@example.com, or call toll-free at 888-471-4502.
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
For all other inquiries, refer to the Contact Us information available on this website or customer service contact information provided by your Plan Sponsor.
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