How Personal Information May Be Disclosed

Your Personal Information may be disclosed or transferred:

• Except as set forth below, we do not sell or share Personal Information with third parties for their own separate use. Rather, data may be shared with third-parties retained by Willis Towers Watson for purposes of fulfilling their obligations to Willis Towers Watson only.
• To vendor partners selected by the plan sponsor to allow them to provide you with services associated with your benefits. Use of your Personal Information by vendor partners is governed by the privacy policies of the plan sponsor or the vendor partner and not this Privacy Notice.
• To our third party service providers who provide services, such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, and auditing and other services.
• To anyone you identify or to anyone to whom you send messages through the Services.
• To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
• As we believe to be necessary: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) as required by law; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, including you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER INFORMATION

Other Information We May Collect

"Other Information" is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

• Browser and device information
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you
• Aggregated information

If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Notice.

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

• Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.


• Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information, such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Services and to recognize your computer in order to assist with your use of the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies to track responses to our online advertisements. If you disable cookies on the site, the site may not function properly.


• Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.


• Analytics. We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.


• IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate location from your IP address.


• From you: Information such as your preferred means of communication is collected when you voluntarily provide it.


• By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information (such as combining your name with your location). If we do, we will treat the combined information as Personal Information as long as it is combined.

If you have provided us with Personal Information, we may associate that information with the information about your usage of our site that is collected automatically.

THIRD PARTY SERVICES

We may include links in the Services to websites for third-parties, such as government agencies and financial service 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.

SECURITY

We seek to use reasonable organizational, physical, technical and administrative measures to protect Personal Information within our organization against loss, misuse, alteration, disclosure, destruction, theft, or unauthorized access, copying, use, alteration, destruction, or disclosure. 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.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

By agreeing with this Privacy Notice, you are providing us with consent to collect, process, use, and disclose your Personal Information in accordance with the terms of this Privacy Notice.

Our standard process for many communications is to send information regarding your benefits and other communications electronically via email or our online portal. You may request to receive communications by paper mail in accordance with the "Contacting Us" section below.

How you can access, change or suppress your Personal Information

If you would like to review, correct, update, suppress or delete Personal Information that we may be processing as a service provider, you may do so by contacting your Human Resources contact or accessing your employer’s online benefits portal. Please use the features or phone number available to you on the Site. 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 set out under applicable law. If you think any of the information we hold about you is inaccurate, you may also request a correction. To exercise these rights, please email or write to us at the address set out in in the "Contacting Us" section of this Privacy Notice. You may also contact us at as referenced below.

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

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 set out under applicable law. If you think any of the information we hold about you is inaccurate, you may also request a correction. To exercise these rights, please email or write to us at the address set out in in the "Contacting Us" section of this Privacy Notice.

If you are a resident of California, under 18, and a registered user of the Services, you may ask us to 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.

RETENTION PERIOD

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 or permitted by law.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of thirteen (13), and we request that they 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 13, except that we do collect information regarding dependent children that pertains to their benefits coverage and to beneficiary designations. Parents and legal guardians are permitted to provide us with information about their children.

CROSS-BORDER TRANSFER

Your Personal Information may be collected, stored, and processed in any country where we have facilities or in which we engage service providers. By using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have laws and data protection rules that are different from those of your country. While your information is in another jurisdiction, it may be accessed by the local courts, law enforcement, and national security authorities. To receive information regarding our policies and procedures with respect to service providers in different countries, please email or write to us at the address set out in in the "Contacting Us" section of this Privacy Notice.

SENSITIVE INFORMATION

We ask that you not send us, and not disclose, any sensitive Personal Information (e.g., social security number, social insurance number, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, 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. The "LAST UPDATED" legend at the top of this page indicates when this Privacy Notice was last revised. Any changes will become effective when we post the revised Privacy Notice. Your use of the Services following these changes means that you accept the revised Privacy Notice. We strongly encourage you to refer to this Privacy Notice often for the latest information about our personal information practices.

CONTACTING US

If you have any questions about this Privacy Notice, or how your Personal Information may be used or disclosed, please contact us at eepoint@willistowerswatson.com. 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 inquires, refer to the Contact Us information available on this website or customer service contact information provided by your Plan Sponsor.