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WHAT CAN WE HELP YOU FIND?
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GLOBAL WEBSITE PRIVACY NOTICE
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Last Updated: October 2021
Willis Towers Watson operates worldwide through subsidiary and affiliate
companies. We are committed to privacy and to transparency in our information
practices. In this privacy notice, we describe our collection, use, disclosure
and processing of personal information that we collect online via our websites,
as well as related to our products and services.
OVERVIEW OF OUR COLLECTION AND USE OF PERSONAL INFORMATION
This overview is intended to summarize key information about our information
practices, which are further explained below. (Go directly to full privacy
policy.) While the actual information we collect and our use of such personal
information varies depending upon the nature of our relationship and
interactions, the table below provides a general overview of the categories of
personal information we collect and the purposes for which we use such
information.
Categories of personal information we collect Name, contact information and
other identifiers: identifiers such as a real name, alias, address, unique
personal identifier, online identifier, Internet Protocol (IP) address, email
address, account name, social security number, driver’s license number, passport
number, or other similar identifiers. Customer records: paper and electronic
customer records containing personal information, such as name, signature,
physical characteristics or description, address, telephone number, education,
current employment, employment history, social security number, passport number,
driver’s license or state identification card number, insurance policy number,
bank account number, credit card number, debit card number, or any other
financial or payment information, medical information, or health insurance
information. Protected classifications: characteristics of protected
classifications under California or federal law such as race, color, sex, age,
religion, national origin, disability, citizenship status, and genetic
information. Commercial Information: including records of real property,
products or services purchased, obtained, or considered, or other purchasing or
use histories or tendencies. Usage data: internet or other electronic network
activity Information including, but not limited to, browsing history, search
history, and information regarding a consumer’s interaction with an Internet
website, application, or advertisement. Geolocation data: precise geographic
location information about a particular individual or device. Biometric
information: physiological, biological or behavioral characteristics that can be
used alone or in combination with each other to establish individual identity,
including DNA, imagery of the iris, retina, fingerprint, faceprint, hand, palm,
vein patterns, and voice recordings, keystroke patterns or rhythms, gait
patterns or rhythms, and sleep, health, or exercise data that contain
identifying information. (to the extent permitted and subject to applicable
laws) Audio, video and other electronic data: audio, electronic, visual,
thermal, olfactory, or similar information such as, CCTV footage, photographs,
and call recordings. Employment history: professional or employment-related
information. Education information: education information and records. Profiles
and inferences: Inferences drawn from any of the information identified above to
create a profile reflecting a resident’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, or aptitudes.
How we use personal information Providing support and services and operating our
websites Analyzing and improving our business Personalizing content and
experiences Advertising, marketing and promotional purposes Securing and
protecting our business Defending our legal rights Auditing, reporting,
corporate governance, and internal operations Complying with legal obligations
Individual rights. Please see the Individual Rights and Choices section below
for a description of the choices we provide and the rights you have regarding
your personal information. If you are a California resident, please be sure to
review the section Additional information for California Residents below for
important information about the categories of personal information we collect
and disclose and your rights under California privacy laws.
1. SCOPE
This privacy notice describes, generally, how Willis Towers Watson, in our
capacity as a “controller” or a “business” or a “responsible party” under
applicable laws, handles and processes personal information related to:
* the use of our websites and associated services that link to this privacy
notice, including www.willistowerswatson.com (the “Homepage”) and other
websites controlled by Willis Towers Watson (collectively, the “Websites”)
* our former, current and prospective clients
* individuals who communicate with us
* individuals who use our products and services (“Services”) and individuals
whose personal information we receive in providing the Services
Our collection, use and disclosure and processing of personal information about
individuals will vary depending upon the circumstances. This privacy notice is
intended to describe our overall privacy and data protection practices. In some
cases, different or additional notices about our data collection and processing
practices may be provided and apply to our processing of certain personal
information.
Personal information. In this privacy notice, our use of the term “personal
information” includes other similar terms under applicable privacy laws—such as
“personal data” and “personally identifiable information.” In general, personal
information includes any information that identifies, relates to, describes, or
is reasonably capable of being associated, linked, or linkable with a particular
individual.
In South Africa only, “personal information” also includes information of
juristic persons, the most common example being a company.
Not covered by this notice. This privacy notice does not apply to job applicants
and candidates who apply for employment with us through our job application
portal or to our employees and non-employee workers whose personal information
is subject to different privacy notices which are provided to such individuals
in the context of their employment or working relationship with a Willis Towers
Watson group entity.
2. CONTROLLER AND RESPONSIBLE WILLIS TOWERS WATSON GROUP ENTITIES
When providing Services to clients, Willis Towers Watson may act as a “service
provider” or “processor” or “operator” under applicable privacy and data
protection laws. This means that we may receive or collect your personal
information from or on behalf of our client. In this scenario, we will only
process personal information on behalf of and subject to the instructions of our
clients (who, from a privacy law perspective, are “controllers” or “businesses”
or “responsible parties” with respect to the personal information we process on
their behalf). In some cases, where we are acting as a “service provider” or
“processor” or “operator,” our clients’ privacy notices (and not this one) will
apply to and control the processing of personal information. If you have any
questions which privacy notice may apply, please contact us as at
privacy@willistowerswatson.com.
Where we act in our capacity as a controller or business or responsible party
with respect to personal information, for the purposes of the GDPR and other
relevant applicable laws, including but not limited to the Cayman Islands Data
Protection Law (“DPL”), this privacy notice will apply, as explained below.
Furthermore, Willis Towers Watson plc is the controller unless the processing is
controlled by another Willis Towers Watson entity.
Our Websites. The Websites are controlled by Willis Towers Watson plc, unless a
Website identifies (in its terms of use or otherwise) that it is controlled by
another Willis Towers Watson entity. Willis Towers Watson group companies (as
well as individual divisions of Willis Towers Watson) may have their own
websites with their own privacy notices, in which case this privacy notice will
not apply to such websites unless such website provides a link to this privacy
notice.
Websites and specific web pages linked to, or from, www.willistowerswatson.com
may be subject to separate terms of use (including separate privacy notices,
separate cookies notices and separate cookies preference managers that you can
access and review on those websites). The inclusion of a link to a third-party
website does not imply endorsement of the linked site or service by us or our
affiliates. These third-party websites will be governed by different terms of
use (including privacy notices) and you are solely responsible for viewing and
using each such website in accordance with the applicable terms of use. Willis
Towers Watson is not responsible for how your personal information is handled by
such third-party websites.
Services and other activities. With respect to our Services and other business
activities, in general, the Willis Towers Watson group company with whom you
engage is the controller for your personal information, together with Willis
Towers Watson plc, the parent company for the Willis Towers Watson group.
3. CROSS-BORDER TRANSFER
Willis Towers Watson is a global company and the data that we collect from you
may be transferred to, accessed, processed or stored in, and subject to requests
from law enforcement in, jurisdictions outside of your home jurisdiction,
including the United States, India, Bermuda, the European Union and other
jurisdictions, in which we or our service providers operate. Some of these
jurisdictions, including the United States, may not provide equivalent levels of
data protection as your home jurisdiction. We have established safeguards to
protect personal information that is transferred to other countries, including
appropriate contractual protections. For more information on the appropriate
safeguards in place, please contact us using the details below.
4. PERSONAL INFORMATION COLLECTED
We collect personal information directly from individuals, automatically related
to the use of the Services and Websites, and in some cases, from third parties
(such as social networks, platform providers, payment processors, and operators
of certain third-party services that we use). Generally, we collect your
personal information on a voluntary basis. However, if you decline to provide
certain personal information that is marked mandatory, you may not be able to
access certain services or we may be unable to fully respond to your inquiry.
The personal information that we collect and process will vary depending upon
the circumstances. For example, the personal information we may collect through
our Websites includes:
* your name, postal address, email address, phone number, occupation and other
contact information
* information regarding your interactions with us and related to your use of
our Websites and Services
* interests you have in relation to our Services or our practice areas
* information you may voluntarily submit to us by completing any form on our
Websites
* information about your usage of our Websites and Services
We may also collect additional personal information in providing our Services,
operating our business, and interacting with individuals in the course of our
business, which may at times include “sensitive" information (otherwise known as
“special categories of personal information” under the GDPR, such as health
records or criminal conviction data, and known as “sensitive personal data”
under the DPL such as physical or mental health or condition, medical data,
commission, or alleged commission of an offense; any proceedings for an offense
committed, or alleged to have been committed. Where required by law, we will
provide specific data processing information to you regarding how we may process
that data and what rights you may have regarding such processing.
For South Africa only:
* when you interact with us because you are receiving our Services, we will
collect your name, postal address, email address, phone number, occupation
and other contact information and the company name and address and phone
number of the company you work for so that we can do business with you.
In respect of our corporate risk and broking services and our actuarial
valuation services, where we are a responsible party, we refer you to our
separate privacy notices governing the provision of these Services available
on our website: Privacy Notice for Clients (insurance and reinsurance
services) and Valuation Services Privacy Notice (Valuator and actuarial
valuation services).
* when you interact with us through our Websites, we collect personal
information you may voluntarily submit to us by completing any form on our
Websites and information about your usage of our Websites.
Categories of sources of personal information. We may collect personal
information directly from you, as well as automatically related to your use of
our Websites and other services, as well as from third parties. For example, we
collect personal information:
* from you, either directly (i.e., through information you submit to us,
including via forms that you may complete and submit through our Websites) or
indirectly (i.e., by observing your actions on our Websites)
* from the content of surveys that you may complete;
* from 'cookies' and other similar tools deployed on parts of our Websites (for
further information regarding cookies used on our Websites, please see
Section 7 below)
* from our clients in connection with us providing professional services to
them
* from data analytics providers
* from government entities
* from service providers (i.e., companies who are assisting us in fulfilling
our contracts and carrying out our business, such as to perform mailings or
to provide customer service)
* from other sources, such as public databases, joint marketing partners,
social media platforms (including from people with whom you are friends or
otherwise connected) and from other third parties.
Categories of personal information we collect. While the personal information we
collect varies—as explained above—depending upon the nature of the services
provided or used and our interactions with individuals, we may collect the
following categories of personal information (subject to applicable legal
requirements and restrictions):
* Name, contact information and other identifiers: identifiers such as a real
name, alias, address, unique personal identifier, online identifier, Internet
Protocol (IP) address, email address, account name, social security number,
driver’s license number, passport number, or other similar identifiers
including company names and addresses where this is personal information in
your country.
* Customer records: paper and electronic customer records containing personal
information, such as name, signature, physical characteristics or
description, address, telephone number, education, current employment,
employment history, social security number, tax ID, passport number, driver’s
license or state identification card number, insurance policy number, bank
account number, credit card number, debit card number, or any other financial
or payment information, medical information, or health insurance information.
* Protected classifications: characteristics of protected classifications under
California or federal law such as race, color, sex, age, religion, national
origin, disability, citizenship status, and genetic information.
* Commercial Information: including records of real property, products or
services purchased, obtained, or considered, or other purchasing or use
histories or tendencies.
* Usage data: internet or other electronic network activity Information
including, but not limited to, browsing history, search history, and
information regarding a consumer’s interaction with an Internet website,
application, or advertisement.
* Geolocation data: precise geographic location information about a particular
individual or device.
* Biometric information: physiological, biological or behavioral
characteristics that can be used alone or in combination with each other to
establish individual identity, including DNA, imagery of the iris, retina,
fingerprint, faceprint, hand, palm, vein patterns, and voice recordings,
keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health,
or exercise data that contain identifying information (to the extent
permitted and subject to applicable laws).
* Audio, video and other electronic data: audio, electronic, visual, thermal,
olfactory, or similar information such as, CCTV footage, photographs, and
call recordings.
* Employment history: professional or employment-related information.
* Education information: education information and records.
* Profiles and inferences: Inferences drawn from any of the information
identified above to create a profile reflecting a resident’s preferences,
characteristics, psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, or aptitudes.
5. PURPOSES AND LEGAL BASES FOR PROCESSING PERSONAL INFORMATION
Certain laws, including the GDPR, require that we inform you of the legal bases
for our processing of your personal information. Pursuant to the GDPR (and other
relevant laws), we process personal information for the following legal bases:
* Performance of contract: to perform contracts that you may have with us (for
example if you use our Services)
* Compliance with laws: to comply with our legal obligations
* Our legitimate business interests: in furtherance of our legitimate business
interests including:
* to facilitate your participation in interactive features you may choose to
use on our Websites and personalize your experience on the Websites by
presenting content tailored to you
* to correspond with you, notify you of events or changes to our services, or
otherwise respond to your queries and requests for information, which may
include marketing to you
* for the purposes of providing professional services to you via Willis
Towers Watson applications; such services will be subject to additional
terms and conditions of use including privacy
* for data analysis, audits, fraud monitoring and prevention, and developing
new products, enhancing, improving or modifying our Websites, identifying
usage trends, determining the effectiveness of our promotional campaigns
and operating and expanding our business activities
* to protect and defend our legal rights and interests and those of third
parties
* With your consent: Where applicable laws require that we obtain your consent
to collect and process your personal information, we will obtain your consent
accordingly. When we obtain your consent, the GDPR (where it applies) and
other applicable laws give you the right to withdraw your consent. You can do
this at any time by contacting us using the details at the end of this
privacy notice. In some jurisdictions, your use of the Websites may be taken
as implied consent to the collection and processing of personal information
as outlined in this privacy notice.
* Medical purposes: The processing is necessary for medical purposes
(applicable to Cayman Islands DPL).
Purposes for using personal information. While the purposes for which we may
process personal information will vary depending upon the circumstances, in
general we use personal information for the purposes set forth below. Where GDPR
or other relevant laws apply, we have set forth the legal bases for such
processing (see above for further explanation of our legal bases) in
parenthesis.
* Providing support and services: including to provide our Services, operate
our Websites, applications and online services; to communicate with you about
your access to and use of our Services; to respond to your inquiries; to
provide troubleshooting, fulfill your orders and requests, process your
payments and provide technical support; and for other customer service and
support purposes. (Legal basis: performance of our contract with you; and our
legitimate interests)
* Analyzing and improving our business: including to better understand how
users access and use our Services and Websites, to evaluate and improve our
Websites, Services and business operations, and to develop new features,
offerings and services; to conduct surveys and other evaluations (such as
customer satisfaction surveys); and for other research and analytical
purposes. (Legal basis: our legitimate business interests)
* Personalizing content and experiences: including to tailor content we send or
display on our websites and other Services; to offer location customization
and personalized help and instructions; and to otherwise personalize your
experiences. (Legal basis: our legitimate business interests and/or with your
consent)
* Advertising, marketing and promotional purposes: including to reach you with
more relevant ads and to evaluate, measure and improve the effectiveness of
our ad campaigns; to send you newsletters, offers or other information we
think may interest you; to contact you about our Services or information we
think may interest you; and to administer promotions and contests. (Legal
basis: our legitimate business interests and/or with your consent)
* Securing and protecting our business: including to protect and secure our
business operations, assets, Services, network and information and technology
resources; to investigate, prevent, detect and take action regarding fraud,
unauthorized access, situations involving potential threats to the rights or
safety of any person or third party, or other unauthorized activities or
misconduct (Legal basis: our legitimate business interests and/or compliance
with laws)
* Defending our legal rights: including to manage and respond to actual and
potential legal disputes and claims, and to otherwise establish, defend or
protect our rights or interests, including in the context of anticipated or
actual litigation with third parties. (Legal basis: our legitimate business
interests and/or compliance with laws)
* Auditing, reporting, corporate governance, and internal operations: including
relating to financial, tax and accounting audits; audits and assessments of
our operations, privacy, security and financial controls, risk, and
compliance with legal obligations; our general business, accounting, record
keeping and legal functions; and related to any actual or contemplated
merger, acquisition, asset sale or transfer, financing, bankruptcy or
restructuring of all or part of our business. (Legal basis: our legitimate
business interests and/or compliance with laws)
* Complying with legal obligations: including to comply with the law, our legal
obligations and legal process, such warrants, subpoenas, court orders, and
regulatory or law enforcement requests. (Legal basis: our legitimate business
interests and/or compliance with laws)
Aggregate and de-identified information. We may de-identify personal information
and create anonymous and aggregated data sets and reports in order to assess,
improve and develop our business, products and services, prepare benchmarking
reports on our industry and for other research, marketing and analytics
purposes.
6. DISCLOSURE OF PERSONAL INFORMATION
We disclose the personal information we collect as set forth in this section.
A. Purposes for Which We Disclose Personal Information
Willis Towers Watson may disclose your personal information to any Willis Towers
Watson group company for the uses and purposes set out above, including for
marketing the products and services offered by other businesses across the
Willis Towers Watson group (subject to applicable laws). We may also disclose
your personal information for the following reasons:
* to third party service providers such as entities providing customer service,
email delivery, auditing, hosting our Websites and other services
* to third parties involved with events that you register for, to facilitate
your participation in those events, support feedback collection and
evaluation and for some events, to third parties who provide a central record
keeping system for continuing professional development event attendance
* if we are obliged to disclose your personal information under applicable law
or regulation, which may include laws outside your country of residence
* in order to enforce or apply our Websites’ terms of use, or to protect the
rights, privacy, safety or property of Willis Towers Watson, our clients,
affiliates or other parties
* subject to applicable laws, to respond to requests from courts, law
enforcement agencies, regulatory agencies, and other public and government
authorities, which may include such authorities outside your country of
residence
* in connection with the planning, due diligence and implementation of
commercial transactions, including a reorganization, merger, sale of all or a
portion of our assets, a 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)—in such cases, your
personal information will be transferred to the acquiring entity
* in accordance with the separate terms and conditions of use that may apply to
you or with your explicit consent.
We request those external service providers to implement and apply security
safeguards to ensure the privacy and security of your personal information.
These third parties have agreed to confidentiality restrictions and to use of
any personal information we share with them or which they collect on our behalf
solely for the purpose of providing the contracted service to us.
Aggregate and de-identified information. We may share aggregate or de-identified
information, which does not identify and is not linked or linkable to a
particular individual, with third parties for research, marketing, analytics and
other purposes.
B. Categories of Personal Information Disclosed
Certain privacy laws (such as the California Consumer Privacy Act (“CCPA”))
require that we disclose the categories of Personal Information that we have
disclosed for a business purpose as well as the categories that we have “sold”
(as that term is defined under the CCPA or other applicable laws). Please review
the descriptions of the categories of personal information under the Personal
Information Collected section above, for further descriptions of each category
of personal information.
Categories of personal information disclosed for a business purpose. In general,
we may disclose the following categories of personal information in support of
our business purposes identified above:
* Name, company name, contact information and other identifiers
* Customer records
* Protected classifications
* Commercial Information
* Usage data
* Geolocation data
* Biometric information
* Audio, video and other electronic data
* Employment history
* Education information
* Profiles and inferences
We have disclosed the categories of personal information listed above to the
following categories of third parties in the preceding twelve months: our
clients, advertising networks, data analytics providers, other service
providers, other insurance companies, and government entities.
Categories of personal information sold. While we do not disclose personal
information to third parties in exchange for monetary compensation from such
third parties, we do disclose or make available personal information to third
parties, in order to receive certain services or benefits from them, such as
when we allow third party tags to collect information such as browsing history
on our Websites, in order to improve and measure our ad campaigns. The CCPA
defines a “sale” as disclosing or making available to a third party Personal
Information in exchange for monetary or other valuable consideration. Pursuant
to the CCPA, the categories of Personal Information that we may “sell” as
defined under the CCPA includes:
* Identifiers
* Usage data
* Geolocation data
We have “sold” the categories of personal information listed above to data
analytics providers in the preceding twelve months.
7. COOKIES AND TRACKING
Our Websites may use first party and third-party cookies, pixel tags, plugins
and other tools to gather device, usage and browsing information when users
visit our Websites or use our online services. For instance, when you visit our
Websites, our server may record your IP address (and associated location
information) and other information such as the type of your internet browser,
your Media Access Control (MAC) address, computer type (Windows or Macintosh),
screen resolution, operating system name and version, device manufacturer and
model, language, and the pages you view and links you click on our Websites, as
well as date and time stamps associated with your activities on our Websites.
We use the information for security purposes, to facilitate navigation, to
personalize and improve your experience while using the Websites, to improve and
measure our advertising campaigns and to better reach users with relevant
advertising both on our Websites and on third party websites. We also gather
statistical information about use of the Websites in order to continually
improve their design and functionality, understand how they are used and assist
us with resolving questions regarding them. Our Cookie Notice contains further
information about our use of cookies. You can manage how your preferences
regarding cookies are set by this Website, using our cookie preference manager.
If you have reached this Privacy Notice from a website other than our Homepage,
please go back and use the cookie preference manager on that website to set your
cookie preferences for that website.
Cookies. Cookies are small text files that a website transfers to your computer
or other device to store and sometimes collect information about your usage of
websites, such as time spent on the websites, pages visited, language
preferences, and other anonymous traffic data. 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. However, if you select such a setting, this may affect the functioning
of our Websites. Unless you have adjusted your browser setting so that it will
refuse cookies, our system will issue cookies when you access or log on to our
Websites. 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 or
www.allaboutcookies.org. For more information about the use of cookies on our
Websites and your choices regarding the placement of cookies, please see our
Cookie Notice. If you have reached this Privacy Notice from a website other than
our Homepage, please go back and review the Cookie Notice on that website to
understand how cookies are used on that website.
Pixel tags and other similar technologies. Pixel tags (also known as web beacons
and clear GIFs) may be used in connection with some Websites to, among other
things, track the actions of users of the Websites (including email recipients),
measure the success of our marketing campaigns and compile statistics about
usage of the Websites and response rates. We and our service providers also use
pixel tags in HTML emails to our customers, to help us track email response
rates, identify when our emails are viewed, and track whether our emails are
forwarded.
Log files. Most browsers collect certain information, such as your IP address,
device type, screen resolution, operating system version and internet browser
type and version. This information is gathered automatically and stored in log
files.
Third Party Analytics Tools. Our Websites may use automated devices and
applications operated by third parties (e.g., Google Analytics), which use
cookies and similar technologies to collect and analyze information about use of
the Websites and report on activities and trends. Please see our Cookie Notice
for more information. If you have reached this Privacy Notice from a website
other than our Homepage, please go back and review the Cookie Notice on that
website to understand how cookies are used on that website.
Do-Not-Track signals. Please note that our Websites do not recognize or respond
to any signal which your browser might transmit through the so-called 'Do Not
Track' feature your browser might have. If you wish to disable cookies on our
Websites, you should not rely on any 'Do Not Track' feature your browser might
have. For more information about do-not-track signals, please click here.
8. INTEREST-BASED ADVERTISING
On some of our websites, we may work with third-party ad networks, analytics
companies, measurement services and others (“third-party ad companies”) to
display advertising on our Websites and to manage our advertising on third-party
sites, mobile apps and online services. We and these third-party ad companies
may use cookies, pixels tags and other tools to collect information on our
Websites (and on third-party sites and services), such as browsing history, IP
address, device ID, cookie and advertising IDs, and other identifiers, general
location information and, with your consent, your device’s geolocation
information; we and these third-party ad companies use this information to
provide you more relevant ads and content and to evaluate the success of such
ads and content.
You can manage how your preferences regarding third party ad company cookies set
by this Website, using our cookie preference manager. If you have reached this
Privacy Notice from a Website other than the Homepage, please go back and use
the cookie preference manager on that Website to set your cookie preferences.
Please see our Cookie Notice for information about the third parties we may work
with to display targeted ads on third-party sites and to measure the success of
our marketing and campaigns. If you have reached this Privacy Notice from a
Website other than the Homepage, please go back and review the Cookie Notice on
that Website to understand how cookies are used there. You may also obtain more
information about targeted or “interest-based advertising” and opt-out of many
ad networks at the industry websites below:
* Canada: www.youradchoices.ca
* EU: www.youronlinechoices.eu
* U.S.: www.aboutads.info
9. SECURITY
Willis Towers Watson has implemented technical and organizational security
measures to protect the personal information we collect. Despite this, the
security of the transmission of information via the Internet cannot always be
guaranteed and you acknowledge this in your access and use of our Websites and
Services. 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 "Contact
and Comments" section below.
10. INDIVIDUAL RIGHTS AND CHOICES
Marketing. You may opt out from receiving marketing-related communications from
us on a going-forward basis by contacting us or by using the unsubscribe
mechanism contained in each email. We will try to comply with your request(s) as
soon as reasonably practicable. Please note that if you opt out of receiving
marketing-related emails from us, we may still send you important administrative
messages, from which you cannot opt out.
Access, amendment and deletion. You may request to review, make amendments, have
deleted or otherwise exercise your rights under applicable privacy laws over
your personal information that we hold, subject to certain limitations under
applicable law. You may submit a request to us related to your personal
information:
* By submitting a request to us at contact us
* By contacting us at 1-800-889-9288 (toll free)
* By emailing us at dataaccessrequest@willistowerswatson.com
We take steps in accordance with applicable legislation to keep your personal
information accurate, complete and up-to-date. If you would like to review,
correct, update, suppress, or restrict the processing of your personal
information or request a copy of personal information about you, you may contact
us by sending us an email at dataaccessrequest@willistowerswatson.com or sending
your request by postal mail to the address provided in the "Contact & Comments"
section below.
In your request, please make clear what personal information you would like to
have changed, whether you would like to have your personal information
suppressed from our database or otherwise let us know what limitations you would
like to put on our use of your personal information. For your protection, we may
only implement requests with respect to the personal information associated with
the particular email address that you use to send us your request, and we may
need to verify your identity before implementing your request. We will try to
comply with your request as soon as reasonably practicable.
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. There may also be residual information that will remain
within our databases and other records, which will not be removed.
To exercise your rights please contact us using the contact information below.
Subject to legal and other permissible considerations, we will make reasonable
efforts to honour your request promptly or inform you if we require further
information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would
impact the duty of confidentiality we owe to others, or if we are legally
entitled to deal with the request in a different way.
Additional information for certain jurisdictions. Willis Towers Watson is
committed to respecting the privacy rights of individuals under all privacy laws
applicable to us. Some privacy laws require that we provide specific information
about individual rights to applicable consumers, which we have set forth at the
end of this Notice:
* California: if you are a California resident, you have certain rights under
California privacy laws regarding your personal information as set forth
below in the Additional Information for Certain Jurisdictions section.
* EU/EEA/UK: if you are in the European Union / European Economic Area/United
Kingdom, please go to the Additional Information for Certain Jurisdictions
below for details about your rights under the GDPR.
* Brazil/LGPD: if you are in the Brazil and subject to the Brazilian General
Data Protection Law (LGPD), please go to the Additional Information for
Certain Jurisdictions below for details about your rights under the LGPD.
* Cayman Islands: if you are in the Cayman Islands and subject to the Cayman
Islands Data Protection Law, please go to the Additional Information for
Certain Jurisdictions below for details about your rights under that law.
11. 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 or defined in an agreement. We may retain personal
information for longer where required by our regulatory obligations or
professional indemnity obligations, or where we believe it is necessary to
establish, defend or protect our legal rights and interests or those of others.
With respect to the data and files we handle as a processor, we retain this
personal information in accordance with our clients’ instructions and as
required by law.
12. CHILDREN AND MINORS
The Websites and Services are not directed to individuals under the age of
sixteen (16), and we do not knowingly collect personal information from minors
under the age of 16.
13. CHANGES TO OUR PRIVACY NOTICE
From time to time, we may change our Privacy Notice. The effective date set
forth at the top indicates the last time this Privacy Notice was revised.
Checking this effective date allows you to determine whether there have been
changes since the last time you reviewed the notice. We will notify you of
changes to this privacy notice by posting the revised Privacy Notice on our
Websites.
14. CONTACT AND COMMENTS
If you have any questions or comments regarding this Privacy Notice, please
contact our Privacy Team, at 800 North Glebe Road, Arlington, VA 22203 or at
privacy@willistowerswatson.com.
In some countries, there is a legal requirement to provide a named individual
and their contact details. These are:
Contacts Country Name Contact details Nigeria Adewunmi Akinmodiro
Adewunmi.Akinmodiro@willistowerswatson.com
Willis Towers Watson Nigeria Limited
6th Floor, Africa RE Building. Plot 1679 Karimu Kotun Street, Victoria Island
Lagos, Nigeria. South Africa André Wild Andre.Wild@willistowerswatson.com
Towers Watson (Pty) Ltd
Level 4, MontClare Place, 23 Main Road, Claremont, Cape Town, 7708
Private Bag X30, Rondebosch, 7701 Pasha Karodia
Pasha.Karodia@willistowerswatson.com
Willis South Africa (Pty) Ltd
Illovo Edge, 1 Harries Road, Illovo, Johannesburg 2196
15. ADDITIONAL INFORMATION FOR RESIDENTS IN CERTAIN JURISDICTIONS
In this section, we set forth additional information as required under
applicable privacy laws in certain jurisdictions.
A. California Residents
In this section, we provide information for California residents as required
under California privacy laws, including the CCPA, which requires that we
provide California residents certain specific information about how handle their
personal information, whether collected online or offline. This section does not
address or apply to our handling of:
* publicly available information made lawfully available by state or federal
governments
* personal information that is subject to an exemption under Section
1798.145(c) – (f) of the CCPA (such as protected health information that is
subject to HIPAA or the California Medical Information Act, and non-public
information subject to the Gramm-Leach Bliley Act or the California Financial
Information Privacy Act)
* personal information we collect about job applicants, independent
contractors, or current or former full-time, part-time and temporary
employees and staff, officers, directors or owners of Willis Towers Watson
* personal information about individuals acting for or on behalf of another
company, to the extent the information relates to our transactions with such
company, products or services that we receive from or provide to such
company, or associated communications or transactions (except that such
individuals have the right to opt-out of any sale of their personal
information and to not be subject to any discrimination for exercising such
right)
Categories of personal information that we collect and disclose. Our collection,
use and disclosure of personal information about a California resident will vary
depending upon the circumstances and nature of our interactions or relationship
with such resident. The table above sets out generally the categories of
personal information (as defined by the CCPA) about California residents that we
collect, sell, and disclose to others for a business purpose. We collect these
categories of personal information from the sources described in the Personal
information we may collect section above, and for the purposes described in the
Purposes for which we use personal information section above.
Rights of California residents. California law grants California residents
certain rights and imposes restrictions on particular business practices as set
forth below.
* Do-Not-Sell: California residents have the right to opt-out of our sale of
their personal information. Opt-out rights can be exercised by clicking the
Do Not Sell My Information link in the footer of our Website Homepage. If you
have reached this Privacy Notice from a website other than our Homepage,
please go back and use the cookie preference manager on that website to
exercise your opt-out rights to the extent they may apply on that website. We
do not sell personal information about residents who we know are younger than
16 years old without opt-in consent.
* Initial Notice: We are required to notify California residents, at or before
the point of collection of their personal information, the categories of
personal information collected and the purposes for which such information is
used.
* Request to Delete: California residents have the right to request deletion of
their personal information that we have collected about them and to have such
personal information deleted, except where an exemption applies. We will
respond to verifiable requests received from California residents as required
by law. The instructions for submitting a verifiable Request to Delete are
described in the “Submitting Requests” section below.
* Request to Know: California residents have the right to request and, subject
to certain exemptions, receive a copy of the specific pieces of personal
information that we have collected, used, disclosed and sold about them in
the prior 12 months and to have this delivered, free of charge, either (a) by
mail or (b) electronically in a portable and, to the extent technically
feasible, readily useable format that allows the individual to transmit this
information to another entity without hindrance. California residents also
have the right to request that we provide them certain information about how
we have handled their personal information in the prior 12 months, including
the:
* categories of personal information collected;
* categories of sources of personal information;
* business and/or commercial purposes for collecting and selling their
personal information;
* categories of third parties with whom we have shared their personal
information;
* categories of personal information that we have sold in the preceding 12
months, and for each category identified, the categories of third parties
to which we sold that particular category of information; and
* categories of personal information disclosed for a business purpose in the
preceding 12 months, and for each category identified, the categories of
third parties to which we disclosed that particular category of personal
information.
California residents may make a Request to Know up to twice every 12 months. We
will respond to verifiable requests received from California residents as
required by law. The instructions for submitting a verifiable Request to Know
are described in the “Submitting Requests” section below.
* Right to non- discrimination: The CCPA prohibits discrimination against
California residents for exercising their rights under the CCPA.
Discrimination may exist where a business denies or provides a different
level or quality of goods or services, or charges (or suggests that it will
charge) different prices, rates, or penalties on residents who exercise their
CCPA rights, unless doing so is reasonably related to the value provided to
the business by the residents’ data.
* Financial incentives: A business may offer financial incentives for the
collection, sale or deletion of California residents’ personal information,
where the incentive is not unjust, unreasonable, coercive or usurious, and is
made available in compliance with applicable transparency, informed consent,
and opt-out requirements. California residents have the right to be notified
of any financial incentives offers and their material terms, the right to
opt-out of such incentives at any time, and may not be included in such
incentives without their prior informed opt-in consent. We do not offer any
such incentives at this time.
Submitting Requests. Do-Not-Sell (Opt-out) Requests, Requests to Know, and
Requests to Delete may be submitted:
* By contacting us at 1-800-889-9288 (toll free).
* By submitting a Consumer Request through this link.
We will use the following process to verify Requests to Know and Requests to
Delete: We will acknowledge receipt of you Consumer Request, verify it using
processes required by law, then process and respond to your request as required
by law. To verify such requests, we may ask you to provide the following
information:
* For a request to know categories of personal information which we collect, we
will verify your identity to a reasonable degree of certainty by matching at
least two data points provided by you against information in our systems
which are considered reasonably reliable for the purposes of verifying a
consumer’s identity.
* For a request to know specific pieces of personal information or for requests
to delete, we will verify your identity to a high degree of certainty by
matching at least three pieces of personal information provided by you to
personal information maintained in our systems and also by obtaining a signed
declaration under penalty of perjury that the requestor is the consumer whose
personal information is the subject of the request.
An authorized agent can make a request on a California residents’ behalf by
providing a power of attorney valid under California law, or providing: (1)
proof that the consumer authorized the agent to do so; (2) verification of their
own identity with respect to a right to know categories, right to know specific
pieces of personal information, or requests to delete which are outlined above;
and (3) direct confirmation that the consumer provided the authorized agent
permission to submit the request.
We will respond to verifiable requests received from California residents as
required by law. For more information about our privacy practices, you may
contact us as set forth in the Contact and Comments section above.
Consumer Requests Received in 2020. In calendar year 2020, we received and
responded to consumer requests under the CCPA as set forth in the table below:
Consumer Requests Received in 2020 Request Type Number of Requests Received
Number of Requests With Which We Complied (in whole or in part) Number of
Requests Denied* Average Response Time (Number of Days) Requests to Know 1 0 1 1
Requests to Delete 1 0 1 6 Requests to Opt-Out of the Sale of Personal
Information 718 646** 0 0
*This includes requests that were denied because we were unable to verify the
identity of the requestor.
**We receive opt-out requests through multiple channels including a cookie
preference manager and by email. The difference between the number of requests
received and the number of requests we responded to is due to the channel by
which we received the requests to opt-out. We received 72 requests to opt-out
through email. We followed up with the requestors for more information, but the
requestor never clarified to which WTW group or information their request
applied to.
B. European Union / European Economic Area / United Kingdom
Residents of the European Union (EU) and the European Economic Area (EEA) have
the following rights, under the GDPR, regarding their personal information:
* Right of access: You have the right to obtain from us confirmation as to
whether or not personal information concerning you is being processed, and
where that is the case, to request access to the personal information. The
accessed information includes – among others - the purposes of the
processing, the categories of personal information concerned, and the
recipients or categories of recipient to whom the personal information have
been or will be disclosed. You have the right to obtain a copy of the
personal information undergoing processing. For further copies requested by
you, we may charge a reasonable fee based on administrative costs.
* Right to rectify and complete personal information: you can request the
rectification of inaccurate data and the completion of incomplete data. We
will inform relevant third parties to whom we have transferred your data
about the rectification and completion if we are legally obliged to do so.
* Right to erasure (right to be forgotten): You have the right to obtain from
us the erasure of personal information concerning you in limited
circumstances where:
* it is no longer needed for the purposes for which it was collected; or
* you have withdrawn your consent (where the data processing was based on
consent); or
* following a successful right to object; or
* it has been processed unlawfully; or
* the data has to be erased in order to comply with a legal obligation to
which Willis Towers Watson is subject.
We are not required to comply with your request to erase personal information
if the processing of your personal information is necessary for:
* compliance with a legal obligation; or
* the establishment, exercise or defense of legal claims.
* Right to restriction of processing: You have the right to obtain from us
restriction of processing your personal information. In this case, the
respective data will be marked and only be processed by us for certain
purposes. This right can only be exercised where:
* the accuracy of your personal information is contested, to allow us to
verify its accuracy; or
* the processing is unlawful, but you do not want the personal information
erased; or
* it is no longer needed for the purposes for which it was collected, but you
still need it to establish, exercise or defend legal claims; or
* you have exercised the right to object, and verification of overriding
grounds is pending.
We can continue to use your personal information following a request for
restriction, where:
* we have your consent; or
* to establish, exercise or defend legal claims; or
* to protect the rights of another natural or legal person.
* Right to data portability: You have the right to receive the personal
information concerning you, which you have provided to us, in a structured,
commonly used and machine-readable format and you have the right to transmit
those data to another entity without hindrance from us, but in each case only
where the processing is (a) based on your consent or on the performance of a
contract with you, and (b) also carried out by automated means.
* Right to object: You have the right to object at any time to any processing
of your personal information which has our legitimate interests as its legal
basis. You may exercise this right without incurring any costs. If you raise
an objection, we have an opportunity to demonstrate that we have compelling
legitimate interests which override your rights and freedoms. The right to
object does not exist, in particular, if the processing of your personal
information is necessary to take steps prior to entering into a contract or
to perform a contract already concluded.
* Right to object to our use of your personal information for direct marketing
purposes: You can request that we change the manner in which we contact you
for marketing purposes. You can request that we do not transfer your personal
information to unaffiliated third parties for the purposes of direct
marketing or any other purposes.
* Right to withdraw consent: if you have given us your consent for the
processing of your personal information, you have the right to withdraw your
consent at any time, without affecting the lawfulness of processing based on
consent before its withdrawal.
* Right to obtain a copy of safeguards and EU Standard Contractual Clauses: you
can ask to obtain a copy of, or reference to, the safeguards and any relevant
EU Standard Contractual Clauses (“SCCs”) under which your personal
information is transferred outside the EU/EEA. We may redact data transfer
agreements/SCCs to protect commercial terms.
* Right to lodge a complaint with your local supervisory authority: You have a
right to lodge a complaint with your local supervisory authority if you have
concerns about how we are processing your personal information. We ask that
you please attempt to resolve any issue with us first by contacting us at
privacy@willistowerswatson.com, although you have a right to contact your
supervisory authority at any time.
C. Brazil
The following information applies to personal data which we process from any
individuals that is related to Brazil’s territory under the National Data
Protection Law (LGPD):
* Scope: In addition to the circumstances set forth in the section above
regarding Scope, the LGPD applies when we process personal data subject to
protect fundamental rights of freedom, privacy and the free development of
the personality of individuals.
* Sensitive Personal Data under the LGPD: Sensitive personal data under the
LGPD includes personal data (as defined above in Scope section of this
Notice) about racial or ethnic origin, religious belief, political opinion,
union membership or organization of a religious, philosophical or political
nature, data relating to health or sexual life, genetic or biometric data,
when linked to a natural person. Please see the section above regarding
Personal Information Collected for more information on how we treat sensitive
personal data.
* Individual rights: Under the LGPD, individuals have certain rights related to
their personal data, subject to other limitations in this law, as follows:
1. Confirmation of the existence of data processing;
2. Access to your personal data;
3. Correction of incomplete, inaccurate, or out-of-date data;
4. Anonymization, blocking, or deletion of unnecessary or excessive data, or
data processed in non-compliance with LGPD;
5. Portability of data to another service or product provider, subject to the
LGPD;
6. Deletion of personal data, to the extent permitted by the LGPD;
7. Information about the entities with whom we have shared personal data;
8. Information about the possibility of denying consent and consequences of
such denial;
9. Revocation of consent.
* Processing of Children’s Personal Data: We process personal data belonging to
children and adolescents, defined as individuals 16 years or younger. In this
case, in accordance with the LGPD, we process children´s personal data when
in their own best interests and with the specific consent of at least one of
their parents or legal representatives.
* Contacting Us in Brazil: If you have any questions or comments about this
Privacy Notice as it relates to the LGPD or our processing activities in
Brazil, please contact our Brazil Data Protection Officer (DPO) at
brasil@willistowerswatson.com.
D. Cayman Islands Data Protection Law (“DPL”)
Individuals whose Personal Data is collected and/or used in the Cayman Islands
have the following rights over their Personal Data:
* Right of Access: You have the right to obtain from us confirmation as to
whether or not personal data concerning you is being processed, and where
that is the case, to request access to the personal data. The information
which may be accessed includes – among others - the purposes of the
processing, the categories of personal information concerned, and the
recipients or categories of recipient to whom the personal information have
been or will be disclosed, any countries or territories outside Caymans that
your personal data is sent and general security measures taken over your
personal data. You have the right to obtain a copy of the personal
information undergoing processing. If the requests are deemed excessive, we
may charge a reasonable fee based on administrative costs.
* Right to stop or restrict processing Personal Data: You have the right to
obtain from us restriction of processing your personal data. We shall comply
with this request unless the processing is necessary for certain purposes.
These purposes include: (a) the processing is necessary for the performance
of a contract to which the data subject is a party or the taking of steps at
the request of the data subject with a view to entering into a contract; (b)
the processing is necessary for compliance with any legal obligation to which
the data controller is subject, other than an obligation imposed by contract;
(c) the processing is necessary in order to protect the vital interests of
the data subject; or (d) the processing is necessary in such other
circumstances as may be prescribed by regulations.
* Right to be informed about the collection and use if their Personal Data: You
have the right to be informed about the collection and use of your personal
data, which includes information such as who we are, and the purposes for our
processing your personal data.
* Right to stop processing for direct marketing: You have the right to obtain
from us restriction of processing of your personal data for direct marketing
purposes. We shall honor this request without undue delay within a reasonable
period of time. You may complain to the Ombudsman if we do not comply with
this request.
* Rights in relation to automated decision making: You have the right to obtain
from us restriction from us making a decision that significantly affects you
based on the processing of automatic means of your personal data for the
purpose of evaluating your performance at work, creditworthiness,
reliability, conduct or other matters.
* Right to complain/seek compensation: You have a right to complain to the
Ombudsman regarding any perceived violation of the DPL. If you suffer damage
due to a violation of the DPL by us, you may be able to seek compensation via
the court system.
* Right to rectification, blocking, erasure, or destruction: You have a right
to have inaccurate personal data rectified or completed if incomplete,
without undue delay. You may complain to the Ombudsman, who may issue an
order for rectification, blocking, erasure or destruction of the data.
Submitting Requests. Requests may be submitted:
* By submitting a Consumer Request through this link.
* By emailing us at dataaccessrequest@willistowerswatson.com
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