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EPA FOR [CLIENT NAME]




EPA PRIVACY NOTICE


 1.  THIS PRIVACY NOTICE
     
     Towers Watson Limited (“we” or “us”) is part of the Willis Towers Watson
     group which operates worldwide through its subsidiary and affiliate
     companies (collectively, “Willis Towers Watson”).
     
     We are the administrators of your occupational pension scheme (“Scheme”)
     and in accordance with the instructions of our client (the trustees of your
     Scheme). We provide ePA (the “Site”) as part of those administration
     services. The Site enables you to view and make decisions relating to your
     Scheme including your Scheme benefits. To do this, the Site uses some of
     your Personal Information. To understand how your Personal Information is
     used in the operation of the Scheme, please check your Scheme's privacy
     notice.
     
     This privacy notice only describes how Willis Towers Watson handles the
     Personal Information we collect when you use the Site, acting as a data
     controller.
     
     Any external websites and specific web pages linked from this Site may be
     subject to separate terms of use (including separate privacy notices). You
     should check the terms of use on those sites before using them. We are not
     responsible for how your Personal Information is handled by external
     websites.


 2.  PERSONAL INFORMATION PROCESSING
     
     “Personal Information” is information that identifies you as an individual
     or relates to an identifiable individual. When you use ePA, we collect and
     use your Personal Information:
     
     * When you log in to the Site (user id and password); and
     * through placing cookies and similar technologies on your device.
     
     
     
     This Personal Information is your Site Usage Data.
     
     You can find out more about the cookies and similar technologies we use and
     why by viewing our Cookie Notice. Our Cookie Notice should be read together
     with this Privacy Notice.


 3.  PURPOSES AND LEGAL BASES FOR PROCESSING INFORMATION
     
     We process Site Usage Data for our legitimate interests, which include:
     
     * enabling you to log in to the Site;
     * analysing use of the Site;
     * improving Site content; and
     * monitoring and improving Site security and performance.


 4.  DISCLOSURE OF YOUR PERSONAL INFORMATION
     
     We may disclose Site Usage Data to other Willis Towers Watson group
     entities and/or third-party services providers that help us to operate or
     improve the Site.


 5.  AGGREGATED AND ANONYMISED DATA
     
     We may aggregate and/or anonymise information about you. Aggregated and
     anonymised data is not capable of being used to identify individuals and is
     not treated as Personal Information under this privacy notice.


 6.  SECURITY
     
     We maintain appropriate technical and organisational security measures to
     protect your data against loss, misuse, unauthorised access, disclosure or
     alteration. 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 the Site. 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 & Comments” section below.


 7.  CROSS BORDER TRANSFER
     
     The Site is hosted in the United Kingdom; however, because of the global
     nature of our business, your Personal Information may be processed in other
     jurisdictions where we have facilities or in which we engage service
     providers. 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 one of the methods listed in the “Contact & Comments” section
     below.


 8.  YOUR RIGHTS
     
     You have the following rights in relation to your Personal Information.
     When making a request, please make clear what Personal Information your
     request relates to and make the request using “Contact & Comments” section
     below.
     
     
     * 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: You can ask to obtain a copy of, or
       reference to, the safeguards under which your Personal Information is
       transferred outside the EU/EEA. We may redact data transfer agreements to
       protect commercial terms.
     * Right to lodge a complaint with your local data protection 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. The Information Commissioner's Office, can be
       contacted at www.ico.org.uk/concerns/.
     
     
     
     We ask that you please attempt to resolve any issue with us first, although
     you have a right to contact your supervisory authority at any time.
     
     Please note that we may need to retain certain information for record
     keeping 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, but where that is the case we will take steps to prevent such data
     from being accessed or used.


 9.  RETENTION PERIOD
     
     We retain your Site Usage Data for as long as we provide the Site to you.
     We may retain aggregated or anonymised data (which is not treated as
     Personal Information under this privacy notice) for longer.


 10. CHANGES TO OUR PRIVACY NOTICE
     
     We review our Privacy Notice regularly. Where the Privacy Notice has been
     updated, it will be clearly identified by reference to the date of this
     Privacy Notice above. We recommend that you review our Privacy Notice
     regularly to ensure you are fully informed.


 11. CONTACTS & COMMENTS
     
     If you have any questions or comments regarding this privacy notice, please
     contact us at the following e-mail address:
     TAS.Customer.Services@willistowerswatson.com or in writing to:
     Customer Services, Willis Towers Watson, PO Box 729, Redhill, Surrey RH1
     9FG.

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