Outsourcing Privacy Notice
LAST UPDATED: August 2021
THIS NOTICE DESCRIBES HOW PERSONAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Concordia Plan Services as the Plan Administrator for the benefits you are eligible for has hired Willis Towers Watson to provide Retirement Connection (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; Plan Administrator data import files; other third party import files approved by the Plan Administrator; mobile devices; and HTML-formatted email messages that may be sent to you (collectively, the "Services"). By providing Personal Information to us, you agree to the terms and conditions of this Privacy Notice.
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, and dependents are eligible for benefits. You may be asked to provide additional information about yourself, your spouse, your dependents, and beneficiary designations. You may also be asked to update or correct information about yourself, your spouse, or your dependents. If 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 to permit us to use the information in accordance with this Privacy Notice.
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
We may use Personal Information:
How Personal Information May Be Disclosed
Your Personal Information may be disclosed:
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:
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:
How We May Use and Disclose Other Information
We may use and disclose Other Information for any purpose, except as provided under applicable law. In some instances, we may combine Other Information with Personal Information) . 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, 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.
SECURITY
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. 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
Our standard process 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 or change your Personal Information
If you would like to review, correct, or update Personal Information you may do so by contacting your Human Resources contact or accessing your employer’s online benefits portal.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began before you requested the change. There may also be residual information that will remain in our databases and other records, which will not be removed.
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
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 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 data protection rules that are different from those of your country.
SENSITIVE INFORMATION
we ask that you not send us, and you not disclose, any sensitive Personal Information (for example, 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.
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 privacy@willistowerswatson.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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