This Privacy Notice describes how the Via Benefits Companies (each individually a "Company"; collectively the "Companies" or "we," "us," or "our") handle personal information collected thought the Via Benefits website and other Company websites that link to this Privacy Notice (the "Websites"). This includes any Personal Information that may be collected by us through your use of any (i) software applications made available by us for use on or through computers and mobile devices (the "Apps"); (ii) social media pages that we control from which link to this Privacy Notice (collectively, our "Social Media Pages"); and (iii) HTML-formatted email messages that we send to you that link to this Privacy Notice.
The Via Benefits Companies include, but are not limited to, the following entities:
- Acclaris. Inc.;
- Extend Health, Inc.;
- Willis Towers Watson ("WTW"); and
- Any other entity linked to any Website that is owned or controlled by WTW or its affiliates.
By visiting the Via Benefits Website, you agree to this Privacy Notice.
1. SCOPE OF THIS PRIVACY NOTICE
This Privacy Notice only applies to the Websites.
2. CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we or our affiliates have facilities or engage service providers, and by using the Websites 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. We have established safeguards to protect Personal Information that is transferred to other countries, including appropriate contractual protections.
3. PERSONAL INFORMATION WE MAY COLLECT FROM YOU
"Personal Information" is information that identifies you as an individual or relates to an identifiable individual. 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 dealings with us;
- Any interest you have in relation to our services or our practice areas; and
- Any information you may voluntarily submit to us by completing any form on our Websites; and
- Details of your visits to and usage of our Websites.
We may collect Personal Information in various ways:
- From any form you may complete and submit through our Websites, for example information collected from the 'Contact Us' page of our Websites;
- From the content of surveys that you may complete on our Websites;
- From session 'cookies' and other similar tools deployed on parts of our Websites that can only be accessed by authenticated users who are logged into the Website (as explained further in Section 6, below);
- When you provide information as a client in connection with us providing professional services to you. Such information may be collected through the Websites when clients access client links within the Website. Access will be subject to the terms of business we have with clients and any additional terms and conditions of use attached to those sites; and
- 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.
4. HOW WE MAY USE YOUR PERSONAL INFORMATION
We may use Personal Information about you for our legitimate business interests, including the following:
- 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 service, or otherwise to fulfill your requests and respond to your queries and requests for information, which may include marketing to you; and
- For the purposes of providing professional services to you via our Apps; such services will be subject to additional terms and conditions of use including privacy;
- For our business purposes, such as 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.
5. DISCLOSURE OF YOUR PERSONAL INFORMATION
We may disclose your Personal Information to our affiliates for the uses and purposes set out above. We may also disclose your Personal Information to third parties for the following reasons:
- To third party service providers such as entities providing customer service, email delivery, auditing, and other services;
- If we are obliged to disclose your personal information under applicable law or regulation, which may include laws outside your country of residence;
- 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 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);
- In accordance with the separate terms and conditions of use that may attach to our Website links.
6. OTHER INFORMATION WE MAY COLLECT
"Other Information" is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. We may collect Other Information in various ways.
For instance, when you visit our Websites, our server may record your IP address. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Websites. We may also derive your approximate location and company details from your IP address. We may also gather 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 name and version of the Websites you are using, which we use to provide you with a more effective service.
Cookies: Additionally, when you visit our Websites, we may store a 'cookie' on the hard drive of your computer. Cookies are small text files that a website transfers to your hard drive 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. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Websites and to recognize your computer in order to assist your use of the 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.
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. Enabling such feature on your browser will not necessarily affect the way in which our Websites operate, and if you wish to disable cookies on our Websites, you should not rely on any 'Do Not Track' feature your browser might have.
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.
From you: Information such as your preferred means of communication is collected when you voluntarily provide it.
By aggregating information: Aggregated Personal Information that does not personally identify you or any other user of the Websites (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
7. HOW WE MAY USE AND DISCLOSE OTHER INFORMATION
We may use and disclose Other Information for any purpose to the extent not prohibited by applicable law. In some instances, we may combine Other Information with Personal Information (such as combining your name with your location), in which case, the combined information will be treated as Personal Information.
We maintain appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorized 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 our Websites. 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.
9. CHOICES AND ACCESS
You may opt out from receiving marketing-related emails from us on a going-forward basis by using the unsubscribe mechanism contained in each such 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.
You may withdraw your consent to this Privacy Notice at any time by sending your request to us at the address listed in the "Contact & Comments" section below. Please note that even if you withdraw your consent, we may still have the right or obligation under applicable law to collect, use, transfer or disclose Personal Information without your consent and we reserve the right to undertake that activity when appropriate.
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 must contact your Employer or Plan Administrator who will then send corrected information or other direction to Acclaris.
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 only implement requests with respect to the Personal Information from Employers or Plan Administrators that contract with us. 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.
10. 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.
11. USE OF WEBSITES BY MINORSThe Websites are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Information through the Websites.
13. CHANGES TO OUR PRIVACY NOTICE
From time to time, we may change our Privacy Notice. The effective date of this Privacy Notice, as indicated at the beginning of this Privacy Notice, 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. Your use of the Websites following these changes means that you of changes to this Privacy Notice by posting the revised Privacy Notice on our Websites. Your use of the Websites following these changes means that you accept the revised Privacy Notice.
14. CONTACT & COMMENTS
The Websites are controlled by the Companies. If you have any questions or comments regarding this Privacy Notice, please contact the Privacy Officer at email@example.com.
You have the right to provide a comment or lodge a complaint with a supervisory authority regarding this Privacy Notice.
Last updated: February 28, 2018