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Text Content

WELCOME TO VIA BENEFITS

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Our Privacy Commitment
Acclaris, Inc. offers all account services and is the HSA custodian.


PRIVACY POLICY

×

Last Updated: October 2023

Acclaris, Inc. (Acclaris) is an affiliate of Willis Towers Watson which operates
worldwide through subsidiary and affiliate companies. A list of the Willis
Towers Watson group companies (collectively, "Willis Towers Watson," "we," "us,"
or "our") can be viewed here. Both Willis Towers Watson and Acclaris are
committed to privacy and to transparency in our information practices.

1. Scope

This privacy notice ("Notice") describes how Acclaris (the "Company," "we,"
"us," or "our") handles personal information collected through this website, our
mobile application(s) ("Mobile App"), and other websites we control that link to
this privacy notice (the "Websites"), as well as related to our products and
services, such as our Health Savings Account ("HSA") Administration Services,
where we act as a "Business" or "Controller" as those terms are defined by
applicable privacy laws. This Notice does not apply to job applicants, others
who may apply for employment with is, or to employees or non-employee workers or
where we are subject to the Health Insurance Portability and Accountability Act
("HIPAA"), the Gramm-Leach Bliley Act ("GLBA"), or act as a "service provider"
or "processor" to our clients.

This Notice additionally describes our use of cookies and similar technologies.

In addition, Websites and specific web pages linked from
www.viabenefitsaccounts.com may be subject to separate terms of use (including
separate privacy notices). 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.

Subject to the foregoing parameters, this Notice describes, generally, how
Acclaris handles and processes personal information related to:

 * the use of our websites and associated services that link to this privacy
   notice, including www.viabenefitsaccounts.com and other websites controlled
   by Us (the "Websites"),
 * our former, current, and prospective clients,
 * individuals who communicate with us,
 * individuals who use our products and services, including our Mobile App,
   ("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 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 may be linkable, with a
particular individual or household, as applicable.

2. Cross-border Transfer

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, the European
Union, and other jurisdictions, in which we or our service providers operate.
Some of these jurisdictions 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 as set forth below.

3. 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 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
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 or through our Services,
 * 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, such as health
records. In these instances, 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.

Categories of sources of personal information we collect. 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 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,
 * from 'cookies' and other similar tools deployed on parts of our Websites and
   Mobile App that can only be accessed by authenticated users who are logged
   into the Website and/or Mobile App (for further information regarding cookies
   used on our Websites, please see Section 6 below),
 * when you provide information as a client in connection with us providing
   professional services to you,
 * from other sources, such as public databases, joint marketing partners,
   vendors supporting our operations, including the functioning of our Websites
   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,
   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, social security number, tax ID,
   insurance policy number, bank account 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 sex, age, disability, and citizenship
   status.
 * Commercial Information: including 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 application, or
   advertisement.
 * Audio, video, and other electronic data: audio, electronic, or similar
   information such as, call recordings.

4. Purposes for Processing 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.

 * 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.
 * 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.
 * 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.
 * 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.
 * 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.
 * 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.
 * 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.
 * 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.

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. Aggregated or de-identified information does not personally identify
you or any other user (for example, we may aggregate Personal Information to
calculate the percentage of our users who have a particular telephone area
code). When we de-identify personal information, we have implemented reasonable
measures as required by law to ensure that the de-identified data cannot be
associated with any individual or client. We will only maintain and use such
data in a de-identified manner and do not attempt to re-identify the data,
except as permitted by law.

5. 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

Acclaris 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 website and other services, to third
   parties involved with events that you register for, to facilitate your
   participation in those events,
 * to our clients to protect and secure our business operations, Services,
   network and information technology and resources and/or inform them of, or
   investigate, prevent, detect, and take action regarding actual or potential
   security incidents, suspicious activity, fraud, unauthorized access, or
   situations involving potential threats to the rights, property or safety of
   any person or third party, or other unauthorized activities or misconduct,
   subject to applicable law,
 * 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 Website terms of use, or to protect the
   rights, privacy, safety, or property of Willis Towers Watson, or those of 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 implicit 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. When we de-identify personal information, we have
implemented reasonable measures as required by law to ensure that the
de-identified data cannot be associated with any individual or client. We will
only maintain and use such data in a de-identified manner and do not attempt to
re-identify the data, except as permitted by law.

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 any 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, contact information and other identifiers,
 * Customer records,
 * Protected classifications,
 * Commercial Information,
 * Usage data,
 * Audio, video, and other electronic data,

Categories of personal information sold. We do not "sell" or "share" Personal
Information.

C. Categories of Third Parties to whom Personal Information is Disclosed.

As set out above we may disclose Personal Information to other Willis Towers
Watson Group Companies, our clients, service providers that support our
operations, and cookies providers. Examples of service providers may include
companies who assist in fulfilling our contracts and providing customer
assistance. For instance, a service provider may be utilized to perform
mailings. We also may disclose Personal Information to cookies providers that
facilitate the operation of our Websites, by supporting the Websites
functionality or providing analytics related to the use of the Websites.

6. Cookies and Tracking

Our Websites and Mobile App 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 associates 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 and/or Mobile
App, 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 and Mobile App 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 set by this Website, using our cookie
preference manager available in the footer of the linked page.

Cookies. 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. 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 Mobile App and your choices regarding the placement of cookies,
please see our Cookie Notice.

User experience analytics: Our Websites and Mobile App use user experience
analytics tools, which use cookies and similar technologies to collect and
analyze information about use of the Websites and report on activities and
trends. This service may also collect information regarding the use of other
websites, apps and online resources.

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 and Mobile App (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 and Mobile App 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 Mobile App and report on activities and trends. Please see our
Cookie Notice for more information.

Opt-Out Preference Signals and "Do-Not-Track" Signals. If your browser enables
the Global Privacy Control (GPC) when visiting our Website, our Website will
automatically opt you out of any tracking cookies that constitute a "sale" where
required by applicable privacy law. For more information about the GPC and to
learn how to implement it on your browser, please click here. Please note, our
Website does not recognize or respond to any signal which your browser might
transmit through its so-called "Do Not Track" (DNT) feature. If you wish to
disable cookies on our Websites, you should not rely on DNT browser settings.
For more information about DNT signals, please click here.

7. 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 available in the footer of
the linked page.

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. 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
 * U.S.: www.aboutads.info

8. Security

We have 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. 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. 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.

Individual Rights. Individual rights regarding Personal Information vary
depending on which laws apply to you. Some of these rights might be subject to
exemptions or limitations under applicable laws. We encourage you to contact us
should you have any questions on the specific rights available to you. Please
see Additional Information for California Residents for details specific to
California residents.

Subject to our obligations under the law, you may request that we confirm
processing of or to review, make amendments to, or delete your Personal
Information, or otherwise exercise your data privacy rights over Personal
Information applicable to you.

In accordance with legal and other permissible considerations, we will make
reasonable efforts to honor your request promptly or inform you if we require
further information in order to fulfil your request. You may submit a request to
us related to your Personal Information in one of the following ways:

 * By contacting us at 1-800-275-9849 (toll free)
 * By emailing us at ViaBenefitsPrivacy@wtwco.com

Additional information for California residents. Willis Towers Watson is
committed to respecting the privacy rights of individuals under all privacy laws
applicable to us. 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 California Residents section.

10. Retention Period

We will retain your personal information for the period necessary to fulfill the
purposes outlined in this Notice unless a longer retention period is required or
permitted by law. 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 or service provider, we retain this personal information in accordance
with our clients' instructions.

11. 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. The sole exception to the forgoing is that our services may
include collection of dependent information as required by the main account
holder's elections, and it is possible such dependents could be under the age of
16.

12. Changes to our Privacy Notice

From time to time, we may change our Notice. The effective date set forth at the
top indicates the last time this 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 Notice by posting
the revised Notice on our Websites and Mobile App.

13. Contact and Comments

If you have any questions or comments regarding this Notice, please contact our
Privacy Team, at 800 North Glebe Road, Arlington, VA 22203 or at
privacy@willistowerswatson.com.

14. Additional Information for California Residents

This section provides additional information as required by the CCPA when we act
as a "business" under the CCPA, such as when we provide Administration Services
for Health Savings Accounts ("HSAs").

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 we 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
   government
 * 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,
   including its subsidiaries and affiliates
 * 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 beginning of this document sets forth generally the
categories of personal information (as defined by the CCPA) about California
residents that we collect 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.

 * 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 Correct: California residents can request the rectification of
   inaccurate personal information. 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. The instructions for submitting a verifiable
   Request to Correct 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, 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, 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, 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. Requests to Know, Requests to Correct, and Requests to
Delete may be submitted:

 * By contacting us at 1-800-275-9849 (toll free)
 * By submitting a Consumer Request through this link.

We will use the following process to verify Requests to Know, Requests to
Correct, 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, requests to correct, 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 2022. In calendar year 2022, we received and
responded to consumer requests under the CCPA as set forth in the table below:

Request Type

Number of Requests Received

Number of Requests to which We Responded

Number of Requests Denied

Average Response Time (Number of Days)

Requests to Know

1

0

1

44

Requests to Delete

2

0

2

49

Requests to Opt-Out of the Sale of Personal Information

0

0

0

N/A

 

 



Via Benefits Accounts Cookie Notice

Last Revised: October 2023

This Cookie Notice describes the different types of cookies and similar
technologies that may be applied on Viabenefitsaccounts.com and our mobile
application(s) ("Mobile App"), where relevant, on other Willis Towers Watson
websites that link to this Cookie Notice (the "Sites").



1.   What is a cookie?

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 Sites, pages visited, language preferences, and other traffic
data. We use the information for security purposes, to facilitate navigation, to
display information more effectively, to personalize your experience while using
the Sites and to recognize your computer in order to assist your use of the
Sites. We also gather statistical information about use of the Sites in order to
improve their design and functionality, understand how they are used and assist
us with resolving questions regarding them.

There are different types of cookies, for example:

• Cookies served directly by Acclaris, Inc. ('first party cookies') and cookies
served on our behalf, for example by advertisers and data analytics companies
('third party cookies')

• Cookies which endure for different periods of time, including those that only
last only as long as your browser is open (referred to as 'session cookies')
These are deleted automatically once you close your browser.

Other cookies are 'permanent cookies', meaning that they survive after your
browser is closed. For example, they recognize your device when you open your
browser and browse the internet again.



2.   What cookies do we use?

We set out below a description of the different types of cookies and similar
technologies that may be used on the Sites.

To the extent any Personal Information (which is information that identifies you
as an individual or relates to an identifiable individual) is collected through
cookies, our Privacy Notice applies and supplements this Cookie Notice.

Strictly Necessary Cookies. Strictly necessary cookies enable you to navigate
the Sites and to use their services and features. Without these necessary
cookies and similar technologies, the Sites will not perform as smoothly for you
as we would like them to, and we may not be able to provide the Sites or certain
services or features.

Functional Cookies. Functional cookies collect information about your use of the
Sites and enable us to improve the way they work. For example, functional
cookies show us which are the most frequently visited pages on the Sites, help
us record any difficulties you have with the Sites, and show us whether our
promotional campaigns are effective. This allows us to see the overall patterns
of usage on the Sites. We use the information to analyze traffic on the Sites.

Advertising Cookies. Advertising cookies are set to display targeted promotions
or advertisements based upon your interests on the Sites or to manage our
advertising. These cookies collect information about your activities on these
and other sites to provide you targeted advertising. You can find information
about advertising cookies, including how to see what cookies have been set on
your device and how to manage and delete them here.



3.   How do I manage cookies?

You have the right to choose whether or not to accept cookies. 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. Information about the procedure to follow in order to
enable or disable cookies can be found on your Internet browser provider's
website via your help screen. You can change your cookies using the cookie
preference manager tool available via a link on our Sites.

However, if you choose not to accept cookies, this may affect the functioning of
our Sites.

If you are using a mobile device, you can limit interest-based advertising on
your device by adjusting the settings provided by your device manufacturer, such
as "Limit Ad Tracking" for iOS or "Opt-out of interest-based ads" for Android.

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,
www.allaboutcookies.org, or www.youronlinechoices.eu.



4.   Changes to our Cookie Notice

We may change this Cookie Notice from time to time. Please take a look at the
"Last Revised" legend at the top of this page to see when this Cookie Notice was
last revised. If we make significant changes to this Cookie Notice, we will
notify you of changes when you next visit any of our Sites.



5.   Contacts and comments

If you have any questions or comments regarding this Cookie Notice, please
contact us by email at ViaBenefitsPrivacy@wtwco.com