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GLOBAL WEBSITE PRIVACY NOTICE
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Last Updated: December 2024
WTW operates worldwide through subsidiary and affiliate companies (collectively
“we” “us” or “WTW”). 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.
1. SCOPE
This privacy notice describes, generally, how WTW, 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, marketing communications and associated services
that link to this privacy notice, including www.wtwco.com (the “Homepage”)
and other websites controlled by WTW (collectively, the “Websites”)
* our former, current and prospective clients, including information related to
the points of contact at our commercial entity clients,
* individuals who communicate with us
* individuals who use our products and services (“Services”), either for
themselves on or behalf of an organization or entity, and individuals whose
personal information we receive in providing the Services. This includes
products, Services, and websites made available through the use of authorized
guest accounts.
Our collection, use, 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 privacy 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
WTW entity.
2. CONTROLLER AND RESPONSIBLE WTW GROUP ENTITIES
When providing Services to clients, WTW may act as a “service provider” or
“processor” “contractor,” 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,” “businesses,”
or “responsible parties,” "organisations," or other equivalent classification
under data privacy law 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 about which privacy notice may apply, please contact us as at
privacy@wtwco.com.
Where we act in our capacity as a "controller," "business," "responsible party"
or "organisation," as applicable, with respect to personal information, for the
purposes of the European Union’s General Data Protection Regulation (“GDPR”) and
other relevant applicable laws, including but not limited to the Cayman Islands
Data Protection Law (“DPL”) and the Personal Information Protection Act 2016 of
Bermuda ("PIPA"), this privacy notice will apply, as explained below.
Furthermore, WTW plc is the controller unless the processing is controlled by
another WTW entity.
Our Websites. The Websites are controlled by WTW plc, unless a Website
identifies (in its terms of use or otherwise) that it is controlled by another
WTW entity. WTW group companies (as well as individual divisions of WTW) 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.wtwco.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 any such website or 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. WTW 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 WTW group company with whom you engage is the
controller for your personal information, together with WTW plc, the parent
company for the WTW group. (Click here to view the WTW group companies).
3. CROSS-BORDER TRANSFER
WTW 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
Canada, the United States, India, Quebec, Bermuda, 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 using the details below.
4. PERSONAL INFORMATION COLLECTED
We collect personal information directly from individuals, automatically related
to the use of the Services and engagement with our marketing 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).
Sometimes we collect information about you in conjunction with our partners or
other companies that we work with to provide you our Services, or they provide
us with your personal information consistent with your direction to do so.
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. This may at times include “sensitive" information (otherwise known as
“special categories of personal information” under the GDPR, “sensitive personal
data” under the DPL or “sensitive personal information” under the California
Consumer Privacy Act (“CCPA”) and PIPA, such as health records or criminal
conviction data; 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
Services and engagement with our marketing and 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 or whether you
engage with email communications);
* third-parties such as insurance companies, other insurance brokers or agents,
credit reporting organizations, motor vehicle and driver licensing
authorities, and financial institutions,
* 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) or within our emails and newsletters
* from our clients in connection with us providing professional services to
them or to the companies for which they work
* 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), 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.
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, 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
state or federal law such as race, color, sex, age, religion, national
origin, disability and citizenship status.
* 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 or email communication.
* Geolocation data: precise geographic location information about a particular
individual or device.
* 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, including
job application materials, hire state, job responsibilities, salary history,
disciplinary or other related human resources records, performance
evaluations, job end or termination date.
* Education information: education information and records, including
educational history, academic status, achievements, or discipline.
* 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.
* Account Access Information: an account log-in, financial account, debit card,
or credit card number in combination with any required security or access
code, password, or credentials allowing access to an account.
* Other forms of Sensitive Personal Data: information concerning racial or
ethnic origin, religious or philosophical beliefs, marital status, physical
or mental disability, physical and mental health, family status, religious
beliefs, political opinions, union membership, health, sex, sex life, or
sexual orientation.
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 use or 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 or your company
(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; and
* 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.
* Publicly available information: the personal information is publicly
available information and will be used for a purpose that is consistent with
the purpose of its public availability.
* Medical or Emergency purposes: The processing is necessary for medical
purposes (applicable to Cayman Islands DPL) or is necessary to respond to an
emergency that threatens the life, health or security of an individual or the
public (applicable to PIPA).
* Your reasonable expectations (other than for sensitive personal information):
where a reasonable person would view that you would not reasonably request
that we cease or not use your personal information and that our use does not
prejudice your rights (applicable to PIPA).
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, fulfil your orders and requests, process your
payments and provide technical support; Risk management and Modelling; and
for other customer service and support purposes. (Legal basis: performance of
our contract with you, our legitimate interests and/or with your consent)
* 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 and/or with your
consent)
* 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. 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.
6. DISCLOSURE OF PERSONAL INFORMATION
We disclose the personal information we process as set forth in this section.
A. Purposes for Which We Disclose Personal Information
WTW may disclose your personal information to any WTW group company for the uses
and purposes set out above, including for marketing the products and services
offered by other businesses across the WTW 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 WTW, 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, amalgamation,
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
* to third party insurers for purposes of obtaining coverage for you
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 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” or “shared” (as those terms are 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
* 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 or shared. 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,
and it defines “share” in pertinent part as disclosing personal information to a
third party for cross-context behavioral advertising. Pursuant to the CCPA, the
categories of Personal Information that we may “sell” as defined under the CCPA
includes:
* Identifiers
* Usage data
* Electronic network activity information, including, but not limited to,
browsing history, search history, and information regarding your interaction
with our Websites
We have “sold” the categories of personal information listed above to data
analytics providers in the preceding twelve months.
We do not “share” personal information with third parties for cross-context
behavioral advertising.
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.
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.
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 are
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
WTW has implemented technical and organizational security measures with the goal
of protecting the personal information we process. 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 in writing related to your
personal information, except that requests under U.S. state privacy laws must be
made in accordance with the information provided in the section below applicable
to each particular state:
* By submitting a request to us at wtwco.com
* By contacting us at 1-800-889-9288 (toll free)
* By emailing us at dataaccessrequest@wtwco.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@wtwco.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, and in any event
within any applicable statutory timeframes.
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 honor 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. WTW 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
privacy notice for the following jurisdictions:
* EU/EEA/UK: If you are in the European Union / European Economic Area /
United Kingdom, please go to the Additional Information for Certain
Jurisdictions page for details about your rights under the GDPR.
* U.S. State Privacy Laws: If you are a resident of California, Virginia, or
Connecticut, you have certain rights under U.S. state privacy laws regarding
your personal information as set forth below at our in the Additional
Information for Certain Jurisdictions page.
* Other Jurisdictions: If your personal data is subject to the privacy laws
enacted in Argentina, Brazil, Bermuda, Cayman Islands, Colombia, Costa Rica,
Nicaragua, or Panama please see our Additional Information for Certain
Jurisdictions page.
11. RETENTION PERIOD
WTW stores personal information as needed to accomplish the purposes identified
in this privacy notice and to meet legal requirements, including legal and
compliance requirements regarding records retention, resolving disputes, and
enforcing our agreements. This means that WTW may be required to maintain your
information, for example, to: (1) comply with our legal or regulatory compliance
needs (e.g., maintaining records of transactions you have made with us); (2) to
exercise, establish or defend legal claims; and/or (3) to protect against
fraudulent or abusive activity on our services and systems. For these and
possibly other reasons, we may be unable to delete personal information upon
request of an individual in certain cases.
We may retain different categories of information for different periods of time
for the instances stated above. However, it is our policy as an organization
that when personal information is no longer needed or after legal authority to
retain it has expired, personal information will be destroyed in accordance with
applicable law and pursuant to procedures established in relation to the
relevant WTW services, systems, or processes. Retention periods for records
maintained by WTW, including those containing personal data are established
based upon business need, statutory and regulatory record keeping requirements
in the geographies where we do business, and legal obligations. If you have any
further questions about our handling of personal information, please contact us
at privacy@wtwco.com.
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. Where we receive personal information related to children
in the course of providing Services, we rely on the legal bases set forth above
to process their information.
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. PRIVACY OFFICER, 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@wtwco.com.
In some countries, there is a legal requirement to provide a named individual or
privacy officer and their contact details. These are:
CountryNameContact DetailsCanada
Attention of the Privacy Officer
130 King St W, Exchange Tower, Suite 1500
P.O. Box 424
Toronto, ON M5X 1E3
Email: privacy@wtwco.com
Phone: 416.960.2700
Nigeria
Adewunmi Akinmodiro
Adewunmi.Akinmodiro@wtwco.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@wtwco.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@wtwco.com
Willis South Africa (Pty) Ltd
Illovo Edge, 1 Harries Road, Illovo, Johannesburg 2196
Bermuda
Attention of the Privacy Officer
90 Pitts Bay Road
Wellesley House, Floor 2
Hamilton HM 08
Email: privacy@wtwco.com
Phone: +1 441 295 1272
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exercise that choice here. To do so, switch the toggle button above to grey,
then click “Confirm My Choices.” If you do this, non-essential cookies, which
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