alliancedatabenefits.ehr.com Open in urlscan Pro
158.82.144.104  Public Scan

Submitted URL: https://alliancedatabenefits.ehr.com/
Effective URL: https://alliancedatabenefits.ehr.com/ESS/Account/LogOn?ReturnUrl=%2fESS
Submission: On November 17 via manual from US — Scanned from DE

Form analysis 1 forms found in the DOM

POST /ESS/Account/LogOn

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Text Content

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[ACCOUNT-LOGIN: Link.Login.Text]

Here you can:

 * Enroll in or change your benefits
 * Designate your beneficiaries
 * Use tools to help you determine your benefit needs
 * Securely email Alliance Data Benefits Enrollment with a benefits question

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Contact Us
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Privacy Notice

Website Privacy Notice

LAST UPDATED: August 2021

THIS NOTICE DESCRIBES HOW PERSONAL INFORMATION ABOUT YOU MAY BE USED AND
DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT
CAREFULLY.

WHO WE ARE
Willis Towers Watson, our affiliated entities, and successors in interest
("Willis Towers Watson," "we," "our," or "us") provide benefits enrollment,
benefits administration, and pension administration services, including the
creation and hosting of websites (collectively, "Services"), on behalf of
employers who offer healthcare, retirement, or similar employee benefit plans.
Our clients who provide health, retirement, or similar plans for the benefit of
their employees are referred to as "Plan Sponsors."

The Plan Sponsor of your benefit plan(s) has hired Willis Towers Watson to
provide these Services (including this website) to you. For most participants,
the Plan Sponsor is your current or former employer. The Services provide
benefits enrollment, eligibility, administration, and other support related to
the benefits programs made available to you by the Plan Sponsor.

SCOPE AND PURPOSE OF THIS NOTICE
Willis Towers Watson is committed to privacy and transparency in our information
practices. This Privacy Notice describes how we receive, collect, process, and
share your personal information when providing the Services, which include, but
are not limited to, this website, our telephone service centers, data import
files that we receive from the Plan Sponsor, other third-party import files
approved by the Plan Sponsor, and electronic communications such as
HTML-formatted email messages that may be sent to you.

This Privacy Notice describes our overall privacy and data protection practices
related to the Services. Our exact practices will depend on and will always be
limited by the terms of our contract with the Plan Sponsor. By utilizing the
Services, you are agreeing to the terms in this Privacy Notice. If you do not
agree to the terms in this Privacy Notice, please do not utilize the Services.

Please note that our collection, use, disclosure, and processing of personal
information about individuals will vary depending upon the circumstances. As a
result, in some cases, different or additional notices about our data collection
and processing practices may be provided and/or may apply to our processing of
certain personal information.

OUR ROLE
When providing the Services, Willis Towers Watson acts as a "data processor" or
"service provider" under applicable privacy and data protection laws. This means
that we will only process the personal information we collect about you through
the Services on behalf of and subject to the limitations and instructions that
we receive from the Plan Sponsor. If our contract with our client is more
restrictive than the terms of this Privacy Notice, the more restrictive contract
terms will apply.

The Plan Sponsor is the responsible "controller" or "business" under applicable
privacy laws with respect to your personal information. The Plan Sponsor's
privacy notices (and not this one) will apply to and control the processing of
personal information, except as set forth below. Please contact the Plan Sponsor
for more information regarding its data protection practices and/or review their
privacy notice for more information.



HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION
"Personal information" includes other similar terms under applicable privacy
laws such as "personal data" or "personally identifiable information." In
general, personal information is information that identifies, relates to,
describes, or is reasonably capable of being associated with, or could be linked
(directly or indirectly) with a particular individual or identifiable person.
The types of personal information we may collect include, but are not limited
to:

 * Name, contact information, and related identifiers (such as name, postal
   address, email address, unique personal identifier, online identifier,
   Internet Protocol address, account name, social security number, driver's
   license or state identification number);
 * Customer records (such as paper and electronic customer records containing
   personal information, such as name, signature, telephone number, insurance
   policy number, employment history, bank account number, credit card number,
   debit card number, or any other financial information, medical information,
   and health insurance information);
 * Characteristics of protected classifications (such as gender, age,
   disability, and citizenship status);
 * Biometric information (such as voice recordings, and sleep, health, or
   exercise data that are disclosed by you through the enrollment process);
 * Usage data (such as internet or other electronic network activity
   information, including information regarding your interaction with our
   websites and applications);
 * Geolocation data (such as precise geographic location information about a
   device used to access our website);
 * Audio/visual data (such as photographs, audio recordings, and other audio,
   electronic, visual, or similar information);
 * Professional or employment-related information (such as worksite, job
   responsibilities, salary history, and job end or termination date);
 * Information about education-related history or background (such as student
   status);
 * Profiles (such as a participant profile reflecting data from multiple
   sources).

Some of the information we collect is provided by the Plan Sponsor to confirm
whether you, your spouse or partner, and/or dependents are eligible for
benefits. You may be asked to provide additional information or to update or
correct information about yourself, your spouse or partner, your dependents, and
beneficiary designations.

If you submit any personal information relating to other people to us or to our
service providers in connection with the Services, you represent that you have
the authority to do so and to permit us to use the information in accordance
with this Privacy Notice and applicable laws.

How We May Collect Personal Information
We may collect personal information in a variety of ways, including, but not
limited to:

 * Through the Plan Sponsor: such as through data files from the Plan Sponsor.
 * Through the Services: such as when you model your benefits or provide or
   change your personal information through the website.
 * Offline: such as through mail or when you contact our telephone service
   center, if applicable.
 * From Other Sources: from third parties engaged by the Plan Sponsor to provide
   benefits-related services.

Google reCAPTCHA.To fight spam and abuse on our websites, we use Google
reCAPTCHA Enterprise which collects hardware and software information, such as
device and application data, and sends this data to Google for analysis. The
information collected is used solely for providing, maintaining, and improving
reCAPTCHA Enterprise and for general security purposes. It will not be used for
personalized advertising by Google. Our use of reCAPTCHA Enterprise is subject
to Google's Privacy Policy and Terms of Use.

How We May Use Personal Information
Our uses of personal information will be subject to and consistent with our
contractual agreements with the Plan Sponsor. The purposes for which we may
process personal information will vary depending upon the circumstances in which
we interact with you. In general, we use personal information that we collect
about you to provide the Services (for example, to determine your benefit
eligibility, validate election information, and otherwise facilitate your
enrollment) and to comply with legal obligations. In addition, to the extent
permitted by our contract with the Plan Sponsor, we may utilize personal
information the following ways:

 * To respond to your inquiries and fulfill your requests, such as to send you
   plan disclosures or benefit information. Your personal information may be
   shared with third-parties (a printer or other service provider, for instance)
   involved in fulfilling the order or request.
 * To send administrative information to you such as information regarding the
   Services and changes to our terms, conditions, and policies.
 * To personalize the content and information provided to you.
 * For our internal use to build or improve the quality of our Services.
 * For fraud monitoring and prevention and security purposes.
 * To audit and improve our Services, including in support of training and
   quality control efforts.
 * As we believe to be necessary: (a) to comply with the law or a legal
   obligation; (b) to comply with legal process (such as a subpoena or court
   order); and (c) to protect the rights, privacy, safety, and property of
   ourselves and others.
 * To contact you regarding the Services by using an automated telephone dialing
   system and/or artificial or prerecorded voice.



Aggregated and de-identified information. Subject to any contractual agreement
with the Plan Sponsor, we may use de-identified and/or aggregated information
and reports related to the Services 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. Any information
contained in such reports is not relatable or identifiable to a particular
individual or Plan Sponsor. We do not share any personal information with third
parties in such cases.

How Personal Information May Be Disclosed
Your personal information may be disclosed or transferred, in accordance with
our contract with the Plan Sponsor, as follows:

 * To the Plan Sponsor.
 * To our affiliated companies, vendors, and service providers who perform
   functions in support of the Services, such as website hosting, data analysis,
   payment processing, order fulfillment, information technology and related
   infrastructure provision, customer service, email delivery, and auditing.
 * To vendors and third parties selected by the Plan Sponsor to provide you with
   services associated with your benefits and/or provide professional services
   to the Plan. Use of your personal information by the Plan Sponsor or such
   vendors and third parties is governed by the privacy policies of the Plan
   Sponsor or the vendors and third parties, not this Privacy Notice.
 * To other individuals and third parties as directed by the Plan Sponsor or by
   you.
 * To a third party 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).
 * As we believe to be necessary: (a) to comply with the law or a legal
   obligation; (b) to comply with legal process (such as a subpoena or court
   order); or (c) to protect the rights, privacy, safety, and property of us and
   others.



COOKIES
Our website may use first-party and third-party cookies and similar technology
to gather device and usage information when users visit the website. We use the
information for security purposes, to facilitate navigation, to display
information more effectively, to personalize your experience while using the
website, and to recognize your computer to assist your use of the website. We
also gather statistical information about use of the website to improve design
and functionality and understand how the website is used. We do not use
advertising cookies on the website.

There are different types of cookies, for example:

 * Cookies transferred directly by Willis Towers Watson or the website vendor
   ('first party cookies') and cookies transferred on our behalf, for example by
   our 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 ('session cookies'). Session
   cookies are deleted automatically from your device once you close your
   browser. Other cookies are 'permanent cookies', meaning that they remain on
   your device after your browser is closed. For example, permanent cookies
   recognize your device when you open your browser and browse the internet
   again.



Below we explain the different types of cookies and similar technologies that
may be used on the Sites. Where we use third party cookies, we provide a link to
the third party's cookie policy.

Strictly Necessary Cookies. Strictly necessary cookies enable you to navigate
the Sites and to use their services and features. Without these necessary
cookies, the Sites will not function properly and we may not be able to provide
the Sites or certain services or features.

Functional Cookies. Functional cookies enable the website to provide enhanced
functionality and personalization. They allow us to see the overall patterns of
usage on the Sites. We use the information to analyze traffic on and improve the
Sites. They may be set by us or by third party providers whose services we have
added to our pages. Without these cookies, some or all of these services may not
function properly.

Performance Cookies. Performance cookies allow us to count visits and traffic
sources so we can measure and improve the performance of our site. They help us
to know which pages are the most and least popular and see how visitors move
around the site. All information these cookies collect is aggregated and
therefore anonymous. Without these cookies, we will not know when users have
visited our site and will not be able to monitor its performance.

We may use the following cookies for our site:



Cookie Name Cookie Type Description or Purpose Persistent or Session 1st or 3rd
Party Cookie Session Cookie - Typical naming pattern: [SystemName]Ess Strictly
Necessary Unique Identifier, identifying user's session Session 1st
Authorization Cookie - Typical naming pattern: AuthId Strictly Necessary Unique
Identifier, identifying user's session Session 1st Verification Token - Typical
naming pattern: __RequestVerificationToken_[UniqueIdentifier] Strictly Necessary
Unique Identifier, identifying user's session Session 1st Network Load Balancing
Cookie - Typical naming pattern: F5-cookie Strictly Necessary Identifier used to
route user traffic to specific resource Session 1st Culture Code - Typical
naming pattern: [SystemName]_CultureCode Functional User culture-code Persistent
1st .ASPXBrowserOverride Functional User mobile or full site selection
Persistent 1st Google Captcha - various naming patterns Functional User
validation Persistent with expiration 3rd www.google.com/recaptcha/about/
SamlSession Functional Third-party initiated Single Sign On Persistent 1st
JSESSIONID Performance Application performance monitoring Session 3rd
https://newrelic.com/ WTID Performance Application trend and usage monitoring
Session 3rd
www.webtrends.com/


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 to enable or disable cookies can be found on your Internet browser
provider's website via your help screen.

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.

THIRD PARTY SERVICES
The Services may include links to websites for the Plan Sponsor and other
third-parties such as insurance carriers, government agencies, and financial
service providers. If you access these links, you will be leaving the Services.
Your use of such third-party sites is governed by the privacy policies of those
third parties, not by this Privacy Notice. This Privacy Notice does not address,
and we are not responsible for, the privacy, information, or other practices of
any third parties, including the Plan Sponsor or any third party operating any
site or service to which the Services may link. The inclusion of a link on the
Services does not imply endorsement of the linked site or service by us or by
our affiliates.

SECURITY
We have implemented security measures to protect personal information we
collect. Unfortunately, no data transmission or storage system can be guaranteed
to be 100% secure. If you have reason to believe that your interaction with us
is no longer secure (for example, if you believe that the security of your
account has been compromised), please immediately notify us in accordance with
the Contacting Us section below.

YOUR DATA PRIVACY RIGHTS
Certain individuals may have a legal right to review, correct, update, or delete
personal information pursuant to applicable privacy and data protection laws. As
indicated above, Willis Towers Watson acts as a "data processor" or "service
provider" under applicable privacy and data protection laws. For this reason,
the Plan Sponsor, not Willis Towers Watson, is legally responsible for
fulfilling any legal rights requests you might have.

Data may be accessed and, in some cases, corrected through our self-service
website. You may also be able to access data and make data corrections through a
toll-free telephone number established for the purpose of administering your
benefits. If you do not want to, or you are unable to, self-serve through our
website or the toll-free telephone number (if any) established for the purpose
of administering benefits, you may exercise your rights by contacting the Plan
Sponsor subject to applicable law.

If you reside in Canada, you have the right to request access to any additional
information that we hold about you subject to limited exceptions under
applicable law. If you believe that any information that is held about you is
inaccurate, you may also request a correction.

Applicable privacy and data protection law may limit the fulfillment of a rights
request. For example, the Plan Sponsor may limit a rights request so that it can
retain certain information for recordkeeping purposes and/or to complete any
transactions that began prior to the request for a change or deletion.

RETENTION PERIOD
We will retain your personal information as directed by the Plan Sponsor and
otherwise for the period necessary to fulfill the purposes outlined in this
Privacy Notice, or longer where required by law.



USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of sixteen (16), and
we request that individuals under age 16 not provide personal information
through the Services.

Because of the nature of our Services, we do not solicit or intentionally
receive information from children under the age of 16, except that we do collect
information regarding dependent children that pertains to their benefits
coverage and to beneficiary designations.



CROSS-BORDER TRANSFER
To the extent allowed by our agreement with the Plan Sponsor, your personal
information may be collected, stored, and processed in any country where we have
facilities or in which we engage service providers. By using the Services, you
acknowledge that we may transfer your personal information to countries outside
of your country of residence, including the United States, which may have laws
and data protection rules that are different from those of your country of
residence. While your information is in another jurisdiction, it may be accessed
by the local courts, law enforcement, and national security authorities. To
receive information regarding our policies and procedures with respect to
service providers in different countries, please email or write to us at the
address in the Contacting Us section below.

SENSITIVE INFORMATION
We ask that you not send us, and not disclose, any sensitive personal
information (for example, information related to racial or ethnic origin,
political opinions, religion or other beliefs, or criminal background) on or
through the Services or otherwise.

UPDATES TO THIS PRIVACY NOTICE
We may change this Privacy Notice from time to time. The "LAST UPDATED" legend
at the top of this page indicates when this Privacy Notice was last revised. We
encourage you to refer to this Privacy Notice often for the latest information
about our personal information practices. By continuing to utilize the Services,
you are agreeing to the terms contained in the last revised Privacy Notice.

INFORMATION FOR CALIFORNIA RESIDENTS
In providing the Services, we do not "sell" any personal information under the
California Consumer Privacy Act (CCPA).

If you wish to submit a consumer rights request under the CCPA, please do so
through the Plan Sponsor. We will cooperate with and facilitate these requests
to the extent required by law.



CONTACTING US
If you have any questions about this Privacy Notice or how your personal
information may be used or disclosed, please contact us at
privacy@willistowerswatson.com or toll-free at 888-471-4502. Because email
communications are not always secure, please do not include credit card or other
sensitive information in your emails to us.

For all other inquiries, please refer to the contact information on this website
or the service center contact information provided by your Plan Sponsor.



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