Last Updated:  14 February 2023

 

PRIVACY NOTICE

 

This privacy notice describes how Towers Watson Limited (the "Company," "we," "us," or "our") handles personal information collected through this retirement options tool website (the "Website").  By providing personal information to us, you agree to this privacy notice.

 

1. SCOPE OF THIS PRIVACY NOTICE

 

This privacy notice only applies to the Website.

 

The Website and specific web pages linked from the Website may be subject to separate terms of use (including separate privacy notices). You must not provide Personal Information if you do not accept such terms of use.

 

Where links from our Website are provided to third-party websites, we are not responsible for those websites. 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.

 

2. CROSS-BORDER TRANSFER

 

Your Personal Information may be stored and processed in any country where we or our affiliates have facilities or engage service providers, and by using the Website you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. We have established safeguards to protect Personal Information that is transferred to other countries, including appropriate contractual protections.

 

3. PERSONAL INFORMATION WE MAY COLLECT FROM YOU

 

"Personal Information" is information that identifies you as an individual or relates to an identifiable individual. Personal Information we may collect through our Website includes:

your name (optional), date of birth and details regarding your pension benefits, but this data is only stored for the duration of your session;

any other information you may voluntarily submit to us by completing any form on our Website; and

details of your visits to and usage of our Website

 

We may collect Personal Information in various ways:

 

from any form you may complete and submit through our Website;

from session 'cookies' and other similar tools deployed on parts of our Website (for further information regarding cookies used on our Website, please see Section 6 below) 

 

4. HOW WE MAY USE YOUR PERSONAL INFORMATION

 

We may use Personal Information about you for our legitimate business interests, including the following:

 

to facilitate your participation in interactive features you may choose to use on our Website and personalize your experience on the Website by presenting content tailored to you;

for our business purposes, such as data analysis, audits, developing new products, enhancing, improving or modifying our Website, and identifying usage trends.

 

5. DISCLOSURE OF YOUR PERSONAL INFORMATION

 

We may disclose your Personal Information to our affiliates for the uses and purposes set out above. We may also disclose your Personal Information to third parties for the following reasons:

 

to third party service providers such as entities providing customer service, auditing, hosting our website and other services;

if we are obliged to disclose your Personal Information under applicable law or regulation, which may include laws outside your country of residence;

in order to enforce or apply our Website terms of use, or to protect the rights, privacy, safety or property of the Company, our clients, affiliates or other parties;

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 accordance with the separate terms and conditions of use that may attach to our website links.

 

6. OTHER INFORMATION WE MAY COLLECT

 

"Other Information" is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. We may collect Other Information in various ways.

 

For instance, when you visit our Website, our server may record your IP address. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Website.  We may also derive your approximate location and company details from your IP address. We may also gather Other Information such as the type of your internet browser, your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and the name and version of the Website you are using, which we use to provide you with a more effective service.

 

Cookies: Additionally, when you visit our Website, we may store a 'cookie' on the hard drive of your computer. Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on the Website, pages visited, language preferences, and other anonymous traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Website and to recognize your computer in order to assist your use of the Website.  We also gather statistical information about use of the Website in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.

 

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 Website. 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 Website.  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.

 

ARRAffinity Cookie: We also use this cookie which is set by websites run on the Windows Azure cloud platform. It is used for load balancing to make sure the visitor page requests are routed to the same server in any browsing session.

 

Seen_cookie_warning: This cookie is used by the website to determine whether the cookies banner has been shown to the user before.

 

Do Not Track signals:  Please note that our Website does not recognize or respond to any signal which your browser might transmit through the so-called 'Do Not Track' feature your browser might have. Enabling such feature on your browser will not necessarily affect the way in which our Website operates, and if you wish to disable cookies on our Website, you should not rely on any 'Do Not Track' feature your browser might have.

 

Pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Website to, among other things, track the actions of users of the Website (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Website and response rates.

 

By aggregating information:  Aggregated Personal Information does not personally identify you or any other user of the Website (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

 

7. HOW WE MAY USE AND DISCLOSE OTHER INFORMATION

 

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  In some instances, we may combine Other Information with Personal Information (such as combining your name with your location).  If we do, we will treat the combined information as Personal Information as long as it is combined.

 

8. SECURITY

 

We maintain appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorized access, disclosure or alteration. Despite this, the security of the transmission of information via the Internet cannot always be guaranteed and you acknowledge this in your access and use of our Website. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contact & Comments" section below.

 

9. CHOICES AND ACCESS

 

You may withdraw your consent to this privacy notice at any time by sending your request to us at the address listed in the "Contact & Comments" section below. Please note that even if you withdraw your consent, we may still have the right or obligation under applicable law to collect, use, transfer or disclose Personal Information without your consent and we reserve the right to undertake that activity when appropriate.

 

If you would like to review, correct, update, suppress, or restrict the processing of your Personal Information or request a copy of Personal Information about you, you may contact us by sending your request by email or postal mail to the addresses 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. 

 

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

 

10. RETENTION PERIOD

 

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this privacy notice unless a longer retention period is required or permitted by law.

 

11. USE OF WEBSITE BY MINORS

 

The Website is not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Information through the Website.

 

12. SENSITIVE INFORMATION

 

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Website.

 

13. CHANGES TO OUR PRIVACY NOTICE

 

From time to time, we may change our privacy notice. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised. Checking this effective date allows you to determine whether there have been changes since the last time you reviewed the notice. We will notify you of changes to this privacy notice by posting the revised privacy notice on our Website. Your use of the Website following these changes means that you accept the revised privacy notice.

 

14. CONTACT & COMMENTS

 

The Website is controlled by the Company.  If you have any questions or comments regarding this privacy notice, please contact retirementoptionstool@wtwco.com. You have the right to provide a comment or lodge a complaint with a supervisory authority regarding this privacy notice.