Privacy Statement

Mercer takes your privacy seriously because we know that you do. This privacy statement (this "Notice") is applicable to this website (the "Website") and to the associated services Mercer HR Services, LLC (together with its applicable affiliates, "Mercer" or "we") provides as a third party service provider to your Plan Sponsor ("Plan Sponsor"). This Notice describes how Mercer may collect, use and share the personal information you submit through this Website.

Please read this Notice carefully and be aware that we may change it from time to time. As a result, we recommend that you check back regularly to this page to be apprised of any updates or changes. We last revised this Notice July 31, 2014.

If you have questions about how we will use your personal information, or if you want to have access to it, make corrections to it, or make any inquiries about how it is maintained, used or made available to you, they should be directed to your Plan Sponsor's Privacy, Benefits or Human Resources Department(s). If you have any other questions, please direct them to privacy.americas@mercer.com. Mercer complies with applicable privacy laws and regulations in every jurisdiction in which we operate. Mercer also complies with its internal privacy policies and with the privacy policies of our parent company, Marsh & McLennan Companies, Inc.

The responsible privacy officer at Mercer is the Americas Privacy Leader, who can be contacted at privacy.americas@mercer.com.

Use of this Website

You can use this Website to access services ("Services") provided or arranged by Mercer , subject to the Web Site Terms of Use (the "Terms of Use") and your Plan Sponsor's policies; you acknowledge that you have read, understood, and accepted the practices described in this Notice and the Terms of Use. This Website is intended for adults. If you are not yet 18 years old or if you lack the legal authority to form legally binding contracts, please do not use this Website. We do not solicit or knowingly collect any information from visitors under 18 years of age.

Pursuant to the Terms of Use, you may provide the personal information of other individuals, including minors. Plan Sponsor and Mercer rely on your authority to provide this information, and use of this Website is conditional upon your authority under applicable law to provide this information on their behalf.

Personal Information

Personal information includes both personally identifiable information ("PII") that we maintain and process in connection with providing Services to you or your Plan Sponsor, typically including your full name, email address and Social Security Number, as well as data that can, under certain circumstances, identify you as an individual ("Related Data"). Depending on the nature of the Services we are providing to you and your Plan Sponsor, your PII may also include:

  • Financial information such as financial account number, or credit or debit card number;
  • Information provided on applications or other forms by you, or acquired from other persons (such as affiliates, government agencies, your Plan Sponsor, insurers, or other third parties) for the purpose of obtaining or providing the Services through this Website;
  • Payroll information and salary, employment, retirement and pension related information;
  • Personal health information, including information regarding past, present or future health or mental condition or payment for health care, or information regarding the provision of health care to an individual;
  • Information on dependents and beneficiaries; and/or
  • Decisions you may make in relation to those benefits or Services provided to you by your Plan Sponsor that are administered by Mercer or that you may otherwise elect to obtain.

Mercer operates this Website and provides administrative services in connection with certain employee, former employee and retiree benefits sponsored or provided by your Plan Sponsor. In this role, Mercer has access to your PII and Related Data for purposes of performing those Services, and for informing you of options or benefits which may be of interest to you. For these purposes, we may also:

    (a) Collect:

      i. Contact information and other information that identifies you personally,

      ii. Demographic information, or

      iii. E-mail addresses and other information you provide when you send us e-mail or other online chat or instant messenger messages;
    (b) Request other information from you; or
    (c) Gather information when you use this Website as set out in "Tracking Technologies".

We will also collect information reasonably necessary to evidence your instructions to us concerning your choices and elections in relation to the benefits we administer and the Services we provide.

By accessing, browsing, or using this Website, you acknowledge that you have read, understand and accept the practices described in this Notice. From time to time, Mercer may modify this Notice to reflect industry initiatives or changes in the law, the collection of and/or our practices relating to PII and Related Data, the features of this Website, or technology. We will notify you of such modifications through this Website by posting updated version of this Notice. Your continued use of this Website after such revisions signifies your acceptance of the modified Notice. Accordingly, it is important that you regularly review this Notice to ensure that you are aware of any changes to Mercer's privacy practices or policies.

Links

This Website may contain links to other sites that are linked to or integrated with the websites operated by organizations other than Mercer. Mercer is not responsible for the privacy practices of websites operated by any other parties that are linked to or integrated with this Website. Once you have left this Website via such a link, you should refer to those websites' separate privacy policies and practices to determine how they will handle any PII and Related Data they collect from you.

Information We Collect and its Uses

Mercer may collect PII and Related Data from you when you use this Website to select and manage your employee or retiree benefits as outlined above under "Personal Information." We also receive data about you and your beneficiaries from your Plan Sponsor in the form of employment-related records and information necessary to administer your benefit plan enrollment and coverage. The information we receive varies depending on the nature of the services that we provide for you or your Plan Sponsor. Mercer contact information and other identifiers, demographic information, employment information and pension related information as well as e-mail addresses and other contact information you provide when you send us e-mail or other online chat or instant messenger messages or request other information from us may also be collected for the purposes set out above under Personal Information, and for the operation and administration of this Website. Uses of this personal information, in addition to the uses otherwise described herein, include:

  • Establishing and maintaining communications with you;
  • Where you have requested a Service from this Website, assisting you in the completion of your requests, the assessment of your eligibility for any such requested Service, the processing and maintenance of the Service, as well as any applicable renewal of such Service;
  • Responding to your inquiries about applications, accounts and other services;
  • Making proposals for future service needs;
  • Allowing our affiliated companies to notify you of certain products or services offered by our affiliated companies;
  • Processing transactions through service providers;
  • Protecting against fraud, suspicious or other illegal activities; and
  • Compiling statistics for analysis of our sites and our business.

Tracking Technologies

We may analyze your history of using this Website by collecting data generated by your activities, including through the use of cookies. Your history of using this Website may also be analyzed for quality improvement and control, security and system monitoring purposes, or to measure the number of visits, pages visited, and average time you spend on this Website.

A cookie is a small text file that a website stores on your computer to identify you during a visit and between visits. Like many other sites, this Website uses cookies to enable the systems to recognize your browser and to navigate this Website more easily. For all visitors to this Website, cookies are used to collect clickstream data, including: the Internet protocol (IP) address used to connect your computer to the internet; computer and connection information such as browser type and version, operating system, and platform; the Uniform Resource Locator (URL) from which you linked to this Website; and possibly, certain other Web protocol header information. Your path through this Website may be tracked to deliver information that may be of interest to you while you are on this Website. Your website use history, through collected clickstream data, including cookies, may also be analyzed. The tracking and website use history information described in this Notice may be shared with and disclosed to your Plan Sponsor.

If you disable cookies, functionality of this Website may be inhibited, and this Website's may not function properly or present to you through your browser correctly.

The major browsers have attempted to implement the draft "Do Not Track" ("DNT") standard of the World Wide Web Consortium ("W3C") in their latest releases. As this standard has not been finalized, this Website is not compatible with DNT.

This website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. It could mean that we advertise to previous visitors who haven't completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone's past visits to this Website. Any data collected will be used in accordance with this privacy policy and Google's privacy policy. You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

Sharing and Disclosure of Personal Information

As mentioned above, your Plan Sponsor has retained Mercer to operate this Website in connection with the services Mercer provides to it, and in that role Mercer may collect PII and Related Data. Mercer will never sell your PII. Mercer may, however, share or disclose information you provide to us, including PII, to other companies and people under the following circumstances:

  • Your Plan Sponsor: As we operate on behalf of and under a contract with your Plan Sponsor to provide Services and to administer benefits, we share information with your Plan Sponsor. We also share data with third parties related to or providing Services for your Plan Sponsor, such as vendors, insurance companies or Plan trustees, pursuant to your Plan Sponsor's directions.
  • Your Instructions: Except as otherwise set forth in this Notice, we may share information you submit on or to this Website solely for and in connection with the provision of Service(s) you have requested from Mercer or that Mercer has contracted with your Plan Sponsor to provide. As well, you may select from optional Services and benefits, and if you do so, we will act on your instructions to share your information in order to fulfill your requests.
  • Agents and Contractors: Your PII and Related Data may be shared with other outside contractors or agents who perform services for your Plan Sponsor, or for Mercer to help manage and run this Website. These other companies may be supplied with or have access to your PII and Related Data solely for the purpose of providing such services to you, the Plan Sponsor or to Mercer, or to assess eligibility for coverage, obtain coverage, or to offer or obtain related products and services.
  • Mercer Affiliates: The Plan Sponsor and Mercer may also share your PII and Related Data with Mercer's affiliates and subsidiaries to perform or provide Services for you or the Plan Sponsor.
  • Legal Matters: Unless otherwise described herein, Mercer will not share your PII and Related Data with other nonaffiliated third parties, except Mercer may disclose your PII, Related Data, or non-PII, to the extent permitted by applicable law, in order to: (a) protect or defend its legal rights or property, or the rights or property of its employees, agents and contractors (including enforcement of its agreements); (b) protect the safety and security of users of this Website or members of the public, including by acting in urgent circumstances; (c) protect against fraud or for risk management purposes; and (d) comply with the law or legal process.
  • Business Transfers: In addition, if Mercer sells all or part of its business or makes a sale or transfer of all or a material part of its assets, or is otherwise involved in a merger or transfer of all or a material part of its business, then subject to applicable law, Mercer may transfer your PII, Related Data, and any other information you have submitted to this Website to the acquiring party or parties, or to their advisors, as part of that transaction.

Security

Mercer places a high priority on keeping your information secure. Mercer maintains this Website and all associated data with technical, administrative, and physical safeguards designed to protect against loss, unauthorized access, destruction, misuse, modification, and improper disclosure. The information you enter on this Website, including your username and password/PIN, are stored securely on data servers, and your account password/PIN is encrypted on a database. However, no computer system or the information it stores can ever be fully protected against every possible hazard. Mercer shall provide reasonable and appropriate security controls to protect this Website and its information against foreseeable hazards.

You must maintain the confidentiality of your username and password/PIN, and you are responsible for preventing unauthorized access to your computer.

Storage of and Access to Information

All information that you submit through this Website is collected, stored, and processed in the United States; however, PII and Related Data you provide may be accessed from locations outside the United States by the Plan Sponsor, Mercer, and other contractors of the Plan Sponsor or Mercer.

Mercer has established records retention policies for the jurisdictions in which we operate. Mercer is obligated by law to retain your personal information for varying periods of time, depending on the nature of the information and the legal requirements of the applicable jurisdiction. Accordingly, portions of your records may be retained for periods of time different than for other portions, depending on the nature of the records and which jurisdiction's laws applies to them. We are also required to maintain records to comply with the terms of our contract with your Plan Sponsor, and with our own business requirements, and for reasons that include evidencing our work and providing materials to comply with the requirements of an audit.

We may also retain your information for a period of time in backup systems as a precaution against system failures, or as required to meet obligations to retain records in the event of a dispute or legal action in which we, our clients or their Plan participants, may be involved. While you as a Plan participant cannot request that personal information be deleted, we keep your personal information secure, and we will dispose of PII or return it to your Plan Sponsor as soon as practicable after we have fulfilled our retention requirements.

California Privacy Rights

YOUR PRIVACY RIGHTS - California Civil Code Section 1798.83 permits California residents to request certain information regarding the disclosure of any personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to privacy.americas@mercer.com.

Contacts and Complaints

This Web Site is operated by Mercer HR Services, LLC and its affiliates, One Investors Way, Norwood, MA 02062, USA.

If you have any questions or concerns about this notice, please address them to Mercer at privacy.americas@mercer.com.