1. Scope of this privacy notice
This privacy notice applies to the Willis Towers Watson Affinity Insurance Web Portal (the "Website"). Its effective date is 25 November 2020.
The Website is made available to you by Willis Towers Watson plc ("Willis Towers Watson") who is responsible for collecting personal data through the Website.
Where links from the 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. We are not responsible for how your Personal Information is handled by such third-party websites. Please review the privacy policy of any third party to understand how your Personal Information is handled by them.
We work closely with a variety of Insurers to deliver the Affinity service. Insurance involves the use and disclosure of Personal Information by various insurance market practice participants such as intermediaries, insurers and reinsurers.
2. Cross-border transfer
Your Personal Information may be stored and processed in any country where the Willis Towers Watson group maintains facilities or in which it engages service providers, and by using the Website you acknowledge that your personal data may be transferred to, and processed in, countries outside of your country of residence, 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. For more information on the appropriate safeguards in place, please contact us using the details in the “Contacts and Comments” section below.
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 Websites includes:
- your name, postal address, email address, phone number, occupation and other contact information
- your age, gender and date of birth
- log in information such as a username and password
- copies of your identification documents
- payment information such as credit card or bank details
- information required by our partner insurance providers to provide a quote (such as your employment details, salary, family details, assets, motor vehicle history or medical history)
- transactional information, such as details of your insurance policy
- information about any claims you make on your insurance policy
- any interest you have in relation to our services or our practice areas
- any 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.
Some categories of personal information we collect are known as special categories of personal data, or "Sensitive Personal Information". This may include information that relates to your health such as your medical history or current medical status if you are making a claim that requires this information. You may also be asked to provide information about criminal records. The law imposes special requirements on us when we collect this type of information, and we will ask for your consent to process this information where required by applicable law.
We may collect Personal Information in various ways:
- directly from you, when you submit your details to register or request a quote, purchase a policy or register a claim
- from any form you may complete and submit through our Websites, for example information collected from the “Contact Us” page of our Websites
- from the content of surveys that you may complete on our Websites
- from session ‘cookies’ and other similar tools deployed on parts of our Websites that can only be accessed by authenticated users who are logged into the Website (for further information regarding cookies used on our Websites, please see Section 7 below)
4. How we may use your personal information
We may use Personal Information about you for our legitimate business interests or for the execution and management of your insurance contract, including the following:
- to operate the Website and provide our services
- to ensure you are eligible for the products you apply for through the Website
- to conduct analysis that allows us to assess risk, price our products, develop new products, and improve the Website and our services
- for fraud prevention and detection purposes
- to facilitate your participation in interactive features you may choose to use on our Websites and personalize your experience on the Website by presenting content tailored to you
- to manage, run and administer your account(s) with the Website
- to correspond with you, notify you of events or changes to our service, or otherwise to fulfil your requests and respond to your queries and requests for information
- for direct marketing purposes (subject to compliance with applicable laws).
5. Legal bases for processing Personal Information
We must have a legal basis to process your Personal Information. In most cases the legal basis will be one of the following:
- for the performance of your contract
- for our legitimate interests, for example to provide and improve our services, manage our risks, maintain accurate transaction records, and manage our business in an efficient way
- for the legitimate interests of third party product providers (for example, to investigate and assess claims made against policies held or underwritten by them and to prevent and detect suspicions of fraud)
- to comply with our legal obligations such as due diligence and reporting obligations; or
- your consent when it is required by applicable law.
We process Sensitive Personal Information only when one of the following applies:
- when we have your consent (in which case you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice);
- to establish, exercise or defend legal claims; or
- where legislation otherwise permits us to process Sensitive Personal Information (for example, where the processing is necessary for insurance purposes).
6. Disclosure of your personal information
Willis Towers Watson may disclose your Personal Information to any Willis Towers Watson group company for the uses and purposes set out above. We may also disclose your Personal Information to the following categories of third parties:
- to our affiliates who support our business operations (who may be located in other jurisdictions);
- to companies involved in the provision of professional services and the sale of insurance products through the Website, including insurance providers and companies that provide reinsurance, loss adjusting, broking and claims handling services;
- to third party service providers such as entities providing customer service, email delivery, cloud computing, auditing, hosting our website and payment service providers;
- to third parties involved with any events that you register for, to facilitate your participation in those events;
- to third parties with whom you have an affinity relationship and who collaborates with Willis Towers Watson in the distribution of products and/or services; or
- to courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence, or to other third parties to whom we may be obliged to disclose your Personal Information by law.
7. Cookies
We use cookies and other technologies on this Website. You can find out more about the cookies we use and why by viewing our Cookie Policy . Our Cookie Policy should be read together with this privacy notice.
8. Security and retention
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 (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact & Comments” section below.
We retain Personal Information for a period of time that enables us to:
- Provide services to you;
- Maintain business records for analysis and/or audit purposes;
- Comply with record retention requirements under applicable law or regulation;
- Comply with any legal or other regulatory obligations;
- Defend or bring any existing or potential legal claims;
- Deal with any complaints regarding our activities; and
- Send marketing to you (unless and until we are requested to cease such marketing).
- We will delete your Personal Information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
9. Choices and access
You may opt out from receiving marketing-related communications from us at any time by contacting us or by using the unsubscribe mechanism contained in each email. 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.
If you would like to review, correct, update, object to, or restrict the processing of your Personal Information or request a copy of Personal Information about you in a portable, machine-readable format, you may contact us by sending us an email at dataaccessrequest@willistowerswatson.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 removed 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.
You also have a right to make a complaint to your national privacy regulator. Find yours here.
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. Where that is the case, we will implement reasonable measures to ensure that this data remains secure and is not accessed or used in any way.
10. Use of websites by minors
The Website is not directed to individuals under the age of sixteen, and we request that minors do not provide Personal Information through the Websites.
11. 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. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will post a notice about this on our Website for a reasonable period of time so that you have the opportunity to exercise your rights (e.g. to object to the processing).
12. Contact & comments
If you have any questions or comments regarding this privacy notice, please contact our Global Privacy Office, at The Willis Building, 51 Lime St, London EC3M 7DQ or at privacy@willistowerswatson.com
