Please read this Terms of Use and Privacy Notice (this “Terms of Use”) carefully.  It describes important conditions that apply when you access and use Willis Towers Watson’s Affinity Technology Platform referred herein as “ATP”, and also explains how your personal information will be handled by ATP. This Terms of Use was last updated on March 12^th, 2019.

1    What is the purpose of this Terms of Use, and does it apply to you?

1.1       The purpose of this Terms of Use is to:

1.1.1    inform you about certain conditions that apply to the use of “ATP”, an online platform which facilitates the administration of insurance policies which are arranged by Willis Towers Watson as part of an Affinity Offering;

1.1.2    explain how and why your personal information will be handled in connection with the operation of ATP; and

1.1.3    provide you with certain important information regarding your application for and purchase of insurance policies through ATP.    

1.2       This Terms of Use will apply to you if you choose to access or use ATP in any way.  If you do not agree to this Terms of Use, you will not be able to access or use ATP. 

1.3       For the purposes of this Terms of Use:

1.3.1    “Affinity Offering” means an arrangement whereby businesses that sell goods/services partner with insurers and/or insurance brokers to make insurance-related products available to the businesses’ end-customers;

1.3.2    “Sponsor” means the particular business that has engaged Willis Towers Watson to assist in the design and operation of an Affinity Offering;

1.3.3    “Willis Towers Watson” means Willis Australia Limited (whose registered address is at Level 4, 555 Bourke Street, Melbourne, Victoria, Australia, 3000); and

1.3.4    “Willis Towers Watson Companies” means the group of companies, including Willis Towers Watson, whose ultimate parent and holding company is Willis Towers Watson PLC.

1.4       This Terms of Use may be amended from time to time to reflect changes in law or changes in ATP and its operation, but where such revision becomes necessary in the future, Willis Towers Watson will notify you to the extent it is practicable for Willis Towers Watson to do so.  At a minimum, changes to this Terms of Use will be published through a link that will be made available within ATP. 

2    Why would I want to use ATP?

2.1       Willis Towers Watson Companies around the world have partnered with leading Sponsors to design a range of Affinity Offerings that complement the products and services they sell to their end-customers.

2.2       If you have obtained an insurance policy through any Affinity Offering arranged by Willis Towers Watson (you may have purchased it yourself, or it may have been provided to you free of charge by the Sponsor), then depending on which particular Affinity Offering you used, you may gain access to interactive features of ATP which enable you to perform certain actions in relation to your insurance policy(ies).

2.3       For example, through ATP, you may be able to:

2.3.1    find policy documentation and other information concerning your insurance policy(ies);

2.3.2    extend your insurance policy(ies), or purchase additional insurance; or

2.3.3    notify or make a claim under your insurance policy(ies), normally without having to complete additional paperwork.

3    Who owns ATP?

3.1       ATP was developed by certain Willis Towers Watson Companies and is hosted in the MS Azure West Europe Region, being the data residency Netherlands.

3.2       All rights, titles, and interests in or to ATP (including copyright and other forms of intellectual property rights) are owned by certain Willis Towers Watson Companies and third-party licensors.

3.3       The use of ATP by you does not give you any right, title, or interest in or to ATP or any part thereof, save for the limited right to access and use ATP in accordance with this Terms of Use.

3.4       Please note that Willis Towers Watson Companies only hosts and maintains ATP and does not become involved in making decisions regarding your insurance policy.  If you have any questions regarding the insurance policy(ies) you obtained, or if you have any questions regarding the services provided through ATP, please contact Willis Towers Watson. 

4    Who can use ATP?

4.1       You can access and use ATP only if you are an individual who, is applying for, or has obtained an insurance policy through an Affinity Offering which was arranged by Willis Towers Watson.

4.2       Willis Towers Watson or any Willis Towers Watson Companies may, in their absolute discretion, refuse to grant, or suspend, vary, or revoke access to ATP where they consider taking such steps to be necessary to protect their own interests, the relevant Sponsor, or other users of ATP. 

5    What are the conditions of use that apply to ATP?

5.1       You may use ATP only for the purpose of taking actions in connection with the insurance policy(ies) you obtained.

5.2       You must keep your log-in details secure and confidential. You must never share your log-in details for ATP with anyone else.

5.3       To provide you with access to the interactive features of ATP, Willis Towers Watson needs to collect certain personal information about you.  If you access and use ATP, you will be deemed to have accepted the explanation regarding how and why your personal information will be handled in connection with the operation of ATP (see sections 6to 13below).

5.4       You must not under any circumstance:

5.4.1    input into or download from ATP any personal information about any person other than you, unless you have the permission of the other person or it is otherwise legal for you to do so;

5.4.2    distribute, sell, rent, lease, assign, sub-license, transfer or in any other way dispose of ATP or your log-in details for ATP to any third party;

5.4.3    disassemble, decompile or otherwise attempt to reverse engineer ATP or any part of it, or otherwise attempt to derive or obtain any source code, structure, algorithms, process, technique, technology, know-how, or ideas underpinning or contained in ATP;

5.4.4    modify ATP or merge all or any part of it into another program, or attempt to do so;

5.4.5    copy, alter, use, modify or create derivative works of any portion or component of ATP, or allow, assist or permit others to do any of the foregoing; or

5.4.6    circumvent or attempt to circumvent any security features of ATP, including by decoding any password, or decrypting encrypted data held or used by ATP.

5.5       As part of security measures that apply to ATP, your access to and use of ATP will be subject to monitoring. Willis Towers Watson may at any time vary, suspend, or revoke your access privilege if any suspicious or inappropriate behaviour is detected through such monitoring (see section 4.2above and section 12below).

5.6       ATP is subject to change, and Willis Towers Watson and/or Willis Towers Watson Companies reserves the right to update or revise ATP and its functionalities (or any part thereof) from time to time. 

5.7       Whilst efforts will be made to keep ATP available and accessible at all times, there may be occasions when ATP becomes unavailable, for example whilst essential maintenance is carried out.

6    What personal information about you does Willis Towers Watson collect?

6.1       In order to provide you with access to interactive features of ATP, Willis Towers Watson needs to collect certain personal information about you.  The particular personal information collected by Willis Towers Watson will vary depending the circumstances, but may include any combination of the following types of information:

6.1.1    Your name and contact details;

6.1.2    Your gender, date of birth, and other like demographic information;

6.1.3    Your unique identifiers such as driving licence number, and Social Insurance Number (where necessary for income reporting);

6.1.4    Information about your property such as the value of your home and its contents;

6.1.5    Employment information including employment history, salary and amount of contributions;

6.1.6    Information about your finances, such as details of your income, financial losses you suffered, and your existing insurance arrangements (including the insurance policy you obtained);

6.1.7    Information about your physical and mental health, including your medical history, description of illness or injury suffered, and any specific treatment received;

6.1.8    Other information about you relating to a claim or any other request you may make in connection with the insurance policy you obtained, such as the details of incidents giving rise to your claim; and

6.1.9    Other information about you which Willis Towers Watson collects in connection with operation of ATP, such as information about your access to and use of ATP (see section 5.5above and section 12below).

6.2       Willis Towers Watson may obtain your personal information directly from you, as well as from other sources, such as the Sponsor of the relevant Affinity Offering in which you participate, and the insurer(s) who provides the relevant insurance policy(ies).

7    Why does Willis Towers Watson collect your personal information?

7.1       Willis Towers Watson collects and uses your personal information primarily for the following purposes:

7.1.1    to provide you with access to ATP (including its interactive features, where this is available in connection with the particular Affinity Offering in which you participate);

7.1.2    to provide services to you through ATP (including assistance with the acquisition or renewal of insurance policies;

7.1.3    to provide services to the Sponsor of the particular Affinity Offering in which you participate;

7.1.4    to contact you and generally maintain the relationship with you in connection with the operation of ATP and the relevant Affinity Offering in which you participate; and

7.1.5    to enable the insurer(s) who provides the relevant insurance policy(ies) (as part of the particular Affinity Offering in which you participate) to provide services to you (including, where applicable, by assessing any claim you submit through ATP).

7.2       Willis Towers Watson also collects and uses your personal information for the following related purposes:

7.2.1    to enable affiliated and non-affiliated third-party services providers of Willis Towers Watson Companies (e.g. IT services providers, administrative support service providers, etc.) to provide services that directly or indirectly support the operation of ATP;

7.2.2    to enable Willis Towers Watson and Willis Towers Watson Companies to comply with applicable legal or regulatory requirements imposed on them (including the requirement to conduct ‘Know-Your-Client’ checks, anti-money laundering/sanctions screening, and other like due diligence checks);

7.2.3    to comply with court orders, compelling the disclosure of your personal information;

7.2.4    to maintain and improve ATP (e.g. by designing new features, improving existing features, or fixing technical issues);

7.2.5    to improve or develop the products and services that Willis Towers Watson Companies provide in general (e.g. designing new types of Affinity Offerings, providing analysis on trends in the insurance market, benchmarking insurance products, devising ways to simplify/streamline the claims handling process, etc.); and

7.2.6    to keep you informed about the products and services offered by Willis Towers Watson Companies which might be of interest or benefit to you.

7.3       For the purpose of improving or developing products and services that Willis Towers Watson Companies provide in general (see section 7.2.5above), Willis Towers Watson may use your personal information to create and analyse statistical data, and the outcome of such analysis might be shared with third parties.  However, such analysis will be conducted solely on an aggregated and anonymous basis and, under no circumstance, will your personal information or any information from which you could be identified be included in such analysis.

7.4       Your personal information will be used by Willis Towers Watson for marketing purpose (see section 7.2.6above) only if you expressly confirm (i.e. “opt-in”) that you are happy to be contacted by other members of the Willis Towers Watson Companies for such purpose.  Willis Towers Watson will always respect your marketing preference.

7.5       Willis Towers Watson will never use your personal information for any purpose not described above without your prior consent.

8    Do you have to give your personal information to Willis Towers Watson or allow Willis Towers Watson to handle your personal information?

8.1       It is not mandatory for you to provide any personal information Willis Towers Watson asks you to provide through ATP or for you to consent to Willis Towers Watson handling your personal information in any particular way.  You can also at any time revoke any consent you give in respect of the processing of your personal information by Willis Towers Watson if you change your mind.

8.2       However, if you:

8.2.1    refuse to provide your personal information which Willis Towers Watson requests;

8.2.2    do not consent to Willis Towers Watson handling your personal information in accordance with this Terms of Use; or

8.2.3    revoke any consent regarding the handling of your personal information by Willis Towers Watson which you have previously given,

8.2.4    then such refusal or revocation might prevent Willis Towers Watson or the relevant member of the Willis Towers Watson Companies from performing its services, and this might in turn, depending on your circumstances, adversely affect you (e.g. through delays in assessment/payment of claims you make under your insurance policy(ies)).

8.3       If you consent to the collection and processing of your personal information by Willis Towers Watson but later revoke your consent, Willis Towers Watson will endeavour to comply with your request but there may be circumstances where Willis Towers Watson will not be able to comply with your request (e.g. if you revoke your consent to the disclosure of your personal information to third parties, Willis Towers Watson will not be able to ‘undo’ a disclosure that has already taken place).

8.4       Additionally, where there is a relevant legal exemption that applies to the way in which Willis Towers Watson collects and processes your personal information, Willis Towers Watson reserves the right to rely on such legal exemption to collect and process your personal information regardless of your wishes but only if and to the extent it is necessary to do so for one or more of the purposes described in section 7above (e.g. where there is a legal requirement to validate your identity for fraud prevention purpose or where a court order compels disclosure of your personal information).

9    Does Willis Towers Watson share your personal information with third parties?

9.1       Willis Towers Watson will share your personal information with third parties only if and to the extent it is necessary and appropriate for one or more of the purposes set out in section 7 above. Specifically, Willis Towers Watson may share your personal information with the following types of third parties:

9.1.1    the member of the Willis Towers Watson Companies who is involved in the operation and maintenance of the particular Affinity Offering in which you participate;

9.1.2    the Sponsor of the particular Affinity Offering in which you participate;

9.1.3    the insurer(s) who provides the relevant insurance policy(ies) as part of the particular Affinity Offering(s) in which you participate, or prospective alternate insurers that may be interested in underwriting the Affinity Offering(s) at some point in the future;

9.1.4    affiliated and non-affiliated third-party services providers of Willis Towers Watson Companies (e.g. IT services providers, administrative support service providers, etc.) who provide services that directly or indirectly support the operation of ATP; and

9.1.5    credit reference agencies, providers of identity verification services, providers of insurance claims validation services, operators of insurance fraud and other business risk screening databases, and other like providers of due diligence services (to the extent necessary for the purpose described in section 7.2.2 above).

9.2       In all other cases, Willis Towers Watson will not share your personal information with other third parties without your prior permission unless Willis Towers Watson has a legal ground on which to do so (e.g. where any applicable law requires Willis Towers Watson to do so, or where Willis Towers Watson is compelled to do so by a court order).

9.3       Please note that if you permit the relevant member of the Willis Towers Watson Group or the relevant Sponsor to share your personal information with other third parties, Willis Towers Watson may, depending on the circumstances, rely on such permission to share your personal information with other third parties.  For example, Willis Towers Watson might share your personal information with the Sponsor’s affiliates where the Sponsor confirms that it has your permission to share your personal information with its affiliates.

10  Does Willis Towers Watson transfer your personal information overseas?

10.1     ATP is hosted by Willis Towers Watson Companies in MS Azure in the Netherlands, Western Europe Region.  However, due to the way in which ATP is maintained and the way in which Affinity Offerings are generally operated, your personal information may be transferred across international borders by Willis Towers Watson Companies to third parties described in section 9.1above, who could be located anywhere in the world.

10.2     Such third-party recipients will include members of Willis Towers Watson Companies in the USA, India and the Philippines, who provide IT infrastructure support, application development/maintenance, and administrative support for ATP.

10.3     Whenever Willis Towers Watson transfers your personal information across international borders, Willis Towers Watson and Willis Towers Watson Companies will take all appropriate steps within their control so as to ensure that such transfer complies with applicable legal requirements.

11  Is your personal information secure on ATP?

11.1     All information processed through ATP will be protected in accordance with the strict standards set by the robust information security policy which applies to Willis Towers Watson Companies, and is enforced by a dedicated team of experienced security experts.

11.2     Encryption, anti-malware, firewalls, back-up/disaster recovery systems, restriction of access to premises/IT systems, careful selection of personnel as well as relevant third-party service providers, and other various measures as appropriate will be used to prevent and detect unauthorized or accidental access, loss, disclosure, or other like incident that might affect your personal information.

11.3     In the unlikely and unfortunate event your personal information becomes compromised due to any information security breach (e.g. unauthorised access, loss, or disclosure/alteration, including where this is caused by contractors), Willis Towers Watson will act promptly to identify the cause of such incident, and remediate and mitigate the consequences of such incident.  Where appropriate, Willis Towers Watson will also notify you (and/or the relevant Sponsor, where applicable) in accordance with any applicable law which requires Willis Towers Watson to notify you about such incidents.

12  How does Willis Towers Watson track your use of ATP?

12.1     If you access ATP, our IT systems will, for systems administration purposes and to improve ATP and its operation, automatically detect and record:

12.1.1  Your IP address (which in most cases is not linked to any of your personal information held by us, but can in limited circumstances be linked to your personal information and used by us to identify you); and

12.1.2  other non-personal information, such as the type of Internet browser and device you use to access ATP.

12.2     Additionally, our IT systems may also place one or more ‘cookies’ on your computer or other device from which you access ATP.  A ‘cookie’ is a small file that websites transfer to your device to store and sometimes collect information about your usage of websites.  You can control the way in which cookies are used by altering your browser settings.  Further information regarding cookies (in English) can be found at http://www.aboutcookies.org and http://www.allaboutcookies.org.

12.3     The type of cookie which may be deployed through ATP is known as “session cookie”, and it is used to temporarily store information about your usage of ATP, so that ATP can remember the information you have entered into ATP (including log-in details where applicable).  This type of cookie is essential for the proper functioning of ATP.  Where applicable, it will be stored on your computer and it may be stored for a short period but ordinarily it will be deleted when you leave ATP and close the browser used to access ATP.

12.4     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 ATP.  Unless you have adjusted your browser or device setting so that it will refuse cookies, ATP will issue cookies when you access ATP, as and when ATP requires this.

12.5     Please note that ATP does not detect and respond in any way to ‘Do Not Track’ signals sent by Internet browsers, and even if you turn on the ‘Do Not Track’ feature of your browser, it will not affect the way in which ATP behaves.

13  Who can you contact about personal information processed through ATP?

13.1     If you have any question, concern, or complaint regarding the way in which your personal information is handled by us through ATP, please contact our privacy officer:

Privacy Officer - Willis Australia

Level 16 Angel Place

123 Pitt Street

SYDNEY   NSW   2000

02 9285 4000

Email:  privacy@willistowerswatson.com.    

13.2     Please note that your right to access/correct or delete your personal information could be subject to certain legal exemptions, and where a relevant legal exemption applies, Willis Towers Watson may not be able to comply with your request to access/correct or delete your personal information.

14  What is Willis Towers Watson’s role in facilitating your purchase of insurance through ATP?

14.1     Willis Towers Watson is the program administrator and managing general agent responsible for placing and administering the insurance programs of the Affinity Offerings, which are made available to you through ATP. Acting in a capacity as a managing general agent, Willis Towers Watson does not act as an insurance broker for any individual participant of the Affinity Offering.

14.2     Willis Towers Watson will review the marketplace to ensure we continue to offer you a competitive insurance product based upon the risk profile of the affinity group to which you belong.

14.3     No insurer owns a sufficient number of shares to exert control over the board of directors of Willis Towers Watson’s ultimate parent company, Willis Towers Watson PLC, which is a public company listed on the NASDAQ.

15  What happens when you submit an application for an insurance policy through ATP?

15.1     Subject to you meeting the eligibility requirements for insurance under the Affinity Offering, the completion of the online application for insurance through ATP will allow you to submit an application for insurance and the information entered will form the basis of the insurance contract should an insurance policy be issued.

15.2     The risk is not bound until all the insurance policy documents are issued to you. The insurance policy and related documentation will be provided to you electronically. Should electronic delivery of such policy and related documentation not be practical or possible, you must request in writing to Willis Towers Watson that you wish to have the documents sent to you by regular mail.

15.3     Before your application for insurance is accepted and an insurance policy is issued to you, underwriter approval may be required.