Liazon, a Willis Towers Watson Company, Privacy Notice

Last updated: 9/10/2019

Liazon, a Willis Towers Watson Company, cares about your privacy and wants you to be familiar with how we collect, use and disclose information. We use personal information to guide you in making smart benefits decisions, generate your plan rates, and enroll you with the insurance carrier(s) you choose as detailed below.

This Privacy Notice describes our practices in connection with information that we collect through the online information portal, decision support tools and enrollment system, collectively known as “the Marketplace,” or through computers and mobile devices, as well as through HTML-formatted email messages that we send to you that link to this Privacy Notice (collectively, including the Marketplace, the “Services”). By providing Personal Information to us, you agree to this Privacy Notice and the accompanying Terms of Service.

PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable person.

Personal Information We May Collect

To create your account in the Marketplace, your employer provides us with certain Personal Information about you, such as: your name, address, Social Security Number, hire date, birth date, gender and other information directly related to your employment. We use this information so that we can identify you and enroll you in your employee benefits.

When you sign in as a Registered User, you will be asked to provide us with your assigned username and password. If you choose to shop for benefits on the Marketplace, we will ask you to provide additional Personal Information that we need in order to provide you with a customized recommendation for the benefits that fit your needs and enroll you in plans, such as your smoking status, your expected health care utilization, your dependent information, your attitudes toward risk and other factors that would influence your insurance and benefits preferences.

If you submit 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.

How We May Collect Personal Information

We and our Service Providers may collect Personal Information in a variety of ways, including:

Through the Services: We may collect Personal Information through the Services, e.g., when you register on our site.
Offline: We may collect Personal Information from you offline, such as when you contact customer service.
From Other Sources: We will receive information from your employer (as mentioned above). In addition, if you have provided consent to a third party to share data with us, we may obtain information about your medical and health care expense history from them. For the avoidance of doubt, use of information that you provide to such third-party data provider shall be governed by the third-party data provider’s privacy notice but use of information that we may receive from the third-party data provider shall be governed by this Privacy Notice.

How We Use Your Personal Information

We may use your Personal Information:

To respond to your inquiries and fulfill your requests, including to enroll you with the insurance carrier(s) you choose;
To generate your plan rates;
To recommend the best insurance coverage for you;
To send you notices or marketing communications (for example, in the form of e-mails, mailings, and the like) regarding products or services you are receiving or we think you may be interested in receiving;
For our business purposes, such as data analysis, developing new products, enhancing, improving or modifying our Services, identifying usage trends, and operating and expanding our business activities;
As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
For any other purposes disclosed at the time the information is collected or to which you consent.

Disclosure of Your Personal Information

Your Personal Information may be disclosed:

To the carrier and vendor partners that you have selected or requested more information about, to allow them to provide you with services through the Marketplace. Use of your Personal Information by our carrier and vendor partners is governed by their privacy policies and not this Privacy Notice.
To your employer. Certain limited information may be shared with your employer, including your demographic information (name, address, etc.), smoking status, dependent information, beneficiary information, benefits elections, and information collected where we indicate that question responses will be shared with your employer (such as on the “Additional Questions” page).
To our affiliates for the purposes described in this Privacy Notice.
To our third-party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
To identify you to anyone to whom you send messages through the Services.
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 or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

PERSONAL HEALTH INFORMATION

Certain Personal Information that relates to your health or the provision of healthcare to you may constitute Protected Health Information (“PHI”) under HIPAA (the Health Insurance Portability and Accountability Act of 1996 and 45 C.F.R. parts 142 and 160-164, as amended). Entities that create or receive this information (such as your health insurance provider) are subject to strict rules regarding how they can share this information. Liazon, a Willis Towers Watson Company, will treat PHI it receives in compliance with all applicable state and federal laws and regulations regarding confidentiality of such information.

OTHER INFORMATION

Other Information We May Collect

Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

Browser and device information
Information collected through cookies and other technologies
Demographic information and other information provided by you
Aggregated information

If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Notice.

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh) screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, and to recognize your computer in order to assist your use of the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. If you disable cookies on the site, the site may not function properly.
IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

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.

If you’ve provided us with Personal Information we may associate that information with the information about your usage of our site that is collected automatically.

THIRD PARTY SERVICES

We may include links in the Services to third-party companies, such as carriers and health and wellness providers. When you access those links, you will be leaving the Services and your usage of those third party sites will not be governed by this Privacy Notice, but by the privacy policies of such third party.

INFORMATION ABOUT CHILDREN

The Services are not directed at children under the age of 13, and we request that they not provide Personal Information through the Services.

Please note that we do collect information about dependent children as it pertains to their benefits coverage.

HOW WE PROTECT YOUR INFORMATION

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. 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 feel that the security of your account has been compromised) please immediately notify us in accordance with the " Contacting Us" section below.

CHOICES AND ACCESS

How you can access, change or suppress your Personal Information

If you would like to review, correct, update, suppress or delete Personal Information that you have previously provided to us, you may contact us at the address 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.

CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice is effective as of the date stated at the top of this Privacy Notice. We reserve the right to revise and update our Privacy Notice from time to time. By accessing the Site or using the Services after we make any such changes to this Privacy Notice, you are deemed to have accepted such changes.

Please refer back to this Privacy Notice on a regular basis.

How to Contact Us

If you have questions about this Privacy Notice, please mail us at the following address:

Liazon Corporation, a Willis Towers Watson Company
Attn: Product Team
199 Scott St.
Buffalo, NY 14204

To contact us by email, please write to privacy@wtwviabenefits.com with PRIVACY NOTICE in the subject line.