Mercer takes your privacy seriously because we know that you do. This privacy notice (this "Notice") is applicable to this website (the "Website") and to the associated services Mercer HR Services, LLC ("Mercer" or "we') provides as a third party service provider to your Plan Sponsor ("Plan Sponsor"). This Policy describes how Mercer may collect, use and share the personal information you submit through this Website. We last revised this Notice on October 31, 2013.
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 employer's Privacy Department, Benefits, or Human Resources. If you have any other questions, please direct them to firstname.lastname@example.org. 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 email@example.com.
Use of this Website
Personal information includes both personally identifiable information ("PII") that we maintain and process in connection with providing services to 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 your Plan Sponsor, your PII may also include:
- financial information such as financial account number, or credit or debit card number;
- 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 provided to you by your Plan Sponsor that are administered by Mercer.
Mercer operates this Website and administers certain employee, former employee and retiree benefits on your Plan Sponsor's behalf. In this role, Mercer has access to your PII and Related Data for purposes of performing those services. For these purposes, we may also:
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 messages;
|(b) request other information from us; or
|(c) provide information when you use this Website.
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 our privacy practices or policies.
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
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.
When your Plan Sponsor permits it, we may also collect statistical and aggregated information, and we may disclose aggregated information to third parties for research, marketing and promotional purposes. However, in those situations, we do not disclose any information that could be used to identify you.
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: We share information with your Plan Sponsor under the contract with your Plan Sponsor to provide services and to administer benefits. 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: 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.
- 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 the Plan Sponsor or to Mercer.
- Mercer Companies: The Plan Sponsor and Mercer may also share your PII and Related Data with Mercer¿s affiliates and subsidiaries to perform benefits administration services for the Plan Sponsor.
- Legal Matters: Unless otherwise described above, 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.
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.
Contacts and Complaints
This Web Site is operated by Mercer, One Investors Way, Norwood, MA 02062, USA. If you have any questions or concerns about this notice, please address them to Mercer at firstname.lastname@example.org.
October 31, 2013