PRIVACY NOTICE

Effective Date: January 2, 2022

The Site is hosted and maintained by Mercer (“Mercer”, “we”, “us”, “our”). Mercer believes strongly in protecting your privacy. This Privacy Notice applies to Site. This Privacy Notice is intended to inform you of the ways in which this Site collects personal information, the uses to which that information is put, how and why we share that information, and the ways in which we protect it. Generally, personal information is information that can identify you or your activities on the Site or through Services offered on the site.

This Privacy Notice applies solely to data collected through use of the Site. You may provide Mercer with or Mercer may receive information about you other than in connection with the Site; the collection and receipt of such information may be subject to separate terms and conditions and a separate privacy notice. We encourage you to review the privacy notices and terms and conditions that may apply to those practices. This Privacy Notice is not intended to alter the terms or conditions of any other agreements you may have with Mercer.

By using this site, you acknowledge that you have read, understand and accept this Privacy Notice and any other terms of use or acceptable use policies that may be included with the Site. If you use this Site as an employee or member of an organization, this Site is also operated pursuant to any agreements we may have with your employer or association. We encourage you to contact your employer or association for more information.

Please take a moment to familiarize yourself with our privacy practices. You may also contact us at PrivacyCoordinator@mercer.com for assistance with any question you may have. Since we may change this Privacy Notice, we recommend that you check the current version available from time to time. If we make changes to this Privacy Notice, we will update the “Effective Date” at the top of the page. If there are significant changes, you will be provided with appropriate online notice. Your continued use of the site constitutes your agreement to the effective Privacy Notice.  

WHAT INFORMATION DOES THIS PRIVACY NOTICE COVER?

This Notice describes how we may collect, use, share, and keep information about you that we get about you. We gather information if you:

· Visit or use our website or apps;

· Register to use this site

· Create or modify your account;

· Receive, send, or reply to electronic communications from us

· View or click on our online content; and

· Interact with us through social media websites and other websites and apps

In this Notice, we also explain how we may combine online information with other information and how we then use the combined information.

WHAT DATA DO WE COLLECT?

The information that you provide to us or that we collect or receive about you may depend on how you interact with us and the services that you choose to use. Generally, we may collect the following information about you and, in some cases, about your dependents or beneficiaries:

· contact information such as your name, address, email address, and phone number;

· demographic information such as your date of birth, marital status, and gender;

· financial information such as your Social Security number, financial account numbers, balances, and transaction history, benefits information, including retirement plan information, and salary;

· information about the use of our site, such as records of, or relating to, your Internet Protocol address, your general geographic location, your browser type, your operating system, the pages you view on the services, the pages you view immediately before and after you access the site, and the search terms you enter on the site;

· information about communications and communications and other interactions between you and us about our site;

· information about your transactions with third parties, including the third party providers you access through our site; and

· decisions you may make with respect to the program services offered.

Information Provided by You, Your Representatives or Third Parties

We collect information from you; your representative; your employer or association; and third parties that have roles in delivering services to you, your employer or association. You might provide this information when you visit this site or communicate with us. In addition, your employer or association or someone acting on their behalf may provide us with information about you.

If you supply us with personal information about other people, you represent that you have the authority to provide this information on their behalf. In these instances, you further represent that the individuals to whom this information relates have been informed of and understand the reason(s) for you providing or us obtaining the information, the manner in which this information will be used and disclosed, and have consented to such use and disclosure.

Information Collected by Automated Means

We also collect or receive information over time and across different websites or platforms when you use the site. We may collect some of this information using cookies, web beacons, and other technologies. Cookies are small pieces of text a website places on your computer to help remember information about your visit. Web beacons are tiny graphics with unique identifiers that are embedded invisibly on the web pages. Neither cookies nor web beacons can read data off your computer’s hard drive. We use information collected from cookies and web beacons to improve your experience and the overall quality of our site. We also may use cookies and web beacons to collect information from third parties (such as Google) to analyze the effectiveness of the performance of this site. We also use web beacons to help deliver cookies and compile analytics. Our cookies and web beacons may come from third-party service providers who have our permission to place such tools on our site. Certain Cookies and Similar Technologies do collect Personal Information. For example, if you click Remember Me when you log in to our website, a cookie will store your username.

We (and our service providers) may collect information using cookies and web beacons about:

· The device used to browse sites

· The IP address and info related to that IP

· Browsing history on our sites

· How you search for our sites

· Browsing activities over time and across other sites

· Whether you open our electronic communications and how you interact with these communications

· Location of your mobile device

You can refuse to accept cookies and delete them by adjusting your browser settings. Please note that refusing or deleting cookies may impair your browsing experience on the site, or prevent you from using some of its services, and it may also delete any preferences you have set. For more information about how to reject or delete cookies, consult with your browser’s or device’s help documentation, or visit http://www.aboutcookies.org.    We do not use technology that recognizes do-not-track signals or similar mechanisms from your browser indicating that you do not wish to be tracked or receive interest based ads. You may be able to take steps to opt out of Internet-based advertising by installing a browser plugin from a third party, where available. For more information about Internet-based advertising, please see: http://www.networkadvertising.org/managing/opt_out.asp.

Information that is Publicly Available

We may also collect information made publicly available through third party platforms (such as online social media platforms), through online databases or directories, or that is otherwise publicly available or lawfully obtained. This information may be governed by the privacy policies provided by the third party at the time of collection. We encourage you to review the privacy policies of each third party website or online service you visit.

Information to Provide and Protect Our Site

In addition, in the course of seeking network security and consistent service for all users, software programs may be employed to monitor network traffic, identify unauthorized access or access to nonpublic information, detect computer viruses and other software that might damage our computers or the network, and monitor and fine-tune our network’s performance. These programs may detect additional information from your computer such as your IP address, addresses from network packets, and other technical information. Such information is used to maintain the security and performance of our networks and computer systems.

We may combine the information you provide us and information we automatically collected with information from public or third-party sources.

HOW DO WE USE THE DATA WE COLLECT?

We use your personal information to:             

· verify your identity;

· register and service your online account;

· providing you with products and services you request, including processing a transaction, enrollment, or other service requested by you, directly or through a third party;

· allow you to manage the program services;

· contact you when necessary and to respond to your requests and inquiries;

· customizing your experience when using the site;

· fulfill legal and regulatory requirements;

· detect and prevent fraud, suspicious claims, and other illegal activities; and

· generating and analyzing statistics about your use of the site;

· analyze and improve products and services, enhance this site, and evaluate the effectiveness of our marketing activities and overall services.

We may also use your data in aggregated and de-identified ways to help us analyze patterns. We may share aggregated data in several ways, including with business partners to conduct analysis and research about customers and website visitors.

We work with our business partners to collect information about the use of the site. Our business partners collect information such as how often users visit the site and what pages users visited prior to visiting the site. We use this information to maintain and improve the site.

We may also use the information we collect and receive as otherwise described to you at the point of collection or pursuant to your consent.

WITH WHOM DO WE SHARE YOUR DATA?

We share your information to assist with managing and running this site, to provide any service you requested or authorized, or provide other products or services as requested by you, your employer, or association, or otherwise as described in this Privacy Notice or when we have your consent. We may share this information with:

· your employer or association;

· third-party service providers that have been retained to perform services on our behalf or on behalf of your employer or other association, or as authorized by your employer or other association; and

· third-party service providers retained by Mercer to provide services directly to you through this program.

We may also share information in association with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

Third parties to whom we disclose information are required by law and/or contractual requirements to keep your personal information confidential and secure. These parties may not use or disclose it except as reasonably necessary to provide services to you, on our behalf, on behalf of your employer or other association, or to comply with or as permitted by applicable law.

We do not rent, sell, or otherwise disclose your information to unaffiliated third parties for their own marketing, unless so authorized by you, your employer or association.

We may disclose your personal information without your prior permission, as permitted by law, including instances when we have a good faith belief that it is necessary to: (a) protect the legal rights, safety, and security of Mercer, our affiliates and business partners, and users of our site; (b) enforce the Terms of Use; (c) respond to claims of suspected or actual illegal activity; (d) respond to an audit or investigate a complaint or security threat; or (e) comply with law or legal process, or a request for cooperation by a government or other entity.

We may share information that is not reasonably identified with you for any purpose.

FOR HOW LONG DO WE RETAIN YOUR INFORMATION?

We may retain information that can reasonably identify you for as long as your account is active or as we determine is needed for our reasonable business purposes, including complying with our legal obligations, resolving disputes, and enforcing our agreements.

WHAT RIGHTS AND OBLIGATIONS DO YOU HAVE WITH RESPECT TO YOUR DATA?

Accessing and Correcting Your Information

Keeping your information accurate and up-to-date is very important. Inaccurate or incomplete information could impair our ability to deliver relevant services to you. Please let your employer or your service provider know about any necessary changes to your personal information.

Securing Your Own Information
By using this site, you represent that you will likewise take measures to protect this information, including the maintenance of any username and password in a confidential manner, and agree not to allow others to access your account or utilize your password.

SOME OTHER MATTERS

Steps We Take To Protect Your Information

This site and all information submitted by or on behalf of you through this site may be collected, stored, and processed in countries other than the one in which you reside, including, but not limited to, the United States.

We restrict access to your personal information to those employees of ours, our affiliates, and third- party service providers who reasonably need it to provide products or services. We have implemented physical, administrative, and technical safeguards to protect your personal information from unauthorized access. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of these systems, nor can we guarantee that information supplied by you or on your behalf cannot be intercepted while being transmitted over the Internet.

External Links

This site includes links to, and application programming interfaces (APIs) with, other websites that are operated by other organizations. If you access another organization’s site using a link or API on our site, that organization may collect information from you. We are not responsible for the content or privacy practices of third-party websites or their use. Once you have left this site via such a link or API (you can tell where you are by checking the URL in the location bar on your browser), you should refer to those websites' privacy policies, terms of use, and practices to determine how they handle any information they collect from you.

Does This Privacy Notice Apply to International Users?

This Privacy Notice is provided in accordance with and subject to U.S. law. If you access this site from a location outside the United States, you agree that your use of this site is subject to the terms of this Privacy Notice and any terms of use.

If you are a resident of the European Economic Area (EEA), in order to provide our Site, products and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the EEA, including to the United States. Accordingly, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as within the EEA to the extent feasible under applicable law. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

Business Transactions
In the event we sell some or all of our assets or go through other business transactions, such as mergers, acquisitions, bankruptcy, or reorganizations, it is possible your personal information could be one of the assets sold or transferred in connection with the transaction. We may disclose and/or transfer your personal information to a third-party purchaser in these circumstances.

Rights of California Residents

California Consumer Privacy Act

Mercer provides the Services pursuant to a contract we have entered into with our corporate client and your employer (“Client”), who is the business ultimately responsible for determining how your personal information will be processed. As such, we act as a “service provider” when it comes to handling your personal information, which means all of the personal information that we collect from or about you in connection with the Service is processed under the direction of our Client and governed by our agreement with our Client. We have no direct ownership over your personal information. Instead, our collection, use, sharing, and retention of your personal information collected through the Service is limited to providing the services for which our Client has engaged us.

Accordingly, if you are using the Service in connection with your duties of employment or by virtue of some other relationship with our Client, we encourage you to review that Client’s privacy notice to understand the full scope of how your personal information will be handled.This includes any processing performed by our Client if we make your personal information available to our Client, as described in this Notice. 

Further, in any case where we are acting as a service provider to a Client, if you wish to exercise any rights that may be available to you under certain data privacy laws (for example, the right to access or deletion under the California Consumer Privacy Act if you are a resident of California as described below), you should direct your request to our Client, who is the party responsible for receiving, assessing, and responding to your requests, as we do not have any obligation, and, notwithstanding anything in this Privacy Notice to the contrary, may elect not, to respond to your requests.

Shine the Light

As of the date of this Notice, Mercer does not use your data for marketing purposes. Under California’s “Shine the Light” law, site visitors who are California residents may request and obtain a notice once a year about the personal information we share with other businesses for their direct marketing purposes. Such a notice includes a list of the categories of personal information that was shared (if any), and the names and addresses of all third parties with which the personal information was shared (if any). The notice covers the preceding calendar year. To obtain such a notice, please contact us as previously described. In addition, under this law you are entitled to be advised how our site handles “do not track” browser signals. As described previously, we do not use technology recognizing do-not-track signals from your browser.

Questions or Concerns

If you have any questions, concerns, or complaints about this Privacy Notice, or our privacy practices in general, please contact please email us at PrivacyCoordinator@mercer.com .