Willis Towers Watson India Insurance Brokers Private Ltd.
("WTWIIBPL")
Please read this Privacy Policy carefully. It describes how WTWIIBPL handles personal information about You which WTWIIBPL collects in connection with the services WTWIIBPL provides. It also explains certain legal rights You have in connection with Your personal information which is handled by Willis Towers Watson India Insurance Brokers Private Ltd. This Privacy Policy may be revised from time to time to reflect changes in law or changes in WTWIIBPL's business operation.
1. What is the purpose of this Privacy Notice, and does it apply to me?
This Privacy Notice explains how WTWIIBPL handles personal information about You. Generally speaking, this Privacy Notice will apply to You if You directly or indirectly benefit from the services WTWIIBPL provides (typically insurance related consultancy and broking services) in India.
1.1 The purpose of this Privacy Notice is to inform You how WTWIIBPL handles personal information about You which WTWIIBPL obtains in connection with its business activities. This Privacy Notice will apply to You if WTWIIBPL obtains Your personal information in connection with Willis Towers Watson's India Insurance Brokers Private Limited business activities.
1.2 Please note that this Privacy Notice does not apply to You if You are:
1.2.1 an employee, contractor, or any other type of worker engaged by WTWIIBPL.
1.2.2 a visitor to any website which is maintained by the Willis Towers Watson Group (including the Willis Towers Watson Group's main website and the online tools accessible from there), in which case the collection of any personal information about You will be subject to the separate website privacy notice for the relevant website. Unless specifically stated otherwise, the website privacy notice applicable to all website maintained by the Willis Towers Watson Group can be found at: Global Website Privacy Notice.
1.3 Nothing in this Privacy Notice alters any existing relationship between You and WTWIIBPL, or creates any new relationship between You and WTWIIBPL. Nothing in this Privacy Notice affects any right You have under any applicable law which regulates the way in which WTWIIBPL handles Your personal information.
2. Who is responsible for the handling of my Personal Information?
The entity that is responsible for the handling of Personal Information is Willis Towers Watson India Insurance Brokers Private Ltd., 2nd Floor Sucheta Bhawan, 11A Rouse Avenue Lane, Vishnu Digambar Marg, New Delhi 110002.
3. What Personal Information about me does WTWIIBPL collect?
Personal information collected by WTWIIBPL will vary depending on many factors, but may include a broad range of personal information, including personal information of a sensitive nature such as details of Your bank account, finances, and information concerning Your health.
3.1 The type and amount of personal information about You which WTWIIBPL collects will vary depending on various factors, including Your personal circumstances, the nature of Your relationship with WTWIIBPL (or WTWIIBPL's client), and the relevant services provided by WTWIIBPL, but may include any combination of the following:
3.1.1 Your contact details such as name, postal address, email address, and telephone number;
3.1.2 Your gender, date/place of birth, marital status, dependents, nationality, country of residence, occupation, hobbies, habits, and other similar demographic information;
3.1.3 Information about Your finances, such as details of Your income, assets, investments, debts, creditworthiness, tax status, and existing pension/insurance arrangements;
3.1.4 Information about Your physical and mental health, including Your medical history, description of illness or injury suffered, and any specific treatment received;
3.1.5 Information about You which WTWIIBPL is obliged to check for legal or regulatory reasons, such as information relating to Your identity, any directorship of companies You hold, and Your criminal history (including allegations of crimes);
3.1.6 Other information about You which WTWIIBPL handles in connection with the services WTWIIBPL provides to You or a client of WTWIIBPL, such as Your personal circumstances that need to be described in arranging any (re)insurance for You or a client of WTWIIBPL, details of incidents giving rise to any (re)insurance claim in which You are involved, and facts and circumstances involving You in respect of which WTWIIBPL is asked to advise a client; and
3.1.7 Other information about You which WTWIIBPL collects as part of its day-to-day business operation, such as information about Your visit to WTWIIBPL’s office, Your attendance at meetings and events hosted by WTWIIBPL, and Your correspondence with WTWIIBPL's brokers, advisors and consultants.
3.2 Please note that personal information which WTWIIBPL collects may include sensitive information such as health information.
3.3 WTWIIBPL will collect Your personal information only if and to the extent it is necessary for one or more of the purposes described in Section 4 below.
4. Why does Willis Towers Watson India Insurance Brokers Private Ltd collect your Personal Information?
WTWIIBPL collects personal information mainly to provide WTWIIBPL's services (e.g. to arrange (re)insurance, to handle (re)insurance claims, to handle insurance claims with third party administrators or to provide related risk management services, claims consultancy services and solutions), but WTWIIBPL also collects personal information for a variety of other related business purposes.
4.1 WTWIIBPL collects and uses Your personal information primarily for the following purposes:
4.1.1 to provide services which You personally request (e.g. where You request WTWIIBPL to arrange personal insurance for Your domestic purpose or commercial insurance for Your own business purpose);
4.1.2 to provide services which You did not personally request but is nevertheless arranged for Your benefit (e.g. where Your employer asks WTWIIBPL to arrange health plan, pension plan, or other forms of employee benefits, or where a client of WTWIIBPL asks WTWIIBPL to arrange any (re)insurance which might directly or indirectly benefit You, or where Your employer asks WTWIIBPL to provide certain types of risk management services, claims consultancy services and solutions, services with third party administrators); and
4.1.3 to provide services which You did not personally request but were requested by WTWIIBPL's client and requires WTWIIBPL to interact, directly or indirectly, with You (e.g. where You bring a claim against Our client and We are required to handle the claim under the relevant (re)insurance policy).
4.2 WTWIIBPL also collects and uses Your personal information for the following related purposes:
4.2.1 to enable underwriters, actuaries, (re)insurers, other brokers, claims handlers, surveyors, loss adjustors/assessors, accident investigators, specialist risks advisors, pension providers, banks and other lenders (including premium finance providers), health professionals, lawyers, accountants, auditors, consultants, and other like third party professional advisors and service providers to provide their services (to the extent their involvement is inherent in or necessary in connection with the services provided by WTWIIBPL);
4.2.2 to enable affiliates of the Willis Towers Watson Group and non-affiliated third party services providers (e.g. IT services providers, administrative support service providers, etc.) to provide services that directly or indirectly support WTWIIBPL's business operations and the services provided by WTWIIBPL;
4.2.3 to comply with legal or regulatory requirements imposed on WTWIIBPL or a client of WTWIIBPL (including the requirement to conduct 'Know-Your-Client' checks, anti-money laundering/sanctions screening, and other like due diligence checks);
4.2.4 to improve or develop the products and services WTWIIBPL provides to WTWIIBPL's clients in general (e.g. improving internal business processes, providing analysis on trends in the (re)insurance market or employee benefits market, benchmarking (re)insurance products, devising ways to simplify/streamline the (re)insurance placement process or claims handling process including that of third party administrators, designing new types of (re)insurance products, etc.); and
4.2.5 to contact You and generally maintain the relationship between You and WTWIIBPL in connection with the services provided by WTWIIBPL, and to keep You informed about the products, services, and opportunities offered by WTWIIBPL on and other members of the Willis Towers Watson Group which might be of interest or benefit to You.
4.3 For the purpose of improving or developing WTWIIBPL's products and services (see Section 4.2.4 above), WTWIIBPL 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 any specific personal information relating to You or any information from which You could be identified be included in such analysis.
4.4 Your personal information will be used for relationship maintenance/marketing purpose (see Section 4.2.5 above) only if You are Yourself a client of WTWIIBPL or if You are the business contact at WTWIIBPL's client (i.e. You fall within the category of persons described in Section 5.2.1 or 5.2.2 below). For further information regarding WTWIIBPL's direct marketing practice, please refer to Section 7 below.
4.5 Please note that WTWIIBPL will never use Your personal information for any purpose not described above without Your prior consent (or the prior consent of the relevant client of WTWIIBPL, where applicable).
5. How does WTWIIBPL obtain Your Personal Information?
Personal information handled by WTWIIBPL is typically provided by a client of WTWIIBPL. However, depending on the circumstances, WTWIIBPL might collect personal information from other third parties who are relevant to the services WTWIIBPL provides, and WTWIIBPL might also collect personal information directly from You.
5.1 Where WTWIIBPL is required to handle Your personal information, WTWIIBPL generally obtains Your personal information indirectly from a client of WTWIIBPL (typically a company, partnership, public authority, or other like body corporate) which receives services that affect You. For example, WTWIIBPL might indirectly receive Your personal information from a client of WTWIIBPL where the client asks WTWIIBPL to:
5.1.1 arrange any (re)insurance that benefits the client's directors, officers, employees, customers, guests, visitors, or other persons that interact with the client;
5.1.2 arrange pensions, medical insurance, and other employee benefits for directors, officers, and employees of the client;
5.1.3 handle claims made against the client under any (re)insurance policy;
5.1.4 advise the client on the management of its business risks and (re)insurance arrangements; or
5.1.5 manage any aspect of the client's business affairs on behalf of the client (e.g. in connection with the set-up and operation of a captive insurance programme);
5.1.6 provide risk management services and claims consultancy services permitted by law;
5.2 Occasionally, it will be necessary for WTWIIBPL to obtain Your personal information directly from You. For example, this could be the case where:
5.2.1 You are employed or otherwise engaged by a client of WTWIIBPL and Your job involves any direct interaction with WTWIIBPL (e.g. if You are a Risk Manager or a Finance Director of a client of WTWIIBPL, and You are involved in making (re)insurance purchase decisions);
5.2.2 You directly interact with WTWIIBPL as a client of WTWIIBPL in respect of Your personal/domestic insurance requirements (e.g. insurance for Your personal motor vehicle or Your family home, etc.), or in respect of Your own business, profession, or trade (e.g. where You act as a sole trader, sole practitioner, or business proprietor and receive WTWIIBPL's services in connection with Your business needs);
5.2.3 You are an individual to be insured by a client of WTWIIBPL or a beneficiary of any insurance or similar benefit a client of WTWIIBPL arranges for Your benefit and WTWIIBPL is required to collect Your personal information directly from You in order to make the necessary arrangements for WTWIIBPL's client;
5.2.4 You bring any insurance claim against a client of WTWIIBPL and where WTWIIBPL is involved in the direct handling of such claim (or the corresponding reinsurance claim); or
5.2.5 WTWIIBPL needs to talk to You or correspond with You in order to provide risk management services, claims consultancy or other similar advisory services to WTWIIBPL's clients.
5.3 Depending on the circumstances, WTWIIBPL may also obtain Your personal information from other sources such as:
5.3.1 publicly accessible registers and databases (such as registers of companies/directors, bankruptcy, and court judgments), 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; and
5.3.2 underwriters, actuaries, (re)insurers, other brokers, claims handlers, surveyors, loss adjustors/assessors, accident investigators, specialist risks advisors, pension providers, banks and other lenders (including premium finance providers), health professionals, lawyers, accountants, auditors, consultants, and other like third party professional advisors and service providers, as well as third parties that have referred You to WTWIIBPL and other like third parties who interact with WTWIIBPL in connection with the services WTWIIBPL provides.
6. Do I have to give my Personal Information to WTWIIBPL or allow WTWIIBPL to handle my Personal Information?
You do not have to provide personal information requested by WTWIIBPL, and You do not have to allow WTWIIBPL to handle Your personal information. However, such refusal can potentially disadvantage You and additionally, WTWIIBPL might handle Your personal information regardless of Your wishes where the law allows WTWIIBPL to do so.
6.1 It is not mandatory for You to provide any personal information WTWIIBPL asks You to provide or for You to consent to WTWIIBPL 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 WTWIIBPL if You change Your mind.
6.2 However, if You:
6.2.1 refuse to provide Your personal information which WTWIIBPL requests;
6.2.2 do not consent to WTWIIBPL handling Your personal information in accordance with this Privacy Notice; or
6.2.3 revoke any consent regarding the handling of Your personal information by WTWIIBPL which You have previously given, then such refusal or revocation of previously given consent might prevent WTWIIBPL from performing its services, and this might in turn, depending on Your circumstances, adversely affect You (e.g. through delays in placement of (re)insurance or assessment/payment of (re)insurance claims).
6.3 If You consent to the collection and processing of Your personal information by WTWIIBPL but later revoke Your consent, WTWIIBPL will endeavour to comply with Your request but there may be circumstances where WTWIIBPL 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, WTWIIBPL will not be able to 'undo' a disclosure that has already taken place).
6.4 Additionally, where there is a relevant legal exemption that applies to the way in which WTWIIBPL collects and processes Your personal information, WTWIIBPL 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 4 above (e.g. where WTWIIBPL is required by law to validate Your identity for fraud prevention purpose or compelled by law to disclose Your personal information to regulators or law enforcement agencies, or where WTWIIBPL would otherwise be prevented from providing the services as requested by WTWIIBPL's client).
7. Does WTWIIBPL use my Personal Information for Marketing?
WTWIIBPL does not engage in direct marketing that targets consumers in general. However, depending on Your relationship with WTWIIBPL, You might receive marketing communications from WTWIIBPL. Where this is the case, WTWIIBPL will always respect Your marketing preference.
7.1 WTWIIBPL does not engage in direct marketing activities that target consumers in general, but if You are Yourself a past or current client of WTWIIBPL (or a prospective client referred to WTWIIBPL by a third party), or if You are a WTWIIBPL's business contact at a past, current, or prospective client of WTWIIBPL, You might from time to time receive marketing communications from WTWIIBPL, e.g. information regarding a new product or service offered by WTWIIBPL, or invitation to a seminar or conference hosted by WTWIIBPL which might be of interest to You (see Section 4.4 above).
7.2 Where WTWIIBPL sends any such marketing communication to You, WTWIIBPL will ensure that such marketing communications are sent in compliance with the applicable laws, and in particular, ensure that there is an easy way for You to stop receiving (i.e. "opt-out" from) such marketing communications in the future.
7.3 WTWIIBPL will also comply with any applicable law that specifically regulates the use of Your personal information for direct marketing purposes, including any applicable rules concerning the use of a 'Do-Not-Call' registry or similar facility.
7.4 WTWIIBPL will never sell, rent, or otherwise share Your personal information with operators of marketing databases, or any other non-affiliated third party solely for such third party's own marketing purposes without Your prior consent (or the prior consent of the relevant client of WTWIIBPL, where applicable). For further clarification regarding how WTWIIBPL shares Your personal information with third parties, please see Section 8 below.
8. Does WTWIIBPL share my Personal Information with third parties?
WTWIIBPL shares personal information with third parties mainly to provide its services (e.g. to arrange (re)insurance, to handle (re)insurance claims, to provide risk management advice, or to provide risk consultancy and solutions), but WTWIIBPL also shares personal information for a variety of other related business purposes.
8.1 WTWIIBPL 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 4 above. Specifically, WTWIIBPL may share Your personal information with the following types of third parties:
8.1.1 underwriters, actuaries, (re)insurers, other brokers, claims handlers, surveyors, loss adjustors/assessors, accident investigators, specialist risks advisors, pension providers, banks and other lenders (including premium finance providers), health professionals, lawyers, accountants, auditors, consultants, third party administrators handling claims/ reimbursement and other like third party professional advisors and service providers, as well as third parties that have referred You to WTWIIBPL (to the extent their involvement is inherent in or necessary in connection with any of the services provided by WTWIIBPL);
8.1.2 clients of WTWIIBPL who receive services which is arranged for Your benefit, or otherwise requires WTWIIBPL to interact, directly or indirectly, with You (to the extent sharing of Your personal information with such clients is necessary and appropriate in the context of the relevant services WTWIIBPL provides, see Section 4.1.2 and Section 4.1.3 above – such a client may, depending on the circumstances, be Your employer);
8.1.3 affiliates of the Willis Towers Watson Group and non-affiliated third party services providers (e.g. IT services providers, administrative support service providers, etc.) that provide services that directly or indirectly support WTWIIBPL's business operation and the services provided by WTWIIBPL;
8.1.4 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 to comply with legal or regulatory requirements imposed on WTWIIBPL or a client of WTWIIBPL); and
8.1.5 regulators, police, courts/tribunals, and other like public authorities who have jurisdiction over WTWIIBPL (to the extent necessary to comply with any legal or regulatory requirements imposed on WTWIIBPL or a client of WTWIIBPL).
8.2 Please note that where WTWIIBPL shares Your personal information with regulators, police, courts/tribunals, and other like public authorities, WTWIIBPL may, depending on the circumstances, be forbidden from advising You (or the relevant client of WTWIIBPL) of the fact that Your personal information was disclosed to or requested by such third parties.
8.3 WTWIIBPL may also share Your personal information in connection with the planning, due diligence and implementation of commercial transactions, including a reorganization, merger, sale of all or a portion of our assets, a 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) – in such cases, Your personal information will be transferred to the acquiring entity.
8.4 In all other cases, WTWIIBPL will not share Your personal information with other third parties without Your prior consent (or the prior consent of the relevant client of WTWIIBPL, where applicable) unless WTWIIBPL has a legal ground on which to do so (e.g. where any applicable law requires WTWIIBPL to do so, or where WTWIIBPL is compelled to do so by a court order).
9. Does WTWIIBPL transfer my Personal Information overseas?
Due to the international nature of WTWIIBPL's business operation and the (re)insurance market in which WTWIIBPL operates, Your personal information may be shared with third parties that are located in other countries.
9.1 Due to the global nature of WTWIIBPL's business operation, and the complex and international nature of the many specialist lines of (re)insurance WTWIIBPL handles, WTWIIBPL may need to transfer Your personal information across international borders to destinations where the law governing the protection of Your personal information may not be equivalent to the law that applies in India.
9.2 Your personal information may be transferred across international borders by WTWIIBPL to affiliates of the Willis Towers Watson Group and non-affiliated third parties described in Section 8.1 above, who could be located anywhere in the world. As a minimum, such third party recipients based overseas will include other Willis Towers Watson Group companies that are based across the globe and India (who provide IT systems support and/or administrative/operational support to Willis Towers Watson).
9.3 Please note that where WTWIIBPL shares Your personal information with other Willis Towers Watson Group companies or any other third party located overseas, Your personal information will be shared only to the extent it is necessary to allow such overseas recipients to perform their relevant task. Some overseas recipients might receive all of Your personal information (e.g. Willis Towers Watson Group companies that supports WTWIIBPL's IT systems) whilst some overseas recipients will only receive limited amount of Your personal information (e.g. those who assist WTWIIBPL in performing ID verification etc. will typically only receive basic personal information such as name and date of birth).
9.4 Whenever WTWIIBPL transfers Your personal information across international borders, WTWIIBPL will take all appropriate steps that are within WTWIIBPL's control to take so as to ensure that such transfer complies with the applicable legal requirements.
10. Will my Personal Information be kept by WTWIIBPL?
WTWIIBPL takes the privacy and confidentiality of Your personal information very seriously. Your personal information will be protected in accordance with the strict information security standards that apply across the Willis Towers Watson Group, including WTWIIBPL.
10.1 Please be assured that WTWIIBPL treats information security very seriously. Regardless of how Your personal information is kept, the privacy and confidentiality of Your personal information under WTWIIBPL 's control will be protected in accordance with the strict standards set by Willis Towers Watson Group's Information and Cyber Security Policy which applies to all members of the Willis Towers Watson Group and is enforced by a dedicated team of experienced security experts.
10.2 In the unlikely and unfortunate event Your personal information under WTWIIBPL's control becomes compromised due to any information security breach (e.g. unauthorised access, loss, or disclosure/alteration, including where this is caused by contractors), WTWIIBPL will act promptly to identify the cause of such information security breach, and remediate and mitigate the consequences of such information security breach. Where appropriate, WTWIIBPL will also notify You (and/or the relevant client of WTWIIBPL, where applicable) in accordance with any applicable law which requires WTWIIBPL to notify You about such incidents.
11. Does WTWIIBPL monitor my interaction with WTWIIBPL in any way?
To ensure the secure handling of Your personal information and to comply with the relevant legal and regulatory requirements, WTWIIBPL records and monitors access to its facilities and premises, and in some cases, communications between You and WTWIIBPL’s brokers, advisors and consultants as well. Please refer to Global Website Privacy Notice for more information.
12. Will this Privacy Notice change in the future?
12.1 This Privacy Notice may be amended from time to time to reflect changes in law or changes in WTWIIBPL's business operation, but where such revision becomes necessary in the future, WTWIIBPL will notify You to the extent it is practicable for WTWIIBPL to do so.
12.2 As a minimum, changes to this Privacy Notice will be publicised on [website address].
13. Who can I contact about my personal information?
If You wish to exercise Your legal right to access/correct Your personal information, or if You have any query or complaint regarding the handling of Your personal information by WTWIIBPL, please contact WTWIIBPL in the first place.
13.1 Where applicable under relevant laws, You might have the legal right to access Your personal information held by WTWIIBPL and to ask WTWIIBPL to correct or delete Your personal information (e.g. where it is inaccurate or out-of-date). If You would like to exercise this right, or if You have any query or complaint regarding the way in which Your personal information is handled by WTWIIBPL, please contact:
wtwiib-ithelpdesk@willistowerswatson.com
13.2 You can also write to the Willis Towers Watson Global Privacy Office at privacy@willistowerswatson.com.
13.3 Please note that Your right to access and correct/delete Your personal information could be subject to certain legal exemptions, and where any legal exemption applies, WTWIIBPL might not be able to comply with Your request to access or correct/delete Your personal information.
13.4 WTWIIBPL will endeavour to respond satisfactorily to Your request to access or correct/delete Your personal information, or any question, concern, or complaint regarding Your personal information You raise with WTWIIBPL.
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