WTW Service Provider Groups and Applicable “Business Purposes”
Captives provides Insurance Management and Consulting services and processes Client Personal Information for the Business Purposes set forth in paragraphs (a) and (d) below.
Employee Experience provides employee insights, change strategies, communication employee engagement, and technology solutions and processes Client Personal Information for the Business Purposes set forth in paragraphs (a) – (d), (f), and (g) below.
Health Outsourcing administers benefits eligibility and enrollment services for employee benefit programs and processes Client Personal Information for the Business Purposes set forth in paragraphs (a) – (d), (f), and (g) below.
Health and Benefits provides brokerage and consulting services, and processes Client Personal Information for the Business Purposes set forth in paragraphs (a), (b), and (d) below.
ICT Consulting provides advisory services to clients to help manage risk and capital, improve business performance and create competitive advantage and processes Client Personal Information for the Business Purposes set forth in paragraphs (a) – (d), (f), and (g) below.
ICT Insurance Technology provides insurance solutions across the selection, financing, and management of risk and processes Client Personal Information for the Business Purposes set forth in paragraphs (a) – (d), (f), and (g) below.
Integrated Global Solutions (IGS) provides strategy, governance and global management of retirement, healthcare and risk benefits services and processes Client Personal Information for the Business Purposes set forth in paragraphs (b) and (d) below.
Investments provides advisory investment services, funds and strategies, and delegated investment services and processes Client Personal Information for the Business Purposes set forth in paragraphs (a) and (d) below.
Pension Outsourcing administers pension benefits and processes Client Personal Information for the Business Purposes set forth in paragraphs (a) – (d), (f), and (g) below.
Retirement provides retirement and actuarial consulting services and processes Client Personal Information for the Business Purposes set forth in paragraphs (a), (b), (d), (f), and (g) below.
Via Benefits Accounts administers lifestyle, adoption, dependent care, tuition, and commuter accounts and processes Client Personal Information for the Business Purposes set forth in paragraphs (a), (b), (d), and (f) below.
Via Benefits Individual Marketplace provides retiree insurance services and only acts as a service provider to our employer clients and referral partners with respect to information initially provided to us by those parties for the purposes of outreach regarding their retiree programs and processes Client Personal Information for the Business Purposes set forth in paragraphs (a), (b), (d), and (f) below.
Work and Rewards analyzes compensation and benefits data to create employee rewards solutions and processes Client Personal Information for the Business Purposes set forth in paragraphs (a) – (g) below.
Business Purposes:
- Helping to ensure security and integrity to the extent the use of Client Personal Information is reasonably necessary and proportionate for these purposes,
- Debugging to identify and repair errors that impair existing intended functionality,
- Short-term, transient use, including but not limited to non-personalized advertising shown as part of an individual’s current interaction with the Client, provided that the Client Personal Information is not disclosed to another third party and is not used to build a profile about the individual or otherwise alter the individual’s experience outside the current interaction with the Client,
- Performing services on behalf of the Client, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services on behalf of the Client,
- Providing advertising and marketing services, except for Cross-Context Behavioral Advertising (as defined in paragraph 3.3(a)), to the individual, provided that for the purposes of advertising and marketing, WTW shall not combine the Personal Information of opted-out individuals which WTW receives from or on behalf of the Client with Personal Information which WTW receives from or on behalf of another person or persons, or collects from its own interaction with individuals,
- Undertaking internal research for technological development and demonstration, and/or
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the client, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the client.
WTW reserves the right to update this Exhibit based on its operational needs and in its sole discretion and as permitted by Applicable Privacy Law.
