Via Benefits | Our Commitment to Privacy

Acclaris Website Privacy Notice

Last Updated : April 2024

Acclaris, Inc. is an affiliate of Willis Towers Watson which operates worldwide through subsidiary and affiliate companies. A list of the Willis Towers Watson group companies (collectively, "Willis Towers Watson ") can be viewed here . Both Willis Towers Watson and Acclaris are committed to privacy and to transparency in our information practices.

1. Scope

This privacy notice ("Notice ") describes how Acclaris ("we,""us,"or "our ") handles personal information collected through this website, our mobile application(s) ("Mobile App "), and other websites we control that link to this privacy notice (the "Websites "), as well as related to our products and services, such as our Health Savings Account ("HSA ") administration services. This Notice does not apply to job applicants, others who may apply for employment with us, or employees or non-employee workers, or where we are subject to the Health Insurance Portability and Accountability Act ("HIPAA ").

This Notice may supplement any other notice regarding our information practices that you may have received from us and additionally describes our use of cookies and similar technologies.

In addition, Websites and specific web pages linked from www.viabenefitsaccounts.com may be subject to separate terms of use (including separate privacy notices). The inclusion of a link to a third-party website does not imply endorsement of the linked site or service by us or our affiliates. These third-party websites will be governed by different terms of use (including privacy notices) and you are solely responsible for viewing and using each such website in accordance with the applicable terms of use. Willis Towers Watson is not responsible for how your personal information is handled by such third-party websites.

Subject to the foregoing parameters, this Notice describes, generally, how Acclaris handles and processes personal information related to:

the use of our websites and associated services that link to this privacy notice, including www.viabenefitsaccounts.com and other websites controlled by Us (the "Websites "),
our former, current, and prospective clients,
individuals who communicate with us,
individuals who use our products and services, including our Mobile App, ("Services "), and individuals whose personal information we receive in providing the Services, subject to limitations set forth herein.

Our collection, use, disclosure, and processing of personal information about individuals will vary depending on the circumstances. This privacy notice describes our overall privacy and data protection practices. In some cases, different or additional notices about our data collection and processing practices may be provided and applied to our processing of certain personal information.

Personal information. In this Notice, our use of the term "personal information "includes other similar terms under applicable privacy laws —such as "personal data "and "personally identifiable information."In general, personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, linked, or may be linkable, with a particular individual or household, as applicable.

2. Cross-border Transfer

The data that we collect from you may be transferred to, accessed, processed, or stored in and subject to requests from law enforcement in jurisdictions outside of your home jurisdiction, including the United States, the European Union, and other jurisdictions in which we or our service providers operate. Some of these jurisdictions may not provide equivalent levels of data protection as your home jurisdiction. We have established safeguards to protect personal information transferred to other countries, including appropriate contractual protections. For more information on the appropriate safeguards, please contact us as set forth below.

3. Personal Information Collected

We collect personal information directly from individuals, automatically related to the use of the Services and Websites, and in some cases, from third parties (such as platform providers, payment processors, and operators of certain third-party services that we use). Generally, we collect your personal information on a voluntary basis. However, if you decline to provide certain personal information that is marked mandatory, you may not be able to access certain Services, or we may be unable to fully respond to your inquiry.

We may also collect additional personal information in providing our Services, operating our business, and interacting with individuals in the course of our business, which may at times include “sensitive ”information, such as health records. In these instances, we will provide specific data processing information to you regarding how we may process that data and what rights you may have regarding such processing.

Sources of personal information. We may collect personal information:

from any form you may complete and
submit through our Websites, for example information collected from the "Contact Us "page of our Websites,
from the content of surveys that you may complete,
from 'cookies 'and other similar tools deployed on parts of our Websites and Mobile App that can only be accessed by authenticated users who are logged into the Website and/or Mobile App (for further information regarding cookies used on our Websites, please see Section 6 below),
when you provide information as a client in connection with us providing professional services to you and
from other sources, such as public databases, joint marketing partners, vendors supporting our operations, including the functioning of our Websites and from other third parties.

Categories of personal information we collect. While the personal information we collect varies —as explained above —depending upon the nature of the services provided or used and our interactions with individuals, we may collect the following categories of personal information (subject to applicable legal requirements and restrictions):

Name, contact information and other identifiers: identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, or other similar identifiers.
Customer records: paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, social security number, tax ID, insurance policy number, bank account number, debit card number, or any other financial or payment information, medical information, or health insurance information.
Protected classifications: characteristics of protected classifications under California or federal law such as sex, age, disability, and citizenship status.
Commercial Information: including products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
Usage data: internet or other electronic network activity Information including, but not limited to, browsing history, search history, and information regarding a consumer 's interaction with an application, or advertisement.
Audio, video, and other electronic data: audio, electronic, or similar information such as, call recordings.

4. Purposes for Processing Personal Information

While the purposes for which we may process personal information will vary depending upon the circumstances, in general
we use personal information for the purposes set forth below.

Providing support and services: including to provide our Services; operate our Websites, applications, and online services; communicate with you about your access to and use of our Services; respond to your inquiries; provide troubleshooting, fulfill your orders and requests; process your payments and provide technical support; and for other customer service and support purposes.
Analyzing and improving our business: including to better understand how users access and use our Services and Websites; evaluate and improve our Websites, Services, and business operations; develop new features, offerings, and services; conduct surveys and other evaluations (such as customer satisfaction surveys); and for other research and analytical purposes.
Personalizing content and experiences: including to tailor content we send or display on our websites and other Services; offer location customization and personalized help and instructions; and otherwise personalize your experiences.
Advertising, marketing, and promotional purposes: including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; send you newsletters, offers or other information we think may interest you; contact you about our Services or information we think may interest you; and administer promotions and contests.
Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; investigate, prevent, detect, and take action regarding fraud, unauthorized access, potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.
Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties.
Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.
Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or
law enforcement requests.

Use and Disclosure of aggregate and de-identified information. We may de-identify personal information and create anonymous and aggregated data sets and reports in order to assess, improve and develop our business, products and services, prepare benchmarking reports on our industry and for other research, marketing and analytics purposes. Aggregated or de-identified information does not personally identify you or any other user (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code). When we de-identify personal information, we have implemented reasonable measures as required by law to ensure that the de-identified data cannot be associated with any individual or client. We will only maintain and use such data in a de-identified manner and do not attempt to re-identify the data, except as permitted by law.

We may share aggregate or de-identified information, which does not identify, and is not linked or linkable, to a particular individual, with third parties for research, marketing, analytics, and other purposes. When we de-identify personal information, we have implemented reasonable measures as required by law to ensure that the de-identified data cannot be associated with any individual or client. We will only maintain and use such data in a de-identified manner and do not attempt to re-identify the data, except as permitted by law.

5. Disclosure of Personal Information

Acclaris may disclose your personal information to any Willis Towers Watson group company for the uses and purposes set out above, including for marketing the products and services offered by other businesses across the Willis Towers Watson group (subject to applicable laws). We may also disclose your personal information for the following reasons:

to third party service providers such as entities providing customer service, email delivery, auditing, hosting our website and other services,
to our clients to protect and secure our business operations, Services, network and information technology and resources and/or inform them of, or investigate, prevent, detect, and take action regarding actual or potential security incidents, suspicious activity, fraud, unauthorized access, or situations involving potential threats to the rights, property or safety of any person or third party, or other unauthorized activities or misconduct, subject to applicable law,
to third parties involved with events that you register for, to facilitate your participation in those events,
if we are obliged to disclose your personal information under applicable law or regulation, which may include laws outside your country of residence,
in order to enforce or apply our Website terms of use, or to protect
the rights, privacy, safety, or property of Willis Towers Watson, or those of our clients, affiliates, or other parties,
subject to applicable laws, to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence,
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 may be transferred to the acquiring entity,
in accordance with any separate terms and conditions of use that may apply to you, or with your implicit or explicit consent.

We request those external service providers to implement and apply security safeguards to ensure the privacy and security of your personal information. These third parties have agreed to confidentiality restrictions and to use of any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us.

6. Cookies and Tracking

Our Websites and Mobile App may use first party and third-party cookies, pixel tags, plugins, and other tools to gather device, usage and browsing information when users visit our Websites or use our online services. For instance, when you visit our Websites, our server may record your IP address (and associated location information) and other information such as the type of your internet browser, your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and the pages you view and links you click on our Websites, as well as date and time stamps associates with your activities on our Websites.

We use the information for security purposes, to facilitate navigation, to personalize and improve your experience while using the Websites and/or Mobile App, to improve and measure our advertising campaigns and to better reach users with relevant advertising both on our Websites and on third party websites. We also gather statistical information about use of the Websites and Mobile App in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Our Cookie Notice contains further information about our use of cookies. You can manage how your preferences regarding cookies set by this Website, using our cookie preference manager available in the footer of the
linked page.

Cookies. Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on the websites, pages visited, language preferences, and other anonymous traffic data. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. However, if you select such a setting, this may affect the functioning of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or log on to our Websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org . For more information about the use of cookies on our Websites and Mobile App and your choices regarding the placement of cookies, please see our Cookie Notice .

User experience analytics: Our Websites and Mobile App use user experience analytics tools, which use cookies and similar technologies to collect and analyze information about use of the Websites and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources.

Pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Websites to, among other things, track the actions of users of the Websites and Mobile App (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Websites and response rates. We and our service providers also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.

Third Party Analytics Tools. Our Websites and Mobile App use automated devices and applications operated by third parties (e.g., Google Analytics), which use cookies and similar technologies to collect and analyze information about use of the Websites and Mobile App and report on activities and trends. Please see our
Cookie Notice for more information.

Opt-Out Preference Signals and "Do-Not-Track "Signals. Please note, our Website does not recognize or respond to any signal which your browser might transmit through its so-called "Do Not Track "(DNT) feature. If you wish to disable cookies on our Websites, you should not rely on DNT browser settings. For more information about DNT signals, please click here .

7. Interest-based Advertising

We may work with third-party ad networks, analytics companies, measurement services and others ("third-party ad companies ") to display advertising on our Websites and to manage our advertising on third-party sites, mobile apps, and online services. We and these third-party ad companies may use cookies, pixels tags and other tools to collect information on our Websites (and on third-party sites and services), such as browsing history, IP address, device ID, cookie and advertising IDs, and other identifiers, general location information and, with your consent, your device 's geolocation information; we and these third-party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.

You can manage how your preferences regarding third party ad company cookies set by this Website, using our cookie preference manager available in the footer of the linked page.

Please see our Cookie Notice for information about the third parties we may work with to display targeted ads on third-party sites and to measure the success of our marketing and campaigns. You may also obtain more information about targeted or "interest-based advertising "and opt-out of many ad networks at the industry websites below:

Canada: www.youradchoices.ca
U.S.: www.aboutads.info

8. Security

We have implemented technical and organizational security measures to protect the personal information we collect. Despite this, the security of the transmission of information via the Internet cannot always be guaranteed and you acknowledge this in your access and use of our Websites. 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 "Contact &Comments "section below.

9. Individual Rights and Choices

Marketing. You may
opt out from receiving marketing-related communications from us on a going-forward basis by contacting us or by using the unsubscribe mechanism contained in each email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

Individual Rights. Individual rights regarding Personal Information vary depending on which laws apply to your specific circumstances. Some of these rights might be subject to exemptions or limitations under applicable laws. We encourage you to contact us should you have any questions on the specific rights available to you with respect to our processing of your personal information. Depending on the circumstances, we may redirect you to send this request to your current or former employer. However, in accordance with legal and other permissible considerations, we will make reasonable efforts to honor your request promptly or inform you if we cannot honor your request, or we require further information in order to fulfil your request. You may submit a request to us related to your Personal Information in one of the following ways:

By contacting us at 1-800-275-9849 (toll free)
By emailing us at ViaBenefitsPrivacy@wtwco.com

10. Retention Period

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Notice unless a longer retention period is required or permitted by law. We may retain personal information for longer where required by our regulatory obligations or professional indemnity obligations, or where we believe it is necessary to establish, defend, or protect our legal rights and interests, or those of others. With respect to the data and files we handle as a processor or service provider, we retain this personal information in accordance with our clients 'instructions.

11. Children and Minors

The Websites and Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. The sole exception to the forgoing is that our services may include collection of dependent information as required by the main account holder 's elections, and it is possible such dependents could be under the age of 16.

12. Changes to our Privacy Notice

From time to time, we may change our Notice. The effective date set forth at the top indicates the last time this Notice was revised. Checking this effective date allows you to determine
whether there have been changes since the last time you reviewed the Notice. We will notify you of changes to this Notice by posting the revised Notice on our Websites and Mobile App.

13. Contact and Comments

If you have any questions or comments regarding this Notice, please contact our Privacy Team, at 800 North Glebe Road, Arlington, VA 22203 or at ViaBenefitsPrivacy@wtwco.com .

Via Benefits Accounts Cookie Notice

Last Revised: April 2024

This Cookie Notice describes the different types of cookies and similar technologies that may be applied on Viabenefitsaccounts.com and our mobile application(s) ("Mobile App "), where relevant, on other Willis Towers Watson websites that link to this Cookie Notice (the "Sites ").

1. What is a cookie?

Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on the Sites, pages visited, language preferences, and other traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Sites and to recognize your computer in order to assist your use of the Sites. We also gather statistical information about use of the Sites in order to improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.

There are different types of cookies, for example:

•Cookies served directly by Acclaris, Inc. ('first party cookies ') and cookies served on our behalf, for example by advertisers and data analytics companies ('third party cookies ')

•Cookies which endure for different periods of time, including those that only last only as long as your browser is open (referred to as 'session cookies ') These are deleted automatically once you close your browser.

Other cookies are 'permanent cookies ', meaning that they survive after your browser is closed. For example, they recognize your device when you open your browser and browse the internet again.

2. What cookies do we use?

We set out below a description of the different types of cookies and similar technologies that may be used on the Sites.

To the extent any Personal Information (which is information that identifies you as an individual or
relates to an identifiable individual) is collected through cookies, our Privacy Notice applies and supplements this Cookie Notice.

Strictly Necessary Cookies. Strictly necessary cookies enable you to navigate the Sites and to use their services and features. Without these necessary cookies and similar technologies, the Sites will not perform as smoothly for you as we would like them to, and we may not be able to provide the Sites or certain services or features.

Functional Cookies. Functional cookies collect information about your use of the Sites and enable us to improve the way they work. For example, functional cookies show us which are the most frequently visited pages on the Sites, help us record any difficulties you have with the Sites, and show us whether our promotional campaigns are effective. This allows us to see the overall patterns of usage on the Sites. We use the information to analyze traffic on the Sites.

Advertising Cookies. Advertising cookies are set to display targeted promotions or advertisements based upon your interests on the Sites or to manage our advertising. These cookies collect information about your activities on these and other sites to provide you targeted advertising. You can find information about advertising cookies, including how to see what cookies have been set on your device and how to manage and delete them here.

3. How do I manage cookies?

You have the right to choose whether or not to accept cookies. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider 's website via your help screen. You can change your cookies using the cookie preference manager tool available via a link on our Sites.

However, if you choose not to accept cookies, this may affect the functioning of our Sites.

If you are using a mobile device, you can limit interest-based advertising on your device by adjusting the settings provided by your device manufacturer, such as " Limit Ad Tracking "for iOS or " Opt-out of interest-based ads "for Android.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org , www.allaboutcookies.org , or www.youronlinechoices.eu .

4. Changes to our Cookie Notice

We may change this Cookie Notice from time to time. Please take a look at the "Last Revised "legend at the top of this page to see when this Cookie Notice was last revised. If we make significant changes to this Cookie Notice, we will notify you of changes when you next visit any of our Sites.

5. Contacts and comments

If you have any questions or comments regarding this Cookie Notice, please contact us by email at ViaBenefitsPrivacy@wtwco.com .