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Acclaris Website Privacy Notice
Last Updated: October 2023
Acclaris, Inc. (Acclaris) 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," "we," "us," or "our") can be viewed here. Both Willis Towers Watson and Acclaris are committed to privacy and to transparency in our information practices.
This privacy notice ("Notice") describes how Acclaris (the "Company," "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, where we act as a "Business" or "Controller" as those terms are defined by applicable privacy laws. This Notice does not apply to job applicants, others who may apply for employment with is, or to employees or non-employee workers or where we are subject to the Health Insurance Portability and Accountability Act ("HIPAA"), the Gramm-Leach Bliley Act ("GLBA"), or act as a "service provider" or "processor" to our clients.
Subject to the foregoing parameters, this Notice describes, generally, how Acclaris handles and processes personal information related to:
Our collection, use, and disclosure and processing of personal information about individuals will vary depending upon the circumstances. This privacy notice is intended to describe 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 apply 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 that is transferred to other countries, including appropriate contractual protections. For more information on the appropriate safeguards in place, please contact us as set forth below.
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.
The personal information that we collect, and process will vary depending upon the circumstances. For example, the personal information we may collect includes:
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.
Categories of sources of personal information we collect. We may collect personal information directly from you, as well as automatically related to your use of our Websites and other services, as well as from third parties. For example, we collect personal information:
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):
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.
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.
5. Disclosure of Personal Information
We disclose the personal information we collect as set forth in this section.
A. Purposes for Which We Disclose 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:
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.
Aggregate and de-identified information. 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.
B. Categories of Personal Information Disclosed.
Certain privacy laws (such as the California Consumer Privacy Act ("CCPA") require that we disclose the categories of Personal Information that we have disclosed for a business purpose as well as any categories that we have "sold" (as that term is defined under the CCPA or other applicable laws). Please review the descriptions of the categories of personal information under the Personal Information Collected section above, for further descriptions of each category of personal information.
Categories of Personal Information Disclosed for a business purpose. In general, we may disclose the following categories of personal information in support of our business purposes identified above:
Categories of personal information sold. We do not "sell" or "share" Personal Information.
C. Categories of Third Parties to whom Personal Information is Disclosed.
As set out above we may disclose Personal Information to other Willis Towers Watson Group Companies, our clients, service providers that support our operations, and cookies providers. Examples of service providers may include companies who assist in fulfilling our contracts and providing customer assistance. For instance, a service provider may be utilized to perform mailings. We also may disclose Personal Information to cookies providers that facilitate the operation of our Websites, by supporting the Websites functionality or providing analytics related to the use of the Websites.
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.
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.
Opt-Out Preference Signals and "Do-Not-Track" Signals. If your browser enables the Global Privacy Control (GPC) when visiting our Website, our Website will automatically opt you out of any tracking cookies that constitute a "sale" where required by applicable privacy law. For more information about the GPC and to learn how to implement it on your browser, please click here. 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
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:
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 you. 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. Please see Additional Information for California Residents for details specific to California residents.
Subject to our obligations under the law, you may request that we confirm processing of or to review, make amendments to, or delete your Personal Information, or otherwise exercise your data privacy rights over Personal Information applicable to you.
In accordance with legal and other permissible considerations, we will make reasonable efforts to honor your request promptly or inform you if 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:
Additional information for California residents. Willis Towers Watson is committed to respecting the privacy rights of individuals under all privacy laws applicable to us. If you are a California resident, you have certain rights under California privacy laws regarding your personal information as set forth below in the Additional Information for California Residents section.
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.
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 email@example.com.
This section provides additional information as required by the CCPA when we act as a "business" under the CCPA, such as when we provide Administration Services for Health Savings Accounts ("HSAs").
In this section, we provide information for California residents as required under California privacy laws, including the CCPA, which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. This section does not address or apply to our handling of:
Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The beginning of this document sets forth generally the categories of personal information (as defined by the CCPA) about California residents that we collect and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the Personal information we may collect section above, and for the purposes described in the Purposes for which we use personal information section above.
Rights of California residents. California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.
California residents may make a Request to Know up to twice every 12 months. We will respond to verifiable requests received from California residents as required by law. The instructions for submitting a verifiable Request to Know are described in the "Submitting Requests" section below.
Financial incentives: A business may offer financial incentives for the collection, sale, or deletion of California residents' personal information, where the incentive is not unjust, unreasonable, coercive, or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time and may not be included in such incentives without their prior informed opt-in consent. We do not offer any such incentives at this time.
Submitting Requests. Requests to Know, Requests to Correct, and Requests to Delete may be submitted:
We will use the following process to verify Requests to Know, Requests to Correct, and Requests to Delete: We will acknowledge receipt of you Consumer Request, verify it using processes required by law, then process and respond to your request as required by law. To verify such requests, we may ask you to provide the following information:
An authorized agent can make a request on a California residents' behalf by providing a power of attorney valid under California law, or providing: (1) proof that the consumer authorized the agent to do so; (2) verification of their own identity with respect to a right to know categories, right to know specific pieces of personal information, requests to correct, or requests to delete which are outlined above; and (3) direct confirmation that the consumer provided the authorized agent permission to submit the request.
We will respond to verifiable requests received from California residents as required by law. For more information about our privacy practices, you may contact us as set forth in the Contact and Comments section above.
Consumer Requests Received in 2022. In calendar year 2022, we received and responded to consumer requests under the CCPA as set forth in the table below:
Number of Requests Received
Number of Requests to which We Responded
Number of Requests Denied
Average Response Time (Number of Days)
Requests to Know
Requests to Delete
Requests to Opt-Out of the Sale of Personal Information
Last Revised: October 2023
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.
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