Willis Group Holdings Privacy Statement
Our Privacy Notice
Keeping customer information secure is a priority for Willis Group Holdings, and its subsidiaries (“Willis”). We are providing this privacy notice to individual clients who purchase or receive our services through one of the Willis Family of Companies for personal, family or household purposes. We hope this helps you understand how we handle the personal information about you that we collect and may disclose. This notice also tells you how you can limit our disclosure of personal information about you. The provisions of this notice will apply to former clients as well as our current clients unless we state otherwise.
When we share personal information within the Willis Family of Companies, it can make it easier to service your placement because it reduces the time it might have taken to obtain needed information. In addition, sharing personal information can help you receive timely notice about new services or other enhancements that may be of interest to you from the Willis Family of Companies or from nonaffiliated third parties.
We protect personal information we collect about you by maintaining physical, electronic, and procedural safeguards that meet or exceed applicable law. Unrelated third parties who have access to personal information must agree to follow appropriate standards of security and confidentiality. We train our employee on how to properly handle personal information and we restrict access to personal information.
Categories of Personal Information We Collect and May Disclose:
The personal information we collect about you comes from the following sources:
- Information we receive from you on applications or other forms, such as name, address, social security number, telephone number, occupation, marital status, claims histories, risk characteristics and activities, personal health information, assets and income;
- Information about your placements we make on your behalf, on behalf of an insurer, or nonaffiliated third parties;
- Information we receive from a consumer reporting agency, such as your credit bureau reports and other information relating to your credit worthiness; and
- Information we receive about you from other sources, such as your employer and other third parties.
We may disclose any of the information that we collect within the Willis Family of Companies and nonaffiliated third parties as described below.
Categories of Affiliates to Whom We May Disclose Personal Information
Our affiliates are the family of companies controlled by Willis. Affiliates with whom we may share personal information about you are all insurance brokers, broker dealers or other insurance industry participants. Our brokers offer different lines of brokerage and placement services which are more fully explained on our website, www.willis.com. Our affiliates generally do business under the Willis brand or the English language equivalent of the Willis brand.
Categories of Nonaffiliated Third Parties to Whom We May Disclose Personal Information
Nonaffiliated third parties are third parties not controlled, directly or indirectly, by Willis. We may disclose personal information about you to the following types of nonaffiliated third parties:
- Financial services providers, such as companies engaged in insurance and securities;
- Non-financial organizations, such as companies engaged in direct marketing and the selling of consumer products and services;
- Governmental authorities, regulatory authorities;
- Unrelated third parties who obtain and present to us appropriate judicial orders;
- Our private lawyers, auditors and other appropriate representatives.
We may also disclose personal information in connection with a sale or merger.
If you check Box 1 on the PRIVACY CHOICES FORM, we will not make these disclosures except as follows. First, we may disclose information about you, as described above in “Categories of Personal Information We Collect and May Disclose,” to third parties that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements. Second, we may disclose personal information about you to third parties as permitted by law, including disclosures necessary to process and service your placement, to protect against fraud, money laundering, terrorists financing, and other legal requirements and to protect the security or confidentiality of our records.
This section describes your privacy choices. Please remember that we will continue to protect your personal information regardless of your privacy choices.
Disclosing to Nonaffiliated Third Parties (Box 1)
As described in this notice, we will limit the personal information we disclose about you to nonaffiliated third parties if you check Box 1 on the PRIVACY CHOICES FORM.
Sharing with Our Affiliates (Box 2)
The law allows us to share with our affiliates any information about our placements or experiences with you. Unless otherwise permitted by law, we will not share with our affiliates other information that you provide to us or that we obtain from third parties (for example, credit bureaus) if you check Box 2 on the PRIVACY CHOICES FORM.
You may be a customer of a number of the members of the Willis Family of Companies. This may mean that you will also receive a notice of their intent to share certain information about you. If you receive such a notice, you will need to separately notify them if you do not want such information shared.
Mailing and Telemarketing Lists (Boxes 3 and 4)
We would like to keep you informed about promotional offers from our affiliates and from nonaffiliated third parties. If you wish to be taken off our mailing and/or telephone lists that we use for such offers, please check Box 3 and/or Box 4 on the PRIVACY CHOICES FORM.
We will continue to mail you information that you may find valuable in managing your placement even if you have checked Box 3. We may also send you promotional offers from third parties in communications that you receive from us concerning your placement.
Information for Vermont, New Mexico and California Customers
In response to a Vermont and New Mexico law, we will automatically treat placements with Vermont and New Mexico mailing addresses as if you checked Box 1 and Box 2 on the PRIVACY CHOICES FORM without requiring you to return the form. And if we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our placements or experiences with you.
In response to a California law, we will automatically treat placements with California mailing addresses as if you filled in Box 1 on the PRIVACY CHOICES FORM and will not disclose personal information about you to nonaffiliated parties except as permitted by applicable California law. We will also limit the sharing of information about you with our affiliates to comply with California privacy laws that apply to us. To further restrict sharing with affiliates as described in this notice, you can fill in Box 2 of the PRIVACY CHOICES FORM.
Notice of Changes
From time to time, we may change our Privacy Statement and post those changes to our website located at www.willis.com. The effective date of this Privacy Statement, as indicated below, indicates the last time this Privacy Statement was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the policy. We will notify you of changes to this Privacy Statement by posting the revised Privacy Statement to our website. Changes to this Privacy Statement are effective 30 days after the date in which the revised Privacy Statement is posted to www.willis.com.
If you have a question about this Privacy Statement, you may contact Group Compliance, Privacy Officer at One World Financial Centre, 200 Liberty Street, 7th Floor, New York, New York 10281-1003, United States. You may also contact the Group Compliance, Privacy Officer at (212) 804-0531 or at group.compliance@willis.com.
Dispute Resolution
If you have any concerns regarding our privacy policies or this Privacy Statement, we encourage you to promptly contact our Privacy Officer, who is authorized to address privacy issues on behalf of Willis. Should you determine that your concern is not properly addressed by our Privacy Officer, we encourage you to contact the Group Compliance Director at 44 0203 124 6000 or chitty_mi@willis.com or The Willis Building, 51 Lime St, London EC3M 7DQ, United Kingdom.
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