In this privacy 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, or could reasonably be linked or linkable with a particular individual or household, either directly or indirectly.
This Policy describes our practices in connection with information that we collect through the online information portal (the “Site”), decision support tools and enrollment system, collectively known as “the Marketplace,” or through computers and mobile devices, as well as through HTML-formatted email messages that we send to you that link to this Privacy Notice (collectively, the “Services”).
When providing the Services, Liazon acts as a “service provider” under applicable privacy and data protection laws.
PERSONAL INFORMATION WE MAY COLLECT
The personal information that we collect and process will vary depending upon the circumstances. We may collect or receive personal information directly from individuals, (including but not limited to automatic collection of certain personal information related to the use of our Site) and from third parties.
Third Party Information You Provide.
As part of our Services, you may provide us or our service providers with personal information relating to other people (such as your dependents or beneficiaries). You represent that you have the authority and/or permission to provide us with this information and to grant us authorization to use such information in accordance with this Policy.
Protected Health Information.
Certain information that relates to health or the provision of healthcare may constitute Protected Health Information (“PHI”) under HIPAA (the Health Insurance Portability and Accountability Act of 1996 and 45 C.F.R. parts 142 and 160-164, as amended) and applicable state privacy laws. Entities that create or receive this information (such as your health insurance provider) are subject to strict rules regarding how they can share this information. If we collect, receive, use or disclose any PHI, we do so as a “business associate” under HIPAA. As a business associate, our collection, use and disclosure of PHI is also subject to our applicable business associate agreements with employers and/or carriers. We will treat PHI that we collect or receive in compliance with all applicable state and federal laws and regulations regarding the confidentiality of such information.
Information We Receive From Third Parties.
We may receive certain information from third parties, such as your employer and carriers.
Information We Collect Directly.
We also collect certain personal information directly from users of our Site.
Information Collected Automatically.
When you use our Site, we may also automatically collect certain information about the use of our Site through cookies, web beacons and other technologies, such as:
Please see the section below regarding Cookies and Tracking for information on how this information is collected and treated by Us.
SOURCES OF PERSONAL INFORMATION WE COLLECT
We may collect your personal Information in a variety of ways, including:
USE OF PERSONAL INFORMATION
We may use personal information:
DISCLOSURE OF YOUR PERSONAL INFORMATION
We may disclose personal information for the following reasons:
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.
COOKIES AND TRACKING
Our Site 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 Site or use our Services. For instance, when you visit our Site, our server may record your IP address (and associated location information) and other information such as your internet browser, your Media Access Control (MAC) address, computer type, screen resolution, operating system and version, device manufacturer and model, language, and the pages you view and links you click on our Site, as well as date and time stamp regarding your activities on our Site.
We use this information for security purposes, to facilitate navigation, and to personalize and improve your experience while using the Site. We also gather statistical information about use of the Site in order to continually improve its design and functionality, understand how it is are used and assist us with resolving questions about it.
We may use and disclose information that we collect automatically for any purpose, except where we are required to do otherwise under applicable law.
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 website (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the website and response rates. We and our service providers may also use pixel tags in HTML emails to you and 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.
Do-Not-Track signals. Please note that our Site does not recognize or respond to any signal which your browser might transmit through the so-called ‘Do Not Track’ feature your browser might have. If you wish to disable cookies on our Site, you should not rely on any ‘Do Not Track’ feature your browser might have.
THIRD PARTY SERVICES
We may include links in the Services to third-party companies, such as carriers, health and wellness providers or other service providers. When you access those links or utilize those products or services, you will be leaving the Services and your usage of those third party sites will not be governed by this Privacy Notice, but by the privacy policies of such third party.
INFORMATION ABOUT CHILDREN
The Services are not directed at children under the age of 13, and we request that they not provide personal information through the Services.
Please note that we do collect information about dependent children as it pertains to their benefits coverage.
HOW WE PROTECT YOUR INFORMATION
We seek to use organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. 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 How to Contact Us section below.
CHOICES AND ACCESS
If you would like to review, correct, update, suppress or delete personal information that you have previously provided to us, you may contact us at the address below.
In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
CHANGES TO THIS POLICY
This Policy is effective as of the date stated at the top of this Policy. We reserve the right to revise and update this Policy from time to time. By accessing the Site or using the Services after we make any such changes to this Policy, you are deemed to have accepted such changes.
Please refer back to this Policy on a regular basis.
HOW TO CONTACT US
If you have questions about this Policy, you may contact us via email at email@example.com (noting LIAZON PRIVACY NOTICE in the subject) or in writing to us at the following address:
Liazon Corporation, a Willis Towers Watson Company
Attn: Privacy Team
800 N. Glebe Road
Arlington, VA 22203
If you would like to submit a request regarding your personal information (e.g., a request to access or delete your personal information) collected or held by us, please email us at firstname.lastname@example.org. We will refer your request to your employer or the relevant carrier as appropriate and will assist them in responding to your request. You can also copy your employer or the carrier directly.