WILLIS.COM: PRIVACY NOTICE



This privacy notice describes how Willis generally handles personal information collected through www.willis.com and other websites controlled by Willis. This privacy notice may be revised from time to time to reflect changes in law or changes in Willis’ business operation. This privacy notice was last updated on 10 June 2013.


  1. SCOPE OF THIS PRIVACY NOTICE
  2. This privacy notice only applies to Willis.com and any other website of Willis where a link to this privacy notice is provided. These websites are controlled by the Group IT function of the Willis Group (“Willis”), whose ultimate holding company is Willis Group Holdings PLC, a company incorporated in the Republic of Ireland.

    Willis operates worldwide with subsidiary and affiliate companies in the North America, Latin America, Asia-Pacific, Eastern and Western Europe, Russia, the Middle East, United Kingdom and Ireland. Such subsidiary and affiliate companies (as well as individual divisions of Willis) may have their own websites with their own privacy notices, in which case this privacy notice will not apply to such websites unless such website provides a link to this privacy notice.

    Websites and specific web pages linked from Willis.com may be subject to separate terms of use (including separate privacy notices). You must not provide personal information if you do not accept such terms of use.

    Where links from Willis.com are provided to non-Willis websites, Willis is not responsible for those websites. 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 is not responsible for how your personal information is handled by such third-party websites.

    If you are a job applicant, please note that in addition to this privacy notice, a separate privacy notice will apply to personal information collected through our job application portal in addition to this privacy notice. This can be viewed here.

  3. WILLIS WEBSITE
  4. Willis.com and other Willis websites to which this privacy notice apply (including our web-based client and carrier tools and our job application portal) are hosted in the United States. If you are located outside the U.S., your provision of personal information or other access to or use of our websites result in your personal information being transmitted to the United States, a jurisdiction where the laws protecting personal information may not be equivalent to the laws of your own country. Further, by providing your personal information, you acknowledge that Willis North America Inc. may, depending on your geographical location, use and disclose your personal information in accordance with its Safe Harbor Privacy Policy (to the extent it is appropriate to do so).

    Willis maintains appropriate technical and organizational security measures to protect the security and confidentiality of your personal information. 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.


  5. INFORMATION WE MAY COLLECT FROM YOU
  6. The information we may collect through our websites includes:

    • your name, address, occupation and other contact information;


    • information regarding your dealings with us;


    • any interest you have in relation to our services or our practice areas (including job openings);


    • any information you may voluntarily submit to us by completing any form on our websites; and


    • details of your visits to and usage of our website including the date and time of your visit, the internet address from which you visited and the resources on our website that you viewed.

    We may collect the information in various ways:

    • from any form you may complete and submit through our websites, for example information collected from the “Contact Us” page of our website;


    • from the content of surveys that you may complete on our website;


    • from ‘cookies’ and other similar tools deployed on our websites (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. Such information may be collected through Willis.com when clients access Willis client links within this website. Access will be subject to the terms of business we have with clients and any additional terms and conditions of use attached to those sites; and


    • when you provide information as a prospective or actual job applicant through our websites. Please refer to our Applicant Privacy Policy for further information in this regard.


  7. WHAT WE MAY DO WITH YOUR PERSONAL INFORMATION
  8. We may use information held about you in the following ways and for purposes specified in the relevant parts of the website:

    • to facilitate your participation in interactive features you may choose to use on our websites;


    • to correspond with you, notify you of events or changes to our service, or otherwise to respond to your queries and requests for information, which may include marketing to you; and


    • for the purposes of providing professional services to you via Willis applications; such services will be subject to additional terms and conditions of use including privacy.


  9. DISCLOSURE OF YOUR INFORMATION
  10. Willis may disclose your personal information to any company affiliated or associated with Willis for the uses and purposes set out above. We may disclose your personal information to independent third parties:

    • if we are obliged to disclose your personal information under applicable law or regulation, or in order to enforce or apply our website terms of use, or to protect the rights of Willis, our clients, or other parties;


    • in accordance with the separate terms and conditions of use that may attach to Willis website links; and


    • where this is necessary for the uses and purposes set out above (for example, where some aspects of our websites’ operations are outsourced to a third-party service provider).


  11. COOKIES AND INFORMATION COLLECTED FROM YOUR COMPUTER
  12. When you visit our website, our server may record your IP address for the purposes of systems administration. In most cases, your IP address is not linked to any of your personal information, but in limited circumstances (e.g. if you log into restricted parts of our website), your IP address can be linked to your personal information. Willis may also gather other non-personal information from you (from which Willis cannot identify you), such as the type of your internet browser, which Willis uses to provide you with a more effective service.

    Additionally, when you visit our websites, Willis may store a ‘cookie’ on the hard drive of your computer. Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites. You can control the way in which cookies are used by altering your browser settings. 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.

    In order to help us improve our websites and the services we provide and to improve your experience of using our websites, our websites use two types of cookies:


    • Session cookie. This type of cookie is used only on those parts of our websites that are restricted and can only be accessed by authorized users who typically authenticate themselves through their user IDs and passwords (e.g. our online client/carrier tools). This type of cookie is essential to keep authenticated users logged into our websites and to enable them to visit different parts of our websites. It will be stored on your computer for a short period (typically 48 hours) and the information held in it will be accessed automatically to authenticate you when you visit the website again. Otherwise, this cookie will be deleted when you log out and close the browser.


    • Google Analytics. This cookie is provided by Google, and we use them on our websites in order to analyze how visitors use our website, thereby helping us to improve our websites. Google Analytics collects information in an anonymous form, including the number of visitors to our websites, how visitors have arrived to our websites, and which pages on our website the visitors have viewed. Click here for an overview of privacy at Google.

    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 (including any ‘Do Not Track’ feature your browser may have), 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.

  13. SECURITY
  14. Willis maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. 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.


  15. CHANGES TO OUR PRIVACY POLICY
  16. From time to time, we may change our privacy notice and post those changes to our website located at www.willis.com. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice 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 notice by posting the revised privacy notice on our website.


  17. CONTACT
  18. If you have any question or comment regarding Willis’ use of personal information you provided through our websites, please contact our Group Head of Compliance, at The Willis Building, 51 Lime Street, London, EC3M 7DQ, United Kingdom, or at group.compliance@willis.com.

    If you are an individual based in South Africa and wish to exercise your rights under South Africa’s Promotion of Access to Information Act, No 2 of 2000 in respect of your personal information which is handled by Willis South Africa (Pty) Limited ("WSA"), please directly contact WSA’s Information Officer, whose contact details are set out in WSA’s Promotion of Access to Information Act Manual.