Alight Solutions Privacy Statement

Effective: January 2017

Last Updated: November 23, 2020

 

Alight Solutions LLC is committed to protecting your privacy. This Privacy Statement ("Statement") explains how Alight Solutions, our subsidiaries and affiliates (collectively, "Alight," "we," "our" or "us") collect, use and share your information when you access any website or software application (the "Sites") administered by us and the choices you can make about what information you share. This Statement applies to information collected in connection with your use of the Sites. Please note that the applicability of certain details of this Statement vary depending on the services Alight provides to your employer or plan sponsor or that are otherwise made available to you at the request of your employer or plan sponsor. If you have questions about the details of this Statement, you can contact Alight using the information at the bottom of this Statement.

Please read this Statement from time to time. BY ACCESSING AND USING ANY OF THE SITES, YOU ACKNOWLEDGE AND AGREE TO THE TERMS OF THIS STATEMENT.


The following topics are covered below:

What type of information does Alight collect?

How does Alight use your personal information?

When and to whom Alight discloses your information?

How does Alight protect your personal information?

Data Retention

Access, Correction, Erasure and Choice

How can I opt-out of receiving messages?

How does Alight use cookies and other tracking technology?

How does Alight protect children’s privacy?

Does Alight transfer personal information to other countries?

Notice to residents of California

Notice to residents of Nevada

Complaints

Your Right to Non-Discrimination

Changes to this Privacy Statement

Contact Us

 

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What type of information does Alight collect?

We collect information about you when you visit and use the Sites and from your employer or its service providers when your employer engages Alight to provide services to you. In addition to the information you or your employer provide us, in some instances, Alight automatically collects information about the devices you use to interact with the Sites. The information we automatically collect may include your IP address, unique device identifier, type of operating system used, mobile carrier and your browser location. We may also use cookies and other online tracking technologies, as described below.

Over the past 12 months, we may have collected information from or about you including, but not limited to, the following information:


Where we collect and process sensitive information (as described above), and where applicable, we rely on one of the exceptions listed in Art.9(2) of the European Union's General Data Protection Regulation ("GDPR") to permit that processing, including the affected person's consent.

Your Choice to Provide Information: You may choose not to provide personal information to Alight by refraining from, among other things, using the Sites. You also may refrain from submitting information directly to us. However, if you do not provide personal information when requested, we may not be able to provide you with the full range of our products and services, or with information about our products and services, promotions, and other opportunities.

 

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How does Alight use your personal information?

We may use the personal information we collect about you, including your financial information and health-related information, for a number of business purposes, including the following:


With your consent, we may also use your personal information for additional purposes.

We will not use your information for automated individual decision-making, including profiling, as contemplated under Article 22 of the GDPR.

Legal Basis for Processing your Personal Data: Your information will be processed by our workforce personnel when they have been instructed to do so in accordance with Alight's policies or as requested by your employer. We will process personal information only when we have a legal basis to do so. The legal basis we rely on will be one of the following:


In order to process any special category of personal information under the GDPR, we rely on the consents that we or your employer obtain from you in order to provide you with the services or any other applicable basis for processing that applies to your employer.

If we intend to use personal information for a purpose other than the purpose for which we collected the data, we will provide you with information about this secondary purpose, the legal basis for processing and, where required, obtain your consent, before we engage in further processing.

We do not sell any personal information to third parties and have not done so for the past 12 months.

 

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When and to whom Alight discloses your information

In the past 12 months, your information may have been disclosed or shared with the following categories of third parties for a variety of business purposes:


The personal information that may have been shared in the past 12 months for these business purposes includes the categories of personal information listed in the What type of information does Alight collect section above.

We do not sell any personal information to third parties and have not done so for the past 12 months.

 

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How does Alight protect your personal information?

Alight has implemented reasonable physical, technical and administrative security safeguards, as appropriate under applicable law(s), to protect personal information from loss, misuse, alteration, exfiltration, or destruction; taking into account the sensitivity of the information and the purpose for which it was collected.

 

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Data Retention

Unless provided otherwise in this Statement, we will retain your information for as long as your account is active or for as long as necessary for the relevant purposes of processing. We may also retain and use your information for longer periods in case it is necessary to comply with our legal obligations, resolve disputes, and/or enforce our agreements. To the extent possible, Alight will de-identify, or take reasonable steps to delete from its records, information no longer required for the purposes identified in this Statement, other than information which we are required by law to retain.

 

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Access, Correction, Erasure and Choice

Online users of the Sites can log into their account at any time and:


In addition, if you are a resident of the United Kingdom or a country within the European Economic Area:


You can access, correct, update, and request deletion of your personal information via your online account, by telephoning the call center dedicated to your employer or plan sponsor, or by directing your query to your employer. We will respond to your request within 30 days.

Alternatively, you may request assistance by emailing Alight's privacy mailbox at privacy.info@alight.com. We may sometimes need to verify your identify before we fulfil your request.

In some circumstances, only your employer, and not Alight, may have the authority to update, correct, or delete your personal information. In these instances, please contact your employer directly. Otherwise, we will forward your request to your employer.

 

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How can I opt-out of receiving messages?

Email: If you request electronic communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included at the bottom of the communication. You can also adjust your notification settings in the Sites profile. In addition, you may communicate your choice to opt out via an email to Alight at privacy.info@alight.com.

Phone: Alight will not call or text you your phone number without first providing notice or obtaining your consent as required by the laws applicable to your jurisdiction. If you previously chose to receive notifications on your mobile device or on your phone, but no longer wish to receive them, you can opt-out and manage your preferences either through your mobile device or in your profile on the Sites.

 

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How does Alight use cookies and other tracking technology?

When you visit the Sites, we may place pieces of code, commonly referred to as "cookies," or similar technology on your device. To learn more about what cookies and related technology we use, please see our Cookie Notice.

Links to Other Websites: The Sites may contain links to other sites that are outside of our control and are not covered by this Statement. If you access other sites using the links provided, the operators of those sites may collect information from you which will be used by them in accordance with their own privacy statements. We encourage you to read the privacy statements on other websites you visit. Alight is not responsible for the content or privacy practices of linked sites or any use of those sites.

Please be aware that the Sites may contain links to sites maintained by other Alight entities that also are not governed by this Statement but by other privacy statements that may differ slightly from this Statement. We encourage you to review the privacy statement of each website you visit.

Do Not Track: Some browsers have "do not track" features that allow you to tell a website not to track you. These features are not all uniform and we do not respond to those signals.

 

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How does Alight protect children's privacy?

The Sites are intended for a general audience and are not directed at children under the age of 16. If you are under the age of 16 please do not provide personal information to us through the Sites. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 16, we will promptly delete the information.

 

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Does Alight transfer personal information to other countries?

Information that you provide to us may be stored on servers and with third-party service providers in the United States and other countries in which we do business and whose data protection laws may differ from the jurisdiction in which you live. When we transfer the personal information of users who are located in the EU to a location outside of the European Economic Area for processing, we use an approved transfer mechanism such as the European Commission approved standard contractual clauses. To learn more about the transfer mechanism that we use to effect such transfer, you may contact us at privacy.info@alight.com.

 

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Notice to Residents of California

If you are a California resident, California law provides you with certain rights.

California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal information by Alight to third parties for those third parties' direct marketing purposes. We do not disclose your personal information to third parties for the third parties' direct marketing purposes unless you affirmatively agree to it. If this Statement were to change, we will update this Statement, and provide California residents with the opportunity to opt-out of such disclosures.

If you are an employee of a client (i.e., your employer) receiving services from Alight, Alight receives your information on the Sites solely as a service provider of your employer. We only uses your information for the purposes of completing a business purpose of our clients and do not use or disclosure your information except as necessary to accomplish the business purpose for which we received your information. In these circumstances, Alight's client remains primarily responsible for your information. As a result, if you were to make a request to know, access or delete your data pursuant to California Civil Code 1798.100 et seq., the California Consumer Privacy Act of 2018 ("CCPA"), we may re-direct that request to our client for response. If you are trying to exercise your CCPA rights, please contact your employer directly.

 

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Notice to Residents of Nevada

We do not presently sell any personal information we collect to any third parties. If we were to do so in the future, we will update this Statement, and provide Nevada residents with the opportunity to opt-out of the sale of their personal information.

 

Complaints

If you have concerns about the way in which we have handled your personal information, please contact us (see below for "Contact information") so that we can try to resolve the issue. You also have the right to lodge a complaint with the applicable supervisory authority.

 

Your Right to Non-Discrimination

We will not discriminate against individuals for exercising any of their data rights under applicable law. This means that if you exercise any of your rights in connection with your data, we will not deny you goods or services; charge you different prices or rates for goods or services; or provide different levels or quality of goods or services to you.

 

Changes to this Privacy Statement

Please read this Statement from time to time as we may modify the Statement at any time in our sole discretion. If we make material changes to the Statement that significantly change how we use your personal information, we will use reasonable efforts to bring these changes to your attention either through an email to your registered email address or by another means.

 

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Contact Information

If you have any questions or concerns about AlightSolutions' use of your personal information or about this Privacy Statement, you can email us at privacy.info@alight.com. Our Data Protection Officer can also be reached using this email address.

You may also write to us at:

Alight Solutions
ATTN: Chief Privacy Officer
Legal Department
4 Overlook Point
Lincolnshire, IL 60069

You can also contact your employer service center with any questions about your benefits account.