Last Updated: June 2023
Alight Solutions LLC is committed to protecting your privacy. This Privacy Policy ("Policy") 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, mobile app or software application (the "Sites") administered by us and the choices you can make about what information you share. This Policy applies to information collected in connection with your use of the Sites. Please note that the applicability of certain details of this Policy 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 Policy, you can contact Alight using the information at the bottom of this Policy.
Please review this Policy from time to time.
The following topics are covered below:
How does Alight collect your personal information?
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?
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
Your Right to Non-Discrimination
Changes to this Privacy Policy
We collect information about you when you interact with us, including when you visit and use the Sites. We also collect information about you from your employer or its service providers. Alight also automatically collects information about the devices you use to interact with the Sites.
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.
We may use the personal information we collect for the following purposes:
We may send text messages to mobile devices of customers who have consented to these messages via an opt-in request. We may also send emails unless you have opted-out. These messages may also include marketing related messages about additional services we think may be useful to you. The opportunity to opt-out of a specific campaign is made available with the messages we send. You can opt-out of these text and email message at any time by following the instructions in the message or by contacting us using the information below.
With your consent, we may also use your personal information for additional purposes. For example, with your consent we may use your Google Fit service or Apple HealthKit service (“Fitness Service”) to collect your fitness activity data through our mobile app. When you agree to this integration, in the background, our mobile app will collect and analyze your fitness activity data from the Fitness Service to track your progress in our health program challenges. We do not use data collected through Fitness Service for marketing or advertising purposes. Our mobile app cannot read from or write to your Fitness Service without your consent. You can disable our access to any type of fitness activity data at any time in Fitness Service settings on your device. The use and transfer of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
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.
In the past 12 months, your information may have been disclosed for a variety of business purposes:
We do not sell any personal information to third parties and have not done so for the past 12 months.
Alight has implemented physical, technical and administrative security safeguards, designed 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. However, no method of data storage or transmission is 100% secure.
Unless provided otherwise in this Policy, 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 Policy, other than information which we are required by law to retain.
Online users of the Sites can log into their account at any time and:
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 submitting your request here. 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.
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 email communication. You can also adjust your notification settings in your profile on the Sites.
Phone: Alight will not call you at 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.
Text Messages: You may opt-in to receive occasional text messages from Alight or our partners or affiliates to enroll in our Services, receive updates on our Services or services we think may be of interest to you. Message frequency will vary. You agree that by providing your mobile phone number and opting in to receive text messages, you expressly consent to receive automated text messages from us to the mobile phone number you provide. Consent to receiving text messages is not required in order to receive our Services. Message and data rates may apply, and you should check the rates of your mobile carrier. Your mobile carrier is not liable for delayed or undelivered messages. You can opt out of receiving text messages by texting STOP in response to any text message. You can also text HELP and we will respond with instructions on how to opt-out of or sign up for text messages from Alight. As we are located in the United States, international rates may apply depending on your location. We share your mobile phone number with service providers with whom we contract in order to send you automated text messages, but we will not share your mobile phone number with third parties for their own marketing purposes without your express consent. Contact us at privacy.info@alight.com if you have any questions about our text message program.
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 Policy. 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 policies. We encourage you to read the privacy policies 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 Policy but by other privacy policies that may differ slightly from this Policy. We encourage you to review the privacy policy 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.
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.
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.
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. You may opt-out of this disclosure by contacting us at the information provided below.
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.
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 Policy, and provide Nevada residents with the opportunity to opt-out of the sale of their personal information.
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.
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.
Please read this Policy from time to time as we may modify the Policy at any time in our sole discretion. If we make material changes to the Policy 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.
If you have any questions or concerns about Alight Solutions' use of your personal information or about this Privacy Policy, 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.