Privacy policy


Thomsons Online Benefits Ltd. (Thomsons) and its affiliates (we) are committed to safeguarding the privacy of our clients and users (you/your) who visit our website (the "Site”). This Privacy Notice is intended to inform you of the ways in which we collect personal information, the uses to which that information will be put, and the ways in which we will protect any personal information you choose to provide us via this Site, via your employer or directly to us.

There may be additional personal (and other) information that we have or collect about you or your company pursuant to other relationships which is subject to other notices, agreements and rules.

This Privacy Notice covers the following areas: 

1) Information we collect about you

 

2) How we use your personal information

 

3) How we protect your personal information

 

4) Contacting us and your rights to prevent marketing and to access and update your personal information

 

5) Our Cookie Policy

 

6) How changes to this Privacy Notice and the Cookies Policy will be made 

 

(1) Information we collect about you

We will collect and process all or some of the following personal information about you:

      (a) Information voluntarily provided by you:

In the course of using this Site, you may choose to provide us with information to help us serve your needs. For example, you may provide us your e-mail address to request information, or you may send us your mailing address so we may send you the material you have requested. You may also choose to apply for a job with us and submit a job application via our careers pages https://www.thomsons.com/about-us/careers/. Any personal information you send us will be used only for the purpose indicated on the careers pages or in this notice

      (b) Our correspondence

If you contact us, we will typically keep a record of that correspondence.

      (c) Survey information

If we ask you to complete surveys that we use for research purposes, we shall collect the information provided in the completed survey.

      (d) Website and communication usage

Details of your visits to the website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources you access.

 

(2) How we use your personal information

This section sets out the purposes for which we use personal information that we collect and, in compliance with our obligations under European law, identify the “legal grounds” on which we rely to process the information.

European Data Protection Laws allows companies to process personal information only when the processing is permitted by the specific “legal grounds” set out in the law (the full description of each of these grounds can be found here.

Please note that in addition to the disclosures we have identified below, in some circumstances we will also disclose personal information to service providers, contractors, agents and affiliates of the Company that perform activities described in this notice on our behalf.

 

      (a) To communicate effectively with you and conduct our business

To conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us, which in some circumstances may include passing your data to third parties such as agents or contractors or to our advisors (e.g. legal, financial, business or other advisors).

Use justification: contract performance and legitimate interests (to enable us to perform our obligations and provide our services to you)

 

      (b)To provide you with marketing material

To provide you with updates and offers, where you have chosen to receive these. We may also use your information for marketing our own products and services to you by post, email, SMS, phone and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communications sent to you or you may opt out by contacting us as set out below.

Use justification: consent and legitimate interest (to keep you updated with news in relation to our products and services)

 

      (c) For research and development purposes

To analyse your personal information together with information from other clients for data analytics purposes, including to create insights, reports and other analytics to better understand and improve the quality of and market Thomsons products and services. The output of such analytics does not identify particular clients or individuals.

Use justification: legitimate interests (to allow us to improve our services)

 

      (d) To monitor certain activities

To monitor queries and transactions to ensure service quality, compliance with procedures and to combat fraud.

Use justification: legal obligations, legal claims and legitimate interests (to ensure the quality and legality of our services)

 

      (e) To inform you of changes

To notify you about changes to our services and products

Use justification: legitimate interests (to notify you about changes to our services)

 

      (f) To ensure website content is relevant

To ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers.

Use justification: contract performance, legitimate interests (to allow us to provide you with content and services on the websites)

 

      (g) To reorganise or make changes to our business

If we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this notice.

Use justification: legitimate interests (in order to allow us to change our business)

 

      (h) In connection with legal or regulatory obligations

We process your personal information to comply with our regulatory requirements or as part of dialogue with our regulators as applicable which may include disclosing your personal information to third parties, the court service, regulators and/or law enforcement agencies  in  connection  with  enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so.  Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

Use justification: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities)

 

      (i) For fraud, anti-money laundering and sanctions screenings

When establishing or maintaining client relationships for the provision of certain services we process your personal information for the purposes of carrying out fraud, anti-money laundering or sanctions violations checks.

Use justification: legal obligations

 

 (3) Transmission, storage and security of your personal information

Security over the internet

No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.

All information you provide to us is stored on our or our secure servers and accessed and used subject to our security policies and standards.  Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of.  We ask you not to share a password with anyone.

 

Export outside the EEA

Your personal information will be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the country in which you are located, whose data protection laws may be of a lower standard than those in your country.  We will, in all circumstances, safeguard personal information as set out in this Privacy Notice.

Where we transfer personal information from inside the European Economic Area (the EEA) to outside the EEA, we are required to take specific measures to safeguard the relevant personal information.  Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which are not subject to this approval (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), we will establish legal grounds justifying such transfer, such as MMC Binding Corporate Rules, model contractual clauses, or other legal grounds permitted by applicable legal requirements.

Please contact us as set out below if you would like to see a copy of the specific safeguards applied to the export of your personal information.

 

Storage limitation

We will retain your personal information for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example where we are required to retain personal information for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information is retained) or securely destroyed.

 

Your rights and contacting us

Marketing

You have the right to ask us not to process your personal information for marketing purposes.  You can exercise the right at any time by clicking the “unsubscribe” option on any electronic marketing communication sent to you or by contacting us as set out below.

 

Updating information

We will use reasonable endeavours to ensure that your personal information is accurate.  In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by contacting us as set out below.

 

Your rights

If you have any questions in relation to our use of your personal information, you should contact us as set out below. Under certain conditions, you have the right to require us to: 

  a) provide you with further details on the use we make of your information;

  b) update any inaccuracies in the personal information we hold;

  c) delete any personal information that we no longer have a lawful ground to use;

  e) object to any processing that Thomsons justifies on the “legitimate interests” ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;

  f) object to direct marketing (including any profiling for such purposes); and

  g) restrict how we use your information whilst we consider your inquiry,

and where processing is based on consent, you have the right to withdraw your consent by contacting us at the contact details below or as indicated when consent was given.

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g.  the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).  If you exercise any of these rights we will check your entitlement and respond in most cases within a month.

If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the data protection regulator in your country.

 

(4) Contacting us

Depending on where you are located, the “data controller” of your personal information processed by us under this Privacy Notice will be different.  Please see here for a list of which group companies will be data controllers in which countries.

If you have any questions in relation to this Privacy Notice, please contact our Data Protection Officer at privacycoordinator@mercer.com.

 

(5) Cookies policy

We use cookies on the websites.  To find out more about how we use cookies, please see our Cookies Policy at [LINK to Cookie Notice]. Ours is here: https://www.thomsons.com/cookie-policy/

 

(6) Changes to our Privacy Notice or Cookies Policy

We may change the content of our websites and how we use cookies and consequently our Privacy Notice and our Cookie Policy may change from time to time in the future.  If we change this Privacy Notice, we will update the date the Privacy Notice was last changed below.  If these changes are material, we will take reasonable steps to notify you of the changes.

This Privacy Notice was last updated on 23 May 2018.

 

 

Annex 1

 

These are the principal legal grounds that justify our use of your information:

Consent: where you have consented to our use of your information you will have been presented with a consent form in relation to any such use and may withdraw your consent as indicated by such form or by emailing us at privacycoordinator@mercer.com.

Contract performance: where your information is necessary to enter into or perform our contract with you.

Legal obligation: where we need to use your information to comply with our legal obligations.

Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.

Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.

 

 

Annex 2

 

Mercer Entity

Country

Mercer (Austria) GmbH

Austria

Mercer (Belgium) SA-NV

Belgium

Mercer (Danmark) A/S

Denmark

Mercer (Finland) OY

Finland

Mercer (France) SAS

France

Mercer Consulting (France) SAS

Mercer Deutschland GmbH

Germany

Mercer Treuhand GmbH

Neuburger Noble Lowndes GmbH

Promerit AG

R R B Beratungsgesellschaft fuer Altersversorgung mbh

realright GmbH

Promerit Hungary Kft

Hungary

Irish Pensions Trust Limited

Ireland

Matsack Trust Limited

Mercer (Ireland) Limited

Mercer Financial Services Limited

Mercer Global Investments Europe Limited

Mercer Global Investments Management Limited

Mercer Investment Consulting Limited

Mercer Ireland Holdings Limited

Mercer Master Trustees Limited

Mercer Trustees Limited

Mercer Italia Srl Socio Unico

Italy

Mercer (Nederland) B.V.

Netherlands

Mercer Consulting B.V.

Mercer (Norge) AS

Norway

Mercer (Polska) Sp.z o.o.

Poland

Mercer (Portugal) Lda

Portugal

Mercer Career, Unipessoal Lda

Mercer Employee Benefits - Medicacao de Seguros Unipessoal Lda.

Thomsons Online Benefits SRL

Romania

Mercer Consulting, S.L.U.

Spain

Mercer Outsourcing, S.L.U.

Mercer (Sweden) AB

Sweden

Pensionsservice Benefit Network Sverige AB

William M. Mercer AB

Mercer Private Markets Advisers (US) AG

Switzerland

Mercer Private Markets AG

Mercer Switzerland Inc.

Promerit Schweiz AG

Mercer Danismanlik Anonim Sirketi

Turkey

Mercer Sigorta Brokerligi Anonim Sirketi

SCM PE II Scotland GP Ltd

United Kingdom

Jelf Financial Planning Limited

Kepler Associates Limited

Mercer Africa Limited

Mercer Consulting Limited

Mercer Employee Benefits Limited

Mercer Limited

Mercer Technology Acquisitions Limited

Online Benefits Limited

Sedgwick Financial Services Limited

Sedgwick Noble Lowndes (UK) Limited

Sedgwick Noble Lowndes Group Limited

Sedgwick Noble Lowndes Limited

TBX Solutions Limited

The Benefit Express Holdings Limited

The Benefit Express Limited

The Positive Ageing Company Limited

Thomsons Online Benefits Limited

PFT Limited

Mercer Trustees Limited