Global Privacy Notice

French Canadian
Effective Date: August 22, 2018

Mercer | Sirota believes strongly in protecting your privacy. This Privacy Notice applies to our websites, mobile applications, online surveys, and other online and mobile applications associated with us and our services that link to or post this Privacy Notice (collectively, the “Services”). This Privacy Notice is intended to inform you of the ways in which this site collects personal information, the uses to which that information is put, how and why we share that information, and the ways in which we protect it. Generally, personal information is information that can identify you or your activities on the site.

This Privacy Notice applies solely to data collected through use of the site. You may provide Mercer | Sirota with or Mercer | Sirota may receive information about you other than in connection with the site; the collection and receipt of such information may be subject to separate terms and conditions and a separate privacy notice. We encourage you to review the privacy notice and terms and conditions that may apply to those practices. This Privacy Notice is not intended to alter the terms or conditions of any other agreements you may have with Mercer | Sirota to the extent that those agreements govern issues other than the collection and use of your information through this site.

This Privacy Notice is incorporated into the Terms of Use. By using this site, you acknowledge that you have read, understand and accept these Terms of Use, including this Privacy Notice. Please take a moment to familiarize yourself with our privacy practices. Let us know if you have any questions by contacting us at privacy@sirota.mercer.com for assistance.

Since we may change this Privacy Notice, we recommend that you check the current version available from time to time. If we make changes to this Privacy Notice, we will update the “Effective Date” at the top of the page. If there are significant changes, you will be provided with appropriate online notice. Your continued use of the site constitutes your agreement to the effective Privacy Notice.

WHAT INFORMATION DOES THIS PRIVACY NOTICE COVER?
This Notice describes how we may collect, use, share, and keep information about you that we get about you. We gather information if you:

  • Visit or use our website or apps;
  • Receive, send, or reply to electronic communications from us;
  • View or click on our ads or other online content;
  • Take a survey;
  • Interact with us through social media websites and other websites and apps; and
  • Create an account as an employer or third party.

In this Notice, we also explain how we may combine online information with other information and how we then use the combined information.

WHAT DATA DO WE COLLECT?
The information that you provide to us or that we collect or receive about you may depend on how you interact with us and in which capacity. Most of Mercer | Sirota’s collection related to surveys is voluntary. Generally, we may collect the following information about you:

  • contact information such as your name, email address, phone number, and IP address;
  • sensitive information such as your date of birth, marital status, gender, and ethnic background;
  • employment information such as employee title, employment district, and team leader;
  • general survey information including information in comment boxes.

Information Provided by You, Your Representatives or Third Parties
We collect information from you; your employer; business partners; and other third parties who have an interest in surveying your satisfaction with their services. You might provide this information when you take a survey; create and manage an account; visit this site; or communicate with us. In addition, your employer or someone acting on their behalf may provide us with information about you so we can contact you about our services and surveys.

Employers or third parties supplying us with personal information about other people or employees, represent that they have the authority to provide this information on their behalf. In these instances, they further represent that the individuals to whom this information relates have been informed of and understand the reason(s) for them providing or us obtaining the information, the manner in which this information will be used and disclosed, and have consented to such use and disclosure.

Survey Open Text Field
Our surveys may offer you the opportunity to provide written comments or elaborate about certain responses. We request that you do not provide information that may personally identify you or others when writing in the comment section. We will do our best to redact personally identifiable information that you may have inadvertently included in the commentaries. However, it is your responsibility to refrain from posting or sharing such information.

Blog and Website Comment Sections
Our site offers the opportunity to participate in blog postings and/or commentary sections. You should be aware that any information you provide in these areas may be read, collected, shared, and used by others who access them. Therefore, we ask that you please be mindful when you share your personal information, and that you do not share personal information about third parties. To request removal of your personal information from our blog or comments section, contact us at privacy@sirota.mercer.com.

Information Collected by Automated Means
We also may collect information using cookies, web beacons, and other technologies. Cookies are small pieces of text a website places on your computer to help remember information about your visit. Web beacons are tiny graphics with unique identifiers that are embedded invisibly on the web pages. Neither cookies nor web beacons can read data off your computer’s hard drive. We use information collected from cookies and web beacons to improve your experience and the overall quality of our site. We also may use cookies and web beacons to collect information from third parties (such as Google) to help advertise our products and services, analyze the effectiveness of our marketing or the performance of this site, and determine whether you may be interested in other products or services. We also use web beacons to help deliver cookies and compile analytics. Our cookies and web beacons may come from third-party service providers who have our permission to place such tools on our site. Certain Cookies and Similar Technologies do collect Personal Information. For example, if you click Remember Me when you log in to our website, a cookie will store your username.

We (and our service providers or third party ad servers) may collect information using cookies and web beacons about:

  • The device used to browse sites
  • The IP address and info related to that IP
  • Browsing history on our sites
  • How you search for our sites
  • Which ads you view, access, or click
  • Browsing activities over time and across other sites
  • Whether you open our electronic communications and how you interact with these communications
  • Location of your mobile device

You can refuse to accept cookies and delete them by adjusting your browser settings. Please note that refusing or deleting cookies may impair your browsing experience on the site, or prevent you from using some of its services, and it may also delete any preferences you have set. For more information about how to reject or delete cookies, consult with your browser’s or device’s help documentation, or visit http://www.aboutcookies.org. We belong to ad networks that may use your browsing history across participating website to show you interest-based advertisements on those websites. We do not use technology that recognizes do-not-track signals or similar mechanisms from your browser indicating that you do not wish to be tracked or receive interest based ads. You may be able to take steps to opt out of Internet-based advertising by installing a browser plugin from a third party, where available. For more information about Internet-based advertising, please see: http://www.networkadvertising.org/managing/opt_out.asp.

Information to Provide and Protect Our Site
In addition, in the course of seeking network security and consistent service for all users, software programs may be employed to monitor network traffic, identify unauthorized access or access to nonpublic information, detect computer viruses and other software that might damage our computers or the network, and monitor and fine-tune our network’s performance. These programs may detect additional information from your computer such as your IP address, addresses from network packets, and other technical information. Such information is used to maintain the security and performance of our networks and computer systems.
We may combine the information you provide us and information we automatically collected with information from public, third-party sources, or affiliates.

HOW DO WE USE THE DATA WE COLLECT?
We use your personal information to:

  • verify your identity, when appropriate;
  • register and service your online account;
  • provide you with products and services you request;
  • allow you to manage the services you requested;
  • market products and services to you, including ours, those of our affiliates, and those of other third parties;
  • conduct research, statistical analysis, survey/demographical interpretation, and other data studies based on the data collected;
  • contact you when necessary and to respond to your requests and inquiries;
  • customize your experience when using the site;
  • fulfill legal and regulatory requirements;
  • analyze and improve services, enhance this site, and evaluate the effectiveness of our surveys and research and overall services.

Most of our studies are conducted with data that has been aggregated and/or de-identified. In a significant number of cases, we are unable to re-identify the data once unique identifiers have been removed and/or the data has been aggregated.
We may use Google Analytics to collect information such as how often users visit the site. We use this information to maintain and improve the site. For information about how Google uses the information, see Terms of Service and the Google Privacy Statement. You can opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.
We may use marketing technologies to analyze trends, administer the website, track users movements around the website, and gather demographic information about our user base. We may receive reports based on the use of these technologies. We may also use this data to improve the site’s content and marketing strategies, ensure the functionality of our systems, and to optimize our website.

We may also use the information we collect and receive as otherwise described to you at the point of collection or pursuant to your consent.
If you receive marketing communications and would wish them to stop you may follow the procedure described in the electronic marketing communications sent to you to unsubscribe or opt-out from future communications.

WITH WHOM DO WE SHARE YOUR DATA?
We share aggregated data with the employer or third party who requested the survey. The results do not contain identifiable information and are shared in aggregated form.

We may also share your information to assist with managing and running this site, to or provide any service you authorized, or provide other services requested by your employer, or otherwise as described in this Privacy Notice or when we have your consent. We may share this information with:

  • your employer;
  • our affiliates, subsidiaries, and business partners to enable them to provide services to you and to contact you regarding additional products and services that may be of interest to you;
  • third-party service providers that have been retained to perform services on our behalf or on behalf of your employer, or as authorized by your employer; and
  • third-party service providers retained by Mercer | Sirota to provide services directly to you through this website.

We may also share information in association with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
Third parties to whom we disclose information are required by law and/or contractual requirements to keep your personal information confidential and secure. These parties may not use or disclose it except as reasonably necessary to provide services to you, on our behalf, on behalf of your employer, or to comply with or as permitted by applicable law.

We do not rent, sell, or otherwise disclose your information to unaffiliated third parties for their own marketing, unless so authorized by you, your employer.
We may disclose and/or process your personal information without your prior permission, as permitted by law, including instances when we have a good faith belief that it is necessary to: (a) protect the legal rights, safety, and security of Mercer | Sirota, our affiliates and business partners, and users of our site; (b) enforce the Terms of Use; (c) respond to claims of suspected or actual illegal activity; (d) respond to an audit or investigate a complaint or security threat; or (e) comply with law or legal process, or a request for cooperation by a government or other entity.

We may share information that is not reasonably likely to identify you personally for any commercially legitimate business purpose.

FOR HOW LONG DO WE RETAIN YOUR INFORMATION?
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 de-identified (and de-identified information is retained) or securely destroyed.

WHAT RIGHTS AND OBLIGATIONS DO YOU HAVE WITH RESPECT TO YOUR DATA?
Accessing and Correcting Your Information
Keeping your information accurate and up-to-date is very important; whenever possible we will provide you with an opportunity to correct inaccurate or outdated information. However, bear in mind that if the data has been de-identified and/or aggregated it may not be possible for Mercer | Sirota to track down your personal information. If you have questions or concerns regarding changes to your personal information please contact us to privacy@sirota.mercer.com.

SOME OTHER MATTERS
Steps We Take to Protect Your Information
This site and all information submitted by or on behalf of you through this site may be collected, stored, and processed in countries other than the one in which you reside, including, but not limited to, the United States.

We restrict access to your personal information to those employees of ours, our affiliates, and third- party service providers who reasonably need it to provide products or services. We have implemented physical, administrative, and technical safeguards to protect your personal information from unauthorized access. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of these systems, nor can we guarantee that information supplied by you or on your behalf cannot be intercepted while being transmitted over the Internet.

External Links
This site includes links to, and application programming interfaces (APIs) with, other websites that are operated by other organizations. If you access another organization’s site using a link that organization may collect information from you. We are not responsible for the content or privacy practices of third-party websites or their use. Once you have left this site via such a link (you can tell where you are by checking the URL in the location bar on your browser), you should refer to those websites’ privacy policies, terms of use, and practices to determine how they handle any information they collect from you.

External Link to Mercer Account Center
This site may grant you to access Mercer Account Center. Mercer Account Center (or Mercer Single Sign On) allows users to create an account and use a single set of login credentials for all Mercer related accounts. When you access the Mercer Account Center you are leaving the Sirota website, we request that you take the time to read and review the Mercer Account Center privacy notice.

Does This Privacy Notice Apply to International Users?
This Privacy Notice is provided in accordance with and subject to U.S. law. If you access this site from a location outside the United States, you agree that your use of this site is subject to the terms of this Privacy Notice and the Terms of Use.

If you are a resident of the European Economic Area (EEA), in order to provide our Site and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the EEA, including to the United States. 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 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 to privacy@sirota.mercer.com if you would like to see a copy of the specific safeguards applied to the export of your personal information.
If you have specific questions or concerns you may contact our EU Data Privacy Officer Mary Pothos at GDPRLegal@mmc.com.

EEA Consent
In situations where special categories of data (such as political opinions, religious views, sex life, etc.) is collected we may request your consent. You may deny consent and choose not to provide the information requested, such decision will not affect your opportunity to participate in the survey. If you consent you still have a right to withdraw consent at any time. However, if the data has been de-identified and/or aggregated we may be unable to properly identify your survey, thereby preventing you from withdrawing consent. Data Subjects whose data has been de-identified within the meaning of the GDPR cannot claim the right to withdraw consent because their data can no longer be used to identify them.

In addition to your consent we also rely on the need to perform our contractual obligations as well as our legitimate interests as our legal bases for processing your personal data under European data protection law.

EEA Rights
If you have any questions in relation to our use of your personal information, you should contact us to privacy@sirota.mercer.com. Under certain conditions, you have the right to require us to:

  1. ) provide you with further details on the use we make of your information;
  2. ) provide you with a copy of information that you have provided to us;
  3. ) update any inaccuracies in the personal information we hold;
  4. ) delete any personal information that we no longer have a lawful ground to use;
  5. ) object to any processing that Mercer justifies on the “legitimate interests” ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;
  6. ) object to direct marketing (including any profiling for such purposes); and
  7. ) restrict how we use your information whilst we consider your inquiry,

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (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.

Business Transactions
In the event we sell some or all of our assets or go through other business transactions, such as mergers, acquisitions, bankruptcy, or reorganizations, it is possible your personal information could be one of the assets sold or transferred in connection with the transaction. We may disclose and/or transfer your personal information to a third-party purchaser in these circumstances.

Children
This site is not intended for children, and we do not knowingly collect, use, or disclose information from children under the age of thirteen (13) years old. In an instance where such information was collected, it would be purely accidental and unintentional. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 13, please email us at privacy@sirota.mercer.com

Rights of California Residents
Under California’s “Shine the Light” law, site visitors who are California residents may request and obtain a notice once a year about the personal information we share with other businesses for their direct marketing purposes. Such a notice includes a list of the categories of personal information that was shared (if any), and the names and addresses of all third parties with which the personal information was shared (if any). The notice covers the preceding calendar year. To obtain such a notice, please contact us as previously described. In addition, under this law you are entitled to be advised how our site handles “do not track” browser signals. As described previously, we do not use technology recognizing do-not-track signals from your browser.

Questions or Concerns
If you have any questions, concerns, or complaints about this Privacy Notice, or our privacy practices in general, please email us to privacy@sirota.mercer.com.