Mercer Privacy Notice
Mercer LLC and its affiliates (we/The Company) are all affiliates of Marsh & McLennan Companies, Inc. (MMC). We are committed to safeguarding the privacy of our clients and users (you/your) who visit our websites (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 directly or via this Site, or via your employer or your benefit program sponsor.
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
(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 at the Company and submit a job application via our careers site https://careers.mmc.com/. Any personal information you send us will be used only for the purpose indicated on the careers site 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 applicable data protection laws of the European Economic Area (EEA) and United Kingdom (UK), identify the “legal grounds” on which we rely to process the information.
EEA and UK 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 or MMC 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 sharing your data with third parties such as agents or contractors or with our advisers (e.g. legal, financial, business or other advisers) or with other companies in MMC’s corporate group (MMC Affiliates).
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 use your personal information to provide you with information about products or services which we think would be of interest to you. We may also share your personal information with MMC Affiliates so that they can provide you with information about their products and services. These may be sent by email, SMS, phone, fax or post.
Within MMC, we operate under a number of brands and you may receive such communications from our different trading names, such as, Mercer, Mercer Marsh Benefits (MMB), Darwin, Marsh, Marsh Commercial, Marsh Networks and others.
We take care to ensure that our marketing activities comply with all applicable EEA and UK legal requirements. In some cases, this may mean that we ask for your consent in advance of us or MMC Affiliates sending you marketing materials.
In all cases, you can always opt out of receiving marketing communications from us or MMC Affiliates, at any time. We will always 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.
Please note that, even if you opt out of receiving marketing messages, we may still send you communications in connection with the services we provide to you.
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 Mercer’s advice, 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 MMC Affiliates, 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 advisers) 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) How we protect your personal information
(a) 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.
(b) Export outside the EEA and the UK
Your personal information may be accessed by staff, MMC Affiliates 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 EEA or the UK to outside the EEA or the UK, we are required to take specific measures to safeguard the relevant personal information. Certain countries outside the EEA and the UK have been approved by the European Commission or the UK government as providing essentially equivalent protections to EEA and UK 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 for the EEA here and the full list for the UK here), 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.
(c) 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.
(4) Your rights & contacting us
(a) 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.
(b) 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.
(c) 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:
- provide you with further details on the use we make of your information;
- provide you with a copy of information that you have provided to us;
- update any inaccuracies in the personal information we hold;
- delete any personal information that we no longer have a lawful ground to use;
- 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;
- object to direct marketing (including any profiling for such purposes); and
- restrict how we use your information whilst we consider your enquiry, 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.
(d) 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) How we use Cookies
(6) How changes to this Privacy Notice will be made
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 1 June 2021.
Mercer LLC and its affiliates (the “Company”) believe strongly in protecting the privacy of Internet users who visit our website, located at www.mercer.com (the “Site”). This Privacy Statement is intended to inform you of the ways in which this Site collects 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. Generally, personal information is information that can be used to identify you or your activities on the Site or information about you which you provide to us through services offered on the Site.
This Privacy Statement applies solely to data collected via the Site. 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 agreements and rules.
What Data Do We Collect?
The information collected by the Company through the Site falls into two categories: (1) information voluntarily supplied by visitors to our Site and (2) information gathered via automated means as visitors navigate through our Site.
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 at the Company and submit a job application via our career site https://careers.marshmclennan.com/. Any personal information you send us will be used only for the purpose indicated on the careers site or in this Statement.
Information Collected by Automated Means:
To understand how we may use cookies on our Site, please see our Cookie Notice.
In addition, in the course of ensuring network security and consistent service for all users, the Company employs software programmes to do such things as monitor network traffic, identify unauthorised access or access to nonpublic information, detect computer viruses and other software that might damage the Company’s computers or the network, and monitor and fine-tune the performance of the Company network and this Site. In the course of such monitoring, these programmes may detect additional information from your computer such as your IP address, addresses from network packets, and other technical information. Any such information is used only for the purpose of maintaining the security and performance of the Company’s networks and computer systems.
How Do We Use the Data We Collect?
We will use the information provided by you in order to serve your needs. This may include things such as sending you electronic or written materials or, for example, if you supply us with your telephone number, you may receive telephone contact from us in response to your request. We work with our business partners to collect information about the use of the site. Our business partners collect information such as how often users visit the site and what pages users visited prior to visiting the site. We use this information to maintain and improve the site.
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.
Who Do We Share Your Data With?
We will not disclose, share, sell, or otherwise use your personal information without your consent, except to the extent required by law, in accordance with your instructions, or as identified in this Privacy Statement:
- Affiliates: To enable them to provide services to you and to enable them to contact you regarding additional products and services that you have expressed an interest in.
- Agents and Service Providers: We sometimes contract with other companies and individuals to perform functions or services for us or on our behalf, such as hosting this Site, sending e-mail messages, and making phone calls. They may have access to personal information, such as addresses, needed to perform their functions, but are contractually restricted from using it for purposes other than providing services for the Company or on our behalf.
- Business Transfers: As we continue to develop our business, we might sell or buy assets. In such transactions, user information generally is one of the transferred business assets. Also, if either the Company itself or any of the Company’s assets were acquired (including through bankruptcy proceedings), your personal information may be one of the transferred assets.
- Legal Matters: The Company may preserve, and has the right to disclose any information about you or your use of this Site without your prior permission if the Company has a good faith belief that such action is necessary to: (a) protect and defend the rights, property, or safety of the Company or its affiliates, other users of this Site, or the public; (b) enforce the terms and conditions that apply to use of this Site; (c) respond to claims that any content violates the rights of third parties; (d) respond to claims of suspected or actual illegal activity; (e) respond to an audit or investigate a complaint or security threat; or (f) comply with applicable law, regulation, legal process, or governmental requests.
What Steps Do We Take to Protect Your Information?
This Site and all information that you submit through this Site is collected, stored, and processed in the United States within Company-controlled databases. We restrict access to your personal information to those employees of ours, and our affiliates, and to those service providers who need to use it to provide this Site and our products or services. We have implemented physical, administrative, and technical safeguards to protect your personal information from unauthorised access. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our systems, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.
Accessing and Correcting Your Information
Keeping your information accurate and up-to-date is very important. Inaccurate or incomplete information could impact our ability to deliver relevant services to you. Please let us know about any changes that may be required to your personal information using the “contact us” feature of this website.
External Links:
This Site includes links to other sites that are operated by organisations other than the Company. If you access another organisation’s website using a link provided, the other organisation may collect information from you. The Company is not responsible for the content or privacy practices of linked 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 will handle any information they collect from you.
Applicability of This Privacy Statement to International Users:
This Privacy Statement is provided in accordance with and subject to U.S. law. If you access this Site from a location outside of the United States, you agree that you use of this Site is subject to the terms of this Privacy Statement and the Terms of Use and you recognise and accept that your personal information may be transferred to and processed in the U.S. and other countries that may not be deemed to provide the same level of data protection as your home country and that may have been deemed to have inadequate data privacy laws under the laws of your jurisdiction. See also the Privacy Statement or Policy available on other Mercer sites, such as country specific sites like mercer.xx or special purposes sites such as imercer.com, for information about privacy treatments for users of these sites.
Children:
This Site is not intended for children, and we do not knowingly collect, use or disclose information of children under the age of thirteen (13) without the consent of their parents or legal guardians. In an instance where such information was collected, it would be purely accidental and unintentional.
Rights of Individuals in Certain US States:
Click here for our privacy notice regarding additional rights you may have in certain US states.
For Company Career Candidates
Please read our Candidate Privacy Statement posted on our careers websites, available at https://careers.marshmclennan.com/
Changes to Privacy Statement
The Privacy Statement is subject to change at any time. It was last changed on December 7, 2022. If we make changes to this Privacy Statement, we will updated the date it was last changed. Any changes we make to this Privacy Statement become effective immediately when we post the revised Privacy Statement on this Site. We recommend that you review this Privacy Statement regularly for changes.
Questions or Concerns?
If you have any questions, concerns, or complaints about this Privacy Statement, or our privacy practices in general, they should be directed to the Company at privacycoordinator@mercer.com or by contacting the Company at:
Mercer LLC
1166 Avenue of Americas
New York, New York 10036
USA