Effective date: January 2019
Last updated: February 2021
This Privacy Statement (“Statement”) explains how Alight Solutions, LLC and its subsidiaries and affiliates (collectively, “Alight”, “we”, “our” or “us”) collect, use and share your information when you visit our website at www.alight.com (“Website”). This Statement does not apply to information collected by Alight in other contexts, including through your use of other websites or services from Alight and/or third parties, where this Statement is not posted.
Please read this Statement carefully. The practices described herein are subject to applicable laws in the countries in which we operate.
BY ACCESSING AND/OR USING OUR WEBSITE, YOU CONFIRM THAT YOU HAVE READ AND UNDERSTOOD THIS STATEMENT.
Alight Solutions LLC, 4 Overlook Point Lincolnshire, IL 60069, is the entity responsible for processing information (i.e. the Controller) under this Statement.
Changes to this Statement
Please read this Statement from time to time. We may modify the Statement at any time at our sole discretion. Any changes to this Statement will be published on our website. If we make material changes to the Statement that significantly change how we use your information, we will use reasonable efforts to bring these changes to your attention, including by email (if you have registered your email address with Alight) or by another means, as appropriate.
Depending on where you live, and in accordance with applicable law, we may collect various categories of information from you when you access or use our website and when you provide information directly to us (e.g. when you register for our events, request our services or access various content and features on our website). Those categories include:
Identifiers, such as your name, email address, postal address, phone number, mobile number, IP address or other similar identifiers;
Internet or other electronic network activity information, such as browsing history specific to your interaction with our website;
Information posted on community discussions and other interactive online features on the websites to which this Statement applies; and
Location data, but not your precise geolocation. We collect location information provided by a mobile or other device interacting with this website, associated with your IP address or any other online or device identifier. We may collect this information through the lawful use and deployment of cookies and other tracking technologies, as set forth in our Cookie Notice.
Your choice to provide information: You may choose not to provide personal information to Alight by refraining from, among other things, 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 services, or with information about our services, promotions and other opportunities.
Alight may use your information for a variety of business and commercial purposes, which are listed below. These uses are necessary for purposes that are in Alight's legitimate interests, provided always that such processing is fair and balanced, and that our processing does not unduly impact your rights. The business and commercial purposes for which Alight uses your information may include:
Provide the information and services requested;
To perform a contract with you (or to take steps at your request prior to entering a contract)
Determine eligibility and process applications our services;
Conduct data analysis to understand how the website is used and to perform other market research;
Improve the performance and functioning of the website;
Market the services that may be of interest to you if further legal requirements for this are fulfilled.
We will not use personal information for automated individual decision-making, including profiling, as contemplated under Article 22 of the European Union’s General Data Protection Regulation (“GDPR”).
Unless provided otherwise in this Statement, we will not retain your information longer than necessary for the relevant purposes of processing, or our legitimate interest. 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.
Your information will be processed by our workforce personnel when they have been instructed to do so in accordance with Alight’s policies. In addition, your information may be disclosed or shared with the following categories of third parties for a variety of business purposes:
With our service providers: We may share your information with third-party service providers and suppliers who perform services on our behalf, but only if (a) the sharing of your information is necessary for them to carry out such services and (b) those service providers and suppliers are required to use information under confidentiality and in compliance with applicable privacy law(s).
With our business partners: We may share your personal information with the business partners with whoever we work to provide you with products and services, or to perform one or more of the business purposes identified above.
In the event of corporate change: We may disclose personal information to a successor to all or part of our business or in connection with a corporate merger; consolidation or restructuring; sale of substantially all of our stock and/or assets; or another corporate change, including, without limitation, during the course of any due diligence process. If necessary and legally required, we will obtain your separate consent in this regard. Disclosure may also be required for company audits or to investigate a complaint or security threat.
To comply with legal requirements: We will disclose your information (i) if we are required to do so by law or legal process, (ii) in response to lawful law enforcement authority or other government official requests, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) in connection with an investigation of suspected or actual illegal activity including any legal proceedings or prospective legal proceedings in order to establish, exercise or defend our or a third party’s legal rights or (v) as required for company audits or to investigate a complaint or security threat.
To companies within our corporate family: We may disclose your personal information to our corporate affiliates for organisational purposes based on a legitimate interest. To the extent that our corporate affiliates have access to your personal information, they will follow practices that are at least as restrictive as the practices described in this Statement, will use your information solely for the purpose for which it was provided, and will not further disclose your information.
Links to other websites: Our website may contain links to websites operated by other Alight entities, or to third-party websites that are not governed by this Statement, but by other privacy statements posted on those websites. 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 that you visit. Alight is not responsible for the content or privacy practices of third-party sites or any use of those third-party sites
Do not track. Some browsers support a “Do not track” feature, which is a signal that you do not wish to be tracked across the websites you visit. Our website does not currently change the way it operates based upon detection of a “Do not track” or similar signal.
Although no system is completely secure, Alight has implemented commercially reasonable physical, technical and administrative security standards, as appropriate under applicable law(s), to protect personal information, taking into account the sensitivity of the information and the purpose for which it was collected.
Among others, Alight is compliant with the EU Cloud Code of Conduct, a comprehensive code of conduct that sets out rigorous requirements for the protection of data in cloud services based on the General Data Protection Regulation (GDPR).
We provide you with the ability to exercise your rights regarding our collection, use, storage and sharing of your information. Please note that for some of these rights, we will need to verify your identity before we are able to respond to your request, including using commercially reasonable efforts to confirm your identity including by matching the information provided in your request with the information we have on file about you. Depending on the sensitivity of the information involved in the request, we may also utilise more stringent verification methods to protect against fraud and ensure that your request is fulfilled in a transparent and secure manner.
Where we are the Data Processor, please contact the Data Controller (e.g. your employer) to effectively exercise your rights.
To exercise your any of the rights described below, send your request to firstname.lastname@example.org or write to us at the postal address provided below, and we will respond as soon as possible in accordance with all applicable laws and regulations.
Right to correct: Regardless of where you live, you have a right to correct or amend the information we have about you.
Right to unsubscribe: If you request electronic communications from us, such as an e-newsletter, or have consented to receive marketing communications, you have the right to unsubscribe from these communications at any time by following the instructions included in the communication.
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.
Right to know and data portability: The right to know and data portability applies differently depending on where you live. If you are a California resident, you have a right to know the categories and specific pieces of personal information (as that phrase is defined under applicable law) we have collected about you in the 12 months preceding the date of your request, including a description of the categories of sources from which we have collected that information, the business or commercial purpose for collecting or sharing that information, and the categories of third parties with which we have shared that information. You may also designate an authorised agent to submit a request on your behalf by submitting proof of written authorisation along with your request. If you are living within the European Economic Area (EEA), you have the right to obtain confirmation as to whether your personal information is being processed, and if so, the right to access your personal information. If we maintain your personal information based on your consent or so that we could enter into a contract with you, you can also request that we provide you with a copy of your data in a structured, commonly used and machine readable format and request the transfer of certain of your personal information to another party under certain conditions.
Right to delete/Erasure: The right to delete/erasure also applies differently depending on where you live. If you are a California resident, you have a right to ask that we delete your information subject to appropriate exceptions. You may also designate an authorised agent to submit a request on your behalf by submitting proof of written authorisation along with your request. If you live in the EEA, where the conditions provided by the applicable legislation are met, and subject to applicable law, you may request that we erase or restrict the processing of your information. You may also request that we delete certain incorrect information about you.
Right to object to processing: If you live in the EEA, you may object to the processing of your personal data (as that phrase is defined under applicable law) in certain circumstances when we (i) process your information for the purposes of our legitimate interests, (ii) use your personal information for direct marketing; or (iii) use your personal information for statistical purposes.
Right to withdraw consent: If you are located in the EEA, and when our legal basis for processing your information is your consent, you may withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
California notice of sale: We do not sell the personal information of California residents, nor have we sold California resident personal information in the past 12 months. We have no actual knowledge of selling the personal information of minors under the age of 16.
Notice to residents of Nevada: We do not 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 information, please contact us (see “Contact us” below) so that we can try to resolve the issue. If you are located in the EEA, you also have the right to lodge a complaint with the supervisory authority applicable in the jurisdiction in which the user is located, and with relevant judicial authorities. If you live in Australia, you may complain to the Office of the Australian Information Commissioner. Contact details can be found at www.oaic.gov.au.
Our website is intended for a general audience and is not directed at children under the age of 16. If you are under the age of 16 please do not provide your information to us through the website. 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 (where we are headquartered) or any 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 European Economic Area (EEA) to a location outside of the EEA for processing, we use an approved transfer mechanism such as the European Commission approved standard contractual clauses. By submitting your personal data to us, you agree to this transfer, storing or processing at any location in the world. To find out more about the transfer mechanism that we use to effect such transfer, you may contact us at email@example.com.
If you have any questions relating to this Privacy Statement, please contact us at firstname.lastname@example.org. Our Data Protection Officer can also be reached using this email address.
You may also write to us at:
Alight Solutions LLC
ATTN: Chief Privacy Officer
4 Overlook Point
Lincolnshire, IL 60069 USA