Privacy Policy

Introduction

Westin Fulfillment, LLC, including its divisions, subsidiaries, and affiliates (the “Company”, “us”, “our” or “we”), respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our website (the “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to the information we collect:

On or through the Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
Offline, in accordance with relevant law, including, but not limited to, the California Consumer Privacy Act of 2018 (“CCPA”).

It does not apply to information collected by:

Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Website. By accessing or using the Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Children

The Website is not intended for children, as defined under applicable law. Children may not provide any information to or on the Website. We do not knowingly collect personal information from children. If you believe we might have any information from or about a child, please contact us at cs@westinfulfillment.com.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of the Website, including information:

by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other information the Website collects that is defined as personal or personally identifiable information under an applicable law (“personal information”); and/or
about your internet connection, the equipment you use to access the Website and usage details.

We collect this information:

directly from you when you provide it to us;
automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and/or
from third parties, for example, our business partners, such as referral partners.

While you are not required to directly provide us with your personal information, please be advised that you may not be able to make use of certain features or functionalities on the Website, if you choose not to provide your personal information.

Information You Provide to Us.

The information we collect on or through the Website may include:

Information that you provide by filling in forms on the Website. This includes information provided when you sign up/subscribe to our newsletter, download any materials, comment on our blog, complete form fills, or contact us. This information may include your name, phone number, email address, company name, website URL, and any comments you voluntarily provide, including information about your company and products.
Information that you provide when you apply for employment with us or share jobs. This information may include your name, email address, telephone number, address, the information contained in your resume and cover letter, LinkedIn profile URL, citizenship/employment eligibility, information related to your availability, criminal convictions, information related to experience, information related to military service, desired salary, earliest start date, whether you were referred to the job by a current WF employee or company affiliate (and, if yes, the name of the WF employee), information related to whether you currently work for WF or have worked for WF in the past, gender, race/ethnicity, veteran status, and disability status.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please see the Choices About How We Use and Disclose Your Information section below for additional details on how the Company responds to do-not-track signals.

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize the Website according to your individual interests.
Speed up your searches.
Recognize you when you return to the Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website.
Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and devices and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present the Website and its contents to you.
To provide you with information, products, or services that you request from us.
To facilitate advertising and marketing activities.
To participate in paid referral programs.
To collect and process applications for employment.
To understand and analyze how our visitors use the Website.
To improve and optimize the Website and your user experience.
To fulfill any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
To notify you about changes to the Website or any products or services we offer or provide through it.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

We may also use your information to contact you about our products and services that may be of interest to you. If you do not want to receive solicitations regarding our products and services, you may unsubscribe from such communications by clicking the link in the applicable communication or by contacting us at cs@westinfulfillment.com.

Our legal bases for processing your information include:

your consent;
exercising our rights and performing our obligations in connection with entering into or performing under any contract we make with you;
compliance with our legal obligations;
our legitimate interests that are not overridden by your interests or your fundamental rights and freedoms, like research and development, to market and promote our services, and to protect our legal rights and interests.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not constitute personal information under applicable law, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

To our subsidiaries and affiliates.
To referral partners.
To contractors, service providers, and other third parties we use to support our business. We may share your information with the following categories of third-party business partners and service providers: advertising networks, call tracking platforms, customer relationship management platforms, data analytics providers, marketing platforms, recruitment platforms (including Indeed), social media platforms (including Facebook, LinkedIn, Twitter, and YouTube), technology services, and video hosting, sharing, and streaming platforms (including YouTube- for more information about YouTube’s collection of information, see Google’s privacy policy at: https://www.google.com/policies/privacy).
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s, its affiliates’ or its subsidiaries’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about the Website users is among the assets transferred.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms & Conditions
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, its affiliates, its subsidiaries, their respective customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We do not respond to Do-Not-Track signals at this time; however, we have enabled mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising.

Google Analytics collects personal data through the Website, including through the use of cookies. For information about how Google Analytics collects and processes data, please visit: https://policies.google.com/technologies/partner-sites. To opt out of having your information used by Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout/.For more information, please visit Google’s privacy policy at: https://policies.google.com/privacy?hl=en&fg=1.
Additionally, third parties, including Google (through, for example, our use of Google Analytics Advertising Features, including Dynamic Remarketing), may place and read cookies on your browser, or use web beacons to collect information in connection with ad serving on or through the Website, including for the purposes of showing our ads on sites across the internet. Our partners will collect personal information for personalization of ads and may use first-party cookies or other first-party identifiers and third-party cookies and other third-party identifiers for personalized and non-personalized advertising and measurement. Ad serving may be based on users’ visits to our Website or other websites on the Internet, and your activity may be tracked over time and across websites. For information about how Google collects, shares, and uses data, please visit: https://policies.google.com/technologies/partner-sites. You can opt out of Google’s use of cookies or device identifiers by visiting the Google Ads Settings web page at: https://www.google.com/ads/preferences/. For more information, please visit Google’s privacy policy at: https://policies.google.com/privacy?hl=en&fg=1. You can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page or control the use of device identifiers by using your device’s settings.
We use the Meta Pixel to analyze user activity on our Website for remarketing and behavioral targeting. The Meta Pixel is triggered when you perform certain activities on the Website, and aids us in displaying Facebook ads to Facebook or Instagram users who have visited our Website, or Facebook or Instagram users who share certain characteristics with visitors to our Website. Meta and other third parties may use cookies, web beacons, and other storage technologies to collect information from the Website and from other internet websites, and use that information for the purposes of targeting ads and providing measurement services. Meta may track your activity over time and across websites. For more information about the data Meta collects, please visit Meta’s privacy policy at: https://www.facebook.com/privacy/policy/. For specific information about Meta Pixel, please visit: https://www.facebook.com/business/help/742478679120153?id=1205376682832142. For more information about ad targeting and exercising your choice to opt out of the collection and use of information for ad targeting, please visit: https://www.facebook.com/help/568137493302217, or https://optout.aboutads.info/?c=2&lang=EN.
Microsoft collects or receives personal information from our users or us to provide Microsoft Advertising (including through individual end user tracking and data sharing with third parties for advertising and marketing purposes). We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our Website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for Website optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your personal information, visit the Microsoft Privacy Statement, available at: https://privacy.microsoft.com/en-US/privacystatement.
Westin Fulfillment’s Chat Feature: By using this chat feature, you consent to the recording and use of information about you and this chat session by Westin Fulfillment or any authorized service provider acting on Westin Fulfillment’s behalf. Westin Fulfillment may use or disclose this information in accordance with its Privacy Policy. If you do not consent to these terms, please do not use this chat feature and reach out to us via email or by phone. Your continued interaction with, or submission of information to, this chat feature will be deemed to be your acceptance of Westin Fulfillment’s Privacy Policy.

Please note that we do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on NAI’s website, which can be found here: https://www.networkadvertising.org/understanding-online-advertising/what-are-my-options. You can also visit the Digital Advertising Alliance’s website, available at https://youradchoices.com/, to use its Consumer Choice Tools. Users in the European Union and United Kingdom can visit the European Digital Advertising Alliance opt-out page, located at https://www.youronlinechoices.com/.

You can additionally set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.

Promotional Offers from the Company.

If you do not wish to have your e-mail address or contact information used by the Company to promote our products or services, you can opt-out by clicking the “unsubscribe” link in the applicable communication, or by sending us an e-mail stating your request to cs@westinfulfillment.com.

International Data Transfers

When you use the Website and provide information through the Website, we may transfer your information to a destination outside your jurisdiction, including to the United States. The United States has not received a finding of “adequacy” from the European Union under Article 45 of the GDPR (or other analogous international data protection regulations, such as the United Kingdom’s (“UK”) GDPR). The Company relies on the safeguards set forth in Article 46 of the GDPR or derogations for specific situations set forth in Article 49 of the GDPR (or other analogous data transfer mechanisms) in order to transfer personal information across international borders.

Individuals in the European Economic Area (“EEA”) and the UK may request a copy of applicable Article 46 agreements by emailing cs@westinfulfillment.com.

Your International Rights

To the extent required by law, the Company provides you with:

reasonable access to the personal information collected through the Website;
the ability to review, correct, export, and delete such personal information; and
the ability to restrict processing of your personal information, or object to its processing.

When the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time, but this will not affect any processing we have already performed. If you withdraw your consent, refuse to provide certain information, or provide inaccurate information, you may not be able to access or utilize all of the features or content available on or through the Website, and we may not be able to fulfill your requests for products or information.

Please contact us using any of the methods identified in the Contact Information section if you would like to exercise your individual rights. We may need to obtain or confirm certain personal information in order to accommodate your request. We will not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Individuals in the EEA and UK: In addition to the above rights, you also have the right to lodge a complaint with a supervisory authority (EEA) or the Commissioner (UK) if you believe we have processed your personal information in a manner inconsistent with your privacy rights. We kindly request that you contact us first so that we may address your concern.

Your State Privacy Rights

Colorado, Connecticut, Virginia, and Utah Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

Confirm whether we process their personal information.
Access and delete certain personal information.
Data portability.
Opt out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

Correct inaccuracies in their personal information, taking into account the information’s nature and processing purpose.
Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Connecticut and Utah also provide their state residents with rights to opt out of processing of sensitive personal data, including personal data that reveals an individual’s citizenship or immigration status.

To exercise any of these rights or appeal a decision regarding a rights request please see the Exercising Your Rights section in the California Consumer Privacy Act policy below.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: cs@westinfulfillment.com.

Please note that where we collect or use personal information that does not individually identify you (also known as de-identified data), we will not attempt to re-identify such information.

California Rights

California Civil Code Section § 1798.83 permits California residents with whom we have an established business relationship to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to cs@westinfulfillment.com

For more information about California resident privacy rights, including the rights of California residents under the California Consumer Privacy Act, please see the California Consumer Privacy Act section below.

Data Security and Retention

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through the Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

We retain your information for as long as needed: (i) to conduct business with you; (ii) as needed for the purposes outlined in this Privacy Policy; and (iii) as necessary to comply with our legal obligations, resolve disputes, and enforce any agreements.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the e-mail address provided by you, if you have provided one, or through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Website and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Westin Fulfillment, LLC
cs@westinfulfillment.com

California Consumer Privacy Act

California Residents

The following disclosures are made pursuant to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”). These disclosures supplement any privacy notices we previously or contemporaneously provided to you, including any California-specific privacy notice provided to you if you are an employee of the Company.

Right to Know

California residents have the right to be informed of the categories and specific pieces of personal information collected about them, including sensitive personal information, collected, used, and disclosed, the categories of sources from which that information is collected, whether that information is sold or shared, the categories of third parties to whom that information has been disclosed, the business or commercial purposes for collecting and using each category of personal information, and the intended retention period for each category of personal information.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not collect or process sensitive personal information for the purpose of inferring characteristics about consumers. We also do not disclose sensitive personal information for purposes other than those specified in section 7027(m) of the CCPA regulations promulgated by the California Privacy Protection Agency. Therefore, we do not offer consumers the option to limit the use of their sensitive personal information.

Right to Opt Out of Sharing for Cross-Context Behavioral Advertising

In the past twelve months we have used data about your activities on our online properties to serve you ads on online properties owned or controlled by third parties. In the past twelve months, we have provided the following categories of information to advertising networks, affiliates, customer relationship management platforms, data analytics providers, marketing platforms, social media platforms, and video hosting, sharing, and streaming platforms for this purpose:

Personal identifiers, such as unique personal identifier, online identifier, internet protocol address, device information and identifiers, and unique advertising identifiers and cookies; Internet and other electronic network activity information; geolocation information; characteristics of protected classifications under California or federal law; commercial data; and inference data.

If you would like to opt out of this sharing, you may exercise your right by modifying your cookie settings, or, you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal to opt out of disclosures of your personal information through the browser you are using.

Right to Opt Out of Sale

We do sell personal information to certain referral partners in exchange for monetary consideration. In the past twelve months, we have provided the following categories of information to referral partners in ways that could be considered a sale under California law:

Personal identifiers; commercial data; California Customer Records personal information; professional or employment-related information; and inference data.

We also share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA. The CCPA broadly defines “sale” in a way that may include activities such as the delivery of targeted advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior. In the past twelve months, we have provided the following categories of information to advertising networks, affiliates, customer relationship management platforms, data analytics providers, marketing platforms, social media platforms, and video hosting, sharing, and streaming platforms in ways that could be considered a “sale” under California law:

Personal identifiers, such as unique personal identifier, online identifier, internet protocol address, device information and identifiers, and unique advertising identifiers and cookies; Internet and other electronic network activity information; geolocation information; characteristics of protected classifications under California or federal law; commercial data; and inference data.

We disclosed these categories of information to these third parties in order to market and advertise our products and services; perform analytics; and to maintain, improve, upgrade, or enhance our products or services.

We have no actual knowledge of selling the personal information or the sensitive personal information or minors under 16 years of age.

California residents have the right to opt out of the “sale” of their personal or sensitive personal information.

If you would like to opt out of such disclosures, you may exercise your right by modifying your cookie settings, or, you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal to opt out of disclosures of your personal information through the browser you are using. To learn more about how to activate the GPC, click here.

Right to Delete Personal Information

You have the right to request the deletion of your personal information, subject to certain exceptions.

Right to Correct Inaccurate Personal Information

You have the right to request the correction of any inaccurate personal information that we maintain about you.

Right to Access

You have the right to request the categories and specific pieces of personal information we have collected about you.

Right of Non-Retaliation and Non-Discrimination

You have the right to exercise the privacy rights conferred to you under the CCPA without receiving retaliatory or discriminatory treatment. The Company does not retaliate or discriminate against you for exercising the privacy rights conferred to you under the CCPA.

Exercising Your Rights

To exercise your rights, you may contact us via email at cs@westinfulfillment.com. Requesters will need to provide us with personal information in order to verify their identity and residency, including name, email, and state of residence. We will compare the information you provide with our internal records. The personal information that we use to verify identity and residency will not be used for any other purpose.

You may authorize an agent to submit a request on your behalf if you provide the authorized agent with written permission signed by you. The Company may require you to verify your identity directly with us and confirm that you provided the authorized agent with permission to submit a request on your behalf.

If you wish to exercise opt-out rights provided by applicable law, including the law of any jurisdiction set forth above, you may do so by reaching out to: cs@westinfulfillment.com