Privacy Policy
West Loop Strategy, LLC. Privacy Policy
Effective January 1, 2023
Dataprivacy and transparency are important to West Loop Strategy, LLC. This PrivacyPolicy addresses what information West Loop Strategy, LLC, and our wholly owned affiliate, AND dba 1AI Stack, collects, why it is collected, how it iscollected and used, with whom the information is shared, and the rights ofindividuals relating to their information. West LoopStrategy, LLC only collects and uses the information necessary for itslegitimate business purposes as set forth in this Privacy Policy. West LoopStrategy, LLC limits the amount and type of data it collects and uses to theextent possible, and to that which West Loop Strategy, LLC deems necessary. For clarity, this Privacy Policy distinguishesbetween West Loop Strategy, LLC’s public website (hereafter, “the Website” or “WestLoop Strategy, LLC Website”) and the West Loop Strategy, LLC cloud-basedsoftware-as-a-service GRC platform (hereafter, “the Service” or “West LoopStrategy, LLC Service”). Moreover, for the purposesof this Privacy Policy, “Visitors” means any third-party individuals who visitor interact with the West Loop Strategy, LLC Website, “Customers” meansindividuals and/or entities who purchase a subscription to the West LoopStrategy, LLC Service, and “End-Users” means authorized individuals who use orotherwise directly interact with the West Loop Strategy, LLC Service (e.g.,employees of Customers). Furthermore, “West LoopStrategy, LLC Offerings” means the Service and its present and future features,informational or promotional materials, and events organized or sponsored by WestLoop Strategy, LLC, and “personal information” means information thatidentifies or could reasonably be linked, directly or indirectly, with aparticular individual (e.g., name, address, and/or email). I. The WestLoop Strategy, LLC Website
What Information Is Collected. The West LoopStrategy, LLC Website only collects and uses the information necessary for itslegitimate business purposes as set forth in this Privacy Policy. West LoopStrategy, LLC limits the amount and type of data it collects and uses to theextent possible, and to that which West Loop Strategy, LLC deems necessary.
Information Submitted by Visitors. WestLoop Strategy, LLC collects information about Visitors when they visit theWebsite. The Website collects information actively fromthose Visitors who choose to submit information through the Website and itsfeatures, including, without limitation:· the Contact Us and Request a Demo pages · other online forms found on or through the Website · communications with the Website Chat function· blog posts and replies to Blog posts· registration for West Loop Strategy, LLC Events· participation in online surveys· reporting of problem(s) with the Website· acknowledgment of online terms of use or privacy policyTheinformation actively collected may include without limitation: Visitor name andcontact information, visitor company information, primary interest in potentialuse of the West Loop Strategy, LLC Service and other West Loop Strategy, LLCOfferings, email address, phone number, the Visitor’s communications with WestLoop Strategy, LLC, and any other information entered into the text boxes orfields on any form(s), notices, or agreements.
Information Collected as a result of Using the West Loop Strategy, LLCWebsite. The passive information collected from Visitors as aresult of visiting the West Loop Strategy, LLC Website may include: · analytics data, such as IP address· general location information (city and country)· company-level information· technical information such as browser type, operatingsystem, device identifiers, URLs of referring pages, conversion page, timestamp, crash data· website usage data (which subpages are viewed, how longVisitors spend on various pages or features, what links visitors click, etcetera).
Why Information Is Collected. Informationis collected to enable, enhance, and customize the Visitor’s online experienceon the Website. Information is also collected and used for WestLoop Strategy, LLC's sales, marketing, advertising, informational, educational,promotional, technical support, and other business purposes relating to WestLoop Strategy, LLC Offerings to potential and current West Loop Strategy, LLCCustomers. For example, contact information submitted byVisitors through an online form is used to direct sales efforts to individualsand companies interested in purchasing the West Loop Strategy, LLC Service orin requesting a demonstration of the West Loop Strategy, LLC Service. Additionally, collection of Visitor usage datahelps West Loop Strategy, LLC determine which online resources are helpful,which are being utilized, what topics are of interest, what needs improvement,etc.
How Information Is Collected. Activelysubmitted information is collected by interacting with our online chat featureas well as by completing and submitting online forms found on the West LoopStrategy, LLC Website. Passively collectedinformation is gathered from website cookies, web beacons, and other trackingor analytics technologies (e.g., Google Analytics, Google Ads, LinkedIn).
How Information Is Used. West Loop Strategy, LLCuses the information it collects from Website Visitors to:· help West Loop Strategy, LLC better understand the needsand goals of Website Visitors· disseminate information and provide updates about West LoopStrategy, LLC's Offerings· support requests from Website Visitors· provide greater customer service and technical support· enable email notification of changes to policies or theService · customize advertising and content· conduct analysis and determine the effectiveness of theWebsite· improve the online experience of West Loop Strategy, LLCWebsite Visitors and West Loop Strategy, LLC Service Customers.
With Whom Information Is Shared. Informationis only shared with West Loop Strategy, LLC employees, representatives,contractors, business partners/affiliates, and third-party service providerswho provide analytics technologies for use in West Loop Strategy, LLC'sinformational, marketing, and promotional endeavors. Personal informationprovided to West Loop Strategy, LLC through the Website is not sold or used forcommercial purposes unrelated to West Loop Strategy, LLC without the expressconsent of individuals. Information, includingpersonal information, may also be shared with law enforcement, governmentagencies, regulatory bodies, courts, or third parties when required orpermitted by law or to enforce or protect West Loop Strategy, LLC's legalrights and duties.
Cookies and Similar Technologies. WestLoop Strategy, LLC and our third-party partners, such as our advertising andanalytics partners, use cookies and other tracking technologies (e.g., webbeacons, device identifiers and pixels) to provide functionality, customizecontent, and recognize Visitors and other individuals across different servicesand devices. Visitors may exercise choice regarding the use of cookies whenthey first visit the Website and may change their preferences at any subsequenttime. Furthermore, Visitors may choose not to have cookies downloaded ontotheir computers by restricting cookies within their browser settings. However, should Visitors restrict their cookiessettings, West Loop Strategy, LLC cannot guarantee that all Websitefunctionality will work as intended.
Legal Basis for Processing. If you are from the European Economic Area (“EEA”), our legal basis for collecting and using aVisitor’s personal information varies depending upon what information isprovided, where it is submitted within the Website, and why it was submitted. However, in general, West Loop Strategy, LLCwill only collect and use a Visitor’s personal information with their expressconsent and in accordance with the general purpose for which the Visitorsubmitted their information or for any other lawful purpose set forth in thisPrivacy Policy including, without limitation, the performance of a contract aVisitor may have with West Loop Strategy, LLC, where West Loop Strategy, LLC islegally obligated to collect such personal information, where processing thepersonal information is necessary for the legitimate interests pursued by WestLoop Strategy, LLC or by a third party and where West Loop Strategy, LLC'slegitimate interests outweigh the Visitor’s data protection or other rights.
International Transfer of Data. WestLoop Strategy, LLC stores and processes personal information collected inconnection with the Website in the United States or in any country where weengage third party service providers. If theVisitor is from the EEA and submits personal information to the Website, WestLoop Strategy, LLC will protect the personal information by processing it in aterritory in which the European Commission has determined provides an adequatelevel of protection or otherwise implementing appropriate administrative,physical, and technical measures to protect the Visitor’s personal informationthrough the use of Standard Contractual Clauses or other approved lawfultransfer mechanisms. West Loop Strategy, LLC may also rely on Visitors’ explicitconsent or other applicable derogations under GDPR for such transfers inaddition to application of measures set forth above. How We Secure Information. West Loop Strategy, LLCimplements and maintains appropriate administrative, physical, and technicalsafeguards to protect personal information of Visitors from accidental orunlawful disclosure, loss, destruction, alteration, unauthorized access, ormisuse. Any West Loop Strategy, LLC service providersutilized in provision of the Website who have access to the personalinformation collected through the Website are required to keep it secure andconfidential.Retention. West Loop Strategy, LLCretains personal information collected through the Website for as long asnecessary to further the legitimate business purposes of West Loop Strategy,LLC or as required by law, until a particular Visitor withdraws his or herconsent. After a Visitor withdraws his or her consent tocollect and use their personal information, West Loop Strategy, LLC will deleteor anonymize the information within a reasonable period of time provided suchdeletion or anonymization is technically feasible. To theextent that such deletion or anonymization is not feasible for technical orlegal reasons—as may be the case with storage on backups or for legallyrequired retention purposes—West Loop Strategy, LLC will take all reasonablesteps to cease using the personal information including without limitationremoval from marketing databases, etc.
Rights of Website Visitors. Within certain jurisdictions, including but notlimited to, the EEA, Visitors have some or all of the following rights inconnection with their personal information:·
Right to Access andPortability – a right to know and access any personal informationcollected by West Loop Strategy, LLC. Additionally,in certain jurisdictions, Visitors have the right to portability of theirpersonal data.·
Right to Object andRequest Changes – a right to object to the collection ofor the accuracy of the content of their personal information. To the extent that Visitors object to theprocessing of personal information or that personal information contains anyinaccuracies, Visitors may request that such information be changed or removedby West Loop Strategy, LLC.·
Non-Discrimination – a right tobe free from unlawful discrimination on the basis of any information providedto West Loop Strategy, LLC. ·
Right to Be Forgotten– right to be forgotten—that is, the right to have theirpersonal information deleted or erased or otherwise removed from West LoopStrategy, LLC's possession.·
Right to Consent or NotConsent – right to consent (i.e., opt-in) or not (i.e., opt-out) ofcollection of information by the West Loop Strategy, LLC Website.·
Right to File a Complaint -the right to lodge a complaint with a supervisory authority/data protection
authority.To theextent required by law, West Loop Strategy, LLC will honor any requests orobjections of Visitors based upon the above-listed rights provided that suchrequests or objections are adequately verified and technically feasible.
With respect to Visitors’ consent to collection or use of their personalinformation: By not opting-out of (or in some jurisdictions, byopting-in to) West Loop Strategy, LLC's use of cookies when first landing onthe West Loop Strategy, LLC Website, Visitors expressly consent to thecollection and use of their information by West Loop Strategy, LLC pursuant tothis Privacy Policy. Website Visitors whoconsent to the collection and use of their information may opt-out and revoketheir consent at any time by notifying West Loop Strategy, LLC. Additionally, individuals can revoke their consentand request to be removed from West Loop Strategy, LLC's marketing andinformational email list by clicking the “Unsubscribe” link contained in theemail(s) received from West Loop Strategy, LLC and following the instructionsto be placed on West Loop Strategy, LLC's “Do Not Contact” list. By doing so, Visitors will opt-out of receivingpromotional communications. However,even after Visitors opt-out of receiving promotional messages from West LoopStrategy, LLC, Visitors who use the Service will continue to receivetransactional messages from West Loop Strategy, LLC for purposes related to theService. Visitors who use the Service may be able toopt- out of some notification messages in their account settings within theService.Additional Privacy Matters.Do Not Track. Some Visitors use webbrowsers which contain a “Do Not Track” feature whereby the browser featuresends a signal to each website visited indicating that the Visitor does notwant its online activities to be tracked by technologies third parties. West Loop Strategy, LLC cannot guarantee thatthe Website will always respond to the Do Not Track features of all websitesdue to a lack of uniformity within the industry for Do Not Tracktechnology. Children. The West Loop Strategy, LLC Websiteand Service is not intended for use by legal minors. Personalinformation of children under age 13 should not be submitted to the Website.Changes to West Loop Strategy, LLC's Privacy Policy. WestLoop Strategy, LLC expressly reserves the right to change and update thisWebsite Privacy Policy and any of its terms as permitted or required by law. When West Loop Strategy, LLC makes materialchanges or updates to its Privacy Policy, West Loop Strategy, LLC will providenotice via email to Visitors who have submitted personal information to theWebsite and will explain the material changes.II. The WestLoop Strategy, LLC ServiceCollection and Use of Information by the West Loop Strategy, LLC Service. WestLoop Strategy, LLC collects and uses information and data about its Customersand their End-Users during and for the purchase, implementation, provision,support, and improvement of the West Loop Strategy, LLC Service. The West Loop Strategy, LLC Service is acloud-based Governance, Risk Management, and Compliance software service whichenables companies to implement, automate, manage, and analyze their policies,workflows, security controls, and compliance measures as well as provide forother functionality and third-party software integrations. In order for the WestLoop Strategy, LLC Service to perform as intended by both West Loop Strategy,LLC and the Customers (i.e., for GRC purposes), the collection and use of someinformation and data by West Loop Strategy, LLC is necessary and may not beremoved or altered without harming the functionality and utility of theService. For the purpose of this Privacy Policy,“Customer Data” means electronic data or information imported, uploaded orotherwise inputted into the Service by Customer or its End-Users in theCustomer’s West Loop Strategy, LLC environment. “OtherCustomer Information” means information or data provided by Customer or itsEnd-Users to West Loop Strategy, LLC by means other than inputting, importing,or uploading into the Service by Customer or its End-Users in the Customer’s WestLoop Strategy, LLC environment. For example,Customer’s contact information or payment information.The WestLoop Strategy, LLC Service primarily collects and uses Customer Data and OtherCustomer Information during and for the implementation, provision, andtechnical support of the Service. For example,Customers supply information such as the name, address, contact and paymentinformation as well as information provided by Customer about their businessincluding their business needs (i.e., number and type of users and applicationsneeded) regarding the Service during the configuration, implementation andprovision of the Service. Additionally, informationis collected and logged from Customers and End-users when they:· register their account to access the West Loop Strategy,LLC Service· log-in and log-out of the West Loop Strategy, LLC Service· perform an activity, use a feature, or create or update arecord within the West Loop Strategy, LLC Service (including the time and dateof such activities). · request support from West Loop Strategy, LLC· provide feedback about the ServiceThisinformation is collected and processed by the West Loop Strategy, LLC Serviceand is needed to enable End-Users and Customers to create records within their WestLoop Strategy, LLC Service instance and for Customers and End-Users to generatereports and utilize other Service features and third-party softwareintegrations for GRC and other business purposes as determined, managed, andcontrolled by the Customers. In addition,this information is collected and used by West Loop Strategy, LLC to providetechnical support to Customers and End-Users as well as to make improvements tothe West Loop Strategy, LLC Service and notify Customers and End-Users aboutchanges to the Service, West Loop Strategy, LLC policies, and other West LoopStrategy, LLC Offerings. Furthermore,West Loop Strategy, LLC collects, processes, and uses Customer usage data andother quantitative data in furtherance of the Service and West Loop Strategy,LLC Offerings.
With Whom Information Is Shared. Personalinformation collected within a Customer’s West Loop Strategy, LLC Serviceenvironment is only shared with West Loop Strategy, LLC personnel and West LoopStrategy, LLC’s data sub-processors as needed to provide the Service or asotherwise permitted in this Privacy Policy or required by law. Customer and End-User information is logged bythe Service as needed to perform the Service and is accessible to West LoopStrategy, LLC and the Customer and other parties as permitted by the Customeror End-User. Except as provided for in this Privacy Policy, WestLoop Strategy, LLC does not share or sell Customer Data to third parties. And except as permitted by the Customer orotherwise provided herein this Privacy Policy, West Loop Strategy, LLC will notuse or disclose Customer Data for unauthorized purposes. West Loop Strategy,LLC may use and disclose personal identifying information to third partyservice providers with whom we work for the following purposes: to providehosting, maintenance, backup, storage, virtual infrastructure, paymentprocessing, analytics, and other services for the West Loop Strategy, LLCService. West Loop Strategy, LLC may use and discloseOther Customer Information as needed to provide, support, or improve theService as well as for analytics or other business purposes. In addition, WestLoop Strategy, LLC may disclose Customer Data or personal information to lawenforcement, regulatory bodies or government agencies, courts or third partieswhen (i) required by law to comply with a court order, subpoena, request forinformation, or other legal process; (ii) enforce the terms of the SubscriptionService Agreement; (iii) defend, protect, or assert West Loop Strategy, LLC'slegal rights or those of its Customers as needed; or (iv) in connection withany proposed merger, acquisition, sale or transfer of West Loop Strategy, LLC'sassets, dissolution, restructuring, liquidation, or similar event. Retention. West Loop Strategy, LLC retains Customer Data as long asthe Customer has a valid contract in effect to use the Service and for theretention period set forth in the contract. West LoopStrategy, LLC may retain Customer Data beyond that period only as necessary tocomply with any legal requirements it may be subject to (e.g., tax, accounting,security, litigation holds) or as adopted by information security industrystandards.
International Transfers. To theextent that West Loop Strategy, LLC or its third-party service providerscollects, processes, and stores Customer Data, West Loop Strategy, LLC adheresto and complies with the EU-US and Swiss-US Privacy Shield Frameworks andPrinciples as set forth by the US Department of Commerce regarding thecollection, use, and retention of personal information transferred from the EU,UK, and Switzerland to the US. West Loop Strategy, LLC may also rely onexplicit consent or other applicable derogations for such transfers in additionto implementing appropriate administrative, physical, and technical measures toprotect the Customer’s personal information. For moredetails, see West Loop Strategy, LLC's Privacy Shield Notice below. For other international transfers of personalinformation from EEA, West Loop Strategy, LLC will implement appropriatesafeguards for the transfer of Customer Data consistent with industry standardsand as agreed upon by West Loop Strategy, LLC’s Customers.
Third Party Integrations. The West Loop Strategy,LLC Service may also permit Customers to enable third party softwareintegrations and applications in furtherance of the Customers’ business and GRCobjectives. Those third-party software integrations mayalso collect and use Customer Data and/or Other Customer Information. The collection and use of any Customer Data orOther Customer Information made available to such third parties through the useof their software and applications by Customer will be governed by theCustomer’s agreements and privacy policies of those third parties.
Information Security of the Service. WestLoop Strategy, LLC maintains appropriate administrative, physical, andtechnical safeguards and information security practices designed to protectCustomer Data from accidental, unauthorized, or unlawful access, disclosure,alteration, or destruction, or loss. Thesesafeguards include but are not limited to end-to-end encryption of data intransit as well as at rest. Furthermore, the Service permits the Customer toimplement, configure, manage, and control their own use of the Service and toimplement and enforce the Customer’s own security practices, including withoutlimitation user access controls and encryption.
For more details about West Loop Strategy, LLC’s platform information security policies, please visit https://www.West Loop Strategy, LLC.com/platform/security/ orcontact us atprivacy@westloop.io. .
Privacy Rights for the Service. WestLoop Strategy, LLC processes Customer Data and Other Customer Information withthe consent and at the direction of its Customers and will not disclose,distribute, or transfer Customer Data or Other Customer Information except asprovided by contract, required by law, or otherwise permitted under thisPrivacy Policy. ·
For End-Users and ThirdParty Individuals: West Loop Strategy, LLC does not manage or controlwhat information or data, including any personal information from End-Users andother third parties, Customers collect or use in connection with the Service,nor does West Loop Strategy, LLC control how such personal information or datamay be accessed, disclosed, or used by West Loop Strategy, LLC's Customers. Therefore, End-Users and other third partiesmust contact the Customer directly in order to request access to anyinformation with respect to any personal information stored or used in theService or exercise any other privacy rights including without limitation therights of objection, correction, erasure/deletion, and portability. Any requests or inquiries by End-Users directed at WestLoop Strategy, LLC will be redirected to the appropriate Customer or Customer’sdesignated administrative user of the Service.
Forprivacy and security purposes, Customers and their administrative users (i.e.,administrators) shall bear the responsibility of managing Customer useraccounts and Customer Data as well as any aspects of the Service which Customerhas control, including without limitation End-User accounts and activities ofCustomer or its End-Users. ·
For Customers: Pursuantto Privacy Shield Framework and Principles as well as any applicable dataprotection laws, West Loop Strategy, LLC will provide Customers with certainchoices regarding certain information provided to West Loop Strategy, LLC byCustomer or any third party affiliates including: to access and know, correct,update, or request deletion of any personal information of Customer, and incertain jurisdictions, restriction of processing and portability of data. Customers should direct any privacy-relatedinquiries or requests relating to Other Customer Information to privacy@West Loop Strategy, LLC.com or use our Data AccessRequest form (click HERE forthe form)III.Additional Information
Changes to this Privacy Policy. WestLoop Strategy, LLC expressly reserves the right to change this West LoopStrategy, LLC Service Privacy Policy at any time. West Loop Strategy, LLC willprovide notice of any material changes to its Privacy Policy to Customers andEnd-Users via email or similar means.
PRIVACY SHIELD NOTICE.
West Loop Strategy, LLC does not rely on the EU-US Privacy Shield as atransfer mechanism of personal data from the EEA or UK to the US or on theSwiss-US Privacy Shield as a transfer mechanism of personal data fromSwitzerland to the US, but remains committed to the obligations and principlesof the Privacy Shield Framework set forth below.
West Loop Strategy, LLC's Compliance with Privacy Principles. The West Loop Strategy, LLC Service has certified to the US Department ofCommerce that it complies with the EU-US Privacy Shield and the Swiss-USPrivacy Shield Framework and is committed to the Privacy Shield Principles asset forth by the US Department of Commerce regarding the collection, use, andretention of personal information transferred from the European Union and Switzerlandto the United States. In the event of a conflictbetween the terms of this Privacy Policy and the Privacy Shield Principles, thePrivacy Shield Principles shall govern. To learnmore about the Privacy Shield program, and to view West Loop Strategy, LLC's certification,please visit https://www.privacyshield.gov/list andenter “West Loop Strategy, LLC” in the search field.
Transfers of Data. West Loop Strategy, LLC isresponsible for the processing of personal data it receives under the PrivacyShield Framework and subsequent transfers to a third party acting as agents on WestLoop Strategy, LLC's behalf. The WestLoop Strategy, LLC Service complies with the Privacy Shield Principles for allonward transfers of personal data from the EU and Switzerland, including theonward transfer liability provisions. With respectto personal data received or transferred pursuant to the Privacy Shieldframework, the West Loop Strategy, LLC Service is subject to the regulatoryenforcement powers of the US Federal Trade Commission (FTC). To theextent the Privacy Shield Framework ceases to apply to certain transfers ofpersonal information from the EU, UK, and Switzerland to the US, West LoopStrategy, LLC may rely on the Standard Contractual Clauses and explicit consentor other applicable derogations under GDPR for such transfers in addition toimplementing appropriate administrative, physical, and technical measures toprotect personal information. Such consent may be requested on a case-by-casebasis as indicated to the Visitor or End-User, as applicable, and may bewithdrawn at any time. Risks of consenting to such a transfer includeprocessing of personal information in the United States, which may not havedata protection laws equivalent to those where the Visitor is located and maynot provide Visitors with the same rights as may be provided where the Visitoror End-User is located. Safeguards applied to personal information transferredto the US include encryption of personal data in transit and at rest,restricted access to Customer Data according to the principle of leastprivilege (i.e., a need-to-know basis), due diligence and monitoring ofsub-processors and vendors who may have access to Customer Data in order to providethe Service, use of software tools to monitor and log use of decryption keys,periodic penetration testing and vulnerability detection of the platform andService, offering Customers the choice to host their platform environment andCustomer Data within the EU, and contractual commitments to protect CustomerData, particularly data which contains personal information. For so long as WestLoop Strategy, LLC retains its Privacy Shield certification, it remains subjectto the oversight of the United States Department of Commerce as furtherdescribed below under the headings “Procedure” and “Principles andCommitments.” Details regarding West Loop Strategy, LLC’s sharing of personalinformation are located under the section headings “With Whom Information IsShared” in this Privacy Policy.Disclosure of Personal Data. Incertain situations, West Loop Strategy, LLC may be required to disclosepersonal data in response to lawful requests by public authorities, includingto meet national security or law enforcement requirements. To the extent permitted by law or contract, WestLoop Strategy, LLC notifies Customers and End-Users of any efforts to obtainpersonal data by government agencies or other third parties and seeks to limitthe personal information tendered pursuant to such efforts.Procedure. In compliance with thePrivacy Shield Principles, West Loop Strategy, LLC commits to resolvecomplaints about West Loop Strategy, LLC’s collection or use of personalinformation. Any inquiries or complaints related to WestLoop Strategy, LLC's Privacy Shield compliance may be directed to privacy@westloop.io. In theevent of a dispute involving allegations that West Loop Strategy, LLC has notcomplied with Privacy Shield, individuals may bring a complaint directly to WestLoop Strategy, LLC, and West Loop Strategy, LLC must respond to the individualwithin 45 days. In the event of an unresolved privacy or data use concern that WestLoop Strategy, LLC has not addressed satisfactorily, contact West LoopStrategy, LLC’s US-based third party dispute resolution provider (free ofcharge) at https://www.jamsadr.com/eu-us-privacy-shield.If an individual submits a complaint to a data protection authority (DPA) inthe EU, the Department of Commerce has committed to receive, review andundertake best efforts to facilitate resolution of the complaint and to respondto the DPA within 90 days. Under certain conditions,more fully described on the Privacy Shield website, a complaining party may beentitled to invoke binding arbitration when other dispute resolution procedureshave been exhausted.
Principles and Commitments. West Loop Strategy, LLCfurther commits to the following with respect to the Privacy Shield Principles:· to cooperate with the US Department of Commerce and respondpromptly to inquiries and requests by the Department of Commerce for informationrelating to the Privacy Shield Framework.· to maintain data integrity and limit personal informationto the information relevant for the purposes of processing.· to comply with the new data retention principle.· to ensure accountability for data transferred to thirdparties in that to transfer personal information to a third party acting as acontroller, West Loop Strategy, LLC must comply with the Notice and ChoicePrinciples; and enter into a contract with the third-party controller thatprovides that such data may only be processed for limited and specifiedpurposes consistent with the consent provided by the individual and that therecipient will provide the same level of protection as the Principles and willnotify the organization if it makes a determination that it can no longer meetthis obligation. The contract shall provide that when such a determination ismade the third-party controller ceases processing or takes other reasonable andappropriate steps to remediate.· when transferring personal data to a third party acting asan agent, West Loop Strategy, LLC will · transfer such data only for limited and specified purposes; · ascertain that the agent is obligated to provide at leastthe same level of privacy protection as is required by the Principles; · take reasonable and appropriate steps to ensure that theagent effectively processes the personal information transferred in a mannerconsistent with the organization’s obligations under the Principles;· require the agent to notify the organization if it makes adetermination that it can no longer meet its obligation to provide the samelevel of protection as is required by the Principles;· upon notice, take reasonable and appropriate steps to stopand remediate unauthorized processing; and· provide a summary or a representative copy of the relevantprivacy provisions of its contract with that agent to the Department uponrequest.· West Loop Strategy, LLC will make public any relevantPrivacy Shield-related sections of any compliance or assessment reportsubmitted to the FTC if the organization becomes subject to an FTC or courtorder based on non-compliance.· ensure commitments made pursuant to the Privacy ShieldFramework are kept as long as data is held; and if an organization leaves thePrivacy Shield Framework, it must annually certify its commitment to apply thePrinciples to information received under the Privacy Shield Framework if itchooses to keep such data or provide “adequate” protection for the informationby another authorized means.For moreinformation, see www.privacyshield.gov.
MISCELLANEOUS Information Obtained By West Loop Strategy, LLC From Events and SourcesOther Than the Website or the Service. WestLoop Strategy, LLC may obtain, collect, and use information, including personalinformation, from sources other than the West Loop Strategy, LLC Website andthe West Loop Strategy, LLC Service. Inparticular, West Loop Strategy, LLC may host or attend in-person or remoteevents such as conferences, trainings, and promotional functions where personalinformation may be collected from individual attendees with their expressconsent (“Event Participants”). Suchinformation will only be used for West Loop Strategy, LLC's legitimate businessand marketing purposes and West Loop Strategy, LLC will not sell, disclose, orotherwise transfer such personal information without the Event Participant’sexpress consent. Event Participants mayrevoke their consent to be included on West Loop Strategy, LLC's marketinglists at any time thereafter by contacting West Loop Strategy, LLC at privacy@westloop.io orby clicking on the “Unsubscribe” link at the bottom of any marketing orpromotional emails received from West Loop Strategy, LLC and following anysubsequent instructions. West Loop Strategy, LLC reserves the right to changeits Privacy Policy as it relates to information obtained from Events as well assources other than the Website or the Service. West LoopStrategy, LLC will provide email notification of any material changes to WestLoop Strategy, LLC's Privacy Policy to Event Participants and other individualswho have consented to the collection or use of their personal information.
Information obtained from job applicants/candidates. WestLoop Strategy, LLC may obtain professional or employment related informationthrough job related inquiries, or applications for employment or internships.Personal information requested during the application process includesfull name, phone number, email address, and resume/CV. Voluntary informationincludes LinkedIn profile address, personal website address, referral name,pronoun, self-identification information, and veteran status. Throughsubmittals of resumes/CVs, West Loop Strategy, LLC may receive postaladdresses, titles, professional history, education and training information,references, and other information that the applicant chooses to provide. Someor all of this information may also be requested and/or received in relation toconsultant or contractor work.Applicantsthat use or provide their information to third party career sites, such asIndeed or LinkedIn, or to a talent acquisition firm, should consult the PrivacyPolicies of those entities for their Personal Information practices. West LoopStrategy, LLC makes no representations or warranties regarding theirinformation security or privacy practices.WestLoop Strategy, LLC will use the information received to assess applications,correspond with applicants, and carry out human resource functions inaccordance with applicable law. West Loop Strategy, LLC will share theinformation with authorized internal human resource professionals as well asprofessionals in our business functions who are participating in theapplication and interview process. West Loop Strategy, LLC utilizes anapplicant tracking system and recruiting software via a third-party serviceprovider. Interviews may be virtual and utilize a third-party service providersuch as Zoom.It is inWest Loop Strategy, LLC’s legitimate business interests to be able to reviewthe qualifications of prospective employees and perform human resourcesfunctions in relation to these business processes. West Loop Strategy, LLCretains applicant information in accordance with legal requirements.
How to Contact West Loop Strategy, LLC. To contact West LoopStrategy, LLC with questions regarding this Privacy Policy or inquire about previous versions of this policy, please send an email to privacy@westloop.io.