We collect non-public personal information about you from the following sources:
Information we receive from you on applications or other forms.
Information about your transactions with us, or others.
We do not disclose any non-public personal information about our customers or former customers to anyone except as permitted by law. We restrict access to non-public personal information about you to those employees with a legitimate business need for the information. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your non-public personal information.

Who is responsible for the processing of your personal data?
When you interact with our website, WIS collects and processes information including personal data relating to you. We are committed to maintaining the confidentiality, integrity and security of your personal information. When you provide your personal information, we believe that you should be aware of our policies to protect the confidentiality of that information.

Which information do we collect and when?
We collect non-public personal information about you from the following sources:
Information we receive from you on applications or other forms.
Information about your transactions with us, or others.

Why and how do we process your personal data?
Without prejudice to our processing of your personal data for providing our services to you, which is subject to a specific privacy policy, we use the personal data we collect from you on our website in the following ways:

To provide the features of the websites you request
When you use our websites, we will use your data to provide the product or service you have selected. For example, if you make a query on wisdirect.com or joinwestern.com, we will use the contact information you give us to communicate with you about your query. This processing of your personal data will be based on your consent to receive our communications, or on the basis of it being necessary in order to take steps at your request prior to and when entering into a contract with you, as the case may be. In many cases, to use particular features within our websites, you may need to provide WIS with additional data or additional consent to use particular data in a certain way. We will be unable to provide these features if you do not allow us to process your personal data.

To communicate information about our products, services, events and for other promotional purposes
When you create a WIS user account, we may use the information you provide as well as information from other WIS sources, such as your use of WIS’ websites, your visits, and your participation in WIS events to send you communications on products and services that may be of interest for you. This processing of your personal data will be based on your consent to receiving our communications. We also process your personal data as a visitor of our website by implementing cookies for retargeting purposes, on the basis of your consent (for further details, see our cookie policy).

Who do we disclose your personal data to?
We do not disclose any non-public personal information about our website users to anyone except as permitted by law. We restrict access to non-public personal information about you to those employees with a legitimate business need for the information as well as third party service providers acting on behalf of WIS. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your non-public personal information.

International Data Transfers
Some of the data recipients with whom WIS shares your personal data may be located in countries other than the country in which your personal data was originally collected. The laws in those countries may not provide the same level of data protection compared to the country from which you initially provided your data. Nevertheless, when we transfer your personal data to recipients in other countries, including the USA, we will protect that information as described in this policy and in compliance with applicable law. If you are located in the European Economic Area (“EEA”) or Switzerland, we take measures to comply with applicable legal requirements and ensure adequate protection for the transfer of personal data to recipients in countries outside of the EEA or Switzerland, for instance through data transfer agreements based on the EU Commission’s model clauses, or a Privacy Shield certification.

Retention of Your Data
We retain your personal data for as long as necessary to fulfil the purposes for which we collect it, except if required otherwise by law. Depending on the purpose, the period for which we retain your personal data may vary. When we process your personal data on the basis of your consent, we will retain your personal data until we achieve the purpose for which we process your data or, if earlier, until you withdraw your consent.

Your rights in respect of your Personal Data
Subject to the legal restrictions that may apply, you have the right to contact us to access, modify, erase, request the restriction or oppose the processing of your personal information or request the portability of the personal data you contributed, without any expenses and at any moment. Where the collection and processing of your personal data is based on your consent, you have the right to withdraw at any time your consent with respect to our use of your personal data. You also have the right to lodge a complaint with the competent supervisory authority. You can contact us to exercise your rights by sending an email to our Data Protection Contact at privacy@www.wisdirect.com

Cookie Policy
Cookies are small files of letters and numbers that can be put on your computer or other internet enabled device such as a smartphone or tablet by a website when you are visiting it. Cookies enable such website to distinguish you from its other users, to provide you with a better user experience and to perform certain functions, depending on the type of cookies used.

We use cookies to improve your online experience, for marketing (including retargeting) and for analytics purposes. These cookies don’t collect information that directly identifies a visitor of our website. Depending on the purposes pursued, the cookies used on the website belong to one of the following categories:

Functional cookies
These cookies include both those which are used for purely technical purposes and those which are strictly necessary to provide a service explicitly requested by you. Examples of functional cookies include remembering previous actions (e.g., entered text) when navigating back to a page in the same session, or remembering previously chosen preferences (e.g., language or country) when starting a new session on the website.

Performance cookies
These cookies help us understand how you interact with the website by providing information about the areas visited, the time spent on the website, and any issues encountered, such as error messages. This allows us to improve the performance of the website (e.g., speed with which we can process your request). The cookies used on the website are listed in the table below which specifies, for each cookie, whether it is managed by WIS itself (so-called “first party cookies”) or by third party partners of WIS (so-called “third party cookies”):

How to disable cookies

For most browsers, you can change settings to refuse new cookies, disable existing ones or simply let you know when new ones are sent to your device. In order to do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” facility). However, please be aware that, if you refuse or disable cookies, some of the website’s functionality may be lost. In addition, disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser.

Here is a link to general information on cookies (including the explanations regarding the way to disable them depending on the type of your browser). For further information on how to opt out of Google Analytics tracking, please visit this specific opt-out page.
View the following link

To opt out of our remarketing campaign, please visit Google’s Ads settings page. View the following link

While we provide the means to opt-out from the use of cookies above, for a comprehensive and up-to-date summary of every third-party accessing your web browser (through WIS websites or otherwise), we recommend installing a web browser plugin built for this purpose. You can also choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings on each browser and device that you use. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to many features that make our websites more efficient and some of our services will not function properly.

WIS reserves the right to change this Privacy Policy at any time to reflect changes in our practices concerning the collection and use of information. If there are material changes to this Privacy Policy, the revised policy will be effective immediately upon posting it to our external website. If you require additional information, please contact us at 626‐793‐7717.