Revised: 5/2/2025

Your privacy is important to Whirlwind Steel Buildings, Inc. (“Whirlwind,” “we” or “us”). This Whirlwind Privacy Policy (“Privacy Policy”) describes how Whirlwind may collect, use, store, disclose, and process your personal information, through your access to or use of Whirlwind products and services, including those at https://www.whirlwindsteel.com/, https://recruiting.paylocity.com/, related websites, mobile software applications, and other offerings (collectively, the “Services”). By using these Services, you signify your acceptance of this Privacy Policy.  If you do not agree to this Privacy Policy, please do not use the Services. Whirlwind may change this Privacy Policy from time to time by posting changes at this URL and may send notification emails. Your continued use of the Services following the posting of such changes will be deemed your acceptance of those changes.

This Privacy Policy only applies to personal information we collect in connection with the provision of the Services when acting as a “controller.” We act as a controller when we make the decision about how to handle your personal information. We act as a “processor” when we process personal information on behalf of and in accordance with the instructions of our customers (which include entities which may sell Whirlwind products and services directly to you). This Privacy Policy does not address the situations in which we act as a processor; if you would like to understand how our customers handle your personal information, please contact them directly.

Whirlwind encourages you to read this Privacy Policy in its entirety, but here are a few key points of our privacy practices:

Privacy Policy Applicability

This Privacy Policy applies when you access the Services or share information with Whirlwind, as indicated below. By using the Services, you consent to this Privacy Policy, which may be updated by us at any time. If you do not consent to this Privacy Policy for any reason, please do not use the Services or share your information with us. Please note that this Privacy Policy applies only to the Services, and not to any other third party website linked to or from it, or any third party website in which Whirlwind content or functionality is embedded. We do not control the privacy policies or practices of others. In addition to what is provided in this Privacy Policy, certain terms related to personal information and the Services are provided in our Terms of Service, provided at https://www.whirlwindsteel.com/terms-of-service/, including with respect to consumer reports and written instructions for Whirlwind to collect such information. 

Information We Collect from You

In general, we receive and collect all information you provide via the Services, including through website input fields (including advertisements), mobile application, phone, email (including email campaigns), web chat, or in other ways. This includes personal information that can identify or relates to you, including but not limited to:

• your first and last name;
• telephone number;
• IP address;
• geolocation information;
• postal and billing address;
• job title, employer name, business address and other corporate information;
• business email address and phone number;
• email address;
• payment information; and
• other information provided by you.

You have the choice on what information to share and the services you want to engage. You can choose not to provide information to us, but in general some information about you is required in order for you to access certain functionality of the Services, such as those mentioned above or for tracking your preferences, subscribing to a newsletter, or initiating other such actions.

Information We Collect from Third Parties

We also may periodically obtain information about you from affiliated entities, partners and other independent third-party sources and plugins and will add it to our database of information. For example, we may receive information about your interaction with advertisements on third party websites and social media platforms, including updated postal addresses and demographic information.

We may use cookies, log files, web beacons, device identifiers, advertising identifiers and similar tracking technologies, including those from third-party service providers like Google Analytics and other cloud-based tools, to automatically collect your preferences, performance data, and information about your web usage when you visit the Services. For example, we may collect your IP address, device and Internet service provider information, Web browser details and the address of any referring website. This may include collecting geolocation signals from your IP address or device settings to determine your location so that we may operate and personalize the Services for you, including to provide more relevant ads and search results.  We may also collect information about your online activity, such as pages viewed and interactions with other users. The Services are not designed to recognize or respond to “do not track” signals received from browsers. You can control the information collected by such tracking technologies or be alerted when cookies are sent by adjusting the settings on your Internet browser or devices, but such adjustments may affect or disable certain functionality of the Services. You can learn more about Google Analytics and your options for opting out of interest-based Google ads at https://adssettings.google.com.   

How We Use Your Information

We also may periodically obtain information about you from affiliated entities, partners and other independent third-party sources and plugins and will add it to our database of information. For example, we may receive information about your interaction with advertisements on third party websites and social media platforms, including updated postal addresses and demographic information.

More specifically, we may use your personal information to:

• Optimize and improve the Services – We continually try to improve the Services based on the information and feedback we receive from you, including by optimizing the content on the Services.

• Personalize the user experience – We may use your information to measure engagement with the Services, and to understand how you and our other users interact with and use the Services and other resources we provide.

• Improve customer service – Your information helps us to more effectively develop the Services and respond to your support needs.
•  Process transactions – We may use the information you provide about yourself to fulfill your requests and product orders. We do not share this information with outside parties except to the extent necessary to provide the Services, fulfill orders, and related activities.
• To send periodic communications – The contact information you provide through our contact forms or otherwise via the Services will be used to send information and updates pertaining to the Services. Such information may also be used to respond to your inquiries or other requests. You can stop receiving promotional messages from Whirlwind by following the “unsubscribe” instructions provided in such communications or by contacting us via the contact information below. You may still receive Services-related communications, including account verification, transactional communications, changes or updates to features of the Services, and technical and security notices.

How We Share Your Information

We share your information with our partners, service providers, contractors, agents and third party vendors as needed to fulfill Services. Please note that our partners may contact you as necessary to obtain additional information about you, facilitate any use of the Services, fulfill orders, or respond to a request you submit.

Third-party vendors who provide product, services or functions on our behalf may include business analytics companies, customer service vendors, communications service vendors, marketing vendors, delivery, parcel, and transportation vendors, and security vendors. We may also authorize third-party vendors to collect information on our behalf, including as necessary to operate features of the Services, facilitate the delivery of orders, or provide online advertising tailored to your interests. Third-party vendors have access to and may collect personal information only as needed to perform their functions, may only use personal information consistent with this Privacy Policy and other appropriate confidentiality and security measures, and are not permitted to share or use the information for any other purpose.

As a prospective renter, we may also share your information with property owners, property managers, landlords and other property professionals who manage a property listing to which you have opted to apply via the Services.

We also may share your information:

• In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.
• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, interests, or safety of our company or the Services, our customers, or others; or in connection with our Terms of Service and other agreements.
• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
• With credit bureaus, collection agencies, loan service providers, lawyers, government agencies, agents, and other companies in connection with our provision of the Services, including issues related to credit, debt collection, or fraud.

Other than as set out above, we will attempt to notify you when your personal information will be shared with third parties.

Personal Information You Post in Public Areas. When you post a message in a Whirlwind forum, chat room, review, or customer feedback, the information you post may be accessible to other users of the Services and the public. If you post personal information anywhere on the Services that is accessible to other users or the public, you are advised that such personal information can be read, collected, used, or disseminated by others and could be used to send you unsolicited information or for other purposes. Accordingly, you assume full responsibility for posting such information and agree that Whirlwind is not responsible in any way for personal information you choose to post in these public areas.

Aggregated Information. We may publish, share, distribute, or disclose personal information that has been aggregated with information from other users or otherwise de-identified in a manner that does not allow such data about you to be separated from the aggregate data and identified as originating from you, to third parties, including Whirlwind partners, sponsors, and advertisers. Such information may help Whirlwind identify and analyze training, demographic, and psychographic trends and information, and report to third parties how many people saw, visited, or clicked on certain content, areas of the Services, ads, or other materials. We may also use such data for research purposes.

How We Store and Secure Your Information

Personal information collected by Whirlwind may be stored and processed in your region, in the United States, and in any other country where Whirlwind or its affiliates, subsidiaries, or service providers operate facilities. Whirlwind will retain your information as long as necessary for the purposes outlined in this Privacy Policy and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection or audit purposes, or as otherwise required by law.

Whirlwind takes technological and organizational measures to protect your personal information against loss, theft, and unauthorized access, use, disclosure or modification. For example:

• we transmit data over secured communication channels using industry standard protocols,
• all personal information is stored by trusted third party providers (e.g., HubSpot and AWS),
• all systems used to provide the Services are password protected, and
• all Services usage is restricted on a per-user basis on the principle of least privilege.

We rely on Microsoft’s security programs to protect personal information while stored in their respective controlled facilities.  For more information on Microsoft’s security practices and processes, please see https://privacy.microsoft.com/en-us/privacystatement.

Whirlwind complies with applicable data protection laws, including applicable security breach notification requirements.

Accessing and Updating Your Information

To the extent provided by the law of your jurisdiction, you may (i) have the right to access certain personal information we maintain about you and request details about how we process it, (ii) request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, (iii) request that we update or correct inaccuracies in that information, (iv) object to our use of your personal information, (v) ask us to block or delete your personal information from our database, and (vi) request to download the information you have shared on the Services. You may make these requests and any other inquiries about this Privacy Policy by emailing marketing@whirlwindsteel.com. Any such requests are subject to the protection of other individuals’ rights and applicable law. Additionally, to help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.

Data Retention

Whirlwind retains personal information for the duration of your relationship with Whirlwind, for the purposes indicated herein, or for other such period as may be permitted or required by law. If you cancel your account or stop using the Services, we may continue to retain your personal information for compliance purposes or as required by property owners, property managers, landlords and other property professionals for their compliance and business purposes.

External Websites and other Third Parties

Except as otherwise expressly included herein, this Privacy Policy addresses only the use and disclosure of information we collect from you via the Services. If you disclose your information to others, whether they are contractors, logistics providers, properties or other websites, different rules may apply to their use or disclosure of the information you disclose to them. We do not control the privacy policies of third parties. We encourage you to review third parties’ privacy notices before you disclose your personal information to others.

The Services have links to other websites that may collect personal information about you if you access or use them. We are not responsible for the privacy practices or the content of those linked websites.

Additional Privacy Information

Data Transfer. Our databases are currently located in North America. Whirlwind makes no claim that its Services are appropriate or lawful for use or access outside North America. If you access the Services from outside North America, you are consenting to the transfer of your personal information from your location to North America. You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and access to the Services. By sending us your information, you further consent to its storage within North America.

Collection of Data from Children. The Services are not directed to children, and you may not use the Services or provide any personal information to Whirlwind if you are under the age of 13 or if you are not old enough to consent to the processing of your personal information in your country. 

Your California Privacy Rights.

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail us or write to us at the addresses below.

Moreover, if you are a California resident, we are required to provide this notice under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), to explain how we collect, use and share your personal information, and the rights and choices we offer California residents regarding our handling of your personal information, which the CCPA currently defines as “information that identifies, relates to, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

1. Personal Information Collection, Use, and Disclosure: We describe the sources through which we collect personal information and the types of personal information collected in the “Information We Collect From You” section in this Privacy Policy and in the below table. We describe the third party sources from which we may collect certain of your personal information and the types of personal information collected in the “Information We Collect From Third Parties” section in this Privacy Policy and in the below table. We describe the purposes for which we use and share this information in the “How We Use Your Information” section in this Privacy Policy and in the below table. Information about how long we retain your personal information can be found in the “Data Retention” section in this Privacy Policy