Other legal basis for collecting Personal Information are: (i) where we need the Personal Information for performance of a contract or requested service; or (ii) where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the Personal Information in question. If we collect your Personal Information with your consent, you may withdraw your consent at any time as provided below. You understand and agree that we may collect, use, disclose and otherwise process the Personal Information you provide even if you are located outside the United States.
We may collect Personal Information that you submit to us voluntarily through our Website. We collect this information when you register, create and edit a profile, answer survey questions, enter contests, use certain features on the Website or other methods of submitting information. The types of information you can choose to provide on our Website may include, without limitation:
We may use your Personal Information for the following general and business purposes:
We use Anonymous Information such as web or mobile pages you have viewed, in order to analyze request and usage patterns so that we may improve our products and services, enhance our user experience, and gather broad demographic information for aggregate use. Anonymous Information consists of data that would not identify you personally; these records exclude information (such as your name) that makes them personally identifiable to you. We may disclose Anonymous Information to third parties that promote our products and services. We reserve the right to use and disclose Anonymous Information to third parties in our discretion.
If you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Information you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
We may share your Personal Information with third party vendor and suppliers to provide you with the products and services that we offer you through the Website and to send you the Newsletters. You expressly consent to the sharing of your Personal Information with our contractors and third-party service providers (for the sole purpose of providing products and services to you. These service providers are contractually obligated to ensure the confidentiality of Personal Information and implement appropriate security measures.
We may participate in co-branding or co-promotional agreements with third parties pursuant to which we may share Personal Information with such third parties (“Partner Companies”). For example, we may participate in agreements with Partner Companies pursuant to which we provide the Partner Companies with a URL and a customer registration page co-branded with, or private labeled by, the Partner Companies, and the Partner Companies distributes and promotes the URL to its customers. A Partner Company may have access to Personal Information that we collect from their customers. As a result, if you register on the Website through a Partner Company, we may provide your Personal Information to the Partner Company. We do not control the privacy practices of these Partner Companies.
We may offer you the chance to participate in drawings, contests, giveaways, and promotions (“Special Promotions”) through our Website. By registering for a Special Promotion, you agree to the official rules that govern that Special Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Special Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Special Promotion. If you choose to enter a drawing, contest or other promotion, personally identifiable information may be disclosed to third parties or the public in connection with the administration of such Special Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Special Promotion’s official rules, such as on a winners list.
We may use your Personal Information in order to provide to third parties non-personal aggregated information about you that does not allow you to be identified or contacted and that is combined with the Personal Information of other users ("Aggregate Information"). For example, we might inform third parties regarding the number of users of our Website and the activities they conduct while on our Website. We might also inform a company that performs services or that provides products and/or services to us (that may or may not be a business partner or an advertiser on our Website) that 50% of our users live in the USA" or that "85% of our users have purchased products and/or services which can be downloaded from our Website." Depending on the circumstances, we may or may not charge third parties for this Aggregate Information. We may not limit the third parties' use of the Aggregate Information.
Under the following scenarios, we may be required to share your Personal Information:
Should you no longer wish to receive our any of our Newsletters to your inbox, you may click on the unsubscribe link located at the bottom of each message received, and/or contact us at email@example.com and we will immediately remove you from our distribution list.
California “Shine The Light” -- As provided by California Civil Code 1798.83, if you are a California resident, you have the right to receive (a) information identifying any third party company(ies) to whom we have disclosed your Personal Information to in the past year; and (b) a description of the categories of Personal Information disclosed. To obtain such information, please email your request to firstname.lastname@example.org with “California Privacy Rights Request” in the subject line.
For California residents under the age of 18 and registered users, California law (Business and Professionals Code § 22581) provides that you can request the removal of content or information you posted on the App or Site. Any such request should be sent to us at email@example.com along with a description of the posted content or other information to be removed. Be advised, however, that applicable law may not permit us to completely or comprehensively remove your deleted content or for other reasons as set forth in this California law.
California Consumer Privacy Act -- The California Consumer Privacy Act (CCPA) gives California consumers enhanced rights with respect to their personal information that is collected by businesses. The CCPA provides California consumers with three rights regarding their personal information.
First, California consumers can opt out of the sale of their Personal Information. However, this option is not available as Walter does not sell your Personal Information.
Second, California consumers may opt out of having their personal information sold to other persons or parties. Second, California consumers can request to know:
Third, California consumers can request that a business delete Personal Information about the consumer that a business has collected from the consumer.
To make a “Request to know” or “Request to Delete” your personal information, send us an e-mail at firstname.lastname@example.org. Please put either “Request to Know” or “Request to Delete” in the subject line of your email. You may also submit these requests via our CCPA Interactive Request Form . Authorized agents may also complete and submit the Interactive Request Form on behalf of a California Consumer.
We will confirm receipt of your request within 10 business days. We must provide the requested information or delete your personal information within 45 days of receipt of your request, but we can use up to an additional 45 days if we let you know that additional time is needed.
Before responding, we must verify that the person making the request is the person about whom we have collected their personal information. We may ask you to provide certain, limited personal information, such as your name and email address to verify and match your identity with our records and systems. If you have an account with us, we may ask that you verify your identity through our account authentication process. This is also to protect against fraud. We will not retain this personal information or use it for any other purpose. Also please be advised that we need to search our records and systems only for the preceding 12 months. There may be cases where we do not have any personal information about you or we are not able to verify your identity for matching purposes. Deleting your Personal Information may result in the closing of your account and inability to access the Services. However, you can always re-register at any time.
(Residents of Nevada and other states may also have similar rights to request information about or delete their personal information. To inquire about exercising these rights, please contact us at email@example.com.)
Walter and the Website are located in the United States and governed by US law. If you are outside the United States when you visit Website or engage in communications with us via mail, e-mail or telephone, please be aware that your Personal Information may be transferred to, stored and processed in the United States where our servers are located. Any information you provide to us, or that we collect through your use of the Website and will be stored, processed, and transferred within, or to, the United States. Please be aware that the United States and jurisdictions other than the one in which you are located may not provide the same level of data protection as considered adequate in your country. Note that your Personal Information may be available to the US Government or its agencies under legal process in the United States.
The Website may use third party services to access your Google user data, only upon your verification and consent to do so. You will be notified prior to accessing your Google user data, and must authorize your account credentials before you are capable of accessing your Google user data. The Google user data you use will not be stored or shared by us. The Google user data accessed by the Website is limited to user contacts, and are used solely to allow you to email those contacts directly from the Website.
For residents of the European Economic Area (EEA), United Kingdom and Switzerland, we advise that your Personal Information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. The United States has not sought or received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (“GDPR”). Our legal basis for collecting and using your Personal Information is to do so with your consent; where we need the Personal Information for performance of a contract or requested service, including to provide you with our daily Newsletter, or where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the Personal Information in question. If we collected your Personal Information with your consent, you may withdraw your consent at any time.
Our retention of your Personal Information and any subsequent communications are based on our legitimate interest in providing you with new and potentially relevant materials based on your geography, role, or company. As always, you can elect to opt out from receiving such future communications.
To the extent that we transfer Personal Information from the EEA, UK or Switzerland to a jurisdiction outside the EEA, UK or Switzerland that has not been adduced by the European Commission as providing adequate data protections (such as the United States), we will ensure that such Personal Information is safeguarded through appropriate contractual terms or other approved mechanisms.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
If we ask you to provide Personal Information to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your Personal Information is required and if not, the consequences of not sharing your Personal Information with us.
Similarly, if we collect and use your Personal Information in reliance on our or a third party's legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.
To withdraw consent or exercise these rights, please contact us via email at firstname.lastname@example.org.
If you are not satisfied with our response, or believe we are processing your Personal Information in violation of the law, you have the right to lodge a complaint with the Supervisory Authority (also known as Data Protection Authority) or other appropriate governmental authority in your EEA Member State or Switzerland.
Walter has implemented technical, administrative and physical security measures to protect your information from unauthorized access and use as described. While we strive to protect your information, no data transmission over the Internet is 100% secure and, consequently, while we strive to protect your Personal Information, we cannot guarantee or warrant the security of any information you transmit you provide, and you do so at your own risk. We cannot promise that your information will remain absolutely secure in all circumstances. We are not responsible for the circumvention of any privacy settings or security measures we may provide.
We will retain your information for the time necessary to provide a requested service, realize our legitimate business purposes and to comply with the law. We will only retain personal information for the longer of the period if: (a) required by law, or (b) there is a time-bound determination business need.
Our Website is not intended to be used by children under the age of 13, and we will not knowingly collect Personal Information from children under this age. We do not use an application or other mechanism to determine the age of users of the Website. All information provided to Walter will be treated as if it was provided by an adult. If, however, we learn that a child has submitted information about himself/herself to us, we will delete the information as soon as possible.
The Website may use third party services to access your Google user data, but only upon your verification and consent to do so. You will be notified prior to accessing your Google user data and must authorize your account credentials before you are capable of accessing your Google user data via the Website. The Google user data you use will not be stored or shared by us. The Google user data accessed by the Website is limited to user contacts and are used solely to allow you to email those contacts directly from the Website to, for example, invite your contacts to sign up for the Newsletters. We do not have access to your contacts.
The Website may contain links to and from third party websites of our business partners and various contact management services and other service providers. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check their individual privacy policies before you submit any Personal Information to those websites.
We may use pixel tags, cookies, and/or other similar technologies to collect visitor information.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website who disable cookies will be able to browse most areas of the Website, but some features may not function. You can find out more information about how to change your browser cookie settings at www.allaboutcookies.org.
You can also mail us at:
28 Liberty Street, Suite #6000
New York, NY 10038