Privacy Policy

^{Last update: June 3, 2024}

This Privacy Policy (the “Policy”) describes our practices regarding the collection, storage, usage, and disclosure of data that relates to identified or identifiable individuals (“personal data” and “data subjects / you”, respectively) who use our website located at: www.getwaltz.com (the “Website”), and the products, services, information, content, and materials that are offered, operated or made available by us to you through the Website or otherwise (collectively, the “Services”). The Services are owned and offered by Waltz, Inc. (together with its affiliated companies and assigns, “Waltz”, “we”, “our”, or “us”) and are designed to facilitate your real estate investments.

Sometimes we collect personal data automatically when an individual interacts with the Services (for information about how we use cookies and tracking technologies, please click here) and sometimes, we collect personal data directly from an individual. At times, we may collect personal data about an individual from other sources and third parties (such as our Service Providers), sometimes even before our first direct interaction with an individual.

Specifically, this Policy describes our practices regarding:

1. User Data: personal data relating to individuals who have opened a user account (“User Account”) on the Website through which we provide various Services (“Users”).
2. Visitor Data: data relating to visitors of the Website, participants at our events, and any other prospective customer or partner (collectively, “Visitors”) who visit or otherwise interact with the Website, online ads and content, emails, various sales and marketing channels, and integrations or communications under our control.
3. Loan Applicant Data: personal data a User provides in connection with such User's application for a business loan from Waltz as part of the Services (the “Loan Applicant”, “Loan”, and “Loan Service”, respectively).

Specifically, this Policy describes our practices regarding:

• Data Collection & Processing
• Data Uses
• Data Location
• Data Retention
• Data Disclosure
• Cookies and Data Collection Technologies
• Communications
• Data Security
• Data Subject Rights
• Data Controller/Processor
• Additional Notice & Contact Details

If you are a User or Visitor, please read this Policy carefully and make sure that you fully understand it. You represent that you are entitled to submit personal data (as defined below) to Waltz for use for the purposes set forth herein, without any obligation by Waltz to pay any fees or be subject to any restrictions or limitations.

You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as defined below), please do not provide it to us and refrain from any interaction with us or with the Websites or use the Services.

1. Data Collection & Processing

When we use the term “personal data” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Sometimes we collect personal data automatically when an individual interacts with the Services and sometimes, we collect personal data directly from an individual. At times, we may collect personal data about an individual from other sources and third parties (such as our Service Providers), sometimes even before our first direct interaction with an individual.

We may collect or generate the following types of personal data about individuals through the Services:

1. Usage, login credentials, and device information about Users and, Visitors (connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based upon such IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, log-in credentials to the Services, and inferred or presumed data generated from their use of the Services);
2. Contact details, communication history, billing and contracts, and preferences about Users and, Visitors (such as name, email, phone number, our communications including sensory information such as call and video recordings, and transcriptions and analyses thereof, feedback and testimonials received, contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement, purchasing details including interest and/or purchase history); and
3. Financial and identifying information about Users in general and as applicable specifically from Loan Applicants (such as passport/ government ID/ social security number etc., date of birth, driver's license, nationality, or certain biometric information (which we require in order to confirm your identity); salary, salary slips, bank number, legal address, tax identification number or its equivalent; credit score, other credit information including consumer credit reports, past and present mortgages; Users and Loan Applicant's personal and business finances and banking relationships, past and present employment, business, investment earnings and records (including without limitation income derived, maintenance costs, investment status, transactional information, investment profitability), bank accounts, court cases, stock holdings, or bankruptcies); to the extent, any of this information is considered to be sensitive information, your explicit consent will be requested prior to any sensitive data processing.

2. Data Uses

We use your personal data as necessary for the following purposes and in reliance on the lawful basis as further detailed in the chart below:

If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing) (“Consent”), your acceptance of our Terms of Service (“Terms”) and/or the provisions contained in the loan documents (“Loan Terms”) and this Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at privacy@getwaltz.com.

We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA). The Third Parties/Service Providers we engage with are contractually prohibited from selling your personal information for the intents and purposes of the CPRA. Relative to those Loan Service Third Parties (as defined below) with whom we conclude a sale of your Loan, once we sell your Loan to them, we will no longer serve as the independent controller of the data associated with your Loan.

3. Data Location

We and our authorized Service Providers (as defined below) maintain, store, and process personal data in the United States of America, Europe, Israel, and other locations as reasonably necessary for the proper performance and delivery of the Services or as may be required by law.

While privacy laws may vary between jurisdictions, Waltz is committed to protecting personal data in accordance with this Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

Waltz, Inc. is headquartered in the US, with a subsidiary, Waltz Tech Ltd., located in Israel, a jurisdiction which is considered by the European Commission and the UK Secretary of State to be offering an equally adequate level of protection for personal data as is granted in the EEA and the UK, respectively. We transfer personal data from the EEA (including Switzerland) and the UK to Israel on this basis. For data transfers from the EEA or UK to countries that are not considered to be offering an adequate level of data protection, including our headquarters in the US, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission and UK Parliament. You can obtain a copy by contacting us as indicated in Section 11 below.

4. Data Retention

We retain personal data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with the Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and applicable laws.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and the applicable legal requirements.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete, anonymize, or restrict access to it for any reason and at any time, with or without notice to you.

If you have any questions about our data retention policy, please contact us by e-mail at privacy@getwaltz.com.

5. Data Disclosure

Relative to Users (including Loan Applicants), and Visitors, we disclose personal data in the following ways:

1. Service Providers: We may engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud/money laundering/ terrorism funding detection and prevention services, identity verification and screening services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription, and analysis services, performance measurement, data optimization, and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing the Services, and may only use the data as determined in our agreements with them.
2. Waltz Subsidiaries and Affiliated Companies: We may share personal data internally within our group for the purposes described in this Policy. In addition, should Waltz undergo any change in control or ownership, including by means of merger, acquisition, or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. We may disclose personal data to a third party during the negotiation of, in connection with, or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy, or receivership.
   
   In addition, you may be presented with the opportunity to apply to and receive (subject to a customary due diligence process) a Loan to help you finance your real estate investment. Our Loans and lending products are offered by Waltz Capital Fund 1, LLC (“Waltz Capital”). You expressly authorize Waltz to share any of your User Data, Visitor Data, and Loan Applicant Data (collectively,“User Information”) that we may have and any documents and information you provide with Waltz Capital to facilitate the processing of your Loan application(s). You also expressly authorize Waltz to retrieve from Waltz Capital, on your behalf as your agent, and Waltz Capital to disclose to Waltz, any business, personal and financial information held by Waltz Capital. This will allow us to facilitate the processing of your Loan application and to provide you with information about the status of your transactions and any Loan you obtain.
3. Third-Party Services: We may engage selected business and channel partners, resellers, distributors, and providers of professional services in connection with the Services, which allow us to provide the Services, including as required by local regulations, and to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for Users and Visitors. In such instances, we may share relevant contact and usage details with the respective third-party provider for such purposes, and in certain cases, you may be required to directly engage with such respective third-party provider and accept its specific terms and privacy policy. Additionally, part of Waltz's one-stop-shop for investing in real-estate property enables you to access services provided by third parties. In such instances, we may share relevant contact, identity, and financial details or preferences at your instruction in order for you to benefit from such third-party services. Such engagement may also be subject to those third parties’ specific terms and privacy policies, depending on the service provided. If you directly engage with any of our third-party providers, please note that any aspect of that engagement that is not directly related to the Services and directed by Waltz is beyond the scope of Waltz's Terms and this Policy and shall be covered by the third-party provider's terms and privacy policy. You hereby agree that Waltz and its third-party service providers may: (1) derive statistical and usage data relating to your use of the Services (“Usage Data”), and (2) use Usage Data for any purpose in accordance with applicable law and this Privacy Policy.
   
   Through your User Account, you may obtain a bank account (“Bank Account”) provided by a third-party financial institution in the name of your U.S.-based limited liability company (LLC) that will own and hold the residential real estate you invest in (“Your LLC”) to help you manage income and expenses related to the management of your real estate investment. All banking services are provided by our banking partner Regent Bank, Member FDIC (“Bank”). The terms and conditions of any banking services you obtain through your User Account are governed by other agreements between you and Waltz, you, Waltz, and the Bank, a direct agreement between you and the Bank, and a direct agreement between you and other relevant third parties, all as applicable. With respect to these Services, where you do not have a direct agreement with the Bank and/or the third-party service provider, and there is no Other Agreement, these Terms will govern.
   
   You acknowledge and agree that by requesting to obtain a Bank Account and/or credit account and banking services via your User Account, you expressly authorize us to share any User Information needed by the Bank or other relevant third party to establish such accounts or provide you with such services. You will be presented with and will be required to review and agree to the relevant privacy policies before using any services provided by the Bank and/or other relevant third parties. You also expressly authorize us to retrieve, on your behalf and as your agent, your banking and transactional information held by the Bank or any other third-party providing banking services to you through your User Account.
4. Event Sponsors: If you attend an event or webinar organized by us or download or access an asset on the Website related to such an event, webinar or other activity involving third party sponsors or presenters, we may share your personal data with them. If required by applicable law, you may be asked to consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your personal data will also be subject to the sponsors' privacy statements. If you do not wish for your personal data to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned.
5. Sharing your Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review on the Website and in the Services. If you wish to remove your public review, please contact us at privacy@getwaltz.com.
6. Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services. Please see our Principles for Responding to Government Access Requests for further details.
7. Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Waltz and our employees, any of the Visitors or Users, or any members of the general public.
   
   Relative to a Loan Applicant's Loan Application which is approved:
   
   You are hereby directing us to disclose certain of your personal data with certain Loan Service Third Parties (as defined below) for the limited purpose of conducting an assessment on the risk factors involved in the loan and on the potential profitability such Third Party may collect should they decide to purchase the rights to such loan from Waltz. Any such Third Party is contractually bound to not conduct any further processing activities or other independent usage of your personal data.
8. Loan Service Third Parties: As further detailed in the Loan Terms, the Loan Service may include the disclosure of certain elements of your personal data with pre-approved Loan Service Third Parties, which may be interested in purchasing the rights to a loan provided to you under the Loan Service (“Loan Service Third Party”). These Loan Service Third Parties are contractually bound to process such personal data solely for the purpose of conducting an assessment on the risk factors involved in the loan, and on the potential profitability such Loan Service Third Parties may collect should they decide to purchase the rights to such loan from Waltz. In the event that a Loan Service Third Party should purchase the rights to a loan from Waltz, the personal data provided to such Loan Service Third Party will continue to be subject to the limited usage set forth in a Data Sharing Agreement (or other similar binding agreement) (“DSA”) between Waltz and such Loan Service Third Party. Such agreements include measures that allow Waltz to enforce conditions and limitations as well as ensure that the Loan Service Third Party complies with the applicable requirements and appropriate standards relating to data privacy and data protection. For further information regarding disclosure to Loan Service Third Parties under this Policy, please contact us at privacy@getwaltz.com.
   
   For the avoidance of doubt, Waltz may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable, and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

6. Cookies and Data Collection Technologies

We and our Service Providers use “cookies”, anonymous identifiers, pixels, container tags and other technologies in order to provide the Services and ensure that they perform properly, to analyze our performance and marketing activities, and to personalize your experience. To learn more about our practices concerning cookies and tracking, please see our Cookie Policy.

We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes in the Services. We may share non-identifiable / aggregated extracts of such information with our partners for our legitimate business purposes.

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.

We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access your User Account. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services' features and tools. We may also use HTML5 local storage or Flash cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it.

Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.

We also use the web analytics tool Google Analytics. This tool helps us understand Users' behavior on the Services, including by tracking page content and click/touch, movements, scrolls, and keystroke activities. Further information about the privacy practices of our analytics service provider is available at www.google.com/policies/privacy/partners. Further information about your option to opt out of this analytics service is available at:https://tools.google.com/dlpage/gaoptout.

Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser's cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt out, so an additional opt-out will be necessary to prevent additional tracking.

For more information on our cookie and data collection technologies practices, you may also use the “Cookie Settings” feature available in the Services depending on your location and activity on the Services, as applicable.

7. Communications

We engage in service and promotional communications through email, phone, SMS, and notifications.

Services Communications: We may contact you with important information regarding the Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to the Services, billing issues, log-in attempts, or password reset notices, etc. Please note that you will not be able to opt out of receiving certain service communications that are integral to your use of some of the Services (like password resets or billing notices).

Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities, or any other information we think you will find valuable, as a User or Visitor, subject to any necessary collection of your consent as appropriate based on applicable laws. We may provide such notices through any of the contact means available to us (e.g., phone, mobile, or email), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify Waltz at any time by sending an e-mail to privacy@getwaltz.com, changing your communications preferences in your profile settings whilst being logged as a User to the Services (upon this feature's availability), or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.

8. Data Security

We implement reasonable industry-standard physical, procedural, and technical security measures, designed to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. Therefore, you should take special care in deciding if to send information and what information you send to us via the Services or e-mail. Please keep this in mind when disclosing personal data to us via the Internet. Additionally, we are not responsible for the circumvention of any privacy settings or security measures contained within the Services or on Service Provider, Third Party, or Loan Service Third Party sites.

9. Data Subject Rights

Individuals have rights concerning their personal data. Please contact us by e-mail at privacy@getwaltz.com if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”) or other, such as – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with Waltz, or to restrict or object to such personal data's processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you).

Under some regulatory frameworks, such as the GDPR, you may also have the right to lodge a complaint with the relevant supervisory authority, as applicable.

Please note that when you ask us to exercise any of your rights under this Policy or applicable law, we may need to ask you to provide us with certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to understand better the nature and scope of data regarding which you request to exercise your rights. We may then retain such additional data for legal, compliance, and auditing purposes (e.g., as proof of the identity of the person submitting the request or proof of request fulfillment).

We may redact from the data, which we will make available to you any personal data related to others.

10. Data Controller/Processor

Certain data protection laws and regulations, such as the EU GDPR, UK GDPR and the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA and CPRA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA and CPRA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to the Services, to the extent that such laws and regulations apply.

Waltz is the “data controller” of User and Visitor Information. With respect to such data, we assume the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.

Additionally, for the Loan Applicant Data of those Loan Applicants with approved Loans:

The DSA prohibits Loan Service Third Parties from making any further uses of the Loan Applicant personal data Waltz discloses to them beyond the scope necessary for such Loan Service Third Party to conduct its financial assessment of a loan or purchase the rights to a loan. If the Loan Service Third Party decides to purchase the Loan, then the DSA also requires Loan Service Third Parties to comply with Waltz’s instructions when it comes to processing of the personal data and assisting Waltz in relation to its obligations as a ‘data controller’.

11. Additional Notice & Contact Details

Updates and Amendments: We may update and amend this Policy from time to time by posting an amended version on the Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

California Requirements: This Policy describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention (Section 4) and deletion rights (Section 9) practices. We also included information about how we may process and share your information (in Sections 2 through 7), which includes for “business purposes” under the CCPA and CPRA. We do not sell your personal information for the intentions and purposes of CCPA and CPRA. We may disclose personal information to third parties or allow them to collect personal information from the Services as described in Sections 5 above if those third parties are authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information, or if you integrate the services of third parties with the Services, or direct us to disclose your personal information to third parties, or as otherwise described in Section 5 above.

Should you wish to exercise your rights under the CPPA or CPRA to Opt Out of the selling or sharing of your personal information, please submit your request to us via email at privacy@getwaltz.com.

Should you wish to limit the use and disclosure of your personal information (CCPA/CPRA) or Sensitive Personal Information (as defined in the CPRA), please submit your request to us via email at privacy@getwaltz.com.

If you have any questions regarding your rights under the CCPA or the CPRA, you can contact privacy@getwaltz.com.

External Links: While the Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave the Services for the website or application of such third parties and to read the privacy policies of each and every website and service you visit. This Policy applies only to the Services.

Children: The Services are not designed to attract children. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person who is considered a minor, according to applicable law, is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such minor. If you believe that we might have any such data, please contact us by e-mail at privacy@getwaltz.com.

Contacting Us: If you have any comments or questions regarding this Policy or the Services, or if you have any concerns regarding your personal data held with us, please contact Waltz's privacy support at privacy@getwaltz.com.

will use reasonable efforts to notify you of any such matter. We reserve the right, at your expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, and in such case, you agree to cooperate with our defense of such claim. You shall cooperate as fully as reasonably required in the defense of any such claim. You agree not to settle any such matter without the prior written consent of Waltz.