Waltz's Privacy Policy

Effective as of October 5, 2026

Welcome to Waltz, Inc., a service that helps older adults (“Clients”) with their tech problems and questions by providing real-time, human-centered tech support. This Privacy Policy (“Policy”) explains how Waltz, Inc. (“Waltz,” “we,” “us,” or “our”) handles the personal information that we collect about users of our website and any related webpages and desktop or mobile applications (collectively the “Platform”), and about Clients who engage in audio and/or visual virtual help sessions (“Sessions”) with our technology helpers (“Tech Helpers”). In this Policy, we refer to our Platform, Sessions, and any other online or offline services we offer as the “Services.”

We encourage you to review our Terms of Use to understand other requirements and limitations related to your use of our Services.

Please note that we are providing the following disclosures and rights in this Policy in the interest of transparency and in furtherance of our privacy commitment to you. Such disclosures and rights are not intended to waive any applicable exemptions under state and federal law.

If you have any questions or concerns about how your data is being handled, please don’t hesitate to contact us as described at the end of this Policy. We are happy to explain anything that is unclear.

Waltz’s Commitment to Your Privacy and a Summary of this Policy

We take your privacy seriously. We know many Clients contact us when they need help with technology, and we value the trust you place in us. We recommend reviewing the entire Policy, but here are a few things we want you to know up front:

• Definitions. When we use the term “personal information” in this Policy, we mean information about you that can be reasonably linked to you, such as contact information (e.g., name, address, email address, or telephone number), information about your activity on our website, and any information that you share when you speak with our Tech Helpers.

• We limit the data we collect, use, and share. We only collect, use, and share personal information as described in this Policy, or with your permission.  We explain what data we collect in Section 1 of this Policy, how we use that data in Section 2, and how we share it in Section 3.

• We do not sell personal information for money. Having said that, some parts of our website use cookies and similar technologies provided by third party companies that collect data about how website visitors use our website and allow us to improve and analyze our Services and promote content and services that relate to website visitors’ interests. Our use of such technologies may be considered a “sale” of personal information, as that term is broadly defined under various privacy laws. We do not use these technologies on our member Platform or Tech Helper Sessions. We explain more about this technology and our practices in Section 4 of this Policy.

• We provide ways for you to control your personal information and express your preferences. We offer ways for you to take charge of your personal information, including by making certain data collection optional, providing you with direct control over updating and editing your user profile, and providing you with unsubscribe options. We provide more information about this in Section 5 of this Policy.

• This Policy applies only to our Services. It does not apply to third-party websites and platforms, even if our Services link to them or vice versa. We recommend that you review the privacy policies for third-party websites and platforms to understand how your personal information is used and stored by those third parties.

• We’re here for you if you have any questions or need support. Please contact us if you have any questions or concerns about our privacy practices or need to access this Policy is another format or language. Our contact information is at the bottom of this Policy (Section 11).

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This Policy is provided in a layered format. You can jump to a specific section by clicking on the section name below:

1. Personal information we collect

A. Information you provide to us. Personal information you provide to us through the Services or otherwise may include:

• Contact data, such as your name, email address, mailing address(es), and phone number.

• Demographic information, such as your city, state, country of residence, postal code, date of birth, and any other information that you add to your account profile.

• Audio, electronic, visual, or other sensory information, such as recordings, transcripts, and summaries of Sessions and phone calls.

• Other communications data, including the content, timing, and method of communications you have with us, such as via phone or email; information you may provide during Sessions; and information you provide when completing one of our surveys or questionnaires.

• Transactional data, such as information relating to or needed to complete your payment for the Services, including confirmation numbers and transaction history.

• Payment information needed to complete transactions, such as credit card information, which is collected by our third-party payment processor, Stripe. 

• Marketing data, such as your preferences for receiving our marketing communications, and details about how you engage with them.

• Inferences about your preferences or behavior drawn from any of the information we collect, including to assess the level of interest in our Services. 

• Other data not specifically listed here, which we will use as described in this Policy or as otherwise disclosed at the time of collection.

A Note About Sessions with Tech Helpers As part of our Services, we offer Sessions with Tech Helpers. We record these Sessions, including what you share on your screen during Sessions. We only record Sessions for internal business purposes such as training, quality assurance, internal analytics, and Services improvement. We do not sell Session data or use the contents of your Session to advertise to you.  

In some cases, your shared screen may contain personal information, including sensitive information such as your state or other government-issued identification card number, Social Security number, and account login information. This means that we collect such information incidentally through our Session recordings, but take appropriate measures to limit how we use and store these recordings. It is your choice what personal information you choose to make available on your screen and otherwise during Sessions. If you are unsure whether something on your screen is sensitive, you may ask your Tech Helper before sharing it.

A Note About Referrals Additionally, we may offer features that help you invite others to use the Services, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

B. Information collected from other sources. We also collect information about you from other sources. Those sources may include:

• Corporate affiliates, including our current and future parent companies, subsidiaries, and other companies under common control and ownership. 

• Service providers who provide services on our behalf or otherwise help us operate the Services or our business, including those providing hosting, payment processing, advertising, analytics, customer and technical support, artificial intelligence, email services, and other services.  

  • Note that as part of offering our Services, we may utilize products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (“AI Technologies”). In simple terms, these are tools that can help with tasks such as recording, transcribing, or summarizing a Session. For example, we may utilize service providers, such as Zoom and OpenAI, who use AI technologies to record, transcribe, and summarize your Session with a Tech Helper on our behalf.  

• Third-party data providers, such as information services and data licensors that provide demographic and other information.

• Third-party platform providers, including advertising and analytics companies, who assist us in serving advertising regarding the Services to others who may be interested. We may also partner with third parties who use Cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location, and/or interests. To keep things simple, we will refer to these third parties as “Third-Party Advertising Platforms and Analytics Providers” for the rest of this Policy. 

• Other Clients, including those who invite you to use the Services.

• Other third parties, including business and marketing partners, unless you have indicated that you don’t want to receive (sometimes referred as having “opted out of”) marketing communications.

We may combine personal information we receive from you with personal information we obtain from the above sources.

C. Information collected automatically. When you visit our website, we may use cookies and other tracking technologies such as web beacons, embedded scripts, and tags which collect certain information from your computer or mobile phone automatically, such as information about your device, information about your activity online, and information about how you interact with our Platform and communications we may send you. 

Some of the details below are technical. We are providing them to help you understand what may be collected when you use our website. Please contact us if you would like help understanding this section or have any questions. 

Below is a summary of the kind of data that is collected automatically about our website visitors.

• Browser and device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 5G), and general location information such as city, state, or geographic area.

• Online activity data, such as web pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Platform, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Below are details about the kind of technologies we use to collect data automatically. Again, we know that this information is technical, so please contact us if you have any questions.

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies can include “session cookies,” which are deleted when a session ends; “persistent cookies,” which remain longer; and “third-party” cookies, which our third-party business partners and service providers store.

• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device, outside your browser, in connection with specific applications.

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

To keep things simple, we will refer to these technologies collectively as “Cookies” for the rest of this Policy. We provide more detail about Cookies in Section 4.

2. How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection.

A. Service delivery. We may use your personal information to:

• Provide, analyze, operate, expand, and improve the Services and our business;

• Establish and maintain your user profile on the Services;

• Connect Clients and Tech Helpers for Sessions;

• Schedule Sessions;

• Enable security features of the Services, such as by sending you security codes via email and remembering devices from which you have previously logged in;

• Communicate with you about the Services, including by sending notifications, appointment reminders, questionnaires, announcements, updates, security alerts, and support and administrative messages;

• Communicate with you regarding promotional opportunities or activities;

• Understand your needs and interests, and personalize your experience with the Services and our communications; and

• Provide support for the Services and respond to your requests, questions, and feedback.

• Develop our Services, including for training purposes related to our use of AI Technologies. For example, AI Technologies may help us organize or summarize information so we can improve our Services.

B. Research and development; de-identification. We may use your personal information for research and development purposes, including to analyze, develop insights, improve the Services and our business, and for other internal business and commercial purposes.

Additionally, we may create aggregated (grouped), de-identified (information from which personal identifiers have been removed), or other anonymous data from personal information we collect. We convert personal information to anonymous and de-identified data by removing information that makes the data personally identifiable to you. De-identified and anonymous data is not subject to most state data privacy laws. Accordingly, we may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and to market and promote our business.

C. Marketing. We may use your personal information for marketing purposes.

Additionally, we may send you direct marketing communications, including product recommendations. You may decline, or “opt out” of, our marketing communications as described in the “Opt out of marketing emails” (Section 5(B)).

D. Compliance and protection. We may use your personal information to:

• Comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities;

• Protect our, Clients’, Tech Helpers’, or others’ rights, privacy, safety, or property (including by making and defending legal claims);

• Audit our internal processes for compliance with legal and contractual requirements or our internal policies;

• Enforce the terms and conditions that govern the Services; and

• Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including privacy violations, cyberattacks, and identity theft.

• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

E. With your consent. In some cases, we may specifically ask for your consent to collect, use, or disclose your personal information, including when consent is required by law.

Please note that we may utilize AI Technologies for any of the above purposes.

3. How we disclose your personal information

We may disclose your personal information with the following parties and as otherwise described in this Policy or at the time of collection. In all cases, we disclose personal information only as permitted by applicable state and federal laws.

• Service providers. We may disclose certain information to service providers who provide services on our behalf or otherwise help us operate the Services or our business (such as hosting, payment processing, advertising, analytics, customer and technical support, artificial intelligence, email services, and other services). For example, Sessions may be recorded and stored by our third-party service providers, Zoom and OpenAI, on our behalf.  

• Professional advisors. We may disclose certain information to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

• Authorities for compliance and harm prevention. Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities, and/or in response to a threat of harm involving an individual’s health and/or safety.

• Business transferees. If we or our affiliates are involved in a merger, acquisition, asset sale, or other corporate combination, your personal information may be transferred to the acquiring or surviving entity.

• Corporate affiliates. We may disclose personal information to corporate affiliates, including our current and future parent companies, subsidiaries, and other companies under common control and ownership. 

• Video hosting platforms. We may host videos on our Platform, which may be embedded and hosted by third party video hosting platforms such as YouTube. These third parties may collect and store video viewing data, including video titles and descriptions, viewing times and duration, and interaction data. 

• Third-Party Advertising Platforms and Analytics Providers. We may disclose personal information to Third-Party Advertising Platforms and Analytics Providers through our use of Cookies. As noted above, we only use these Cookies on our informational website and do not use them on our member Platform or Tech Helper Sessions. 

• Any other third party with your prior consent to do so.

Please note that we do not disclose text messaging originator opt-in data and consent to third parties.

4. Cookies and other tracking technologies

As mentioned above, like most companies, we use Cookies to collect and track information about the use of our website. We use Cookies to help us improve and analyze our Services, and in some cases, to promote content and services that relate to your interests. Cookies that we use generally fall into the following categories:

• Strictly Necessary Cookies: These are required for the operation of our Services. They include, for example, Cookies that enable you to log into secure areas.

• Functional Cookies: These improve the functional performance of our Services and make it easier for you to use.

• Performance/Analytics. We may use Cookies that are useful to assess the performance of our Services, including as part of our analytic practices or otherwise to improve our Services. For example, we may use Google Analytics or other service providers for analytics services. These analytics services may use cookies to help us analyze how users use the Services. Information generated by these services (e.g., your IP address and other usage information) may be transmitted to and stored by Google Analytics and other service providers on servers in the U.S. or elsewhere and these service providers may use this information for purposes such as evaluating your use of the Services, compiling statistic reports, and providing other services relating to activity and other Internet usage. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

• Targeting/Advertising. We may use Cookies to deliver content, including advertisements, relevant to your interests on our Services based on how you interact with advertisements or content. As noted above, we only use these Cookies on our informational website and do not use them on our member Platform or Tech Helper Sessions, and we do not use any Session records to market to you.

You can modify the use of certain Cookies in your browser settings. Note that if you decline certain Cookies, some of our website features may not function as designed.

5. Your choices

A. Access or update your information. If you have registered for an account with us through the Platform, you may review, change, or update certain account information by logging in to your account.

B. Opt out of marketing emails. You may opt out of marketing emails that we send by following the opt-out or unsubscribe instructions at the bottom of the email or by contacting us as described below. Please note that if you choose to opt out of marketing-related emails, you may continue to receive service-related and other nonmarketing communications from us.

C. Declining to provide information. We need to collect certain personal information to provide certain Services. It is your choice what information you provide to us. However. if you do not provide the information we identify as required or mandatory, we may not be able to provide those Services.

6. Data security and retention

We follow generally accepted standards, practices, and procedures to protect the personal information we collect against unauthorized access, destruction, loss, alteration, disclosure, or misuse. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. 

We retain personal information for as long as necessary for the purposes outlined in this Policy, including complying with any legal obligations or policies, resolving disputes, enforcing legal agreements, and for internal analytics purposes. Our determination of precise retention periods will be based on (a) the length of time we have an ongoing relationship with you; (b) whether there is a legal obligation to which we are subject; and (c) whether retention is advisable in light of our legal position, including with regard to applicable statutes of limitations, litigation, or regulatory investigations.

7. International data transfer

Your personal information may be transferred and maintained outside of your state, province, country, or other jurisdiction where the privacy laws may differ from those of your jurisdiction. If you are located outside of the United States and choose to provide information to us, please note that we transfer personal information to the United States and process it there. For such transfers, we take the necessary measures to ensure that your personal information receives an adequate level of protection.

8. Children's privacy

The Services are not intended for use by anyone under 18 years of age. If we learn that we have collected personal information from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information. If you think that your child provided information via our Services, please contact us using one of the methods described at the end of this Policy.

9. Supplemental state notices

Some states provide residents with various rights concerning their personal information. 

We are providing the following supplemental notices in the interest of transparency and in furtherance of our privacy commitment to you. Such disclosures and rights are not intended to waive any applicable exemptions under state and federal law.

A. Supplemental notice to California residents California residents have the right to request information regarding third parties to whom we have disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes under California’s “Shine the Light” law (Cal. Civ. Code §1798.83). We do not disclose personal information to third parties for such purposes. However, if you wish to request information regarding such practices under California’s “Shine the Light” Law, please contact us using one of the methods described at the end of this Policy. You must include your full name, email address, and postal address in your email or mail request so that we can verify your residency and respond.

B. Supplemental notice to Nevada residents We do not “sell” personal information as that term is defined under Nevada law. Nevada residents have the right to opt out of any future sale of their personal information under Nevada SB 220. If you are a Nevada resident and would like to make such a request, please contact us using one of the methods described at the end of this Policy. You must include your full name, email address, and postal address in your request so that we can verify your residency and respond.

C. Supplemental notice to Connecticut, Nebraska, and Texas residents This notice contains additional information for residents of Connecticut, Nebraska, and Texas about our data practices and your rights with respect to personal information under applicable laws and regulations. The provisions contained within this notice, in addition to the disclosures throughout the rest of this Policy, are intended to provide disclosures in compliance with the Connecticut Data Privacy Act, the Nebraska Data Privacy Act, and the Texas Data Privacy and Security Act (collectively “State Privacy Laws”).

i. Our personal information practices Information about what kinds of personal information we may collect or have collected, how we collect it, why we collect it, and to whom we may disclose it is found in Sections 1-3 of this Policy.  Note that we may disclose personal information about website visitors to Third-Party Advertising Platforms and Analytics Providers via Cookies for purposes of providing targeted advertising, which may be considered a “sale” of personal information under State Privacy Laws. As mentioned above, we do not use such Cookies on our member Platform or Tech Helper Sessions.

ii. Your privacy rights Connecticut, Nebraska, and Texas residents may have the following rights under applicable law in relation to your personal information, subject to certain exceptions: 

• Right to know and access. You have the right to know what personal information we collect, use, disclose, and “sell” (as defined by applicable law). You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.

• Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal information that we collect about you.

• Right to correct. You have the right to request the correction of inaccurate personal information.

• Right to opt out. You have the right to opt-out of the processing of personal information for the purposes of targeted advertising, the sale of your personal information, and profiling in furtherance of a decision that produces a legal or similarly significant effect concerning you. Please note that we do not process personal information for such profiling. 

• Rights concerning sensitive personal information. We cannot process sensitive data or use your personal information for certain purposes without your affirmative consent. 

• Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

You can exercise these rights by contacting us using the information at the end of this Policy.

All requests are subject to certain exceptions under applicable law. Consistent with applicable law, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of your authorization of the agent and/or verification of the agent’s own identity. Please note that any request submitted to us is subject to an identification and residency verification process, to the extent permitted under applicable law. We will only use personal information provided in a request to verify your (or your authorized agent’s as applicable) identity or authority to make the request. 

We will respond and process requests consistent with applicable law. Except where otherwise noted, we will respond to your request within forty-five (45) calendar days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary, provided that the extension is made within the first forty-five (45) days. 

We do not charge a fee to process or respond to a request unless it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. You may be limited in how many requests you make within a twelve (12) month period.

iii. How to appeal decisions about your rights Connecticut, Nebraska, and Texas residents can appeal our decisions about privacy rights requests as follows:

• Connecticut residents. If you are a Connecticut resident and want to appeal our decision regarding a request that you have made, please contact us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Connecticut’s Office of the Attorney General by phone at (860) 808-5420 or by submitting a form here.

• Nebraska residents. If you are a Nebraska resident and want to appeal our decision about a request you have made, please contact us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Nebraska’s Office of the Attorney General by phone at (402) 471-2683 or by submitting a form here.  

• Texas residents. If you are a Texas resident and want to appeal our decision about a request you have made, please contact us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Texas’ Office of the Attorney General by phone at (800) 621-0508 or by submitting a form here.

10. Changes to this Policy

We may modify this Policy at any time, including to reflect changes in our data practices or applicable law. We will notify you of changes consistent with applicable law, including by updating the “effective date” at the top of this Policy and posting it on our website or through other appropriate means. Any modifications to this Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting).

11. How to contact us

• Email: [email protected]

• Mail: E2Technology, LLC, 1165 Park Avenue Suite 2C, New York, NY 10128

• Phone: 844-629-2589