Waltz's Privacy Policy

Effective as of April 2, 2024

Welcome to Waltz, Inc., a service that helps older adults (“Clients”) with their tech problems and questions by delivering real-time, human-centered tech support. This Privacy Policy (“Policy”) describes how Waltz handles the personal information that we collect as we provide our services. Waltz may be referred to throughout this Policy as “us,” “we,” or “our.”

If you have 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.

Waltz employs technology helpers (“Tech Helpers”) who provide audio and/or visual virtual help sessions (“Sessions”). When we say “you” or “user,” we’re referring to anyone who interacts with our website, either to provide or receive Sessions (collectively, our “Services”), including both Clients and Tech Helpers.

This Policy describes how Waltz handles personal information that we collect through all digital properties that link to this Privacy Policy, including our website and any mobile application (“app”) that may exist in the future (collectively the “Platform”), as well as through our Services, and through social media, marketing activities, and other activities described in this Policy.

First, a note about Waltz’s commitment to your privacy:

Waltz deeply values its role in assisting Clients with accessing and receiving our Services, including Tech Helper Sessions. We have no higher priority than safeguarding the privacy of personal information.

Here are a few things we want you to know:

• Definitions. So we are clear about the terms we are using, when we use the term “personal information” in this Policy, we mean information about you that is personally identifiable to you, such as your contact information (e.g., name, address, email address, or telephone number) and any other nonpublic information that is associated with such information. This includes Session recordings, which we make so that you have access to previous Sessions. And when we use the term “cookies,” which is defined further below, we mean the small pieces of information that a website sends to your browser while you are viewing that website.

• We collect only the personal information we need in order to provide you with access to our Platform and our Services. We do not collect more information than we need. The personal information that we ask Clients to provide us, or give Clients the option to provide us, is intended to help Tech Helpers deliver high-quality services to Clients. The information we ask Tech Helpers to give us is intended to help Clients receive Sessions from them.

• We do not use your personal information for purposes unrelated to the reasons for which it was collected or unrelated to your reasonable expectations. We know it is important to you that you be aware of all the reasons your information is collected and handled by Waltz and Tech Helpers.

• We do our best to minimize the amount of data we store. We understand the importance of keeping to a minimum the personal and sensitive data that we may maintain.

• We will never sell your identifiable personal information without your consent.

• We offer you ways to control your personal information and express your preferences. We provide you with a variety of ways to exercise control over your personal information, including making certain data collection optional, providing you with direct control over updating and editing your user profile, and providing you with unsubscribe options.

Please note that in addition to this Policy, information we collect from you may also be subject to state data privacy laws and the Federal Trade Commission’s authority. Please feel free to contact us if you have any questions about these laws.

By accessing or using our Platform or Services, you agree to this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Services. We also encourage you to review our Terms of Use to understand other requirements and limitations related to your use of the Services. Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use.

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

Personal information we collect

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, and postal code.

• Profile data, such as your date of birth, your biographical details, and any other information that you add to your account profile.

• Communications that occur over the Platform, including during Sessions (such as notes taken by Tech Helpers during such Sessions, and recordings of those Sessions); other communications you may have with Tech Helpers, such as through phone calls, or when you share photos or videos with your Helper; or when you contact us through the Services, social media, or otherwise (including for support).

• Questionnaire, survey, and Session data, such as information you provide when completing one of our surveys or well-being 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, as described further below.

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

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

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, which may include:

• Data helpers, such as information services and data licensors that provide demographic and other information.

• Marketing partners, unless you have indicated that you don’t want to receive (have “opted out of”) marketing communications.

Automatic data collection. We (and our service helpers, defined below) may 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. The details below are dense, we know – don’t hesitate to contact us if you have any questions!

• 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.

Cookies and similar technologies. Some of the automatic collection described above may be facilitated by the following technologies:

• 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 helpers 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.

For more information about our use of cookies, please refer to our Cookie Policy[10].

Data about others. 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.

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:

Service delivery. We may use your personal information to:

• Provide, operate, 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.

Research and development; de-identification. We may use your personal information for research and development purposes, including to analyze and improve the Services and our business. As part of these activities, 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.

Marketing. We, along with our service helpers (defined below), may collect and use your personal information for marketing purposes. 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 communications” section below, in which case, we will not collect or use your personal information for marketing purposes.

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.

With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information, including when consent is required by law. Your Tech Helpers may request your consent to use certain of your information for promotional purposes.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Services, such as by remembering your selections and preferences as you navigate the Platform and whether you are logged in when you visit password-protected areas of the Platform.

• Functionality. To enhance the performance and functionality of our Platform and Services.

Analytics. We may use your personal data for analytics purposes, such as to help us understand user activity on the Services, including which pages are most and least visited and how users move around the Services, as well as user interactions with our emails. We may also use your personal data for business analytics purposes, such as helping us build and scale our Services. We use Google Analytics for such purposes; you can learn more about how Google Analytics collects and uses data by visiting https://policies.google.com/technologies/partner-sites.

We also use Google APIs, which are application programming interfaces developed by Google that allow communication with Google Services and their integration with other services. Examples of these include Google Calendar, Search, Gmail, Translate, and Google Maps. Google APIs also provide analytics functions. Our use and transfer to any other site or app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. You can learn more about Google APIs and read this policy by visiting https://developers.google.com/terms/api-services-user-data-policy.

How we will NOT use your personal information

We do not sell your identifiable personal information to others. We will not sell your personal information to third parties without your consent.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

How we share your personal information

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

Helpers. We will share Clients’ information with Tech Helpers to facilitate access to and receipt of Sessions and other services from Tech Helpers.

Clients. We will share Tech Helper information with Clients to facilitate access to and receipt of Sessions and other services Clients may choose to receive from Tech Helpers.

Service helpers. We may share certain information with third parties that provide services on our behalf or help us operate the Services or our business (such as hosting, customer support, email delivery, marketing, consumer research, and website analytics).

Payment processors. Any payment card information you use to make a purchase on our Platform is collected and processed directly by our payment processors, Stripe. Stripe may use your payment data in accordance with its privacy policy.

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

Authorities and others. We may share certain information with law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. We have the right to share your data with or transfer it to acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Waltz (including in connection with a bankruptcy or similar proceeding).

Your choices

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.

Opt out of marketing communications. You may opt out of marketing-related communications 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.

We cannot offer any assurances that the third parties we work with participate in the opt-out programs described above.

Do Not Track. Some internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to Do Not Track requests[15] . To find out more about Do Not Track, please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain Services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those Services.

Other sites and services

The Services may contain links to websites, mobile applications, and other online services operated by third parties. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Security

We follow generally accepted standards, practices, and procedures to protect the personal information we collect, both during transmission and once it is received. We maintain appropriate technical, administrative, and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, disclosure, or misuse.

However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information beyond the protections we employ to the greatest extent of our ability.

Children's Privacy

The Services are not intended for use by anyone under 18 years of age or the applicable age of majority in a particular state or jurisdiction unless an account is created by a parent or guardian. If we learn that we have collected personal information through the Platform 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.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Policy, we will notify you by updating the date of this Policy and posting it on our website or through other appropriate means . Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Services after the effective date of any modified Policy indicates your acceptance of the modified Policy.

How to contact us

• Email: [email protected]

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

• Phone: 844-629-2589