October 2021

The Walters Group website and our mobile applications (collectively, the “Site”) is a service of TWGRP LLC. We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use the Site. This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information (defined below). By accessing or using the Site, you consent to this Privacy Policy.

WE MAY REVISE THIS PRIVACY POLICY AT ANY TIME. WHEN WE DO, WE WILL ALSO REVISE THE “LAST UPDATED” DATE AT THE TOP OF THIS PRIVACY POLICY. YOU ARE RESPONSIBLE FOR REGULARLY REVIEWING THE CURRENT PRIVACY POLICY. THE MOST CURRENT VERSION OF THE PRIVACY POLICY CAN BE REVIEWED BY CLICKING ON THE “PRIVACY POLICY” LINK LOCATED AT THE BOTTOM OF OUR WEB PAGES. YOUR CONTINUED USE OF THE SITE AFTER WE POST ANY REVISIONS TO THE PRIVACY POLICY CONSTITUTES YOUR AGREEMENT TO ANY SUCH REVISIONS.

We welcome your comments regarding this Privacy Policy. Please send any comments to us by email at info@thewaltersgrp.com.

The Walters Group (TWG) values your privacy. We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use the TWG website and mobile applications (collectively, the “Site“) or TWG services (“Services“). This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information. By accessing or using the Site or Services, you consent to this Privacy Policy.

1.   Managing Your Information Preferences

You can review, correct, update, or change your Personal Information (defined below) or opt out of receiving certain e-mails by changing the relevant settings in your TWG profile or account or by e-mailing us at info@thewaltersgrp.com. If you have questions or concerns regarding this Privacy Policy, please e-mail us at info@thewaltersgrp.com.

2.   Information We Collect

Personal Information

We collect information that personally identifies you, such as your name, address, phone number, e-mail, information you submit for inquiries, such as loan inquiries, information you submit through loan applications, and other personally identifiable information that you choose to provide us with or that you choose to include in your TWG account (“Personal Information“). You may be asked to provide us with Personal Information when you register with the Site or use any of our Services, and at other times.

We may also collect Personal Information from the following sources:

• Social media websites and services;
• Loan applications;
• Personal financial statements;
• Tax returns;
• Credit reports;
• Partnership agreements;
• Searches on google.com;
• Client events, including webcasts; and
• Other sources.

The decision to provide Personal Information to us is optional; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services.

Usage Data and Site Activity

We automatically collect information regarding the actions you take on the Site (“Usage Data“). For example, each time you use the Site we automatically collect the type of web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits to the Site. We use this information to help us understand how people use the Site and Services, and to enhance the services we offer.

Cookies and Other Tracking Technologies

We use cookies (a small text file placed on your computer to identify your computer or device and web browser). We use cookies to improve the experience of the Site and Services, such as pre-populating your username for easier login. We do not use cookies to collect Personal Information. From time to time, TWG and its Service Providers (defined below) track your online activity on the Site. TWG and those third party providers will at times associate that tracking information with information that can identify you, an account belonging to you, or your device or with information that can be used to contact you.

Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Certain features of the Site or Services may not work if you delete or disable cookies. Some of our Service Providers may use their own cookies or other tracking technologies in connection with the services they perform on our behalf.

3.   How We Use Information and When We May Share and Disclose Information Generally

Except as otherwise stated in this Privacy Policy, we use Personal Information for internal purposes only, such as to provide you with the Site and Services, to provide you with Services that you request, to process and evaluate a job application that you submit, to improve the Site and Services, to notify you of new products or services offered by TWG and its affiliates, and to otherwise communicate with you about TWG and its affiliates. We may share your Personal Information with third parties as necessary to provide services requested by you, such as in response to a loan inquiry or application or to send you a research report in response to an inquiry from you.

We may share your Personal Information with the following entities to provide services that you request:

• Commercial banks;
• Investment banks;
• CMBS aggregators/issuers;
• Private and public funds;
• Fannie Mae, Freddie Mac, and HUD;
• Mortgage bankers;
• Insurance companies;
• Private lenders;
• Other third party vendors; and
• The Walters Group and Re/Max Select sales agents.

We will not disclose Personal Information to third parties, including for their direct marketing purposes, without your consent, except as explained in this Privacy Policy. We may disclose to third parties for ours and others’ marketing purposes, certain Usage Data regarding the Site and Services. However, in such cases, your Usage Data is aggregated with the usage data of others and does not identify you individually.

4.   Service Providers

From time to time, we may establish a business relationship with other businesses we believe to be trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers“). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices appropriate to the nature of the information involved in order to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by TWG.

5.   Access to Personal Information and Retention of Your Personal Information

TWG provides access to your Personal Information to TWG employees and contractors, such as originators, processors, and closers, in order to provide you with the services that you request.  Once we complete providing services that you request, we may retain certain of your Personal Information and we may contact you from time to time as detailed in this Privacy Policy.  After a certain period of time, we may destroy certain information and files we have about you.

6.   Other Transfers

We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with TWG. If TWG is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our discretion, the new entity plans to handle your information in a way that differs materially from this Privacy Policy.

7.   Compliance with Laws and Law Enforcement

TWG cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of TWG or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

8.   Security

We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.

9.   Links To Other Websites

Our Site and Services may contain links to other websites or allow others to send you such links. A link to a third party’s website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.

10.   Children’s Privacy

The Site and Services are intended for users who are 18 years old or older. We do not knowingly collect Personal Information from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.

11.   Processing in the United States and Elsewhere

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store information in the United States, in addition to other jurisdictions, including Canada. The laws in the United States may not be as protective of your privacy as those in your location. By using the Site or Services, you agree that the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.

12.   Privacy Policy Changes

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will go into effect on the “Revised” date shown in the revised Privacy Policy. By continuing to use the Site or Services, you consent to the revised Privacy Policy.