Updated on: January 1, 2021
At Walkthroo, your privacy and data security are our top priority. We strive to be transparent about who we are as well as how we and why we collect, store, use, and share information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). This policy explains your rights regarding your Personal Information and how to contact us or supervisory authorities in the event you have a complaint.
When we collect, use, and take responsibility for certain Personal Information about you, we are subject to various laws in the United States.
By collecting Personal Information, we are responsible as a “controller” for the purposes of those laws. A reference to “Walkthroo,” “we,” “us,” or the “Company” is a reference to Walkthroo LLC. Please see the “Contacting Us” section below for our contact information and the contact information for our data protection officer.
We require certain Personal Information to provide the Walkthroo platform and services to you. If you do not provide the Personal Information that we ask for, it may delay or prevent us from providing the Walkthroo platform to you.
The Personal Information that we may collect directly from you includes the following:
| Categories of Personal Information | Specific Types of Personal Information Collected |
|---|---|
| Identifiers | Name, address, IP address, email address, account name, sign-in, and online identifiers |
| Information that identifies, relates to, describes, or is capable of being associated with, a particular individual | Signature, telephone number, employment information |
| Commercial information | Individual purchases, such as products and services listed in change orders or selections |
| Internet or other electronic network activity information | Browsing history and information regarding interaction with social media profiles, advertisements, and the Walkthroo services |
| Geolocation data | Location information, if enabled |
We may also collect other information that you may provide to us, including the content that you submit, post to, or create within the Walkthroo platform, such as your photos, comments, reviews, searches, photo notes, discussions, project details and costs, and style preferences.
When you communicate with us (via email, phone, through the Walkthroo platform, or otherwise) and when you use our software to communicate with others, we may record, monitor, or otherwise collect details about your communications. We will provide you notice or obtain consent in accordance with applicable law before recording or monitoring any of these calls.
We collect most of this Personal Information directly from you, either through email, telephone, thewalkthroo.com, or the Walkthroo platform. However, we may also collect information about you from other sources, including third parties from whom we have purchased Personal Information, and combine this information with Personal Information provided by you. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. In particularly, we collect Personal Information from the following sources:
We collect and process Personal Information for the purposes and on the legal bases identified in the following:
| Providing our websites and services | We process your Personal Information to perform our contracts with you for the use of our websites and to fulfill our obligations under applicable terms and conditions or terms of use; where we have not entered into a contract with you, we base the processing of your Personal Information on our legitimate interest to operate and administer our websites and to provide you with the content you access and request (e.g., to interact with content from our websites) |
| Promoting the security of our websites and services | To the extent it is necessary for our legitimate interest in promoting the safety and security of the services, systems, and applications, and protecting our rights and the rights of others, we process your Personal Information by tracking use of our websites and services, created aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our term and policies |
| Providing necessary functionality | We process your Personal Information to perform our contract with you for the use of our websites and services; where we have not entered into a contract with you, we base the processing of your Personal Information on our legitimate interest to provide you with the necessary functionality required during your use of our websites and services |
| Managing user registrations | If you have registered for an account with us, we process your Personal Information by managing your user account for the purpose of performing our contract with you according to applicable terms and conditions |
| Handling contact and user support requests | If you fill out a web form or request customer support, or if you contact us by other means including via a phone call, we process your Personal Information to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you |
| Managing payments | If you have provided financial information to us, we process your Personal Information to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you |
| Developing and improving our websites and services | We process your Personal Information to analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and service offerings, or where we seek your valid consent |
| Reviewing compliance with applicable usage terms | We process your Personal Information to review compliance with the applicable usage terms in our customer’s contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms |
| Identifying customer opportunities | We process your Personal Information to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the interests of our customers and their users’ experiences |
| Displaying personalized advertisements | We process your Personal Data to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our websites or, where necessary, to the extent you have provided your prior consent |
| Sending marketing communications | We will process your Personal Information and/or device and usage data, which in some cases may be associated with your Personal Information, in order to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent |
| Complying with legal obligations | We process your Personal Information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests. |
We may share your Personal Information with:
We may also collect, process, and use non-personal, aggregated, or anonymized data in any way, including by disclosing, sharing, or otherwise making it available to third parties for various research, marketing, analytics, and measurement purposes. Additionally, Walkthroo may share such anonymous usage on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show the general use of our services.
Any Personal Information or other information you choose to submit in communities, forums, blogs, or chat rooms on our websites may be read, collected, and used by others who visit these forums.
We only allow our service providers and joint marketing partners to handle your Personal Information if we are satisfied that they take appropriate measures to protect your Personal Information. We also impose contractual obligations on service providers and partners to ensure they can only use your personal information for the purposes outlined in our contracts to provide services to us and to you.
Our websites and services are not directed at children. We do not knowingly collect Personal Information from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Information without your consent, please contact us by using the information in the “Contacting Us” section, below, and we will take steps to delete such Personal Information from our systems.
We may retain your Personal Information for a period of time consistent with the original purpose of collection (see the “Purposes for which we process Personal Information and the legal bases on which we rely” in Section 3, above). We determine the appropriate retention period for Personal Information on the basis of the amount, nature and sensitivity of your Personal Information processed, the potential risk of harm from unauthorized use or disclosure of your Personal Information and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
| Disclosure of Personal Information We Collect About You | You have the right to know: The categories of Personal Information we have collected about you; The categories of sources from which the Personal Information is collected; Our business or commercial purpose for collecting or selling Personal Information; The categories of third parties with whom we share Personal Information, if any; and The specific pieces of Personal Information we have collected about you. Please note that we are not required to: Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or Provide the Personal Information to you more than twice in a 12-month period. |
| Personal Information Sold or Used for a Business Purpose | In connection with any Personal Information we may sell or disclose to a third party for a business
purpose, you have the right to know: The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold; and The categories of Personal Information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your Personal Information. If you exercise your right to opt-out of the sale or disclosure of your Personal Information, we will refrain from selling your Personal Information, unless you subsequently provide express authorization for the sale of your Personal Information. To opt-out of the sale or disclosure of your personal information, please email support@thewalkthroo.com to Opt Out of the Disclosure of Your Personal Information. |
| Right to Deletion | Subject to certain exceptions set out below, on receipt of a verifiable request from you, we
will: Delete your Personal Information from our records; and Direct any service providers to delete your Personal Information from their records. Please note that we may not delete your Personal Information if it is necessary to: Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. |
| Protection Against Discrimination | You have the right to not be discriminated against by us because you exercised any of your rights under
the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your Personal Information. |
As stated above, your privacy and data security are our top priority. We take precautions including organizational, technical, and physical measure to help safeguard against the accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Information we process or use.
While we follow industry best practices to protect your Personal Information, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the information in the “Contacting Us” section, below.
By creating an account and agreeing to our Privacy Policy, you expressly consent to the use of your provided phone number for us to send you text messages, which may include notifications related to your activity on our application, such as job-related updates, account activities, promotions, special offers, and more.
These text messages may be sent via an automatic telephone dialing system. Your agreement to receive such messages is not a condition of any purchase or use of our services. Standard data and message rates may apply whenever you receive a text message from us.
You may opt-out of receiving text messages at any time by updating the settings in your user profile. After opting out, you may still receive non-promotional service-related messages from us.
We take your privacy very seriously. We will only use and store your phone number as described in this Privacy Policy and for no other purpose without your express permission.
We will update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements and other factors. If we do, we will update the “effective date” at the top of this Privacy Policy. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.
We encourage you to periodically review this Privacy Policy to stay informed about our collection, processing, and sharing of your Personal Information.