Privacy Policy

1. Scope and Overview

This Privacy Policy (the “Policy”) describes how Waltz Marketing Inc. (“Waltz,” “we,” “us,” or “our”) collects, uses, discloses, retains, and protects personal information when you visit mywaltz.com, use app.mywaltz.com, create an account, communicate with us, or use Waltz websites, applications, Walter AI, website and landing-page tools, image and design tools, CRM and lead-management tools, email and marketing automation, analytics and heatmaps, booking and scheduling, Managed Services, and related offerings (collectively, the “Services”).

This Policy applies to personal information that Waltz handles as a business or controller. It also explains Waltz’s role when we process personal information on behalf of a customer. It does not apply to a customer’s own privacy practices, third-party websites or services that Waltz does not control, or employment applicant and workforce information governed by a separate notice.

This Policy should be read with the Waltz Terms and Conditions and Cookie Policy. If a customer has a written agreement or Data Processing Addendum (“DPA”) with Waltz, that agreement controls to the extent it conflicts with this Policy for customer-controlled data.

2. Who We Are and Our Privacy Roles

2.1 Waltz as Business or Controller

Waltz is the business or controller for personal information we determine how and why to use, including information about website visitors, account owners and authorized users, prospects, business contacts, subscribers, and people who contact Waltz for support, sales, billing, security, or legal matters.

2.2 Waltz as Service Provider or Processor

A customer controls the personal information it or its users upload, create, collect, or manage through the Services, including CRM records, leads, contact lists, form submissions, booking information, campaign recipients, website visitor data, and other Customer Content (“Customer-Controlled Data”). For that data, the customer is generally the business or controller and Waltz is generally its service provider or processor. Waltz processes Customer-Controlled Data according to the customer’s instructions, the applicable agreement and DPA, and law.

If you are an end user, lead, customer, employee, or website visitor of a Waltz customer, direct privacy requests first to that customer. Waltz may refer or transmit your request to the customer and will assist the customer as required by contract and law.

3. Personal Information We Collect

The information we collect depends on how you interact with the Services and which features you or a customer enable.

Account and identity information. Name, username, business name, title, role, account identifiers, profile details, login information, and authentication records.
Contact information. Business or personal email address, phone number, mailing address, and communication preferences.
Subscription, transaction, and billing information. Plan, Credits, order, invoice, payment status, billing contact, purchase history, and tax information. Payment processors, rather than Waltz, generally receive complete payment-card details.
Customer Content and AI information. Prompts, instructions, text, documents, images, logos, audio or other files, website content, code, brand information, AI-generated Output, feedback, and related context supplied to Walter AI or other generative features.
CRM, lead, and campaign information. Contact and lead records, email lists, form responses, customer notes, pipeline status, segments, campaign content, delivery events, opens, clicks, unsubscribes, bounces, complaints, and consent or suppression records.
Website, booking, and analytics information. Website and landing-page content, domain and publishing settings, form submissions, appointment details, traffic sources, page views, clicks, scrolling, cursor movement, navigation, referral URLs, conversion events, and other interaction data used for dashboards or heatmaps.
Device, usage, and log information. IP address, approximate location derived from IP, browser and device type, operating system, language, timestamps, pages and features used, session identifiers, performance information, errors, diagnostics, and security events.
Support, sales, and communications. Messages, call or meeting details, survey responses, support tickets, attachments, and other information you provide when communicating with us.
Connected-service information. Information received from or sent to integrations, authentication providers, social platforms, advertising platforms, domain providers, email services, calendars, payment providers, and other services you connect or authorize.
Cookies and similar technologies. Cookie identifiers, pixels, local storage, session data, analytics events, and advertising or attribution information, as described in Section 9 and the Cookie Policy.
Inferences and derived information. Information reasonably inferred from the data above, such as account health, feature preferences, likely interests, audience segments, campaign performance, fraud risk, or suggested marketing actions.

3.1 Sensitive Information

The core Services do not require government identification numbers, precise geolocation, health information, biometric identifiers used for identification, financial-account credentials, or other highly sensitive information. Please do not place such information in prompts, Customer Content, CRM fields, forms, or campaigns unless it is necessary, lawful, covered by your agreement with Waltz, and protected by appropriate notices, consent, and safeguards. Account credentials and the contents of certain communications may be treated as sensitive personal information under some laws.

4. Sources of Personal Information

Waltz may obtain personal information from:

you, when you visit, register, subscribe, buy Credits, use features, connect services, or communicate with us;
your employer, organization, account owner, administrator, teammate, or another person who invites or authorizes you;
Waltz customers and their websites, forms, CRM records, campaigns, booking pages, uploaded lists, and other Customer Content;
your browser, device, and use of the Services through logs, cookies, pixels, analytics, and similar technologies;
connected services and service providers, such as authentication, payment, hosting, analytics, email-delivery, advertising, and AI providers; and
publicly available and business sources, referrals, events, and partners, particularly when you ask for Managed Services or sales assistance.

5. How We Use Personal Information

Depending on the context and our role, Waltz may use personal information to:

provide, host, operate, configure, personalize, and maintain the Services;
create and manage accounts, authenticate users, process subscriptions and Credits, issue invoices, and support transactions;
process prompts and Customer Content, generate Output, run websites, manage leads, deliver campaigns, schedule appointments, and provide analytics or Managed Services;
communicate about accounts, transactions, security, support, service changes, and requested demonstrations or information;
measure performance, troubleshoot, test, research, develop, and improve the reliability, usability, and safety of the Services;
generate aggregated or deidentified analytics, benchmarks, and service insights;
market Waltz products and services, measure referrals and campaigns, and personalize communications where permitted by law;
detect, investigate, and prevent fraud, abuse, security incidents, unlawful activity, and violations of our agreements;
protect rights, safety, property, users, Waltz, and the public;
comply with law, valid legal process, tax and accounting duties, and enforceable government requests; and
establish, exercise, or defend legal claims, enforce agreements, complete corporate transactions, and administer our business.

6. AI Features, Prompts, Output, and Model Improvement

When you use Walter AI or another AI-enabled feature, Waltz and its AI and infrastructure providers may process prompts, files, contextual information, account and usage data, and generated Output to provide the requested feature; maintain context and history; detect abuse; troubleshoot; improve quality and safety; and comply with law. AI Output may be reviewed by authorized personnel when reasonably necessary for support, security, safety, or quality control, subject to access controls and confidentiality obligations.

Waltz may use aggregated, deidentified, or otherwise non-identifiable information to analyze and improve the Services and develop models, features, and benchmarks. Waltz will not use identifiable Customer-Controlled Data or private Customer Content to train generalized AI models unless the customer or user affirmatively opts in through a clear in-product choice or a separate written agreement authorizes that use.

Third-party AI model providers process information under their terms with Waltz. Do not enter information you are not authorized to disclose. Where available, account or product controls may allow you to manage history, connected sources, or optional improvement uses.

7. Customer-Controlled Data

Customers decide what personal information they collect through Waltz-built websites, landing pages, forms, bookings, CRM, email campaigns, analytics, heatmaps, and other tools. Customers are responsible for their own lawful basis, notices, cookie and consent tools, data-subject request handling, marketing permissions, retention settings, and compliance with sector-specific rules.

Waltz does not independently control a customer’s reasons for processing Customer-Controlled Data. We may process that data to deliver the Services, follow documented instructions, protect the Services, comply with law, and perform other activities allowed for service providers or processors. We do not sell Customer-Controlled Data or use it for cross-context behavioral advertising on our own behalf.

Customers should configure forms and heatmaps to avoid collecting passwords, payment-card security codes, health information, government identifiers, precise location, information about children, or other sensitive fields unless expressly supported and lawfully configured.

8. How We Disclose Personal Information

Waltz may disclose personal information to the following categories of recipients for the purposes described in this Policy:

Service providers and subprocessors. Providers of cloud hosting, content delivery, authentication, security, fraud prevention, analytics, payment processing, customer support, communications, email delivery, domain and website services, AI models, development, and professional services. They receive information needed to perform services for Waltz and are subject to contractual restrictions where required.
Customers, account owners, and administrators. Organizations may access and manage information associated with their workspaces, authorized users, Customer Content, leads, and end users. Administrators may control accounts, permissions, integrations, exports, retention, and deletion.
Connected services and user-directed recipients. When you connect a service, publish a website, launch a campaign, share Output, or otherwise direct a disclosure, information is sent to the selected provider, audience, recipient, or public location.
Professional advisers and business partners. Lawyers, accountants, auditors, insurers, financing sources, and consultants who need information to advise or support Waltz and are subject to appropriate confidentiality duties.
Authorities and protected parties. Courts, regulators, law enforcement, government agencies, rights holders, or other parties when reasonably necessary to comply with law, respond to valid process, enforce agreements, investigate misconduct, or protect rights, safety, and security.
Corporate transaction participants. Actual or prospective buyers, investors, lenders, sellers, successors, and advisers in connection with financing, due diligence, reorganization, merger, acquisition, sale, insolvency, or another corporate transaction, subject to appropriate safeguards.

Waltz may disclose aggregated or deidentified information that cannot reasonably identify an individual. Waltz will not attempt to reidentify deidentified data except to test whether deidentification measures work, as permitted by law.

9. Cookies, Analytics, Heatmaps, and Similar Technologies

Waltz and its providers use cookies, pixels, local storage, SDKs, and similar technologies on Waltz websites and Services. Depending on the context, these technologies may be used for strictly necessary functions, security and authentication, preferences, performance and analytics, heatmaps and product improvement, communications measurement, advertising, and attribution.

You can manage non-essential cookies through the cookie preference tool where available and through browser settings. Blocking some technologies may affect functionality. For more details, review our Cookie Policy.

9.1 Do Not Track and Universal Opt-Out Signals

Because there is no uniform industry standard for browser “Do Not Track” signals, the Services may not respond to them. Where required by applicable law, Waltz recognizes qualifying browser-based universal opt-out signals, such as Global Privacy Control, as a request to opt out of sale, sharing, or targeted advertising for the browser or device that sends the signal. You may need to apply the signal separately to each browser or device.

10. Your Choices

Account information. You may update certain account and profile information through the Services or by contacting Waltz.
Marketing communications. You may unsubscribe through the link in a marketing email or contact us. You may still receive transactional, billing, support, security, or legal messages.
Cookies. Use available cookie settings, browser controls, or a qualifying universal opt-out signal. Necessary technologies cannot be disabled through our preference tool where they are required to provide the Services.
Connected services. You may disconnect integrations through available account or provider settings. The third party may retain information it received under its own policy.
Customer-Controlled Data. Contact the relevant Waltz customer if your information was collected through that customer’s website, form, CRM, booking flow, or campaign.

11. Data Retention

Waltz retains personal information only for as long as reasonably necessary for the purposes described in this Policy, including to provide an account or Service; honor customer instructions; maintain security, backups, suppression lists, and business records; complete transactions; comply with tax, accounting, legal, and regulatory duties; and resolve disputes or enforce agreements.

Retention periods vary by data type, sensitivity, volume, the nature of the relationship, account status, customer configuration, legal requirements, and operational need. After an account ends, Waltz may provide a limited retrieval period where supported. Deletion from active systems may occur after that period, while residual copies may remain temporarily in backups or longer when required for legal holds, security, fraud prevention, billing records, or compliance.

Waltz may retain deidentified information without a specific time limit when it no longer reasonably identifies an individual. Email suppression records may be retained to honor opt-outs. Customers control retention of Customer-Controlled Data within available product settings and their agreement with Waltz.

12. Security

Waltz uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, use, alteration, disclosure, or destruction. Measures may include access controls, authentication, encryption in transit and at rest where appropriate, monitoring, backups, incident response, vendor review, and personnel confidentiality obligations.

No system, network, or storage method is completely secure. You are responsible for using strong, unique credentials, protecting authentication methods, limiting permissions, reviewing integrations, and promptly notifying Waltz of suspected unauthorized access. Waltz will provide legally required notices of a qualifying security incident.

13. International Processing and Transfers

Waltz is based in the United States, and personal information may be processed in the United States and other countries where Waltz, its affiliates, customers, and providers operate. Those countries may have privacy laws different from those where you live.

Where applicable law requires a transfer mechanism, Waltz may rely on adequacy decisions, the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum or other approved clauses, contractual protections, or a permitted legal exception. You may request information about applicable transfer safeguards at info@waltzmarketing.com.

14. Children’s Privacy

The Services are designed for businesses and adults and are not directed to children under 13. Waltz does not knowingly collect personal information directly from a child under 13 without legally required parental consent. If you believe a child has provided personal information to Waltz in violation of this Policy, contact us so we can investigate and take appropriate action.

Customers may not use the Services to collect, profile, sell, share, or use personal information of minors in violation of law. Waltz does not knowingly sell or share personal information of consumers under 16 for cross-context behavioral advertising. Where a state requires consent for targeted advertising or sale involving an older minor, the customer and Waltz will follow the applicable age and consent requirements for their respective roles.

15. Privacy Rights and Requests

Depending on your location and applicable law, you may have rights to confirm whether we process your personal information; access or obtain a copy; correct inaccuracies; delete information; receive portable data; restrict or object to processing; withdraw consent; opt out of targeted advertising, sale, sharing, or certain profiling; limit certain uses of sensitive information; appeal a denied request; and receive equal service without unlawful discrimination. These rights are subject to legal conditions and exceptions.

To submit a request concerning personal information Waltz controls, email info@waltzmarketing.com with the subject “Privacy Request” and describe the right you wish to exercise. We may ask for information reasonably necessary to verify your identity, authority, account, state or country of residence, and the information involved. We will use verification information only for the request and related recordkeeping.

An authorized agent may submit a request where permitted by law. We may require proof of the agent’s authority and, where allowed, confirmation directly from you. If your request concerns Customer-Controlled Data, contact the relevant customer; Waltz will assist that customer as required. We will respond within the period required by applicable law and may extend the period when law permits.

16. Supplemental U.S. State Privacy Notice

This Section supplements the rest of the Policy for residents of states with comprehensive consumer privacy laws, including California, Colorado, Connecticut, Delaware, Florida, Montana, Oregon, Texas, Utah, Virginia, and other states as their laws apply. Rights and definitions vary by state, and this Section applies only when the relevant law applies to Waltz or the processing.

16.1 Categories Collected, Used, and Disclosed

During the preceding 12 months, depending on the interaction and enabled features, Waltz collected and may continue to collect the categories below. Waltz may disclose each category for the business purposes in Section 5 to the recipient categories in Section 8.

Identifiers. Name, alias, username, postal address, unique online identifier, IP address, email address, account identifiers, or similar identifiers.
Customer-record information. Contact, account, subscription, billing, transaction, and customer-service information.
Commercial information. Purchases, subscriptions, Credits, preferences, campaigns, products or services considered, and transaction history.
Internet or electronic-network activity. Browsing, search, interaction, device, log, cookie, analytics, heatmap, campaign, and security data.
Approximate geolocation. General location inferred from IP address. Core web Services do not intentionally collect precise geolocation unless a feature, connected service, or user-provided content supplies it.
Audio, electronic, visual, or similar information. Images, designs, recordings, files, and other media submitted to or generated through the Services.
Professional or employment-related information. Employer, business, title, role, professional profile, and business communications.
Inferences. Preferences, segments, likely interests, feature recommendations, campaign insights, account health, or security and fraud indicators derived from other information.
Sensitive personal information. Account login credentials and, if a user chooses to provide it, contents of certain communications or Customer Content that applicable law treats as sensitive. Waltz does not use sensitive personal information to infer characteristics except as permitted or directed by the customer.

Waltz does not intentionally collect biometric information for unique identification through the core Services. We do not use or disclose sensitive personal information for purposes that require a California right-to-limit notice unless we provide that notice and choice.

Waltz does not sell personal information for money. Some privacy laws define “sale,” “sharing,” or “targeted advertising” broadly enough to include making identifiers, device data, or internet activity available to advertising, analytics, or attribution partners through cookies or similar technologies. To the extent such activity occurs and is covered by law, the relevant categories may include identifiers and internet or electronic-network activity, and recipients may include advertising, analytics, and attribution partners.

You may opt out through the cookie preference tool where available, a legally recognized universal opt-out signal, or a request to info@waltzmarketing.com. Waltz does not knowingly sell or share personal information of consumers under 16. Waltz does not sell Customer-Controlled Data or use it for targeted advertising on Waltz’s own behalf.

16.3 State Rights, Appeals, and Non-Discrimination

Subject to applicable law, you may exercise the rights described in Section 15. If we deny a request and your state provides an appeal right, reply to the denial within 60 days with the subject “Privacy Appeal” and explain why you believe the decision should be reconsidered. We will provide the result and any method to contact the appropriate regulator when required.

Waltz will not unlawfully discriminate against you for exercising a privacy right. A request may affect a feature when the information is necessary to provide it. We may deny or limit a request where we cannot verify it, an exception applies, another person’s rights would be affected, or the request is manifestly unfounded or excessive, and we will explain the decision when required.

16.4 California-Specific Information

California residents may have rights to know the categories and specific pieces of personal information collected; know sources, purposes, and recipient categories; delete or correct information; opt out of sale or sharing; limit certain uses of sensitive personal information; access information about certain automated decisionmaking technology where applicable; and receive non-discriminatory treatment.

Waltz does not offer a financial incentive or price or service difference in exchange for personal information unless it provides a separate Notice of Financial Incentive. California’s “Shine the Light” law may allow eligible residents to request information about disclosure of personal information to third parties for their own direct-marketing purposes. Requests may be sent to info@waltzmarketing.com.

16.5 Automated Decisionmaking and Profiling

Waltz uses AI and automation to generate content, recommend marketing actions, organize leads, detect fraud or abuse, and improve workflows. Waltz does not use solely automated processing to make legal or similarly significant decisions about an individual in Waltz’s direct relationship with that individual. A customer may configure its own workflows or use Output in decisions; that customer is responsible for notices, human review, opt-outs, assessments, and other requirements that apply to its decision. If Waltz begins covered automated decisionmaking in its controller role, it will provide legally required pre-use notice and rights.

17. EEA, United Kingdom, and Switzerland

17.1 Lawful Bases

Where the European Economic Area (“EEA”), UK, or Swiss privacy laws apply and Waltz acts as controller, Waltz relies on one or more lawful bases: performance of a contract or steps requested before a contract; legitimate interests in operating, securing, supporting, improving, and marketing the Services and administering the business; consent; and compliance with legal obligations. Where processing relies on consent, you may withdraw it at any time without affecting earlier lawful processing.

Our legitimate interests may include providing a reliable business platform, understanding and improving use, protecting users and systems, preventing fraud, communicating with business contacts, and promoting Waltz. We balance those interests against the rights and expectations of affected individuals.

17.2 Rights

Subject to applicable law, you may request access, correction, deletion, restriction, portability, or objection. You have an absolute right to object to direct marketing. You may also withdraw consent and lodge a complaint with the data-protection authority where you live or work or where you believe an infringement occurred. UK residents may contact the Information Commissioner’s Office.

Waltz does not make solely automated decisions in its controller role that produce legal or similarly significant effects on individuals. Contact info@waltzmarketing.com for questions about our legal bases, legitimate-interest assessments, transfers, or rights.

18. Third-Party Services and Public Content

The Services may link to or integrate with third-party websites, platforms, models, payment providers, advertising networks, calendars, social media, email services, and other providers. Their handling of personal information is governed by their own terms and policies when they act independently. Review those policies before connecting or directing information to a third party.

Information you publish through a website, landing page, campaign, public link, directory, social post, or other public feature may be accessible, indexed, copied, or redistributed by others. Do not publish personal information unless you have authority and an appropriate lawful basis to do so.

19. Changes to This Policy

Waltz may update this Policy to reflect changes in law, technology, Services, vendors, or business practices. The updated version will show its effective or last-updated date. We will provide additional notice of material changes when required, such as through the Services, email, or a prominent website notice. If law requires consent for a new use, we will obtain it before that use.

20. Contact Waltz

Questions, complaints, requests, and inquiries about this Policy or Waltz’s privacy practices may be sent to:

Waltz Marketing Inc.
401 Park Ave S
10th Floor
New York, NY 10016
Email: info@waltzmarketing.com
Phone: 888-750-4240
Website: https://mywaltz.com

For privacy requests, use the subject “Privacy Request.” For an appeal of a denied state-law request, use the subject “Privacy Appeal.” For requests about Customer-Controlled Data, identify the relevant Waltz customer, website, form, or campaign when possible.