Privacy policy of Waller & Company

Effective Date:  July 1, 2019

Last Modified Date: August 1, 2019

1. General

Waller & Company (hereinafter: Company) is committed to safeguarding the privacy of visitors of Company's websites, social media and other tools for communication (hereinafter: Website), and of users of services provided by Waller & Company. The parties referred to in this Policy are Waller & Company, owner and operator of the Website and you, as a visitor of it (hereinafter: User), as well as user of Company's services (hereinafter: Client).

In this Privacy Policy (hereinafter: Policy), it is explained how the information of Users and Clients is collected, used, retained and secured. 

The Company processes information of a personal and non-personal nature. The term “Personal Information” means any information that could directly identify a User or a Client, such as name, email address, date of birth, contact details, social media account information. Moreover, an IP address of a device and the location of accessing the Website, as non-personal information, linked with other data identifiers may represent personal information. 

By using the Website or by otherwise giving us your Personal Information, you are expressly consenting to the Company's use of your Personal Information, regardless of when it was obtained or captured and accepting the practices described in this Policy. If you do not agree to this Policy, please do not use the Website or provide any of your Personal Information.

2. Amendments of This Policy

We reserve the right to amend or modify this Policy and our other policies at any time and in any manner. You should periodically check for any modifications of this Policy by re-visiting this web page. The date of the last version of this Policy appears at the top of this Policy. The updated or edited version supersedes any prior versions immediately upon posting.

3. Types of Collected Information 

The Company collects, processes and uses the information of personal and non-personal nature.

Personal Identification Information, such as name, address, date of birth, gender, contact details, email, phone number, social media account is provided to the Company by User or Client in terms of creating a profile, subscription, asking a question about Company's services and through social media. IP Address is recorded when the User visits the Website. An IP address can be considered as personal and non-personal information, depending on its correlation with other personal data, such as logs and other identifiers. 

Non-Personal Information is collected through cookies or other features for the functioning of the Website and tracking services. Non-Personal Information is aggregated number of visits of the Website, number of visits of specific pages on the Website, geographic location, browser and session information, etc. This information is not tied to User or Client identity nor for other information we collect, for which reason is defined as a non-personal. 

Recruiting information, collected in a process of engaging third parties to perform tasks under instructions of the Company, is information included in a resume or application, such as employment and educational background, personal interests and activities, name, email address, phone number, and residence address. 

The Company does not collect sensitive categories of personal information. This website is not directed at children and the Company does not purposely collect information of children under 16 years of age. The Company shall use its best endeavors to prevent the collection of information of such children. However, in case of doubts, parents or guardians of children under the age of 16 should contact the Company to request clarification and deletion of Personal Information from systems.

4. How Information Is Collected

Personal Identification Information is provided by Users or Clients directly through filling out the form for new Clients, subscription on the Website or submission of it through email and other digital, analog or audio format. Personal Information made publicly by Clients or Users may be collected through third parties sites, such as social media.

Non-Personal Information is recorded by placing cookies on Users computers when the Website is visited. This information is anonymous and used for the improvement of site navigation, maintenance of the Website, tracking of visitor preferences, provision of analytics reports and assist in identifying possible fraudulent activities. Cookies are placed on the Website only by third parties, such as Squarespace, as a service provider, to run the Website effectively. The Company does not place its cookies for monitoring of Users' or Clients' behavior. Third-party cookies are regulated by the privacy policy of the companies who place them on the Website, thus Users and Clients are encouraged to read and understand third party website’s policies and procedures.

Moreover, the Website includes social media features, such as the Facebook and Twitter buttons and widgets, such as the Share button, which tools may place cookies, to enable them to function properly. Also, it may contain advertisements in the form of banners/links to third party sites. Such third party sites, as well as social media and advertisements providers, define their policies and procedures (terms of use, privacy policy, etc.) that are different from this Policy and other Company's policies. Users and Clients are encouraged to read and understand third party website’s policies and procedures.

The Company may process Users, Clients or third parties information by application of automated decision-making. The Company may use machine learning algorithms in a case when the analysis is necessary for the fulfillment of contractual obligations under Clients' agreements. For this purpose, the Company may monitor and analyze the public activities of third parties on social media sites, including posts, blogs, tweets, and profile information, including such social media messages directed at our Clients.

This Website does not have the capability of recognizing all web browser Do Not Track request (Do Not Track Disclosure). 

5. How Collected Information is Used

The information collected by the Company shall be used for the limited purpose of providing the Website's services and Company's services to the Clients.

Personal Identification Information is used for:

  • providing services to the Clients and Users

  • marketing and/or promotional activities, such as sending newsletters and proposals

  • placing personalized advertisements

  • choosing the best candidate, in the case of the recruitment process.

Cookies, as tools for collection of Non-Personal information, are used for:

  • proper functioning of the Website and diagnostic of problems with the server

  • customization of experience of Users on the Website 

  • statistics and monitoring the use of the Website and its popularity. 

The Company does not transfer Users` and Clients` information to third parties, nor sell, rent or provide any of this information to other entities such as advertisers, or other companies selling services similar to this Company’s services.

6. Users' and Clients' Rights

The Users and Clients may use the following Rights related to collected Personal Information: 

  • right to access is the right to know what Personal Information is collected

  • right to rectification is the right to request amendments of retained Personal Information

  • right to erasure is the right to ask us to delete Personal Information from our systems

  • right to restriction of processing is the right to request limited processing of Personal Information

  • right to object is the right to oppose to the use of Personal Information.

7. Retention of Personal Information 

The Company will retain your Personal Information for the period of subscription or provision of Services. If you wish to cancel your subscription or request that we no longer use your Personal Information to provide Services, please contact us on team@wallerandcompany.com.

The Company may keep information about Users and Clients on back-up storage for recovery and security purposes for up to twelve (12) months or longer, for alignment with law and statutory obligations. 

8. Disclosure of Personal Information In Special Сases

The Company may disclose information about Users or Clients without notice and approval, including, but not limited to:

  • to satisfy any laws, or governmental or judiciary requests for such information or purposes of law enforcement;

  • to disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Terms and Conditions and other Company's policies and procedures;

  • to facilitate Company's asset sale transaction or reorganization or in the event of bankruptcy or similar event. 

In the event of any of these activities, Users and Clients give their consent to the disclosure, transfer, sell and/or release of their personal information to the respective third party.

9. Our Commitment to Data Security

The Company takes reasonable measures to protect the transmission of all Users and Clients information and applies accepted standards to protect the collected Personal information. Nevertheless, the Company cannot guarantee that security measures will prevent third-party ‘hackers’ from illegally obtaining information. Users and Clients should assume the risk of such attacks to the extent that they occur despite our reasonable security measures.

10. Questions About Our Privacy Policy

If you have any comments or questions about this Policy, the Company's practices or exercise of your rights, you may contact us at team@wallerandcompany.com.