Last Updated: December 26, 2023
Walker & Dunlop, Inc. together with its subsidiaries (collectively, or individually as applicable, referred to as "Walker & Dunlop,” “we,” “our,” or “us”) recognize the importance of your privacy rights. This global Corporate Privacy Policy and Cookie Notice (“Notice”) explains who we are, our data collection and handling practices, and how individuals with privacy rights under law (“you” or “your”) can exercise those rights when personal information is collected or processed related to:
Please carefully review this Notice. To the extent permitted by applicable law, by using the Services or having Professional Interactions with us, you are agreeing to the terms of this Notice. Moreover, if you provide personal information of someone other than you, you are responsible for complying with all applicable privacy and data protection laws for the personal information provided, including obtaining consent for us to process the personal information, in accordance with this Notice.
You may choose not to provide your personal information to us. However, by withholding certain personal information, you may not be able to use our Services, receive our Services or otherwise have Professional Interactions with us. The provision of your personal information may be necessary to allow us to perform a contract with you or your company and/or to provide Services to you or your company. If a company provides your personal information to us to fulfill a contract, provide the Services, or enable Professional Interactions, while you can make a request to Walker & Dunlop regarding your personal information, we may direct you to the entity that provided your personal information to us for processing.
We may update this Notice from time to time, and you should review this Notice periodically. Please note that some privacy rights and obligations may differ in certain locations based on applicable local data protection laws. We have included supplemental information for certain jurisdictions in this Notice.
Table of Contents
Information We Collect and Process and Sources
2. Sensitive Personal Information
How Walker & Dunlop Uses Your Personal Information
Disclosure of Personal Information
Requesting Access to Personal Information and Other Rights
When Acting As a Registered Adviser
Cookie Policy and Similar Tracking Technology
California Consumer Privacy Policy (“California Policy”)
Personal Information We Collect and Sources: We collect personal information about your use of the Services and Professional Interactions such as Contact Information, Registration Data (such as username/account number), Professional Information (such as job title, industry, employer), Business Relationship Information (such as your primary Walker & Dunlop contacts), Social Media Information and Cookie, Device and Web Analytics Information. We collect this personal information from you or your devices, from publicly available websites, our business partners and from third parties. We may aggregate information to create new information that does not identify a specific individual.
Use and Legal Bases: We use your personal information to make the Services accessible to you, to communicate with you, to have Professional Interactions with and provide marketing to you, to improve our Services, and to fulfill other commercial or business-related purposes.
Data Sharing: The personal information we collect or you provide may be shared and processed as necessary with other Walker & Dunlop entities, including those better suited to respond to your request and to provide you with access to the Services. We may also share your personal information with others like service providers who assist us with IT and data hosting, marketing, and legal and regulatory compliance, with joint venture partners, and with public authorities where required by law.
International Data Transfers: We may share your personal information with other Walker & Dunlop entities and others located outside of your home country. When doing so, we use safeguards for international data transfers as required by applicable law.
Data Security: We implement technical and organizational security measures designed to safeguard the personal information we collect and process against loss and unauthorized alteration or disclosure.
Privacy Rights: Depending on the legal regulations in your country, you may have certain rights to request access, rectification, deletion or other actions regarding your personal information. See details below, including how to exercise any privacy rights you may have under applicable law.
Changes to This Notice: If we make any material changes to this Notice, we will make changes here. Where required, we will obtain your consent.
Contact Walker & Dunlop: You are always free to contact us if you have questions or concerns regarding this Notice, have a question or problem related to your use of the Services, our Professional Interactions or wish to exercise your rights.
When Acting As a Registered Adviser: To the extent we are acting as a registered adviser to you or your representative, additional regulations may apply to the handling of your personal information. Please visit https://www.wdinvestmentpartners.com/privacy-policy/ for more information on your rights when receiving our Services or having Professional Interactions with us in our registered investment adviser capacity.
Cookie Policy and Similar Technology: We use Cookies on parts of the Services, and you can restrict our use of Cookies other than Required Cookies.
California Consumer Privacy Policy: Additional disclosures required under California law to be made to individuals who are residents of California, including relating to applicable privacy rights, are provided in Walker & Dunlop’s California Consumer Privacy Policy.
To the extent permitted by applicable law, your use of the Services or engagement in Professional Interactions with us signifies your understanding and acceptance of the terms of this Notice.
Third parties that link from or to our Services, or from whom we collect personal information may have their own privacy policies and practices. This Notice does not apply to sites or applications offered by other companies or individuals, including third party products and services that may be displayed as content in a search on our website. Please review any third-party policies to learn more about their practices.
To the extent a notice provided at the time of collection from a website or specific Service conflicts with this Notice, the terms of that specific notice or supplemental privacy statement will apply. Similarly, if you enter into a separate agreement with us which requires, or contemplates collecting, sharing, transferring, using or otherwise processing information about you in a manner that is different than that which is described in this Notice, the terms of that agreement will apply.
Walker & Dunlop is a provider of commercial real estate services. It is based in Bethesda, Maryland. For more information about Walker & Dunlop, please see our About Us page.
Below is a summary of the categories of Personal Data we collect, process, and in some cases share and disclose. This Personal Data which may be provided by you (either to us directly or online), your devices, from publicly available websites, our business partners or potentially from other third parties, including your company or employer as applicable. We may obtain information from third parties who share personal information they collect with us for research or marketing purposes.
Contact Information such as your name, postal or email address, phone number, online handle, or alias. This information may be provided by you or third parties. The third parties who collect and share your Contact Information with us may include your employer, operators of property listing and other websites, and other business partners. These third parties are independently responsible (also referred to as an independent data controller in some jurisdictions) for the collection and processing of your Contact Information for their own, independent purposes. We refer you to their privacy notices to understand their privacy practices and how to exercise any rights you may have.
Registration Data such as newsletter requests, event/seminar registrations, subscriptions, downloads, username and account set up information.
Professional Relationship Information such as business contact information, industry, job title or role, your primary Walker & Dunlop contacts and record of interactions with Walker & Dunlop, information you provide to us which assist us in serving the business relationship, such as the types of investments you are interested in, and information you provide about your personal life. This may include demographic and commercial information (information about your properties or yourself that you provide) and inferences reflecting your preferences, predispositions, behavior, and attitudes drawn from the information we collect from visits to our websites, use of our applications, interactions with our tools, or other use of the Services or Professional Interactions with us.
Business Relationship Information such as loan origination and servicing documents, information related to creditworthiness, records of property and operating information, or records of products or services purchased, obtained, or considered. This may include demographic, commercial information or customer record information (information about your properties or yourself, or the services you are seeking).
Troubleshooting Data such as calls or requests to us that you place to us when using the Services, or technical information related to your user experience of our Services. All telephone communications with us or our authorized agents may be monitored or recorded.
Cookie, Device, and Web Analytics Data such as your Computer Internet Protocol (IP) address, geo-location data, browser settings and similar data about the use of the Services, mobile device advertising identifier, calendars and call information, media files, metadata, Cookies and other data linked to a device. We also collect app logs and usage statistics. For more information, see our Cookie Policy and Similar Tracking Technology information below.
Marketing Data such as your interests and preferences in our Services or our events. This information may be provided by you or third parties. The third parties who collect and share your Marketing Data with us may include companies in the business of compiling and selling marketing data and other business partners to whom you have provided your personal information. The third parties who collect and share your Marketing Data with us are independently responsible (also referred to as an independent data controller in some jurisdictions) for the collecting and processing of your Marketing Data for their own, independent purposes. We refer you to their privacy notices to understand their privacy practices and how to exercise any rights you may have.
Social Media Information such as your social media username, profile, statements or opinions about Walker & Dunlop or others in our industry, aggregated usage reports about your interactions with Walker & Dunlop's social media accounts, and content of your interactions with Walker & Dunlop-operated social media. This information may be provided by you or based on your interactions with third-party social media sites (including Walker & Dunlop’s accounts on such third party sites).
Job Applicant Data such as employment and educational history, relevant skills, professional certifications and affiliations, and any other information included in curriculum vitaes/resumés, online professional profiles, and job applications, opinions of references you provide, willingness to relocate, and, where allowed by law: test and assessment results, information about your outside activities or family relationships that may give rise to a conflict of interest, past compensation, and information about criminal offense, conviction, pending investigations and administrative sanctions.
Employee Information such as information to form an employment or contractual relationship with the applicant and for legal compliance (such as national ID card, residency permits, and visas demonstrating the Right to Work), to processing payroll and providing employee benefits (such as bank account information, tax withholding elections, and beneficiary information), disability or other data (where allowed by law or volunteered by you) needed to provide workplace accommodations.
Third Party Advertisement Technical Data from advertisements we place on third party websites: such as your IP address, browser type and version, device identifiers, location and time zone setting.
Certain locations segregate personal information that reveals specific information about a natural person that poses more risk if exposed than other personal information, known as special categories of data or sensitive personal information. Information described above may include the following sensitive personal information:
Registration Data, Job Applicant Data, Employee Information, Professional Relationship Information: social security, driver’s license, state identification card, or passport number; information about race or ethnic origin, religious or philosophical beliefs, or sexual identity or sexual orientation (1) as disclosed by you and (2) as limited to (a) fulfilling the contract with you including provision of benefits, (b) to comply with applicable law, and (c) to improve hiring practices and workplace conditions; and, where allowed by law: test and assessment results, and information about criminal offense, conviction, pending investigations and administrative sanctions; biometric information for the purpose of uniquely identifying you if opted-into by you for secure access to systems and locations (with a non-biometric option also available).
Professional Relationship Information and Business Relationship Information: social security, driver’s license or other state identification card, or passport number; information about race or ethnic origin, religious or philosophical beliefs, sexual identity or sexual orientation; and, where allowed by law: test and assessment results, and information about criminal offense, conviction, pending investigations and administrative sanctions. All of this information is (1) as disclosed by you or your representative and (2) as limited to (a) fulfilling the contract with you, (b) to comply with applicable law including Know Your Customer requirements and other due diligence, or (c) as otherwise consented to by you at point of collection.
We limit collection and processing of sensitive personal information to what is necessary to fulfill a business purpose, as described in How Walker & Dunlop Uses Your Personal Information.
As anonymized data, deidentified data, and aggregated data are not considered personal information under U.S. law, Walker & Dunlop reserves its right to collect, process, share, and disclose these types of data. Anonymized data is data for which an individual’s personal information have been removed such that a specific individual cannot be identified from the dataset. Deidentified data means data that can no longer be associated back to a particular individual by what remains. Aggregated data involves information about groups of persons that can make generalities but does not identify a single individual.
Some of the information within our Services contain publicly available personal information about owners, sellers, or buyers or other entities associated with a specific real estate property. We may also receive personal information derived from government or official information (such as census data). These shall, to the greatest extent permitted by law, not be considered personal information.
The purposes for which we use your personal information and the legal bases for such processing are as follows:
1. To Manage and Provide the Services and Professional Interactions.
We collect and process personal information such as Cookie, Device and Web Analytics Data, Marketing Data and Social Media Information, and Third Party Advertisement Technical Data to manage the Services and to provide you with opportunities for Professional Interactions. We process this personal information to provide you, your company or your employer with access to the Services which we maintain for marketing and other business purposes, or based on your consent if required by law. This includes personalizing your experience with us, auto-filling data fields to improve your experience, marketing to you via different channels based on your interactions with us (in order to provide you with the best personalized experience, sometimes this communications may be tailored to your preferences), and improving the Services, communications, fulfilling requests and orders, providing customer support, analysis and facilitation of Services and Professional Interactions, registration administration, warranty administration and validation, providing updates, research, analytics, troubleshooting and improvement of Services or business, including development of new offerings and optimization of advertising. Where required by law, we will obtain your consent before starting any marketing activities, and you may withdraw your consent to marketing emails or other communications as described in Right to Opt-Out below.
We collect and process personal information such as Contact Information, Registration Data, Professional Relationship Information and Business Relationship Information, Troubleshooting Data and Cookie, Device and Web Analytics Information to provide the Services and maintain accurate records of your Professional Interactions, in furtherance of our contract with you, your company, or your employer, as required to comply with applicable law, or based on your consent if required by law. This includes ensuring the security and integrity of accounts with us, identifying and authenticating users, processing payments, providing the Services and Professional Interactions, communicating with you or others for Professional Interactions or in furtherance of the Services (such as sponsoring or guaranteeing a loan), for administrative and compliance purposes, for marketing, for internal research and development and for quality assurance, to personalize your experience with us, and for improving the Services and Professional Interactions including research, analytics, improvement of existing Services and development of new offerings.
2. For Job Application Recruitment, Communications and Determinations. We collect and process personal information such as Contact Information, Job Applicant Data and Employee Information when considering an applicant’s (or current employee or contractor’s) qualifications and suitability for open positions in furtherance of the terms available at submission of the application, to comply with applicable law, and/or based on your consent, if required by law. This includes to recruit job applicants or promote current employees or contractors, to assess a person’s suitability for available position(s), which may include interviews, terms of employment, verification of information, carrying out pre-employment screening checks, determining the person’s ability to legally work for us in the United States or in other jurisdictions (including, as applicable, verifying the person’s visa status), and for onboarding you once hired as either a Walker & Dunlop employee, consultant or contractor.
3. To Carry Out and Manage Employment or Service Contracts. We collect and process personal information such as Contact Information, Registration Information and Employee Information to carry out and manage our onboarding process and people management procedures if we offer and you accept either employment with us or a service contract with us as an independent contractor. We process this personal information in furtherance of our contractual relationship with you, to comply with our legal obligations, and as based on your consent if required by law. This includes granting and maintaining secure access protocols to our resources, processing payments, and providing benefits as applicable.
4. To Transact Business and Maintain Professional Relationships. We collect and process personal information such as Contact Information, Registration Information, Professional Relationship Information, and Business Relationship Information to transact business and maintain a professional relationship with you or your company. We process this personal information where necessary to take steps prior to entering into a contract with you, your company or employer; in furtherance of a contract between us and you, your company or employer; to comply with applicable law; or as consented to by you if required by law. This includes providing information requested about our Services, ensuring the appropriate use of the Services, to allow you and others to make purchases through our Services, as appropriate, guarding against malicious or illegal activity, and to improve our Services.
5. To Provide Relevant Marketing to You. We collect and process personal information such as Contact Information, Registration Data, Marketing Data, and Third Party Advertisement Technical Data, and Cookie, Device, and Web Analytics Data to contact you about the Services, offerings, events and newsletters in which you have expressed an interest or about similar offerings or services (including those of third parties such as business partners) and to provide pertinent offers in which we think you would be interested. We process this personal information to keep you and our clients informed about our latest news and Services, to improve our advertising to you, your company or employer for Professional Interactions, and as based on your consent if required by law.
6. To Maintain and Manage Walker & Dunlop’s Brand. We collect and process personal information such as Social Media Information and Third Party Advertisement Technical Data to maintain Walker & Dunlop’s brand reputation through our presence on Walker & Dunlop-operated and third party social media sites, including through Professional Interactions with you when you interact with our social-media channels. We process this personal information in maintaining and managing our brand reputation and based on your consent if required by law and for other business purposes stated in this Notice.
7. To Operate, Evaluate and Improve Our Business. We collect and process personal information such as Marketing Data, Contact Information, Professional Relationship Information, Third Party Advertisement Technical Data and Cookie, Device and Web Analytics Data to operate, evaluate and improve our business. We process this personal information in furtherance of our terms with you at time of collection or under contract and based on your consent if required by law. This includes developing new Services and offerings; managing our communications; determining the effectiveness of and optimizing our advertising; analyzing our Services, including websites, mobile applications and any other digital assets; facilitating the functionality of our websites, and mobile applications and any other digital assets; for security, identification, authentication and verification; to analyze the use of and help us continually refine and improve our Services and better serve our customers and others in our Professional Interactions; and for administration and analytics.
8. To Comply With Legal Obligations and Establish, Exercise or Defend Legal Claims. We collect and process personal information, where legally permissible to do so, to establish, exercise or defend our legal rights, to comply with lawful government requests for disclosure of personal information, to comply with legal process, to enforce our terms of use or otherwise protect our rights. We process this personal information where necessary to comply with Walker & Dunlop’s legal obligations, pursuant to our contract with you, your company or employer, or based on your consent if required by law. This includes processing to investigate possible violations of the law or of company policy and to take appropriate corrective action, such as employee discipline or legal proceedings, and to compile statistical information on reports of misconduct.
9. To Carry Out Walker & Dunlop Responsibilities or Otherwise Ensure Compliance With Our Policies. We collect and process personal information related to ensuring compliance with applicable laws, regulations and requirement of organizations of which we are a part. We process this personal information where necessary to comply with Walker & Dunlop’s legal obligations, pursuant to our contract with you (or your company or employer, as applicable), or based on your consent if required by law. This includes processing for the safety and security of Walker & Dunlop employees, contractors, applicants, and other guests at our corporate offices or online, as well as improving the quality, safety and security of our Services and Professional Interactions.
Where we can do so under applicable law, the personal information we collect may be shared and processed with the following categories of recipients, some of whom may be located in a country that does not provide an adequate level of data privacy and protection rights as your home country, as necessary for the purposes identified above in How Walker & Dunlop Uses Your Personal Information. Walker & Dunlop has safeguards in place as described in International Data Transfers of this Notice regarding our international personal information transfers.
1. With our Group Companies or Joint Ventures, as Applicable. Walker & Dunlop is a multi-national firm and the personal information collected or that you provide may be shared and processed with Walker & Dunlop entities, including our joint venture partners, as necessary for the purposes identified in How Walker & Dunlop Uses Your Personal Information. For example, we may share your personal information internally with another Walker & Dunlop entity better suited to respond to your request, a decision-maker employed by another Walker & Dunlop entity, or site administrators employed by another Walker & Dunlop entity who manage access to, maintain or improve the functionality of the Services.
2. With Third Party Service Providers. Walker & Dunlop may share personal information as needed to provide the Services or facilitate Professional Interactions with you. In the majority of cases, this personal information is largely derived from publicly available sources and frequently from mandated corporate or government disclosures such that it would not constitute “personal information,” but it could include sharing personal information when consulting with professional advisers or consultants, external auditors, or product content providers. The potentially relevant third parties include:
a. Service Providers who assist with IT, cyber security, data hosting, deal management, communications and other providers of services that further the Professional Interactions or Services described in How Walker & Dunlop Uses Your Personal Information.
b. Third Party Cookies Providers who may track your browsing activity related to Services or Professional Interactions, web browsing or social media use through tracking technology. More information on these Cookies, including how to provide or revoke your consent, can be found in Cookie Policy and Similar Tracking Technology below.
c. Consultants and Advisors who assist us with legal, regulatory, and business operations activities, such as legal counsel, compliance consultants, business auditors and insurance representatives.
Service providers of Walker & Dunlop are subject to confidentiality obligations and compliance with applicable law. For information you provide directly to a service provider, personal information handled by our service providers may be subject to their own terms of use and privacy policies as notified to you. Please review the service provider’s terms of use and privacy policies to better understand how they manage your personal information.
3. With Law Enforcement Bodies, Regulatory Agencies, Courts or Related Parties. We provide personal information to any law enforcement body, regulatory, government agency, court or other third party in accordance with applicable law and regulation when we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to protect against fraud or for risk management purposes, (iii) to exercise, establish or defend our legal rights, (iv) to protect your vital interests or those of any other person, or (v) to protect the interests, rights, safety or property of us or others.
4. With Potential Buyers. We may provide personal information to a potential acquirer or a target (and that third party’s or our agents and advisers) in connection with any proposed purchase, merger, transfer, acquisition or liquidation or similar event, of all or any part of our business. If such a change happens to our business, the acquirer or target will use your personal information in the same way as set out in this Notice or will inform you about how it will use your personal information as required by applicable law.
5. With Other Persons or Entities. Personal information that you disclose on message boards, chat areas or social media pages or in direct messages to other users of these platforms may be collected and used by third parties to contact you, to send you unsolicited messages or for other purposes without our knowledge or control. Also, please be aware that social media forums and chat rooms not operated by us may have additional rules and conditions. We are not responsible for the personal information or any other information you choose to submit on these forums that are not controlled by us. We also may solicit your consent to share personal information with any other person or entity.
The Services may offer you the ability to share personal information through a social networking site (e.g., Facebook, Twitter) using integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.
We encourage you to use caution when publicly disclosing your personal information. If you terminate our services or become an inactive client, we will continue to adhere to this Notice.
We implement physical, technical and organizational security measures designed to safeguard personal information we collect and process against loss and unauthorized alteration or disclosure. These measures include computer safeguards, secured files, and secured buildings. We also contractually require confidentiality obligations with our service providers, employees and contractors. We evaluate our security measures periodically for continuing and new security threats. No method of transmission or method of electronic storage however is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
1. Your Passwords. To the extent applicable, it is your responsibility to keep safe and secure any passwords or other security devices used in connection with the Services or Professional Interactions. These should not be shared with another individual, and you must notify us immediately of any actual or suspected loss or compromise of any such password or security device.
2. Data Retention. Our information governance policies require that personal information be retained for as long as necessary for the purpose for which that information was collected and to the extent permitted by applicable laws. The criteria used to determine our retention periods include: whether there is an ongoing relationship with you (for example, as long as you have an account with us, have a Professional Interaction with us, or keep using our Services); whether we have a legal obligation to keep the data (due to certain laws requiring some records be kept for a certain period of time); and whether retention is advisable in light of our legal position (such as enforcing our agreements, resolving disputes, and responding to regulatory investigations).
Some state laws provide opt-out rights with respect to a business’ use of “automated decision-making technology,” which includes evaluating certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements. Walker & Dunlop’s decision-making processes that can be automated are overseen by one or more natural persons prior to deployment.
Our Services and Professional Interactions are not directed at individuals under the age of 16. We do not knowingly collect personal information from children under 16, nor do we knowingly sell or share information from individuals under the age of 16. To the extent permitted by applicable law, by using the Services or having Professional Interactions with us, you represent and warrant that any personal information you provide is for individuals over the age of 16.
Your personal information may be processed, transferred and/or hosted in countries other than the country in which you reside or in which the information was originally collected, including countries that may have less stringent data protection laws than those countries.
If you are located in a non-US jurisdiction, the transfer of personal information to another country, in particular to Walker & Dunlop, Inc. and its subsidiaries in the United States, may be necessary to provide you with the requested Professional Interactions and/or to perform the Services. To the extent permitted by law, your request for information and/or services also constitutes your consent for the cross-border transfer.
With respect to international data transfers initiated by Walker & Dunlop from the European Economic Area (“EEA”) or United Kingdom (“UK”) to recipients in any non-EEA or non-UK jurisdictions:
● Some recipients are located in countries which are considered as providing an adequate level of data protection under EU law (or UK law, as applicable). These transfers do not, therefore require any additional safeguards under EU (or UK, as applicable) data protection laws.
● Other recipients are located in countries not providing an adequate level of data protection under EU or UK law, such as the U.S. and, where required by law, we have safeguards in place, such as EU Standard Contractual Clauses, binding corporate rules of the recipient, or another derogation permitted under law. These safeguards can include implementing contractual clauses for transfers of personal information and additional security measures when personal information is transferred to these countries.
Depending on the legal regulations in your country and the applicable laws to which you are subject, you may have all or some of the following rights set out below and may submit a request(s) to exercise any such rights described in Contact Information below.
We respond to requests we receive from individuals wishing to exercise their data protection rights. Please be aware that in order to accommodate some requests, we must verify your identity before we can respond. In certain jurisdictions, a fee may be levied in connection with the multiple or excessive requests in a given timeframe.
Depending on which laws apply to your personal information, you may have the following data protection rights:
● Right to know what of your personal information we collect and process, as well as the types of third parties with whom we disclose your personal information.
● Right to access or request deletion of your personal information (where your personal information is no longer necessary in relation to the purposes for which we collected it), and to request a copy of your personal information in a portable format.
● Right to rectification of the accuracy of our records about you, or you make a request to amend the records.
● Right to restrict processing of your personal information if we are using the personal information for direct marketing purposes. You may have additional rights not to be subject to a decision, which may adversely affect you, which is based on solely automated processing. See Automated Decision-making above for more on our practices.
● Right to data portability of any personal information that you have provided to us if we are using consent or necessity in relation to a contract with you to justify our processing, or, in some cases, personal information that has been generated in the course of your association with Walker & Dunlop.
● Right to opt-out of marketing and promotional e-mails and communications we send you. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing e-mails we send you or by contacting us using the information below. You may further contact us by sending an e-mail at [email protected], including a copy of the e-mail you have received and by typing “Remove” in the subject line of your e-mail, in addition the Contact Information provided in this Notice; or by mail, at Walker & Dunlop ATTN: Legal, 7272 Wisconsin Ave, Suite 1300, Bethesda, MD 20814 with the copy of what you received or information on your request. Please note that even if you opt-out from receiving marketing communications, you might still receive administrative communications from us, such as technical updates of our Services, order confirmations, notifications about your account activities, and other important notices.
● Right to withdraw consent if we collect and process your personal information with your consent for marketing and profiling purposes, if any. Withdrawing your consent will not affect the lawfulness of any processing we conducted before withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
● Right to object or appeal to decisions being made by automated means that has legal effect (see Automated Decision-making) or to the grounds we present to you to comply, partially comply, or deny a request you make pursuant to this Notice.
● Right to complain to a data protection authority about our collection and use of your personal information in your home country, in particular with respect to automated decision-making. A list of European Union Data Protection Authorities is available from the European Data Protection Board.
● Right not to be discriminated against for exercising any of the above rights, though exercise of some of these rights may affect functionality or ability to provide the Services or Professional Interactions.
o For Nevada Residents: Notice provided pursuant to state law. To be placed on our internal do-not-call list, call 855.550.0007. If you would like more information about telemarketing practices, please contact us at the Contact Information below. For more on Nevada law, contact Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; by phone: 1.702.486.3132; or by email: [email protected].
o For UK or EEA Citizens: For further information on each of those rights, including the circumstances in which they apply, please review the Guidance from the UK Information Commissioner’s Office (ICO) on the individual rights under the General Data Protection Regulation (or other relevant guidance).
We are a rapidly evolving, growing business. We will continue to assess this Notice against new technologies for Professional Interactions and Services, new business practices as well as the needs of our clients. If we make any material changes to this Notice, we will make changes here and update the date of the Notice.
We use a self-assessment approach to verify compliance with this Notice and to verify that the Notice is: accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible. If you believe that your personal information has been processed or disclosed in violation of this Notice, Walker & Dunlop encourages you to raise any concerns using the Contact Information provided in this Notice. We will investigate any complaints and disputes regarding use and disclosure of personal information.
If you have any questions or concerns about our use of your personal information, please contact us at [email protected] or write to us at Walker & Dunlop, 7272 Wisconsin Ave, Suite 1300, Bethesda, MD 20814 Attn: Legal Department.
You may also reach us by calling us toll-free at (855) 550-0007 or filing a request here to contact us or exercise any of your rights. Our standard business practice is to retain any communications from Professional Interactions with our website visitors to help us to serve each of you better. We may contact you by email in relation to any questions and concerns you raise. If you prefer us to contact you in an alternative manner, please let us know and we will work to accommodate your request if possible and as necessary.
To the extent we are acting as a registered adviser to you or your representative, additional regulations may apply to the handling of your personal information. Please visit https://www.wdinvestmentpartners.com/privacy-policy/ for more information on your rights when receiving our Services or having Professional Interactions with us in a registered investment adviser capacity.
If you would like to change your preferences or limit sharing of your information for registered investment purposes, please see Requesting Access to Your Personal Information and Other Rights. Please note that because this information is required due diligence to fulfill a contract with you or to comply with applicable law, abilities to opt out may be limited.
We use cookies and similar tracking technology (collectively, "Cookies") in certain Services and Professional Interactions, including our websites. These are small text files that a website stores on your personal computer, telephone or other device, with information about your navigation on that website. Cookies serve various purposes, such as allowing you to navigate between pages efficiently, remembering your preferences, analyzing the use of the Services or Professional Interactions, and ensuring that advertisements you see online are more relevant to you and your interests. A Cookie contains the name of the server it came from, the expiry of the Cookie, a value (usually a randomly generated unique number) as well as other data relating to your use of our Services or your Professional Interactions. Depending on the applicable data protection law, such information and data may qualify as personal information.
We use session Cookies, which are temporary cookies that are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent Cookies, which are stored on your device until they expire, unless you delete them before that time. We group Cookies on our Services into four categories:
Essential Cookies: These Cookies are necessary to enable the basic features of a website or application to function, such as identifying you as a valid user, ensuring that no one else can sign on simultaneously with your account from another computer and helping us serve you better based on your registration preferences. These Cookies may also be used to remember and honor your Cookie preferences.
Functional Cookies: These Cookies allow us to analyze your use of our websites or applications to evaluate and improve our performance. They may also be used to provide a better customer experience.
Analytical Cookies: These Cookies track information about website visitors and their user behavior (e.g., how many people watched a podcast, how effective was this communication). This data is then used to improve the way our websites work and in turn, used to improve user experience. Google Analytics (GA) Cookies are one of the most common analytics Cookies set by websites. We use Google Analytics to better understand how visitors use our Services by using Cookies that Google or its affiliate DoubleClick recognize when you visit other websites and applications. For more information about how Google collects, uses, and shares your information, including information collected through our Services and Professional Interactions, please visit the Google Privacy Policy – Partners website at https://policies.google.com/technologies/partner-sites or see Google’s own Privacy Policy at https://policies.google.com/privacy.
Advertising Cookies: These Cookies may be used to share data with advertisers so that the ads you see on our websites or on third party websites are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our websites. We may use third party marketing Cookies to help deliver ads relevant to your interests. These include: LinkedIn – you can learn more about LinkedIn Cookies and how you can control them at https://www.linkedin.com/legal/cookie-policy; Google/YouTube – you can learn more about Google Cookies and how you can control them at https://policies.google.com/technologies/cookies; and DemandBase – you can learn more about Demandbase Cookies and how you can control them at https://www.demandbase.com/cookie-policy/.
Do Not Track (“DNT”) is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We have taken steps to recognize or respond to browser initiated DNT signals, also known as Global Privacy Control signals (“GPCs”). As the Internet industry is still working towards defining exactly what DNT means, or whether GPCs will be the common approach to responding to DNT requests, our steps may not recognize or respond to all DNT requests.
Our websites provide you ways to make choices regarding our use of Cookies on our websites, with the exception of Essential Cookies. You can also contact us as provided in this Notice or file a request here if you would like to make Cookie choices for Services or Professional Interactions other than our websites. You will need to set your preferences from each device and each web browser from which you wish to opt out. Also, if you clear your Cookies in your browser settings, this will remove all Cookies including the opt-out Cookies set to honor your previously made Cookie choices. In those cases, you will need to reset your preferences on our websites and elsewhere.
You may also restrict, block or delete the Cookies from our websites at any time by changing the configuration of your browser. You can find out how to do this, and find more information on Cookies, at https://www.allaboutcookies.org/. In addition, while each browser has different settings and configurations, cookies settings can typically be adjusted in the "Preferences" or "Tools" menu of your browser. Your browser’s "Help" menu may provide additional information. Note, however, that deleting or blocking Required Cookies will cause the Services to not function properly.
Walker & Dunlop’s collection, use and disclosure of certain personal information is governed by this Notice, as well as the following state-specific California Policy, as applicable:
Effective Date: January 1, 2020
Last Updated: January 1, 2023
This California Policy supplements the information providing in this Notice solely for personal information we have collected from individuals who are residents of the State of California.
Certain information we collect may be exempt from the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”) because the information is considered public information (i.e., it is made available by a government entity) or covered by a federal privacy law, such as the Gramm-Leach-Bliley Act or the Fair Credit Reporting Act. Additionally, aggregated information based on collected information that is not used to, or coupled with other information to, reidentify a California resident or their household is not considered personal information.
Unless limitations are listed in this California Policy, we use personal information collected for the purposes described in the Notice. Information covered under the When Acting As a Registered Adviser section of this Notice is to the greatest extent permitted by law not subject to this California Policy.
1. Rights of California Consumers. Under the CCPA, California consumers have the rights to:
● Know: request a business disclose personal information that a business has collected, used, disclosed, and (if applicable) sold or shared about them;
● Amend: request a correction of inaccurate personal information that a business maintains about them;
● Delete: request deletion of personal information a business has about them, with some exceptions. We may have grounds to deny your deletion request under the CCPA;
● Opt-out of sale: request opt-out of sale or share of personal information by business with third parties;
● Limit Sharing of Sensitive Personal Information: request a business limit use of their sensitive personal information, with some exceptions;
● Automated Decision-making: know logic involved in automated decision-making if used by a business (if any); and right to opt-out of use of automated decision-making technology, if said technology makes decisions about the natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movements; and
● Non-Discrimination: not be discriminated against by exercising rights under California law.
2. How to Exercise Your Rights and Process for Verifying Your Request. To exercise your rights under this addendum, please see the Contact Information section. If you make a request to us, then upon receipt of your request and in order to protect you and your personal information from unauthorized disclosure, we will need to reasonably verify that you are entitled to make the request under law. We may do this by asking for additional information (“Verifiable Information”) to compare against the information we hold about you or, if you have an account with us, by asking you to log in to that account. We will only use Verifiable Information to verify your identity or authority to make the request and to complete and log the request. We may ask you to provide additional detail or clarify your request to help us properly understand, evaluate and respond to it. Types of Verifiable Information we may ask for depend on the context of your relationship with Walker & Dunlop, but may include: name of a Walker & Dunlop employee with whom you interacted; date or other details of a transaction you had with Walker & Dunlop; and email address, phone number, or other contact information we may have on file for you.
3. Authorized Agent. You may authorize someone to submit a rights request on your behalf. You may do this by providing that person with power of attorney pursuant to the California Probate Code. Alternatively, you may provide that person with signed, written permission to submit requests on your behalf, but we will still require you to verify your identity with us directly by one of the methods listed above. In either case, we will also require that person to verify their personal identity via one of the above methods, or, in the case of a business entity, by response to communications directed at a well-known internet domain associated with that business or to contacts provided in that entity’s official filings with the California Secretary of State.
4. Categories of Personal Information. The categories of personal information we collect or process are disclosed above at Information We Collect and Process and Sources. Collected and processed personal information may include identifiers; customer records information; characteristics of protected classifications under state or federal law; commercial information; internet or other electronic network activity information; geolocation data; visual information or biometric information (if you choose it); professional or employment-related information; education information that is not “publicly available personally identifiable information” as defined in the California Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99); and inferences reflecting your preferences, predispositions, behavior, and attitudes drawn from the information we collect from visits to our websites, use of our applications, interactions with our tools, or other use of the Services or Professional Interactions with us (“Categories of Personal Information”). Sensitive personal information is described in Information We Collect and Process and Sources at Sensitive Personal Information.
5. Sources of Collection. The categories of personal information we collect or process are disclosed above at Information We Collect and Process and Sources.
6. Purposes for Which We Collect This Personal Information. We collect the categories of personal information for the purposes outlined at How Walker & Dunlop Uses Your Personal Information.
7. Disclosures and Categories of Receiving Parties. How we disclose personal information to external parties is described above at Disclosure of Personal Information. Please note that for each of the Categories of Personal Information, we may have disclosed that personal information to the following categories of third parties for a business purpose: third parties, including third party vendors; service providers who help us manage or provide our Services and/or Professional Interactions, including but not limited to marketing, advertising and communications agencies, external auditors and advisors, and our vendors who provide data processing, IT, software, information security or other related services; legally affiliated entities, affiliates and subsidiaries; professional, financial, legal, audit or other advisors; and enforcement or regulatory authorities, if and when required. Disclosure of sensitive personal information is limited to disclosure as described in Information We Collect and Process and Sources at Sensitive Personal Information.
8. Sale or Share to Third Parties who are not Service Providers. Walker & Dunlop does not sell personal information in a conventional sense. “Sale or share” under California law means to disclose personally identifiable information to an external party for monetary or other benefit. Walker & Dunlop does not sell personal information for monetary benefit, but, like many companies, we use advertising services that try to tailor online ads to interests based on information collected via Cookies about a user’s online activity (“interest based advertising”). To the extent this constitutes a sale, you may opt out by filing a request or contacting us as described in our Contact Information.
a. No Sale or Share of Child Personal Information. Walker & Dunlop has no knowledge of selling or sharing personal information of any child under 16 years of age, as further described in Children’s Privacy.
b. No Sale or Share of Sensitive Personal Information. Where sensitive personal information is collected or processed by Walker & Dunlop, as described earlier in this Notice at Information We Collect and Process and Sources, this information is not used for cross-contextual advertising and is not otherwise sold.
9. Exceptions to Your Right to Request Deletion or Limitations. You have the right to request deletion of your personal information in certain circumstances. Our collection and processing may fall under a legal exception, however, where we would not be required to honor your request, such as to: complete the transaction for which the personal information was collected; use the data as reasonably anticipated by you within the context of an ongoing business relationship; enable solely internal uses that are both reasonably aligned with reasonable expectations based on the relationship with the business and compatible with the context in which the information was provided; or to comply with a legal obligation (e.g., ensuring affordable housing tax credit compliance, completing due diligence).
Similarly, if sensitive personal information is collected or processed by Walker & Dunlop, it is described in “Sensitive Information” of the Information We Collect and Process and Sources and is limited to the business purposes described at and in this California Policy. While Californians may have a right to request businesses limit the use of their sensitive personal information, Walker & Dunlop limits its use and disclosure of sensitive personal information such that we may be exempt from having to comply with requests to further limit.
10. Automated Decision-Making. Our practices are described at Automated Decision-making.
11. Security Measures. Our practices are described at Data Security Measures.
12. Retention of Personal Information for California Residents. Our practices are described at the Data Retention subsection of Data Security Measures.
13. "Shine the Light" Law. Residents of the State of California also have the right to request information regarding third parties to whom a business has disclosed certain categories of personal information during the preceding year for the third parties' direct marketing purposes. If you have questions related to Shine the Light, please contact us. Third parties that link to or from our Services or assist with Professional Interactions may have their own privacy policies and practices. Please review any third-party policies to learn more about their practices.
14. How to Contact Us. You may contact us in the ways described at Contact Information and should note on your request whether you are a California consumer under California law.
