Preface

This privacy policy (hereafter, the “Notice”) discloses the privacy practices for Walker & Dunlop, Inc., its subsidiaries and affiliates (collectively “Walker & Dunlop,” “we,” “our” or “us”). This Notice explains how we collect, use, share, transfer and process information collected from or about a user of one or more of our services or websites (referred to herein as “you” or “your”).

General Information

Included in this Notice are:

  • the types of Personal Data (defined below) we may collect, process, disclose or share about you or about an individual whose Personal Data you provide to us and why;
  • to whom we disclose or share that Personal Data; and
  • how you may exercise rights that you may have regarding your Personal Data. 

Please carefully review this Notice. To the extent permitted by applicable law, by interacting with us or our Products or Services, you are agreeing to the terms of this Notice.  Moreover, if you provide Personal Data of anyone other than yourself, you are responsible for complying with all applicable privacy and data protection laws for Personal Data you provide to us, including obtaining consent for us to process the Personal Data in accordance with this Notice.

If you do not consent to this Notice, you should stop using our Products and Services. In some circumstances, if you do not want to provide us with your information, certain Products and Services may be unavailable to you.

We may update this Notice from time to time. As such, you should review this Notice periodically. Your continued interactions with us or continued use of one of our Products and Services constitutes your agreement to this Notice.

"Personal Data”

“Personal Data” for this Notice means any information that can be used to identify an individual, natural person, such as name, address, email address, telephone number, date of birth or credit card number, as applicable. Personal Data in some jurisdictions can include information that indirectly identifies a natural person.

Personal Data may be collected or processed by us when you:

  • interact with us online (through websites, applications and otherwise),
  • when you interact with us in-person, by telephone, email or regular mail,
  • when we provide products or services to you, and
  • in other situations where you interact with us, including anywhere this Notice is posted or referenced

(collectively, the “Products and Services”). Walker & Dunlop may have other privacy notices that apply to certain specific situations, products or service offerings. To the extent this Notice and a separate privacy notice from Walker & Dunlop apply and there is a conflict in terms, the more specific privacy notice shall govern over this Notice.

Anonymized, Deidentified, or Aggregated Data

“Anonymized Data” is data for which an individual’s personal characteristics have been removed such that an individual cannot be identified from the dataset. “Deidentified Data” means individual records that can no longer be associated or relinked with a particular individual. “Aggregated Data” involves information about groups of consumers that can no longer be linked back to a specific individual. As Anonymized Data, Deidentified Data, and Aggregated Data are not considered Personal Data, Walker & Dunlop reserves its right to collect, process, share, and disclose these types of data.

What We Collect and Why

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, your devices, our business partners or potentially from other third parties. Examples and the legal bases for processing Personal Data are included below.  In some jurisdictions, you may also have the right to request the specific pieces of personal information collected about you as a consumer, examples of which are provided below.

Categories of Personal Data We Collect

  • Identifiers and Customer Records Information
  • Demographic Information
  • Commercial Information, Electronic Network Activity Information
  • Professional, Educational, or Employment-Related Information

Identifiers and Customer Records Information

(Name, alias, signature, postal address, online identifier, IP address, email address, telephone number, insurance policy number, account name, social security number, driver’s license number, bank account number, credit or debit card number, passport number, loan origination and servicing documents, credit reports and other information related to creditworthiness, other financial information, other similar identifiers)

  • To provide the Products and Services; 
  • To communicate with you or others on your behalf regarding the Products and Services; 
  • To contact you or others on your behalf regarding sponsoring or guaranteeing a loan; 
  • To manage accounts; 
  • To identify and authenticate users; 
  • To customize content; 
  • To detect security incidents; 
  • To protect against malicious or illegal activity; 
  • To ensure the appropriate use of Products and Services, including to provide Product and Services to others as authorized by you; 
  • To improve our Products and Services; 
  • For short-term, transient use; 
  • For administrative purposes; 
  • For marketing, internal research and development; 
  • For quality assurance 

Demographic Information

(Age, gender, marital status and date of birth)

  • To provide the Products and Services; 
  • To communicate with you or others on your behalf regarding the Products and Services; 
  • To contact you or others on your behalf regarding sponsoring or guaranteeing a loan; 
  • To manage accounts; 
  • To identify and authenticate users; 
  • To customize content; 
  • To detect security incidents; 
  • To protect against malicious or illegal activity; 
  • To ensure the appropriate use of Products and Services, including to provide Product and Services to others as authorized by you; 
  • To improve our Products and Services; 
  • For short-term, transient use; 
  • For administrative purposes; 
  • For marketing, internal research and development; 
  • For quality assurance

Commercial Information, Electronic Network Activity Information

(Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, Internet Protocol (IP) addresses, browser type, browser language, device type, geolocation information, the date and time you use our Products and Services and activity on our Products and Services, browsing history, search history, and information regarding your interaction with an Internet website, application, or advertisement)

  • To provide the Products and Services; 
  • To communicate with you or others on your behalf regarding the Products and Services; 
  • To contact you or others on your behalf regarding sponsoring or guaranteeing a loan; 
  • To manage accounts; 
  • To identify and authenticate users; 
  • To customize content; 
  • To detect security incidents; 
  • To protect against malicious or illegal activity; 
  • To ensure the appropriate use of Products and Services, including to provide Product and Services to others as authorized by you; 
  • To improve our Products and Services; 
  • For short-term, transient use; 
  • For administrative purposes; 
  • For marketing, internal research and development; 
  • For quality assurance

Professional, Educational, or Employment-Related Information

(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))

  • To consider you for employment; 
  • To provide the Products and Services; 
  • To communicate with you or others on your behalf regarding the Products and Services; 
  • To contact you or others on your behalf regarding sponsoring or guaranteeing a loan; 
  • To identify and authenticate users; 
  • To customize content; 
  • To detect security incidents; 
  • To protect against malicious or illegal activity; 
  • To ensure the appropriate use of the Products and Services, including to provide Product and Services to others as authorized by you; 
  • To improve the Products and Services; 
  • For short-term, transient use; 
  • For administrative purposes; 
  • For marketing, internal research and development; 
  • For quality assurance

To Whom We Disclose Personal Data

Generally, Walker & Dunlop limits disclosing of Personal Data to our teams, our business partners and our third-party service providers who are contractually limited in how they process Personal Data provided by Walker & Dunlop. In limited circumstances, Personal Data may be shared to help us and others improve marketing, administer services, or comply with the law. For example:

  • in the event of a sale, assignment, or transfer of a Product or Service, such as a loan, Personal Data may be shared with your buyer, assignee, or their transferee; 
  • Where required, Personal Data may be disclosed to government officials, law enforcement, or others, as dictated under this Notice, by our agreements with you, or by law;  
  • sharing cookies, pixel tags, web beacons, local storage and other technologies for improved website experiences as described below in our Cookie Policy; or
  • as otherwise authorized by you. 

Children's Information

By using our Products and Services, you represent and warrant to us that Personal Data you provide is for individuals over the age of 16. Walker & Dunlop does not knowingly process Personal Data of any individuals under the age of 16.

Transfer of Personal Data Across National Borders

Personal Data may be collected, processed, shared, disclosed, or transferred outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location.  Walker & Dunlop has put in place safeguards, in accordance with United States law, to protect Personal Data.

To the extent a third-party service provider of Walker & Dunlop processes Personal Data outside of the United States, you agree that we may share Personal Data with third-party service providers to provide the Products and Services as follows: third-party service providers shall only access Personal Data to provide and support use of the Products and Services, to prevent or address service or technical problems; as you expressly permit in writing, or as necessary to comply with applicable law.

How We Safeguard Information

Walker & Dunlop has in place physical, technical and administrative safeguards designed to protect Personal Data from unauthorized access, unauthorized alteration, unauthorized disclosure, and unauthorized deletion. We evaluate these safeguards periodically to minimize risks from new security threats. However, as is the case with all websites, applications, products and services, we unfortunately are not able to guarantee the security of Personal Data collected through our Products and Services.

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 Products and Services. You must notify us immediately of any actual or suspected loss or compromise of any such password or security device.

Data Retention Policy

We retain Personal Data for as long as we maintain a relationship with you and for as long as reasonably necessary for a legitimate business purpose.  Walker & Dunlop will maintain administrative, physical and technical safeguards designed to protect the security, confidentiality and integrity of your Personal Data for as long as we retain Personal Data about you (See “HOW WE SAFEGUARD INFORMATION”). 

Rights Regarding Personal Data You Provide

In some jurisdictions, you may have a right under data protection law to:

  • request access to Personal Data collected, sold or shared about you (or someone you are authorized to represent); 
  • to request that we rectify or erase that Personal Data; 
  • to request that we restrict or block the processing, sharing, or selling of that Personal Data;
  • to limit the use and processing of Sensitive Personal Data; 
  • to provide you a copy of that Personal Data, e.g., a right to data portability; and 
  • where consent was previously provided, to withdraw that consent. 

At present, Walker & Dunlop does not sell Personal Data. Moreover, Walker & Dunlop limits sharing of Personal Data as set forth above in “TO WHOM WE SHARE OR DISCLOSE PERSONAL DATA” and for just those Bases for Collection mentioned in “WHAT WE COLLECT AND WHY.”

Nevertheless, to exercise the rights you may have, please write to us at Walker & Dunlop ATTN: Legal Department, 7272 Wisconsin Ave, Suite 1300, Bethesda, MD 20814. You may also reach us by calling us at 855.550.0007 or filing a request here.

After receiving such a request, we may require additional information from you to verify your identity and honor the request. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

Marketing and Promotional Emails

You may unsubscribe from any of our marketing or promotional emails. To do so, please email us at [email protected] You may also use the unsubscribe mechanism offered in our marketing emails or other communications, as applicable. Please note that it may take a short period of time to update your preferences in our systems.

Forum Comments

To the extent we offer any public or group forums on our Products or Services, such as newsfeeds, blogs, message boards, or similar tools (“Interactive Features”), the posts or comments you make may be public and viewable by others. You acknowledge and understand that you have no expectation of privacy or confidentiality in the content you submit to Interactive Features over the Products and Services. Except when required to do so by applicable law, we assume no obligation to remove Personal Data posted on our Products and Services.  Personal Data is disclosed in the Interactive Features at your own risk.

Links to Other Websites

Our Products or Services may contain links to other websites, applications, products, or services that are not owned or operated by Walker & Dunlop, such as social media websites and applications like Facebook and Twitter. You should carefully review the applicable privacy policies and practices, as we cannot control and are not responsible for privacy policies, notices or practices of third-party websites, applications, products or services.

Cookie Policy

You acknowledge that your use of the Products and Services may have a unique ID via cookies, pixel tags, web beacons, local storage and other technologies (collectively, “Cookies”).  Cookies are essentially small data files placed on website visitor device(s) that provide certain information, like how the visitor uses online services.  Cookies help to improve software function, facilitate site navigation, personalize your experience and authenticate you online. The Cookies may sync with third-party cookies, in which cases, the use of Cookies by third parties is subject to their own privacy policies and is not covered by this Notice, except as required by law. Generally, we use Cookies to perform various functions as follows:

  • Strictly Necessary Cookies: Cookies essential for the operation of Products and Services, such as security and user authentication. While you may be able to configure your browser to reject these Cookies, doing so would affect how the Products and Services function.
  • Performance Cookies: Cookies that analyze use of and performance of our Products and Services, to quickly identify and fix usability issues that arise. Opt-out information is provided below.
  • Functional Cookies: Cookies personalizing your experience of Products and Services by remembering your preferences. Opt-out information is provided below.
  • Advertising Cookies: Cookies that serve you with advertisements logically believed to be relevant to you and your interests. By using our websites, you consent to our use of these Cookies. To opt-out of advertising cookies specifically from your browser, you may visit: https://optout.aboutads.info/.

If you would like to opt-out of or withdraw consent to other Cookies, you can set your web browser to prevent the use of cookies from Walker & Dunlop websites, as well as other websites that you may visit (see www.aboutcookies.org for more information on how to do this). You can still use Walker & Dunlop Products and Services after doing so, but it is possible that some portions of the Products and Services will not function properly or may perform more slowly.

Contact Us

If you have any questions, including how to access this Notice in an alternative format, please email us at [email protected] or write to us at Walker & Dunlop, 7272 Wisconsin Ave, Suite 1300, Bethesda, MD 20814 Attn: Legal Department. 

Updated: March 3, 2022

© 2022 Walker & Dunlop. All Rights Reserved.

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