Preface

This Walker & Dunlop Privacy Notice (“Notice”) explains how we collect, use, share, transfer, and process information collected from or about you (“Personal Data”) by any subsidiary or affiliate of Walker & Dunlop, Inc. (collectively “Walker & Dunlop,” “we,” “our,” or “us”). 

Scope 

This Notice describes the types of Personal Data that Walker & Dunlop may collect or process, how we may use and disclose that Personal Data, and how you may exercise any rights you may have regarding our processing of your Personal Data. This Notice applies to Personal Data collected or processed by us online (through websites, applications, and otherwise), 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 (products, services, websites, and other systems will be referred to in this Notice as “Products and Services”). This Notice also applies to Personal Data that is collected or processed when you interact with us in-person, by telephone, or by mail.

Walker & Dunlop may have other unique privacy notices that apply to certain specific situations, such as privacy notices for specific Products and Services in various specific circumstances. To the extent you were provided with a different privacy notice or policy and those policies or notices apply, those policies or notices will govern our interactions with you, not this one. 

If you provide Personal Data of anyone other than yourself, please note that you are responsible for complying with all applicable privacy and data protection laws prior to providing that information to Walker & Dunlop (including obtaining consent, if necessary and required).

Please carefully review this Notice. To the extent permitted by applicable law, by providing us your Personal Data or otherwise interacting with us, you are agreeing to this Notice. 

Information Collection

Personal Data

“Personal Data” is any information that can be used to identify an individual or that we can link directly to an individual, such as name, address, email address, telephone number, or credit card number, as applicable. Personal Data in some jurisdictions can include information that indirectly identifies a person.

Some examples of instances where we collect Personal Data include if you:

  • Purchase, use, or receive our Products or Services, including documents provided in connection with loan applications and other financial Services we provide; 
  • Register for an account for one of our Products or Services;
  • Provide us with information regarding sponsors and guarantors; 
  • Sign up for newsletters or other informational or marketing materials;
  • Ask us a question by contacting us; 
  • Apply for employment with or are employed by us; 
  • Interact with us as a customer, vendor, supplier, or business partner or an employee or representative of same;
  • Respond to our surveys or questionnaires; or
  • Make a complaint to us.

We will process any Personal Data we collect in accordance with applicable law and as explained in this Notice (unless, as explained above, one of our other policies or notices governs). In some circumstances, if you do not want to provide us with your information, certain Products and Services may be unavailable to you.

Below is a summary of how we collect, process, and use Personal Data and the potential recipients of your Personal Data. Some jurisdictions require us to state the legal bases for processing your Personal Data, which is included below, but please note that not all jurisdictions may recognize all legal bases. 

Categories of Personal Data We Collect

  • Examples of Personal Data Processed
  • Sources of Personal Data
  • Purpose of Processing Personal Data
  • Recipients of Your Personal Data
Identity and Contact Information
  • Examples of Identity and Contact Information: First and last name, email address, postal address, phone number, job title, account username and password, and IP address
  • Sources: Directly from you; from your devices; from our business partners or other third parties
  • Purposes: To provide you or others with our Products and Services; to communicate with you; to contact you regarding sponsoring or guaranteeing a loan; to manage your account; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for administrative purposes; and/or for marketing, internal research, and development
  • Recipients: Walker & Dunlop and third parties and partners in connection with providing the Products or Services; third parties to help us improve our marketing or administration*
Demographic Information
  • Examples of Demographic Information: Age, gender, marital status, and date of birth
  • Sources: Directly from you; from your devices; from our business partners or other third parties
  • Purposes: To provide you or others with our Products and Services; to communicate with you; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for administrative purposes; and/or for marketing, internal research, and development
  • Recipients: Walker & Dunlop and third parties and partners in connection with providing the Products or Services; third parties to help us improve our marketing or administration*
Commercial and Financial Information
  • Examples of Commercial and Financial Information: Transaction records, Products and Services purchased, obtained, or considered, request documentation, loan origination and servicing documents, credit reports and other information regarding your creditworthiness, sponsor and guarantor information, customer service records, financial transaction history, and financial account number and information
  • Sources: Directly from you; from your devices; from our business partners or other third parties
  • Purposes: To provide you with our Products and Services; to communicate with you; to manage your account; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for administrative purposes; and/or for marketing, internal research, and development
  • Recipients: Walker & Dunlop and third parties and partners in connection with providing the Products or Services; third parties to help us improve our marketing or administration*
Professional and Educational Information
  • Examples of Professional and Education Information: Job title or position, employer, employment history, and education history
  • Sources: Directly from you; from your devices; from our business partners or other third parties
  • Purposes: To consider you for employment; to provide you with our Products and Services; to communicate with you; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for administrative purposes; for marketing, internal research, and development; and/or for quality assurance
  • Recipients: Walker & Dunlop and third parties and partners in connection with providing the Products or Services; third parties to help us improve our marketing or administration*
Technical Information
  • Examples of Technical Information: Internet Protocol (IP) addresses, browser type, browser language, device type, advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)), the date and time you use our Products and Services, Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services, activity on our Products and Services and referring websites or applications, data collected from cookies or other similar technologies, and geolocation information
  • Sources: Directly from you; from your devices; from our business partners or other third parties
  • Purposes: To provide you with our Products and Services; to communicate with you; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our
  • Products and Services; for short-term, transient use; for administrative purposes; and/or for marketing, internal research, and development
  • Recipients:  Walker & Dunlop and third parties and partners in connection with providing the Products or Services; third parties to help us improve our marketing or administration*
Anonymized / De identified Data
  • Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer consider Personal Data under data protection laws
  • Sources: Directly from you; from your devices; from our business partners or other third parties
  • Purposes: To improve our Products and Services; for short-term, transient use; for administrative purposes; for marketing, internal research, and development; and/or for our own purposes
  • Recipients: Walker & Dunlop and third parties and partners in connection with providing the Products or Services; third parties to help us improve our marketing or administration*

*In limited circumstances, recipients may include, (1) in the event of a sale, assignment, or transfer, to the buyer, assignee, or transferee; and, (2) government officials, law enforcement, or others when permitted by this Notice or required by law.

Cookies and Similar Tools

When you visit Walker & Dunlop websites or applications, we may use “cookies,” web beacons, and other technologies to help us serve users better and to help us evaluate and improve the content or functions of the Products or Services. A cookie is a small piece of data (a unique numeric code) sent from a website or application and stored on a user’s device while the user is browsing the website or using the application. Cookies do lots of different jobs, like identifying previous activity so that your use of the Product or Service is more efficient and enjoyable, remembering your preferences (like language choices), and authenticating you.

Common uses for cookies include:

  • Identifying users who have signed into a Product or Service to avoid users having to submit a user name and password repeatedly;
  • Keeping track of users' preferences regarding the content they would like to see and the format in which they would like to view it so they do not need to resubmit preferences;
  • Keeping track of which pages users’ request to make improvements to site content and navigation;
  • Engaging in analytics about how the Products or Services are used; and
  • Collecting information about users’ activities over time and across different websites or applications while using the website or application.

Web beacons (also known as Internet tags, pixel tags, and clear GIFs) are small pieces of code that may be placed on our websites or other Products and Services that allow us to obtain information about usage. Web beacons cannot identify you as an individual and are used to help display content to visitors and to generate statistics regarding web traffic and trends.
Generally, our Cookies perform these different functions:

Strictly Necessary Cookies

Some Cookies are essential for the operation of our website, such as security, network management, user authentication, and accessibility. While you may be able to configure your browser to reject these Cookies, doing so would affect how the website functions.

Performance Cookies

We use other Cookies to analyze how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customizing our offering and quickly identifying and fixing any issues that arise. For example, we might use performance Cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these Cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website. 

Functional Cookies

We may use Cookies to help personalize the website by remembering your preferences.

Advertising Cookies

Walker Dunlop and advertisers may use Cookies to serve you with advertisements that we believe are relevant to you and your interests. You might see ads that target you based on your user behavior on sites that you visit. However, we do not tell advertisers who you are. Where required by law, we will obtain your consent before placing Advertising Cookies on your device.

If you would like to opt-out or withdraw consent to use non-essential cookies and related technologies, 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). If you do so, you can still use Walker & Dunlop Products and Services, but it is possible that some portions of the Products and Services will not function properly or may perform more slowly. 

Children’s Information

Walker & Dunlop does not knowingly collect, maintain, disclose, or otherwise process Personal Data from minors below the age of 13 without the permission of such minor’s parents or legal guardians. 

Combination of Data

We may combine information we collect, whether Personal Data or not, with Personal Data that we may obtain from third parties. 

Interactive Features of Our Websites

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 viewed by others. You should use care before posting information about yourself, including Personal Data. 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 you post on our Products and Services, and you disclose any Personal Data 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 privacy policies and practices of other websites, products, and services as we cannot control and are not responsible for privacy policies, notices, or practices of third party websites, applications, products, and services.

Safeguarding Information

Consistent with applicable laws and requirements, Walker & Dunlop has put in place physical, technical, and administrative safeguards to protect Personal Data from loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure, consistent with legal obligations and industry practices. We evaluate these safeguards to help 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 security for data collected through our Products and Services.

Your Rights Regarding Your Personal Data and How to Exercise Them

You may have a right under your jurisdiction’s data protection law to the following with respect to some or all of your Personal Data:

  • To request access to your Personal Data;
  • To request that we rectify or erase your Personal Data;
  • To request that we restrict or block the processing of your Personal Data;
  • To provide your Personal Data directly to another, i.e., a right to data portability; and
  • When we previously obtained your consent, to withdraw consent to processing.

To exercise these rights, please write to us at [email protected] or Walker & Dunlop, 7501 Wisconsin Ave, Suite 1200E, Bethesda, MD 20814 Attn: Legal Department. 

You may also reach us by:

We may, after receiving your request, require additional information from you to honor the request and verify your identity. 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.

If you are concerned about how your Personal Data is used, please email us or contact us. You may also have the right to lodge a complaint against us. To do so, contact your local data protection authority.

Transfer of Personal Data Across National Borders

Please be aware that Personal Data we collect and process may be transferred and maintained outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location, including the United States. Walker & Dunlop has put in place safeguards, in accordance with applicable legal requirements, to protect your Personal Data irrespective of the standards in the country where your Personal Data may be transferred. This includes entering into agreements with third parties, such as service providers, to require them to adopt standards that ensure an equivalent level of protection for data as those we adopt. 

Marketing and Promotional Emails

You may unsubscribe from any marketing or promotional emails. To do so, please email us at [email protected] or use the unsubscribe mechanism offered in our marketing emails or other communications, as applicable. Please note that if you already have requested our Products or Services when you decide to withdraw consent, a short period of time may elapse before we can update your preferences and ensure that we honor your request.

How Long We Keep Your Personal Data

We will retain your Personal Data for as long as we maintain a relationship with you and/or for as long as we provide a Product or Service to you. We may retain Personal Data therefore as long as is reasonably necessary for legitimate business purposes or legal and regulatory purposes.

Changes to This Privacy Notice

We may update this Notice from time to time without notice. As such, you should review this Notice periodically. Your continued interactions with us and/or the use of our Products and Services subject to this Notice constitutes your agreement to this Notice. 

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, 7501 Wisconsin Ave, Suite 1200E, Bethesda, MD 20814 Attn: Legal Department. 

Updated: September 2021

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