Wallach & Company (“Wallach” “we” or “us”) is committed to protecting our users’ privacy. We feel it is important that you fully understand the terms and conditions under which we use the information we gather from you, including through the use of our websites (“Sites”), hosted service offerings (“Services”) and mobile applications (“Mobile Apps”, and together with our Sites and Services, our “Offerings”). Please read this Privacy Policy (“Policy”) carefully to understand how we will use and protect your personal information. The Policy also describes the choices available to you regarding how you can access and update this information. Changes to this Policy will be announced on the home page of our Sites and Mobile Apps so please check back periodically.

EU-U.S. Privacy Shield

Wallach & Co participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

Wallach is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf in certain circumstances. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact privacy@wallach.com.

Pursuant to Article 37 of the European Union’s General Data Protection Regulation, TIBCO has appointed a Data Protection Officer, Ms. Tonya Washington. She may be reached by email at privacy@wallach.com.

1. What information do we collect from you?

In order to better provide you with services, we collect two types of information about visitors: Personal Information and Non-Personal Information. Our primary goal in collecting information from you is to provide you with a smooth and efficient experience while using our products.

Personal Information

Personal information refers to the specifics of who you are, such as your name, address, telephone number, email address and any other information needed to provide a service to you while using our Offerings. We gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected information with other information we collect about you to improve services, marketing, analytics, or site functionality.

Wallach collects personal information when you register with Wallach for Wallach issued product as a customer, potential customer, or guest user. We use the personal information that we collect to send you information that you have requested, respond to an inquiry, or to facilitate the purchasing and servicing of insurance policies. Information may be retained by Wallach to verify compliance with the agreement, log software licenses granted, to track software downloaded from those pages, or track usage of other applications.

Referral Services

If you choose to use our referral service to introduce third parties to our products, we will retain information about the individual or company referred as well as the time and date you made the referral in order to facilitate appropriate compensation.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Non-Personal Information: non-personal information refers to information that does not by itself identify a specific individual. We gather certain information about you based upon the pages that you access in our offerings using various tracking technologies. This information is compiled and analyzed on both a non-aggregated and an aggregated basis. (See “Cookies” section below)

Service-Related Announcements

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if a purchased policy is about to expire, we might send you an email.

Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account. Please see “Choice and Opt-out.”

Customer Service

Based upon the personal information you provide us, we will send you an initial email to provide you with policy information and critical contact information should you need to file a claim. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email or telephone, in accordance with your wishes.

2. With whom do we share your information?

In the case of a claim being filed in accordance with the policy, we may communicate with medical and administrative service providers to facilitate servicing of your claim. All such entities are governed by this Privacy Policy or are bound by the appropriate confidentiality and data transfer agreements. We do not sell your personal information to third parties. Your personal information is never shared outside of Wallach without your permission, except under conditions explained above. At Wallach your data is stored in controlled servers with limited access. Your information may be stored and processed in the United States or any other country where Wallach, its subsidiaries, affiliates, or agents are located. We do not have any access to your financial or credit card information at any time. All credit card transactions are processed through Authorize.net. Wallach does not have access to this information beyond confirmation that a payment was processed successfully.

3. How may you update, correct, or delete your Personal Information?

Upon request we will provide you with information about whether we hold any of your personal information. If your personal information changes, or if you no longer desire our service, you may correct, update, amend, or delete/remove information by emailing us at privacy@wallach.com. We will respond to your request within 30 days.

4. What security precautions are in place to protect against the loss, misuse, or alteration of your information?

We employ industry-recognized information technology to protect the security of the information you submit to us, both during transmission and once we receive it. The importance of security for all personal information associated with our users is of utmost concern to us. Our secure servers protect this information using password protection and advanced encryption, and we may use firewall technology for additional protection. When you enter sensitive information (such as a credit card number) Authorize.net encrypts the transmission of that information using secure socket layer technology (SSL).

Furthermore, all of the user data we collect is protected against unauthorized access by physical security means. However, no method of transmission over the internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Offerings, you can contact us at privacy@wallach.com.

5. “Cookies” and other Tracking Technologies

We use cookies for the limited purposes of enhancing your visit to our website and tor track referral sources. A cookie cannot be read by a website or mobile application other than the one that set the cookie. No other company will have access to our cookies. A cookie cannot retrieve any other data from your hard drive or device, pass on a computer virus, or capture your email address.

Most browsers and devices are initially set up to accept cookies. If you prefer, you can reset your browser to notify you when you have received a cookie, or alternatively, to refuse to accept cookies. It is important to note that you may not be able to use certain features on our Site if you choose not to accept cookies. Some of the third-party web-monitoring providers use cookies and other tracking technologies on our Sites.

Wallach and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, ascertain your interest in our communications, and to gather demographic information about our user base as a whole.

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.

6. You should carefully review privacy policies of any third-party sites accessible from our website

Other sites accessible through our website have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties. Please be aware that our Sites may contain links to other sites on the internet that are owned and operated by third parties. This Privacy Policy does not cover the information practices of those Web sites linked to our website. These other sites may send their own cookies to users, collect data, or solicit personal information. We cannot control this collection of information. You should contact these sites directly if you have any questions about their use of the information that they collect.

7. Contacting us about privacy questions or concerns

If you have any questions about this Privacy Policy, the practices of our offerings, or your dealings with our offerings, please contact us by sending an email privacy@wallach.com

8. Privacy Policy changes

This Privacy Policy was last changed on January 22, 2019. If we make changes to any terms or conditions of the Privacy Policy, the changes will be posted in this document so that you will always know what information we gather, how we might use that information, and to whom we will disclose it. Any change, modification, addition, or removal of portions of this Policy that are changes in a material way will be announced on the homepage(s) of our Offerings prior to the change becoming effective. Please be sure to check this page before proceeding to use our Offerings.