These Terms were last revised on May 1, 2021
This website, and all other WHC websites (collectively, the “Websites”) are general audience sites and we do not knowingly collect personal, or other, information from children under the age of 18. If you are under the age of 18, please do not use our site. If we suspect that information provided to us is, in fact, personal information of an individual younger than 18 years of age, such information will be deleted, aggregated, or anonymized as soon as possible. Please notify us if you know of any individuals under the age of 18 using our services so we can take action to prevent access to our services.
Types of Information and Data We Collect
Our website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
To establish an account and access our Services, we’ll ask you to provide us with some important information about you. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services (e.g. you will need to provide three (3) months of bank statements), or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information.
Please note that we may not be able to serve you as effectively or offer you our Services if you choose not to share certain information with us.
Collection of Data
For example, we may automatically receive and record the following information on our server logs:
- How you came to and use the Services;
- Device type and unique device identification numbers;
- Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
- How your device interacts with our Sites and Services, including pages accessed and links clicked;
- Geographic location; and,
- Other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.
We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third-party site.
How We Use Your Information
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We generally use personal information to create, develop, operate, deliver, and improve our Services, content and advertising; and for loss prevention and anti-fraud purposes.
We may use this information in the following ways:
To maintain legal and regulatory compliance
Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, WHC must identify and verify customers using our Services in order to comply with commercial lending laws across jurisdictions. In addition, we use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. When you seek to link a bank account to your WHC Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we reserve the right to close your account.
If you authorize one or more third party applications to access your Personal Information stored by WHC , then information you have provided to WHC may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using WHC Services. Please note that third parties you interact with may have their own privacy policies, and WHC is not responsible for their operations. Information collected by third parties, which may include such things as contact details, or other personal information, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
Examples of account connections include:
- Lenders: If you use your WHC account to conduct a transaction with a third-party merchant, the merchant may provide data about you and your transaction to us.
- Your Financial Services Providers: For example, if you send us funds from your bank account, your bank will provide us with identifying information in addition to information about your account in order to complete the transaction.
Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Please review the privacy notice of any third-party that will gain access to your personal information.
Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, WHC has absolute discretion in providing you with those rights.
Your rights to personal information are not absolute. Depending upon the applicable law, access may be denied: (a) when denial of access is required or authorized by law; (b) If you are a resident of a state that does not provide for this right; (c) when granting access would have a negative impact on another’s privacy; (d) to protect our rights and properties; or (e) where the request is frivolous or vexatious, or for other reasons.
Access and portability
You may request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another data controller.
Rectification of incomplete or inaccurate personal information
You may request us to rectify or update any of your personal information held by WHC that is inaccurate. You may do this at any time by logging in to your account and clicking the Profile or My Account tab.
To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of WHC ’s processing based on consent before your withdrawal.
Restriction of processing
In some jurisdictions, applicable law may give you the right to restrict or object to us processing your personal information under certain circumstances. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instruction included in these emails or you can contact us at email@example.com
You can choose not to provide us with certain information, but this will likely result in the inability to use certain features of the Websites and to obtain the services and products you are seeking. As a general matter, do not post personal information on public forums. You are solely responsible for the posting of any personal information on public forums.
If, after signing up for our services, you decide you no longer wish to receive our services or future contact from lenders, brokers, or other third parties to which your information has been referred, you may cancel your account as discussed herein. Upon cancelling your account, your information will no longer be sent to lenders, brokers, or other third parties. This does not guarantee that these lenders, brokers, or other third parties will cease contacting you or using your information. Please be sure to reach out to all lenders, brokers, and/or other third parties to ensure they cease contacting you.
Certain federal and state regulations require that we maintain a record of your information for certain periods of time. Due to these regulations, we may be unable to completely delete your information from our database until the time requirements of these regulations have expired.
Will Holmes Consulting
714 S. Wolfe Street #38913
Baltimore, MD 21231