(347) 854 9623
138 Hinsdale St. Brooklyn, NY 11207
Privacy Policy
Here at Working And Learning Together Electronics Recycling, Inc., we take your privacy very seriously. Please read our Privacy Policy carefully as it contains important information on who we are and our information practices (meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information). Our Policy also explains your rights in relation to your personal information and how to contact us in case you have a complaint or request.
- Key Terms. It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Working And Learning Together Electronics Recycling, Inc. (“WALTER”) |
| Our representative | Guillaume Charvon Email: privacy@walt-electronicsrecycling.com |
| Our data protection officer | Guillaume Charvon Email: privacy@walt-electronicsrecycling.com |
| Platform | WALTER Website |
| Personal information | Any information relating to an identified or identifiable individual. |
| Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs; genetic and biometric data; and data concerning health, sex life or sexual orientation.For the purposes of WALTER use, we do not collect this type of information. |
| Sensitive Personal Information | For the purposes of WALTER use, we do collect an individual or corporate entities email address. |
| Biometric Information | For the purposes of WALTER use, we do not collect this type of information. |
- Personal Information We Collect About You. Here’s what this means, we may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
| Categories of Personal Information | Specific Types of Personal Information Collected |
| Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) | Your real or Corporate entity name, email address, city, state and zip code, telephone number and other publicly available information will be stored by MaxBurst. We use MaxBurst to maintain our database of active users. You can read more about how MaxBurst uses your data here: MaxBurst – Privacy Policy. |
| Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | Your real or Corporate entity name, email address, city, state and zip code, telephone number and other publicly available information will be stored by MaxBurst. We use MaxBurst to maintain our database of active users. You can read more about how MaxBurst uses your data here: MaxBurst – Privacy Policy. |
| Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. | This does not apply. WALTER does not collect any financial information from its users. Your real or Corporate entity name, email address, city, state and zip code, telephone number and other publicly available information will be stored by MaxBurst. We use MaxBurst to maintain our database of active users. You can read more about how MaxBurst uses your data here: MaxBurst – Privacy Policy. |
| Characteristics of protected classifications under California or federal law. | We do not collect characteristics of protected classifications under California or federal law. |
| Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) | We do collect commercial information related to a Businesses name, information related to the company (i.e., size of office, or other public information), telephone number and commercial address. |
| Biometric information | We do not collect biometric information. |
| Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement) | We use cookies to personalize content and ads, to provide social media features and to analyze our site traffic. Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. You can accept or reject cookies when you first visit our site by following the instructions provided in the “WALTER Uses Cookies” pop-up. You can also reject cookies by following the directions provided by your Internet provider. You can change your cookie preferences or withdraw your consent at any time. We share information about your use of our site with our advertising, and analytics partners to best serve your needs. You consent to our cookies if you continue to use our website. |
| Audio, electronic, visual, thermal, olfactory, or similar information | We do not collect your audio, electronic, visual, thermal, olfactory, or similar information. |
| Professional or employment-related information | Any information collected, that is identified within this section, is collected for purposes of WALTER. Such information includes your real or Corporate entity name, email address, city, state and zip code, telephone number and other publicly available information will be stored by MaxBurst. We use MaxBurst to maintain our database of active users. You can read more about how MaxBurst uses your data here: MaxBurst – Privacy Policy. |
| Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) | We do not collect your education information. |
| Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | Not applicable. |
| Racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status | We do not collect information regarding your racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status. |
| Contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication | We do not collect contents of a consumer’s mail, email, or text messages unless we are the intended recipient of the communication. |
| Genetic data | We do not collect genetic data. |
| Processing of biometric information for the purpose of uniquely identifying a consumer | We do not process biometric information. |
| Health information | We do not collect health information. |
| Sex life or sexual orientation | We do not collect this type of information. |
If you do not provide personal information required to provide our “Working And Learning Together Electronics Recycling services” (WALTER) to you, it may delay or prevent us from providing our WALTER services to you.
- How Your Personal Information is Collected. We collect personal information from the following categories of sources:
- You, directly in person, by telephone, text, or email and/or via our website and apps
- Operating systems and platforms
- Social networks
- Data brokers
- Publicly accessible sources (e.g., property records)
- Cookies on our website
- Our IT and security systems:
- Automated monitoring of our websites and other technical systems, such as our computer networks and connections, , communications systems, email, and instant messaging systems –and–
- How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:
- To comply with our legal and regulatory obligations
- For our legitimate interests or those of a third party –or–
- Where you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our reasons |
| To provide our “Working And Learning Together Electronics Recycling” services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
| To prevent and detect fraud against you or Working And Learning Together Electronics Recycling (“WALTER”) | For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
| Conducting checks to identify our customers and verify their identityScreening for financial and other sanctions or embargoesOther processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator | To comply with our legal and regulatory obligationsWe will maintain user data for a period of time (3 years). WALTER will remove existing collected user data after a period of three years. After such time, information collected and stored by WALTER will be removed from its database. |
| Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, e.g., policies covering security and internet use | For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training, and quality control | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable informationTo comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, WALTER services or other efficiency measures. | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you. |
| Preventing unauthorized access and modifications to systems | For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for youTo comply with our legal and regulatory obligations |
| Updating and enhancing user records | For the performance of our contract with you or to take steps at your request before entering into a contractTo comply with our legal and regulatory obligations |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services and those of selected third parties to:Existing and former customersThird parties who have previously expressed an interest in our servicesThird parties with whom we have had no previous dealings | For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers |
| External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standardsTo comply with our legal and regulatory obligations |
- Who We Share Your Personal Information With. We routinely share personal information with:
- Service providers we use to help deliver our Working And Learning Together Electronics Recycling services to you, such as analytic service providers, other related providers for Working And Learning Together Electronics Recycling.
- Other third parties we use to help us run our organization such as marketing agencies or website hosts
- Our insurers and brokers
- Our bank[s]
- Potential Investors and Donors
We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO [or Investors in People] accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
- Personal Information We Sold or Shared. In the preceding 12 months, we have not sold or shared the following categories of personal information:
- Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, , physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
- Characteristics of protected classifications under California or federal law
- Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
- Professional or employment-related information
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) –and–
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
- Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have not disclosed the following categories of personal information for a business purpose:
- Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, , physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
- Characteristics of protected classifications under California or federal law
- Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
- Professional or employment-related information
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes –and–
- Sensitive personal information
- How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing Working And Learning Together Electronics Recycling Hub services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf
- To show that we treated you fairly –or–
- To keep records required by law
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
- For California Residents Only: Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:
| Disclosure of Personal Information We Collect About You | You have the right to know, and request disclosure of:The categories of personal information we have collected about you, including sensitive personal informationThe categories of sources from which the personal information is collectedThe categories of third parties to whom we disclose personal information, if any –and–The specific pieces of personal information we have collected about youPlease note that we are not required to:Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retainedReidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–Provide the personal information to you more than twice in a 12-month period |
| Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose | In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know: – The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and– – The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. To opt-out of the sale or sharing of your personal information, please contact: privacy@walt-electronicsrecycling.com |
| Right to Limit Use of Sensitive Personal Information | You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and– As authorized by further regulations You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. To limit the use of your sensitive personal information, please contact: privacy@walt-electronicsrecycling.com |
| Right to Deletion | Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:Delete your personal information from our records –and–Delete your personal information from our records –and–Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effortPlease note that we may not delete your personal information if it is reasonably necessary to:Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and usHelp to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposesDebug to identify and repair errors that impair existing intended functionalityExercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by lawComply with the California Electronic Communications Privacy ActEngage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consentEnable solely internal uses that are reasonably aligned with your expectations based on your relationship with usComply with an existing legal obligation –or–Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information |
| Right of Correction | If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. |
| Protection Against Retaliation | You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:Deny goods or services to youCharge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penaltiesProvide a different level or quality of goods or services to you –or–Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or servicesPlease note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information. |
Do Not Track
At this time, we do recognize or respond to browser-initiated Do Not Track signals with the exception of the Global Privacy Control for residents of California, Colorado, Connecticut, Utah, and Virginia.
Shine the Light
Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information as defined under California law (if any) during the preceding year for third party direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the information in writing at: privacy@walt-electronicsrecycling.com with the subject heading
“California Privacy Rights.”
- How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you may email us at privacy@walt-electronicsrecycling.com.
- Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
- If you choose to contact us directly by website/email/phone/in writing, you will need to provide us with:
- Enough information to identify you (e.g., your full name, address and customer or matter reference number)
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–
- A description of what right you want to exercise and the information to which your request relates
- We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.
- Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
- Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
- Changes to This Privacy Notice. This privacy notice was published on January 8, 2025, and last updated on January 8, 2025.
We may change this privacy notice from time to time–when we do, we will inform you via email.
- How to Contact Us. Please contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
| Our contact details | Our Data Protection Officer’s contact details |
| WALTER address | 138 Hinsdale St. Brooklyn, NY 11207 |
| WALTER email address | privacy@walt-electronicsrecycling.com |
| WALTER telephone number | (347) 854-9623 |
- Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).