Your Privacy Rights

Privacy Policy – Collection, Use and Disclosure of Personal Information

Scope and Application of Policy

This Privacy Policy (this “Policy”) for Westphalia.com (the “Website”), has been created to demonstrate our commitment to protecting and maintaining the accuracy, confidentiality and security of your personal information. This Policy describes the personal information we collect or may collect from or about you, how we use that information, and to whom and in what circumstances we disclose that information.

This Policy applies to all information you provide to us, or we obtain from you, through the Website. This Policy is intended to comply with all applicable privacy legislation.

Collection, Use and Disclosure of Personal Information
For purposes of this Policy, personal information means any information about an identifiable individual, other than such person’s business title or business contact information when collected, used or disclosed in the course of commercial activity, to conduct business with you or provide services or products to you.

The information we collect will vary depending on how you use this Website. The type of information we may collect about you includes the following:

• Information such as your name, address, telephone number and e-mail address
• Information that you provide to us, such as general information relating to product and Website preferences, personal interests, household income or areas of interest on our Website, feedback and comments

In addition to the information provided by you, we may automatically receive and record information from your Internet browser, including your IP address, cookie information, and the pages you request.
The Website is not directed to children and we do not knowingly solicit data from children or knowingly market to children.

We use information you provide on an aggregated basis to do such things as operate our site, enhance our site, and to better understand the profile of our online audience. We may also use this data, both aggregate and personal to you, to enhance your site experience on our site by displaying content and marketing messages that we believe will be of interest to you. In some cases we use your personal information to contact you or to provide information to you, such as to send you information that you request. We may provide your information to third parties such as homebuilders and service and product providers to enable them to follow-up with you on your requests. We may also use your information for market research purposes, for project planning or for developing prospect lists for our existing and future communities. In doing so, we may reproduce, publish, broadcast or post such information to third parties assisting with our planning.

We may share your personal information with our employees, auditors, contractors and consultants and other parties, including our subsidiaries and affiliated companies who require such information to assist us with administering our business. These include third parties that provide services to us or on our behalf, third parties that collaborate with us, and third parties with whom we contract to perform our services.

We will not sell or rent your personal information or share your personal information with third parties or nonaffiliated companies, except with your permission, or under the following limited circumstances:

• We may need to share your information or send your information to partners who work on our behalf in order to provide the information, product or services you have requested, or to help us communicate with you (provided that these companies do not have any independent rights to use the personally identifiable information we provide to them beyond what is necessary to assist us, unless they have your consent to do so);
• We may share aggregated, non-personally identifiable information about our users with homebuilders and service and product providers for marketing and promotional purposes;
• We may store and disclose personal information as allowed or required by applicable law, including making disclosures in order to respond to subpoenas, court orders, or legal process;
• We may establish or exercise our legal rights or defend against legal claims as necessary or advisable to protect the rights, safety or property of our communities or others and to conform to legal or regulatory requirements;
• We may share information if believe it is necessary in connection with an investigation or proceeding; to investigate, prevent, or take action relating to emergencies, illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of the Website terms of use; if the disclosure is required or authorized by law;
• We may share information if it is publicly available (other than as a result of disclosure in violation of this Policy); and
• We may transfer information about you in connection with a merger, joint venture or the acquisition of all or a portion of our assets.

Consent

We require your consent to collect, use and disclose your personal information in accordance with this Policy. Consent may be expressed or implied. Express consent may be given orally or in writing, including electronic transmission. Implied consent is consent that can be reasonably inferred by your action or inaction. By providing us with the personal information described in this Policy, we assume you have impliedly provided us with your consent to collect, use and disclose your personal information in accordance with this Policy. Unless otherwise notified by you to do otherwise, we use all information in accordance with this Policy under which the information was collected. If you do not agree to any provision of this Policy, or any update or modification thereto, please do not use our Web site.

You may withdraw or limit your consent to our collection, use and disclosure of your personal information at any time. You must provide reasonable notice of the withdrawal of your consent. All communications with respect to the withdrawal or limitation of your consent should be directed to us in writing. Our contact information is below.

Accuracy and Retention of Personal Information

We endeavor to ensure that any personal information in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If your personal information changes or you believe information we have about you is not accurate, please notify us as soon as reasonably possible. Any request to verify or correct your personal information must be made in writing. In some circumstances, we may not agree to your request to change your personal information, but will instead append an alternative text to the record in question.

We keep your personal information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but it will only be for as long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date and to comply with applicable law and regulatory requirements. When we no longer require your personal information, we will either destroy or erase it, or we will make it anonymous such that it cannot be associated with or tracked to you.

Safeguarding Personal Information

We are committed to protecting the security of your personal information. We endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure. Notwithstanding the foregoing, and despite our efforts to maintain the privacy of your information, third parties (hackers) may unlawfully intercept or access information or confidential transmissions.

Access to Your Personal Information

You may ask to see the personal information we have about you. A request to review your personal information must be made in writing. We will endeavor to provide the information requested within a reasonable time from the date of the written request, or within the time otherwise required by law.

If you make a request to review your personal information, we may request specific information from you to enable us to confirm your identity and right to access such information. We may also require information that would assist us in locating your personal information. If permitted by law, we may charge a fee to access your personal information; if so, we will notify you of that fee at the time you make your request or within a short time thereafter.

Subject to any disclosure required by applicable law, we reserve the right to decline to provide access to personal information in certain circumstances. These include, but are not limited to, circumstances where the information requested:

• Would disclose personal information, including opinions, about another individual;
• Would disclose our trade secrets or other confidential business information;
• Is subject to attorney-client privilege;
• Is not readily retrievable and the burden or cost of providing it would be disproportionate to the value of the information;
• Is not readily retrievable and the burden or cost of providing it would be disproportionate to the value of the information;
• Does not exist or cannot be found;
• Could result in serious harm to the individual requesting it, serious harm to the life, safety or health of another person, or serious emotional harm or embarrassment to another individual;
• May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions; or
• May be or is required to be withheld as a matter of law.

Where information requested will not or cannot be disclosed, we will notify you of the reasons for non-disclosure.

Cookie Policy
We may use cookies and similar technologies such as JavaScript and HTML (“cookies”) on the Website to facilitate and improve your online experience.

How We Use Cookies
When you visit the Website, your web browser may automatically download cookies to your device. Cookies allow for faster loading of website content and allow the Website to help you navigate efficiently to obtain the information and services you have requested. Cookies also allow the Website to remember your preferences, such as language selection, and help you to view information that is most relevant to your interests. Our third party content manager server may use cookies to store session data so you can leave our website and come back without re-entering information.

We may use tracking scripts or cookies to count website visits, email opens, email link clicks, and unsubscribe requests.

Links to Third Party Websites
The Website may contain links to third-party websites, including homebuilder websites, which are provided solely as a convenience to viewers and not as an endorsement of the contents of such sites. While we endeavor to only provide links to websites maintained by reputable organizations, you should be aware that these third parties might be able to gather information from and about you if you visit their websites. In these cases, those third parties will use such information in accordance with their own privacy policies, which may differ substantially from our policy. We assume no liability for the privacy practices of such other sites and are not responsible for the availability or content of, any off-site pages or any other sites linked to the Website. Your linking to off-site pages or other sites is at your own risk.

Revisions to this Policy

This Policy may be updated and modified from time to time by us in our sole discretion. We will post any revised version of this Policy on the Website. We encourage you to review the Website on a regular basis. Any changes to this Policy will be effective as of the date posted on the Website.

Interpretation of this Policy

This Policy does not create or confer any rights or obligations beyond those established by applicable law. Should there be, in a specific case, any inconsistency between this Policy and applicable law, then this Policy will be interpreted to give effect to and comply with such law.

Contact Information
In order to ensure compliance with this policy and applicable privacy law, including providing you any information to which you are entitled upon request, we have provided our contact information below. If you have any questions about the application of this policy or if you would like to request information, please contact us as follows:

Via U.S. Mail:
Ryan Kretschmer
Walton Global Holdings, LLC
14614 North Kierland Blvd., Suite 120
Scottsdale, Arizona 85254

Via Email:
info@westphalia.com

California Privacy Rights

In accordance with California Senate Bill No. 27 (“S-27”), which became effective as of January 1, 2005, we are required to notify all California consumers of their right to request a California Information-Sharing Disclosure. Unless otherwise notified by you to do otherwise, we use all information in accordance with our Privacy Policy under which the information was collected. If you do not agree to any provision of this Privacy Policy, or any update or modification thereto, please do not use our website.

If you wish to request a California Information-Sharing Disclosure, you may do so by contacting us via the following means. In accordance with S-27, we are only able to respond to requests of California consumers who contact us at one of the designated addresses listed in the “Contact Information” section above.