OnTour Privacy Policy

This Privacy Policy describes how WayMaker Technology, Inc. (“WayMaker,” “we,” “our,” or “us”) collects, uses, processes, and protects information in connection with the OnTour platform and related services (the “Services”).

OnTour is a business-to-business software platform provided to property owners, operators, and management companies (“Customers”). This Privacy Policy applies to information processed through Customer use of the Services.

1. Information We Collect

We may collect and process the following categories of information:

• Audio recordings captured during property tours, where enabled by Customer.
• Transcriptions generated from recorded audio.
• Tour-related notes, comments, and metadata.
• Performance analytics, scoring outputs, and benchmarking data.
• Prospect interaction data voluntarily provided during tours.
• Account information for Authorized Users (e.g., name, email address, phone number, role).
• Technical data such as device type, browser type, IP address, operating system, and usage logs.

2. How We Use Information

We process information to:

• Provide, operate, and maintain the Services.
• Generate transcriptions and AI-driven analytics.
• Improve platform performance, accuracy, and reliability.
• Provide customer support and respond to inquiries.
• Maintain security, detect fraud, and prevent misuse.
• Develop aggregated and anonymized benchmarking insights.
• Comply with applicable legal obligations.

We do not sell Customer Data. We do not use Customer Data for advertising purposes.

3. Cookies, Tracking & Analytics

When you use the Services, we may use cookies, local storage, and similar technologies to:

• Authenticate your session and maintain your login state.
• Remember your preferences and settings.
• Analyze usage patterns to improve platform performance.
• Ensure security and detect anomalous activity.

We use only essential and functional cookies required for the operation of the Services. We do not use third-party advertising cookies or cross-site tracking technologies.

You may adjust cookie settings in your browser at any time. Disabling essential cookies may affect your ability to use the Services.

4. AI & Machine Learning

The Services use artificial intelligence and machine learning to generate transcriptions, performance scores, coaching insights, and analytics. The following applies to our AI practices:

• AI models used in the Services are general-purpose models and are not trained on individual Customer Data.
• Customer Data is processed through AI models to generate outputs but is not retained by the models or used to improve models for other customers.
• We may use aggregated, anonymized, and de-identified data to improve platform accuracy and develop benchmarking insights. Such data cannot be used to identify any individual or Customer.
• AI-generated outputs are informational and assistive only. They are not guarantees of accuracy, completeness, or suitability for any particular decision.

5. Biometric Information

Certain features of the Services involve the processing of audio recordings, which may be considered biometric data or biometric identifiers under applicable state laws, including the Illinois Biometric Information Privacy Act (“BIPA”), the Texas Capture or Use of Biometric Identifier Act (“CUBI”), and similar statutes.

WayMaker processes audio data solely on behalf of and at the direction of the Customer. We do not independently collect, use, or store biometric data for our own purposes.

Customers are solely responsible for:

• Providing legally required notice to individuals before recording.
• Obtaining informed written consent where required by applicable biometric privacy laws.
• Establishing and publishing a data retention and destruction schedule for biometric data as required by law.
• Ensuring compliance with all applicable federal, state, and local biometric privacy statutes.

WayMaker will cooperate with Customers to support compliance with biometric privacy obligations, including timely deletion of audio recordings upon Customer request.

6. Legal Basis & Customer Responsibility

Customers are responsible for ensuring that appropriate notice and consent are provided before recording conversations, and for complying with all applicable federal, state, and local privacy and recording laws.

WayMaker processes Customer Data on behalf of and under the instruction of the Customer, consistent with the applicable Subscription Agreement.

7. Data Sharing & Disclosure

We may share information:

• With the Customer that controls the Workspace.
• With service providers (“Sub-processors”) who assist in operating the Services, such as cloud hosting, transcription engines, and analytics infrastructure.
• When required by law, regulation, subpoena, court order, or other legal process.
• To protect the rights, safety, or property of WayMaker, Customers, or others.
• In connection with a merger, acquisition, reorganization, or sale of assets, subject to confidentiality obligations.

We require all Sub-processors to process data in accordance with confidentiality, security, and data protection obligations consistent with this Privacy Policy.

Sub-processor List

A current list of Sub-processors used by the Services is available upon request by contacting us at connect@waymakertour.com. We will notify Customers of material changes to our Sub-processor list in advance.

8. Data Retention

Customer controls data retention settings within the platform. WayMaker retains Customer Data only as long as necessary to provide the Services, fulfill contractual obligations, and comply with applicable legal requirements.

Upon termination of a Customer's Subscription Agreement, WayMaker will delete or return Customer Data within a commercially reasonable period, unless retention is required by law.

9. Data Security

We implement commercially reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, loss, misuse, or alteration. These measures include:

• Encryption of data in transit (TLS) and at rest.
• Role-based access controls and authentication mechanisms.
• Regular security assessments and monitoring.
• Secure development practices and code review processes.

No method of transmission or storage is 100% secure. We cannot guarantee absolute security.

10. Data Breach Notification

In the event of a confirmed data breach involving Customer Data, WayMaker will:

• Notify affected Customers without unreasonable delay, and in no event later than seventy-two (72) hours after confirmation of the breach.
• Provide a description of the nature of the breach, the categories and approximate number of records affected, and the measures taken or proposed to address the breach.
• Cooperate with Customers in fulfilling their own notification obligations under applicable state breach notification laws.

11. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). Because OnTour is a business-to-business platform, most data processed through the Services relates to individuals acting in a professional capacity.

To the extent the CCPA applies:

• Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You may request deletion of personal information we hold about you, subject to certain exceptions.
• Right to Correct: You may request correction of inaccurate personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
• No Sale or Sharing: We do not sell personal information. We do not share personal information for cross-context behavioral advertising.

To exercise your rights, contact us at connect@waymakertour.com. Because data is processed on behalf of Customers, we may direct requests to the applicable Customer for verification and fulfillment.

12. Other State Privacy Laws

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states with comprehensive privacy laws may have similar rights to access, delete, correct, and opt out of certain processing activities.

To exercise rights under any applicable state privacy law, please contact us at connect@waymakertour.com. We will respond within the timeframe required by the applicable law.

13. International Data Transfers

Information may be processed and stored in the United States or other jurisdictions where WayMaker or its service providers operate. By using the Services, you acknowledge that your information may be transferred to and processed in the United States.

14. Individual Rights

Because OnTour is a business-to-business platform, individuals should direct privacy-related requests to the Customer that controls the Workspace.

Where required by law, WayMaker will assist Customers in responding to verified privacy rights requests in a timely manner.

15. Children's Privacy

The Services are not intended for individuals under the age of 16. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 16, we will take steps to delete such information promptly.

16. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected by updating the “Last Updated” date above and, where appropriate, by notifying Customers via email or through the platform.

17. Contact Information

WayMaker Technology, Inc.
Phone: 972-897-2329
Email: connect@waymakertour.com